Final
Feasibility Study Report
Lower Ley Creek Subsite of the Onondaga Lake
Superfund Site
Syracuse, New York
EPA Contract No.: EP-W-10-007
Work Assignment Number: 007-RICO-024Q
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Final
Feasibility Study Report
Lower Ley Creek Subsite of the Onondaga Lake
Superfund Site
Syracuse, New York
EPA Contract No.: EP-W-10-007
Work Assignment Number: 007-RICO-024Q
S7^
£
<
V
A
ui
a
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Prepared for:
U.S. Environmental Protection Agency Region 2
290 Broadway
New York, NY 10007
Prepared by:
HydroGeoLogic, Inc.
Northway 10 Executive Park
313 Ushers Road
Ballston Lake, NY 12019
March 2014
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Section
TABLE OF CONTENTS
Page
Executive Summary ES-1
1.0 INTRODUCTION 1-1
1.1 OBJECTIVES 1-1
1.2 REPORT ORGANIZATION 1-1
2.0 SITE BACKGROUND 2-1
2.1 SITE LOCATION AND DESCRIPTION 2-1
2.1.1 Site History 2-1
2.1.2 Site Physical Characteristics 2-2
2.1.2.1 Surface Features 2-2
2.1.2.2 Land Use 2-3
2.1.2.3 Climate 2-3
2.1.2.4 Geology 2-3
2.1.2.5 Soils 2-4
2.1.2.6 Surface-Water Hydrology 2-4
2.1.2.7 Hydrogeology 2-4
2.1.2.8 Ecology 2-5
2.1.2.9 New York State Wetland SYW-12 2-5
2.2 PREVIOUS SITE ACTIVITIES AND INVESTIGATIONS 2-5
2.2.1 Lower Ley Creek Investigations 2-5
2.2.1.1 Old Ley Creek Channel Investigation 2-6
2.2.2 Current Activities at the Former Town of Salina Landfill 2-7
2.3 NATURE AND EXTENT OF CONTAMINATION 2-7
2.3.1 Lower Ley Creek 2-7
2.3.1.1 Fish Tissue 2-8
2.3.1.2 Surface Water 2-8
2.3.1.3 Sediments 2-8
2.3.1.4 Soils 2-9
2.3.1.5 Summary 2-10
2.3.2 Old Ley Creek Channel 2-10
2.3.2.1 Soil Investigation 2-10
2.3.2.2 Sediment Investigation 2-10
2.3.2.3 Groundwater Investigation 2-10
2.3.2.4 Surface Water Investigation 2-10
3.0 RISK ASSESSMENT OVERVIEW 3-1
3.1 HUMAN HEALTH RISK ASSESSMENT 3-1
3.1.1 Selection of Chemicals of Potential Concern 3-1
3.1.2 Exposure Pathways 3-1
3.1.3 Non-Cancer Summary 3-1
3.1.3.1 Recreati onal Vi si tor - Adult 3-1
3.1.3.1.1 Sediments 3-1
3.1.3.1.2 Soils 3-2
3.1.3.2 Recreational Visitor- Older Child (6 - <16 years old) 3-2
3.1.3.2.1 Sediments 3-2
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TABLE OF CONTENTS (continued)
Section Page
3.1.3.2.2 Soils 3-2
3.1.3.3 Recreational Visitor - Younger Child (<6 years old) 3-2
3.1.3.3.1 Sediments 3-2
3.1.3.3.2 Soils 3-2
3.1.3.4 Construction Worker - Adult 3-3
3.1.3.4.1 Sediments 3-3
3.1.3.4.2 Soils 3-3
3.1.4 Cancer Risk Summary 3-3
3.1.4.1 Recreational Visitor - Adult 3-3
3.1.4.1.1 Sediments 3-3
3.1.4.1.2 Soils 3-3
3.1.4.2 Recreational Visitor- Older Child (6 - <16 years old) 3-3
3.1.4.2.1 Sediments 3-3
3.1.4.2.2 Soils 3-4
3.1.4.3 Recreational Visitor - Younger Child (<6 years old) 3-4
3.1.4.3.1 Sediments 3-4
3.1.4.3.2 Soils 3-4
3.1.4.4 Construction Worker - Adult 3-4
3.1.4.4.1 Sediments 3-4
3.1.4.4.2 Soils 3-4
3.1.5 Sediments and Soils Exposure Risks 3-4
3.2 BASELINE ECOLOGICAL RISK ASSESSMENT 3-4
4.0 CONCEPTUAL SITE MODEL 4-1
4.1 CONTAMINANT SOURCES AND TRANSPORT 4-1
4.1.1 Sediment Contamination 4-1
4.1.2 Soil Contamination 4-2
4.1.3 Contaminant Persistence 4-2
4.2 HYDROLOGIC EVALUTION 4-3
4.2.1 Streamflow Characteristics 4-3
4.2.2 Stream Channel Characteristics 4-3
4.2.3 Sediment Transport Characterization (Erosion and Depositional
Environments) 4-4
5.0 GENERAL SCOPING OF THE FEASIBILITY STUDY 5-1
5.1 INDENTIFICATION OF APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS 5-2
5.2 REMEDIAL ACTION OBJECTIVES 5-3
5.3 PRELIMINARY REMEDIATION GOALS 5-3
5.4 CLEANUP GOALS 5-4
5.4.1 Sediment Cleanup Goals 5-4
5.4.2 Soil Cleanup Goals 5-4
5.5 IDENTIFY AREA AND VOLUMES OF MEDIA THAT REQUIRE
REMEDIAL ACTION 5-5
5.5.1 Extent of Contamination in Soil 5-5
5.5.2 Extent of Contamination in Sediments 5-5
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Section
TABLE OF CONTENTS (continued)
Page
6.0 GENERAL RESPONSE ACTIONS AND APPLICABLE SCREENING
TECHNOLOGIES 6-1
6.1 GENERAL RESPONSE ACTIONS 6-1
6.1.1 No Action 6-1
6.1.2 Institutional Controls 6-1
6.1.3 Monitored Natural Recovery 6-2
6.1.4 Containment and Engineering Controls 6-3
6.1.4.1 Granular Material Sediment Cap 6-4
6.1.4.2 Engineered Bentonite Cap 6-4
6.1.5 Removal and Disposal 6-4
6.1.5.1 Dredging (Sediments) 6-4
6.1.5.2 Excavation (Sediments and Soils) 6-5
6.1.6 In Situ Treatment 6-5
6.1.7 Ex Situ Treatment 6-5
6.2 INFORMATION SOURCES USED TO IDENTIFY REMEDIAL
TECHNOLOGIES 6-6
6.3 IDENTIFATION AND SCREENING OF APPLICABLE REMEDIAL
TECHNOLOGIES 6-7
6.3.1 Effectiveness 6-7
6.3.2 Implementability 6-7
6.3.3 Cost 6-8
7.0 IDENTIFICATION AND SCREENING OF REMEDIAL ALTERNATIVES 7-1
7.1 SOIL REMEDIAL ALTERNATIVES 7-1
7.1.1 Soil-1: No Action 7-1
7.1.2 Soil-2: Excavation of Soil to Meet Cleanup Goals 7-2
7.1.2.1 Restoration 7-3
7.1.2.1.1 Baseline Sampling 7-3
7.1.2.1.2 Site Restoration 7-3
7.1.2.1.3 Success Criteria 7-4
7.1.2.2 Monitoring and Controls 7-4
7.1.2.2.1 Sampling Methodology 7-4
7.1.2.2.2 Percent Survivorship 7-5
7.1.2.2.3 Controls 7-5
7.1.3 Soil-3: Excavation of Southern Swale Soils to Meet Cleanup
Goals and Soil Capping of Northwest Soils 7-5
7.1.3.1 Restoration 7-6
7.1.3.1.1 Baseline Sampling 7-6
7.1.3.1.2 Site Restoration 7-7
7.1.3.1.3 Success Criteria 7-8
7.1.3.2 Monitoring and Controls 7-8
7.1.3.2.1 Sampling Methodology 7-8
7.1.3.2.2 Percent Survivorship 7-9
7.1.3.2.3 Controls 7-9
7.1.4 Soil-4: Soil Cap over All Contaminated Soils 7-9
7.1.4.1 Restoration 7-10
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TABLE OF CONTENTS (continued)
Section Page
7.1.4.1.1 Baseline Sampling 7-10
7.1.4.1.2 Site Restoration 7-10
7.1.4.1.3 Success Criteria 7-11
7.1.4.2 Monitoring and Controls 7-12
7.1.4.2.1 Sampling Methodology 7-12
7.1.4.2.2 Percent Survivorship 7-12
7.1.4.2.3 Controls 7-13
7.2 SEDIMENT REMEDIAL ALTERNATIVES 7-13
7.2.1 Sediment-1: No Action 7-13
7.2.2 Sediment-2: Removal of Sediments to Cleanup Goals 7-13
7.2.2.1 Restoration 7-14
7.2.2.1.1 Baseline Sampling 7-15
7.2.2.1.2 Site Restoration 7-15
7.2.2.2 Monitoring 7-15
7.2.2.3 Controls 7-15
7.2.3 Sediment-3: Granular Material Sediment Cap 7-16
7.2.3.1 Restoration 7-18
7.2.3.1.1 Baseline Sampling 7-18
7.2.3.1.2 Site Restoration 7-18
7.2.3.2 Monitoring 7-18
7.2.3.3 Controls 7-18
7.2.4 Sediment-4: Engineered Bentonite Sediment Cap 7-19
7.2.4.1 Restoration 7-21
7.2.4.1.1 Baseline Sampling 7-21
7.2.4.1.2 Site Restoration 7-21
7.2.4.2 Monitoring 7-21
7.2.4.3 Controls 7-21
7.2.5 Sediment-5: Monitored Natural Recovery 7-22
7.2.5.1 Baseline Sampling 7-22
7.2.5.2 Monitoring 7-22
7.2.5.3 Controls 7-22
8.0 REMEDIAL ALTERNATIVE EVALUATION 8-1
8.1 EVALUATION PROCESS AND EVALUATION CRITERIA 8-1
8.1.1 Overall Protection of Human Health and the Environment 8-2
8.1.2 Compliance with ARARs 8-2
8.1.3 Long-Term Effectiveness and Permanence 8-2
8.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment 8-2
8.1.5 Short-Term Effectiveness 8-3
8.1.6 Implementability 8-3
8.1.7 Cost 8-4
8.1.8 State Acceptance 8-4
8.1.9 Community Acceptance 8-5
8.2 SOIL REMEDIAL ALTERNATIVES 8-5
8.2.1 Soil-1: No Action 8-5
8.2.1.1 Overall Protection of Human Health and the Environment 8-5
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TABLE OF CONTENTS (continued)
Section Page
8.2.1.2 Compliance with ARARs 8-5
8.2.1.3 Long-Term Effectiveness and Permanence 8-5
8.2.1.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-5
8.2.1.5 Short-Term Effectiveness 8-5
8.2.1.6 Implementability 8-5
8.2.1.7 Cost 8-6
8.2.1.8 State Acceptance 8-6
8.2.1.9 Community Acceptance 8-6
8.2.1.10 Conclusion 8-6
8.2.2 Soil-2: Excavation of Soil to Meet Cleanup Goals 8-6
8.2.2.1 Overall Protection of Human Health and Environment 8-6
8.2.2.2 Compliance with ARARs 8-6
8.2.2.3 Long-Term Effectiveness and Permanence 8-6
8.2.2.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-7
8.2.2.5 Short-Term Effectiveness 8-7
8.2.2.6 Implementability 8-8
8.2.2.7 Cost 8-8
8.2.2.7.1 On-site Disposal 8-8
8.2.2.7.2 Off-site Disposal 8-8
8.2.2.8 State Acceptance 8-9
8.2.2.9 Community Acceptance 8-9
8.2.2.10 Conclusion 8-9
8.2.3 Soil-3: Excavation of Southern Swale Soils to Meet Cleanup
Goals and Soil Cap for Northwest Soils 8-9
8.2.3.1 Overall Protection of Human Health and Environment 8-9
8.2.3.2 Compliance with ARARs 8-9
8.2.3.3 Long-Term Effectiveness and Permanence 8-9
8.2.3.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-10
8.2.3.5 Short-Term Effectiveness 8-10
8.2.3.6 Implementability 8-11
8.2.3.7 Cost 8-11
8.2.3.7.1 On-site Disposal 8-11
8.2.3.7.2 Off-site Disposal 8-11
8.2.3.8 State Acceptance 8-11
8.2.3.9 Community Acceptance 8-11
8.2.3.10 Conclusion 8-12
8.2.4 Soil-4: Soil Cap Over All Contaminated Soils 8-12
8.2.4.1 Overall Protection of Human Health and Environment 8-12
8.2.4.2 Compliance with ARARs 8-12
8.2.4.3 Long-Term Effectiveness and Permanence 8-12
8.2.4.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-13
8.2.4.5 Short-Term Effectiveness 8-13
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Section
TABLE OF CONTENTS (continued)
Page
8.2.4.6 Implementability 8-13
8.2.4.7 Cost 8-14
8.2.4.7.1 On-site Disposal 8-14
8.2.4.7.2 Off-site Disposal 8-14
8.2.4.8 State Acceptance 8-14
8.2.4.9 Community Acceptance 8-14
8.2.4.10 Conclusion 8-14
8.3 SEDIMENT REMEDIAL ALTERNATIVES 8-14
8.3.1 Sediment-1: No Action 8-14
8.3.1.1 Overall Protection of Human Health and the Environment.... 8-14
8.3.1.2 Compliance with ARARs 8-14
8.3.1.3 Long-Term Effectiveness and Permanence 8-15
8.3.1.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-15
8.3.1.5 Short-Term Effectiveness 8-15
8.3.1.6 Implementability 8-15
8.3.1.7 Cost 8-15
8.3.1.8 State Acceptance 8-15
8.3.1.9 Community Acceptance 8-15
8.3.1.10 Conclusion 8-15
8.3.2 Sediment-2: Removal of All Sediments to Cleanup Goals 8-16
8.3.2.1 Overall Protection of Human Health and the Environment.... 8-16
8.3.2.2 Compliance with ARARs 8-16
8.3.2.3 Long-Term Effectiveness and Permanence 8-16
8.3.2.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-16
8.3.2.5 Short-Term Effectiveness 8-16
8.3.2.6 Implementability 8-17
8.3.2.7 Cost 8-18
8.3.2.7.1 On-site Disposal 8-18
8.3.2.7.2 Off-site Disposal 8-18
8.3.2.8 State Acceptance 8-18
8.3.2.9 Community Acceptance 8-18
8.3.2.10 Conclusion 8-19
8.3.3 Sediment-3: Granular Material Sediment Cap 8-19
8.3.3.1 Overall Protection of Human Health and the Environment.... 8-19
8.3.3.2 Compliance with ARARs 8-19
8.3.3.3 Long-Term Effectiveness and Permanence 8-19
8.3.3.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-20
8.3.3.5 Short-Term Effectiveness 8-20
8.3.3.6 Implementability 8-20
8.3.3.7 Cost 8-21
8.3.3.7.1 On-site Disposal 8-21
8.3.3.7.2 Off-site Disposal 8-21
8.3.3.8 State Acceptance 8-21
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TABLE OF CONTENTS (continued)
Section Page
8.3.3.9 Community Acceptance 8-21
8.3.3.10 Conclusion 8-21
8.3.4 Sediment-4: Engineered Bentonite Sediment Cap 8-21
8.3.4.1 Overall Protection of Human Health and the Environment.... 8-21
8.3.4.2 Compliance with ARARs 8-21
8.3.4.3 Long-Term Effectiveness and Permanence 8-22
8.3.4.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-22
8.3.4.5 Short-Term Effectiveness 8-22
8.3.4.6 Implementability 8-23
8.3.4.7 Cost 8-23
8.3.4.7.1 On-site Disposal 8-23
8.3.4.7.2 Off-site Disposal 8-24
8.3.4.8 State Acceptance 8-24
8.3.4.9 Community Acceptance 8-24
8.3.4.10 Conclusion 8-24
8.3.5 Sediment-5: Monitored Natural Recovery 8-24
8.3.5.1 Overall Protection of Human Health and the Environment.... 8-24
8.3.5.2 Compliance with ARARs 8-24
8.3.5.3 Long-Term Effectiveness and Permanence 8-24
8.3.5.4 Reduction of Toxicity, Mobility, or Volume through
Treatment 8-25
8.3.5.5 Short-Term Effectiveness 8-25
8.3.5.6 Implementability 8-25
8.3.5.7 Cost 8-25
8.3.5.8 State Acceptance 8-25
8.3.5.9 Community Acceptance 8-25
8.3.5.10 Conclusion 8-25
9.0 COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES 9-1
9.1 SOIL REMEDIAL ALTERNATIVES 9-1
9.1.1 Overall Protection of Human Health and Environment 9-1
9.1.2 Compliance with ARARs 9-1
9.1.3 Long-Term Effectiveness and Permanence 9-1
9.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment 9-2
9.1.5 Short-Term Effectiveness 9-2
9.1.6 Implementability 9-3
9.1.7 Cost 9-3
9.1.7.1 On-site Disposal 9-3
9.1.7.2 Off-site Disposal 9-3
9.2 SEDIMENT REMEDIAL ALTERNATIVES 9-4
9.2.1 Overall Protection of Human Health and Environment 9-4
9.2.2 Compliance with ARARs 9-4
9.2.3 Long-Term Effectiveness and Permanence 9-5
9.2.4 Reduction of Toxicity, Mobility, or Volume through Treatment 9-5
9.2.5 Short-Term Effectiveness 9-5
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TABLE OF CONTENTS (continued)
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9.2.6 Implementability 9-6
9.2.7 Cost 9-6
9.2.7.1 On-site Disposal 9-6
9.2.7.2 Off-site Disposal 9-7
10.0 REFERENCES 10-1
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LIST OF FIGURES
Figure 2.1 Site Location
Figure 2.2 Site Layout
Figure 2.3 Location of Pipelines, Floodplain, and Wetlands
Figure 2.4 Soil Areas of Lower Ley Creek
Figure 2.5 Upstream, Middle, and Downstream Sections of Lower Ley Creek
Figure 2.6 Cross Section Locations
Figure 2.7 Old Ley Creek, Northeast-Southwest Cross Section A-A'
Figure 2.8 Old Ley Creek, West-East Cross Section B-B'
Figure 2.9 Lower Ley Creek Northern Upstream Cross Section C-C'
Figure 2.10 Lower Ley Creek Southern Upstream Cross Section D-D'
Figure 2.11 Lower Ley Creek Middle Section Cross Section E-E'
Figure 2.12 Lower Ley Creek Downstream Section Cross Section F-F'
Figure 2.13 Lower Ley Creek and Old Ley Creek PCB Concentrations in Surface Soil (0-2
Feet Below Ground Surface)
Figure 2.14 Lower Ley Creek and Old Ley Creek PCB Concentrations in Shallow Subsurface
Soil
Figure 2.15 Old Ley Creek PCB Concentrations in Deep Subsurface Soil
Figure 2.16 Lower Ley Creek and Old Ley Creek Mercury Concentrations in Surface Soil (0-
2 Feet Below Ground Surface)
Figure 2.17 Lower Ley Creek and Old Ley Creek Mercury Concentrations in Shallow
Subsurface Soil
Figure 2.18 Old Ley Creek Mercury Concentrations in Deep Subsurface Soil
Figure 2.19 Lower Ley Creek and Old Ley Creek Benzo(a)pyrene Concentrations in Surface
Soil (0-2 Feet Below Ground Surface)
Figure 2.20 Lower Ley Creek and Old Ley Creek Benzo(a)pyrene Concentrations in Shallow
Subsurface Soil
Figure 2.21 Old Ley Creek Benzo(a)pyrene Concentrations in Deep Subsurface Soil
Figure 2.22 Lower Ley Creek and Old Ley Creek Total Chromium Concentrations in Surface
Soil (0-2 Feet Below Ground Surface)
Figure 2.23 Lower Ley Creek and Old Ley Creek Total Chromium Concentrations in Shallow
Subsurface Soil
Figure 2.24 Old Ley Creek Total Chromium Concentrations in Deep Subsurface Soil
Figure 3.1 Conceptual Site Model for Human Health Risks
Figure 3.2 Conceptual Site Model for Ecological Risks
Figure 4.1 Lower Ley Creek Streamflow, Monthly Mean, 2000-2010
Figure 4.2 Lower Ley Creek Streamflow, Peak Flow, 1974-2010
Figure 7.1 Soil Alternatives 2 and 3 - Extent of Southern Swale Soil Excavation
Figure 7.2 Soil Alternative 2 - Extent of Northwest Soil Excavation
Figure 7.3 Soil Alternatives 3 and 4 - Extent of Northwest Soil Cap
Figure 7.4 Soil Alternative 4 - Extent of Southern Swale Soil Cap
Figure 7.5 Sediment Alternative 2 - Extent of Upstream Section Excavation
Figure 7.6 Sediment Alternative 2 - Extent of Middle Section Excavation
Figure 7.7 Sediment Alternatives 2, 3, and 4 - Extent of Downstream Section Excavation
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LIST OF FIGURES (continued)
Figure 7.8 Sediment Alternative 3 - Extent of Upstream Section Sand/Armor Sediment Cap
Figure 7.9 Sediment Alternative 3 - Extent of Middle Section Sand/Armor Sediment Cap
Figure 7.10 Sediment Alternative 4 - Extent of Upstream Section Bentonite Sediment Cap
Figure 7.11 Sediment Alternative 4 - Extent of Middle Section Bentonite Sediment Cap
LIST OF TABLES
Table 3.1
Human Health Risk Concerns
Table 4.1 Streamflow Characteristics in Lower Ley Creek
Table 5.1 Chemicals of Potential Concern Contributing to Human Health and Ecological
Risks in Lower Ley Creek
Table 5.2 Soil Preliminary Remediation Goals
Table 5.3 Sediment Preliminary Remediation Goals
Table 5.4 Soil Cleanup Goals
Table 5.5 Estimated Area and Volumes for All Chemicals Above Cleanup Goals in Soil
Table 5.6 Estimated Area and Volumes for All Chemicals Above Cleanup Goals in
Sediment
Table 6.1 Identification and Screening of Remedial Technologies for Lower Ley Creek
Table 7.1 Lower Ley Creek Soil Remedial Alternatives
Table 7.2 Development and Initial Screening of Soil Remedial Alternatives
Table 7.3 Soil Alternative 2 Excavation and Capping Calculations
Table 7.4 Soil Alternative 3 Excavation and Capping Calculations
Table 7.5 Soil Alternative 4 Excavation and Capping Calculations
Table 7.6 Lower Ley Creek Sediment Remedial Alternatives
Table 7.7 Development and Initial Screening of Sediment Remedial Alternatives
Table 7.8 Sediment Alternative 2 Excavation Calculations
Table 7.9 Sediment Alternative 3 Excavation and Capping Calculations
Table 7.10 Sediment Alternative 4 Excavation and Capping Calculations
Table 8.1 Detailed Evaluation of Soil Remedial Alternatives for Lower Ley Creek
Table 8.2 Detailed Evaluation of Sediment Remedial Alternatives for Lower Ley Creek
Table 9.1 Comparative Evaluation of Soil Remedial Alternatives for Lower Ley Creek
Table 9.2 Comparative Evaluation of Sediment Remedial Alternatives for Lower Ley Creek
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LIST OF APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
Identification of Federal and State Applicable or Relevant and Appropriate
Requirements (ARARs) and To Be Considered (TBCs)
Development of Soil and Sediment PRGs
Remedial Alternative Cost Estimates
Site Photographs
Sand and Armor Sediment Capping Details
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LIST OF ACRONYMS AND ABBREVIATIONS
AE
AFCEC
ARAR
ARCS
bgs
BERA
BNA
bwsi
CERCLA
CFR
CHA
CLU-IN
COPC
CSM
CTE
CWA
DOA
DOC
DOD
DOE
DOI
EA
EPA
ERT
ETWG
°F
FACTS
FRTR
FS
ft
GLNPO
GM
GRA
HGL
HHRA
HI
HQ
assessment endpoints
Air Force Civil Engineer Center
applicable or relevant and appropriate requirements
Assessment and Remediation of Contaminated Sediments
below ground surface
baseline ecological risk assessment
base/neutral/acid organic compounds
below the water-sediment interface
Comprehensive Environmental Response, Compensation, and Liability
Act
Code of Federal Regulations
Clough, Harbour & Associates
Clean-Up Information
chemicals of potential concern
Conceptual Site Model
central tendency exposure
Clean Water Act
U.S. Department of Agriculture
U.S. Department of Commerce
U.S. Department of Defense
U.S. Department of Energy
U.S. Department of the Interior
EA Science and Technology
U.S. Environmental Protection Agency
Environmental Response Team
Engineering/Technology Work Group
degrees Fahrenheit
Field Analytical and Characterization Technologies System
Federal Remediation Technologies Roundtable
feasibility study
feet
Great Lakes National Program Office
General Motors
general response action
HydroGeoLogic, Inc.
human health risk assessment
hazard index
hazard quotient
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LIST OF ACRONYMS AND ABBREVIATIONS (continued)
IFG Inl and Fi sher Gui de
ITT Innovative Treatment Technologies
LATA Los Alamos Technical Associates
LOAEL lowest observed adverse effect level
LUC land-use control
mg/kg milligrams per kilogram
MNR monitored natural recovery
NCP National Oil and Hazardous Substances Contingency Plan
NYCRR New York Codes, Rules and Regulations
NOAA National Oceanic and Atmospheric Administration
NOAEL no observed adverse effect level
NPL National Priorities List
NYS New York State
NYSDEC New York State Department of Environmental Conservation
NYSDOH New York State Department of Health
O&M operations and maintenance
% percent
PAH polyaromatic hydrocarbons
PCB polychlorinated biphenyls
PPE personal protective equipment
ppm parts per million
PRG preliminary remediation goals
RACER™ Remedial Action Cost Engineering and Requirements
RA remedial action
RAO remedial action objective
RCRA Resource Conservation and Recovery Act
REACH IT Remediation and Characterization Innovative Technologies
RG remedial goal
RI remedial investigation
RIMS Remediation Information Management System
RME reasonable maximum exposure
ROD Record of Decision
RSL regional screening levels
RTN Remediation Technologies Network
SCO Soil Cleanup Objective
SDA sediment dewatering area
SEL severe effect level
SERAS Scientific, Engineering, and Analytical Services
Site Lower Ley Creek Sub site of the Onondaga Lake Superfund Site
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LIST OF ACRONYMS AND ABBREVIATIONS (continued)
SITE
SLERA
SVOC
TBC
TEC
TSCA
^g/L
USACE
USGS
VISITT
VOC
WA
WAF
Superfund Innovative Technology Evaluation
screening level ecological risk assessment
semi-volatile organic compound
To Be Considered
total equivalent concentrations
Toxic Substances Control Act
micrograms per liter
U.S. Army Corps of Engineers
U.S. Geological Survey
Vendor Information System for Innovative Treatment Technologies
volatile organic compound
Work Assignment
Work Assignment Form
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EXECUTIVE SUMMARY
This Remedial Investigation/Feasibility Study (RI/FS) for Lower Ley Creek Subsite of the
Onondaga Lake Superfund Site (the Site) is being performed under U.S. Environmental
Protection Agency (EPA) RAC2 Contract Number EP-W-10-007 (Work Assignment Number
007-RICO-024Q) with Los Alamos Technical Associates, Inc. (LATA). HydroGeoLogic, Inc.
(HGL) is a Team Subcontractor to LATA on this contract and has the lead technical role for this
Work Assignment (WA). The Original WA Form (WAF) for the RI/FS to be performed by
LATA for this Site was issued and received on 02 March 2012.
HGL has been tasked by LATA to prepare this Final FS for the Site. In accordance with the
approved Work Plan dated 15 August 2012, the purpose of this Final FS is to:
• Establish Remedial Action Objectives (RAO).
• Establish General Response Actions.
• Identify and Screen Applicable Remedial Technologies.
• Develop Remedial Alternatives in accordance with the National Contingency Plan
(NCP).
• Screen Remedial Alternatives for Effectiveness, Implementability, and Cost.
• Assess each individual alternative against the evaluation criteria.
• Perform a comparative analysis of all options against the evaluation criteria.
SITE LOCATION AND DESCRIPTION
The Site (CERCLIS ID No. NYD986913580) consists of the lower 2 miles of Lower Ley Creek,
beginning at the upstream portion of the Route 11 (a.k.a. Brewerton Road) Bridge and ending
downstream at Onondaga Lake. The Site also includes the Old Ley Creek Channel, originally a
portion of the original Ley Creek prior to its rerouting in the 1970s. The Site is a subsite of the
Onondaga Lake Superfund Site, which was listed on the National Priorities List (NPL) on 16
December 1994. The creek passes through the Salina Landfill and under the 7th North Street
Bridge and Interstate 81 bridges. The banks of the stream channel are near vertical in most
areas, and the channel is very well defined. The bottom of the stream is dominated by soft
sediment with very little stone or other hard surfaces. Much of the stream is shallow, but there
are sections where the water depth may be 8-10 feet (ft) deep, particularly downstream of the 7th
North Street Bridge. The creek, in general, is narrower and shallower upstream of the 7th North
Street Bridge, and wider and deeper downstream of 7th North Street Bridge. The immediate
banks of the stream are bordered predominantly by herbaceous vegetation. Some woody shrubs
are also mixed in with herbaceous vegetation and sections of the bank are wooded. Beyond the
narrow strip of vegetation, the creek is surrounded by manufacturing operations, parking lots, a
landfill, and railroad tracks that parallel and are a short distance from much of the southern bank.
The creek trends north and then southwest in the last 500 ft before passing under the railroad
tracks where it enters Onondaga Lake. The Site is located within the urbanized area of Eastern
Syracuse, New York.
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NATURE AND EXTENT OF CONTAMINATION
In 2010, the New York State Department of Environmental Conservation (NYSDEC) tasked EA
Engineering, P.C., and its affiliate EA Science and Technology (EA), to perform an RI at the Old
Ley Creek Channel. During the most recent investigation (concluded in 2012), the EPA
Scientific, Engineering, and Analytical Services (SERAS)/Environmental Response Team (ERT)
collected fish tissue samples, surface water samples, soil samples, and sediment samples to
characterize the nature and extent of contamination at Lower Ley Creek.
Lower Lev Creek
The fish tissue samples exhibited detectable concentrations of metals, organic compounds,
polychlorinated biphenyls (PCB), and dioxins/furans. Ecological risks exist from concentrations
of dioxins and PCBs in the fish tissue. In addition, human health risks exist from the potential
consumption of contaminated fish from Lower Ley Creek. The primary human health risk
drivers in the fish tissue are PCBs, arsenic, and mercury.
The surface water samples exhibited detections of metals, volatile organic compounds (VOC),
and base/neutral/acid organic compounds (BNA). No metals or VOCs were detected above
NYSDEC Water Quality Standards. BNAs were detected at or above their respective NYSDEC
Water Quality Standards at several surface water sample locations.
PCBs were not detected in surface water samples collected during this investigation. However,
surface water samples collected during the baseline monitoring program for the Lake Bottom
Subsite of the Onondaga Lake Superfund Site in 2011 (samples collected by Honeywell)
exhibited PCB concentrations ranging from 0.048 to 0.23 micrograms per liter (|ig/L), which is
above the NYSDEC Water Quality PCB Standard of 0.09 |ig/L when used as a human water
source. For human fish consumption, 1 x 10"6 |ig/L is the NYSDEC Water Quality PCB
Standard.
Soil samples were collected along the banks and dredged spoils areas adjacent to Lower Ley
Creek. Soil samples exhibited detections of pesticides, metals, cyanide, PCBs, VOCs, BNAs,
and dioxins/furans. Pesticides, metals, PCBs, VOCs, and BNAs were detected above their
respective unrestricted use New York State (NYS) soil criteria. Metals, PCBs, and BNAs were
detected above their respective restricted use NYS soil criteria for commercial use and their
respective ecological use values. Although the dioxins/furans detected in soil do not have NYS
soil criteria for comparison, some dioxins/furan analytical results were above the EPA
preliminary remediation goal (PRG) for dioxins in residential soil.
Sediment samples were collected along the entire 2 mile length of the Lower Ley Creek Site.
Sediment samples exhibited detections of pesticides, metals, cyanide, PCBs, VOCs, BNAs, and
dioxins/furans. Pesticides, metals, mercury, PCBs, VOCs, and BNAs were detected above their
respective unrestricted use NYS sediment criteria. Cyanide and the dioxins/furans detected in
sediment samples have no NYS sediment criteria for comparison. However, some dioxins/furans
in sediment were detected above the EPA preliminary remediation goal for dioxins in residential
soil.
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The major areas of contamination in soil are present where spoils associated with the dredging of
Lower Ley Creek were reportedly deposited. Soil contamination extends from the surface to as
deep as 14 ft below ground surface (bgs). The major areas of contamination in sediment are in
the upstream portion of Lower Ley Creek, with decreasing concentrations towards Onondaga
Lake. Sediment contamination extends from the surface to as deep as 8 ft below the water
sediment interface (bwsi). The contamination in the sediment is likely influencing the
contamination also present in fish tissue and surface water samples.
Old Ley Creek Channel
The Old Ley Creek Channel is approximately 1,350 ft in length and flows from northeast to
southwest draining to Ley Creek. The contaminants identified in the Old Ley Creek Channel RI
performed by EA in 2010 included:
• VOCs, semi-volatile organic compounds (SVOC), metals, pesticides, and PCBs were
detected in groundwater but exhibited limited impact. Some metals were detected at
concentrations greater than their respective NYSDEC Water Quality Standards.
• Metals, pesticides, and PCBs were present in surface water during two of the sampling
rounds at concentrations greater than their respective NYSDEC Water Quality Standards.
• SVOCs, PCBs, and metals were present in soils above NYSDEC restricted use soil
criteria from the surface to several ft below grade with the highest concentrations being
within the first 2 ft. Only limited low-level impacts to soils by VOCs were identified.
• VOCs, SVOCs, pesticides, PCBs, and metals were present in sediment above NYSDEC
sediment criteria from the surface to 2 ft below grade.
REMEDIAL ACTION OBJECTIVES
RAOs are developed to specify the requirements that the remedial action alternatives must fulfill
to protect human health and the environment. The RAOs developed for the Site are:
Soil RAOs
• Reduce the cancer risks and non-cancer health hazards to human health from the
incidental ingestion of and dermal contact with contaminated soil.
• Prevent migration of contaminants that would result in surface water contamination at
levels that are associated with unacceptable ecological risk.
• Remediation of soil to levels that are of acceptable ecological risk.
Lower Lev Creek RAOs
• Prevent the direct contact with contaminated sediments.
• Reduce the cancer risks and non-cancer health hazards for people eating fish from Lower
Ley Creek by reducing the concentration of contaminants in fish.
• Prevent releases of contaminant(s) from sediments that would result in surface water
levels in excess of ambient water quality criteria.
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• Prevent impacts to biota from ingestion/direct contact with sediments causing toxicity or
impacts from bioaccumulation through the marine or aquatic food chain.
• Restore sediments to pre-release/background conditions to the extent feasible.
• Reduce the risks to ecological receptors by reducing the concentration of contaminants in
fish.
• Minimize the current and potential future bioavailability of contaminants in sediments.
Contaminants in sediments may become bioavailable by various mechanisms (e.g., pore
water diffusion, bioturbation, biological activity, benthic food chains, ice jam scour, etc.).
CLEANUP GOALS
The Site is located within a highly urbanized area of Eastern Syracuse, New York. Lower Ley
Creek is surrounded by manufacturing operations, parking lots, a landfill, railroad tracks, and
commercial operations. This has been a commercial/industrial area for at least 50 years and will
continue to be a commercial/industrial area for the foreseeable future. However, the Site also
contains an undeveloped riparian corridor that includes Old Ley Creek, Lower Ley Creek, and
the adjacent wetlands and floodplains associated with these surface water bodies. Therefore,
cleanup goals are based both on commercial use and the protection of ecological resources.
As documented in the Record of Decision (ROD) for the Crouse-Hinds Landfills State
Superfund Project (Site No. 734004), located along the southern shore of Lower Ley Creek, the
cleanup goal of 1 milligram per kilogram (mg/kg) PCBs in creek sediment is recognized as a
previously selected sediment cleanup goal at NYS Hazardous Waste Sites. Therefore, 1 mg/kg
PCBs was used as a cleanup goal for sediments at Lower Ley Creek. Additional areas exhibiting
sediments below 1 mg/kg PCBs were added to the sediment remedial alternatives based on
elevated concentrations of other risk drivers (i.e., chromium and polyaromatic hydrocarbons
[PAH]).
Cleanup goals for soil were based on 6 NYCRR Part 375 Soil Cleanup Objectives (SCO) for
Commercial Use and the Protection of Ecological Resources. Although the area is a riparian
corridor, widespread landfilling exists beneath much of the soil areas and the surrounding land
use is industrial and commercial. For soils shallower than 2 ft bgs, the lower value between
Commercial Use SCOs and Ecological SCOs was used as a cleanup goal. For soils deeper than 2
ft bgs, Commercial Use SCOs were used as cleanup goals as there are very limited ecological
pathways and exposures deeper than 2 ft bgs.
SOIL REMEDIAL ALTERNATIVES
To assist with the determination of remedial alternatives for soil, site soils have been separated
into two areas (Southern Swale Soils and Northwest Soils). This separation was made because
there are specific remedial challenges associated with each area. While the Northwest Soil area
has two large buried pipelines to consider, remediation of the Southern Swale Soil area may
require limited wetland restoration. Four soil remedial alternatives (including the No Action
alternative) were developed, screened, and evaluated for the Site.
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Soil-1: No Action
Soil Alternative 1 is the No Action alternative and is presented for comparison only. The No
Action Alternative consists of refraining from the active application of any remediation
technology to soils of Lower Ley Creek. The No Action alternative also excludes source control
removal action, administrative actions, and monitoring. As required by Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), periodic reviews would
be conducted at 5-year intervals to reassess the long-term appropriateness of continued No
Action.
The No Action alternative would not actively reduce the toxicity, mobility, or volume of the
contamination through treatment. The cancer risks and non-cancer human health hazards and
risks to ecological receptors would continue to remain above acceptable levels and the surface
water quality would continue to be degraded.
Soil-2: Excavation of Soil to Meet Cleanup Goals
Soil Alternative 2 includes both excavation and installation of a soil cap in select locations. In
the Southern Swale Soil Area, all soils with concentrations above cleanup goals would be
excavated. In the Northwest Soil Area, all soils above with concentrations above cleanup goals
would be excavated, except in areas near the two pipelines located adjacent to each other in the
Northwest Soil Area. One pipeline is an active natural gas line while the other pipeline is an
inactive oil line. Based on restrictions imposed on the field sampling team during the site
investigation and discussions with utilities, it is likely that there will be a 20-ft wide "safety
zone" digging restriction near the pipelines. Therefore, in areas of soil contamination adjacent to
and above the pipelines, a soil cap would be installed.
This alternative includes excavation and either on-site or off-site disposal of soils exceeding
cleanup goals. Clean backfill would then be placed to bring the excavation back to the original
grade. At least 6 inches of topsoil would be placed over disturbed areas and seeded to grow
vegetation to reduce or eliminate erosion from the disturbed areas.
This alternative also includes a soil cap for soils located adjacent to and above the pipelines. The
soil cap would be a 1-fit thick layer of clean soil to isolate the contaminated soils. The soil cap
would be a vegetated habitat layer. A demarcation layer (e.g., non-woven geotextile) would be
installed between the contaminated soil and the soil cap. The soil cap would be seeded to grow
vegetation that would reduce or eliminate erosion from the areas. In floodplain areas, an
excavation of 1 ft of soil would be completed before the soil cap is installed to avoid loss of
floodplain capacity. In addition, this alternative would require a site management plan to manage
the soil cap and the remaining contamination at the site.
As part of this alternative, controls would be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Institutional controls could
include, but would not be limited to, potential land-use controls (LUC), environmental
easements, deed notices, and public health advisories. Additional controls would likely include
fencing and signage.
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This alternative significantly reduces the risks to human health and the environment from soil
contamination at the site. This conclusion is based on a combination of factors that includes the
area remediated and the volume of soils removed. This is the most extensive soil remedial
alternative, and as such provides the greatest benefits at the highest costs. It serves as the upper
bound of the benefits of active remediation of soils at Lower Ley Creek.
Soil-3: Excavation of Southern Swale Soils to Meet Cleanup Goals and Soil Cap for
Northwest Soils
Soil Alternative 3 includes both excavation and installation of a soil cap in select locations. In
the Southern Swale Soil Area, all soil with concentrations above cleanup goals would be
excavated to meet the cleanup goal. In the Northwest Soil Area, all soils with concentrations
above cleanup goals would either be excavated or covered with a soil cap. Clean backfill would
then be placed to bring the excavation back to the original grade. At least 6 inches of topsoil
would be placed over disturbed areas and seeded to grow vegetation to reduce or eliminate
erosion from the disturbed areas.
This alternative also includes a soil cap for some soils located in the Northwest Soil Area. The
soil cap would be a 1-ft thick layer of clean soil to isolate the contaminated soils. The soil cap
would be a vegetated habitat layer. A demarcation layer would be installed between the
contaminated soil and the soil cap. A 2-ft thick habitat layer will be placed above the soil cap and
will be seeded to grow vegetation that would reduce or eliminate erosion from the areas.
Vegetation in the soil cap areas would be restored, including trees and shrubs, to create a riparian
buffer.
In all areas, an excavation of 3 ft of soil would be completed before the soil cap is installed so
there is no loss of floodplain capacity. Due to this requirement, soil caps will only be placed in
areas exhibiting contamination deeper than 3 ft bgs. Any areas with contamination less than 3 ft
deep will be excavated and replaced with backfill.
As part of this alternative, controls would be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Institutional controls could
include, but would not be limited to, potential LUCs, environmental easements, deed notices, and
public health advisories. Additional controls would likely include fencing and signage.
This alternative significantly reduces the risks to human health and the environment from soil
contamination at the Site. This conclusion is based on a combination of factors that includes the
area remediated and the volume of soils removed. This is the next most extensive and expensive
soil remedial alternative after Soil Alternative 2. This alternative appears to provide a good
balance in achieving the RAOs and cleanup goals at costs that are more moderate as compared to
Soil Alternative 2. Similar to Alternative 2, this alternative also addresses the most contaminated
soils at the Site.
Soil-4: Soil Cap Over All Contaminated Soils
Soil Alternative 4 includes the excavation or installation of a soil cap over all soils exhibiting
concentrations above cleanup goals in both the Southern Swale Soil Area and the Northwest Soil
Area.
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This alternative also includes a soil cap for some soils located in the Southern Swale Soil Area
and the Northwest Soil Area. The soil cap would be a 1-ft thick layer of clean soil to isolate the
contaminated soils. The soil cap would be a vegetated habitat layer. A demarcation layer would
be installed between the contaminated soil and the soil cap. A 2-ft thick habitat layer will be
placed above the soil cap and will be seeded to grow vegetation that would reduce or eliminate
erosion from the areas. Vegetation in the soil cap areas would be restored, including trees and
shrubs, to create a riparian buffer.
In all areas, an excavation of 3 ft of soil would be completed before the soil cap is installed so
there is no loss of floodplain capacity. Due to this requirement, soil caps will only be placed in
areas exhibiting contamination deeper than 3 ft bgs. Any areas with contamination less than 3 ft
deep will be excavated and replaced with backfill.
As part of this alternative, controls would be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Institutional controls could
include, but would not be limited to, potential LUCs, environmental easements, deed notices, and
public health advisories. Additional controls would likely include fencing and signage.
This alternative significantly reduces the risks to human health and the environment from soil
contamination at the site. As with Soil Alternative 3, this alternative appears to provide a good
balance in achieving the RAOs and cleanup goals at costs that are more moderate as compared to
Soil Alternative 2.
SEDIMENT REMEDIAL ALTERNATIVES
To assist with the determination of remedial alternatives for sediment, the 2-mile stretch of the
Lower Ley Creek Subsite has been separated into three sections (upstream, middle, and
downstream). This separation was made because the downstream section of the Site exhibits
lower concentrations of contaminants and a smaller extent of contamination than the upstream or
middle sections of the Site. In addition, the upstream and middle sections of the site exhibit
distinctive stream characteristics. Five sediment remedial alternatives (including the No Action
alternative) were developed and screened for the Site.
Sediment-1: No Action
Sediment Alternative 1 is the No Action alternative and is presented for comparison only. The
No Action Alternative consists of refraining from the active application of any remediation
technology to sediments in all three sections of Lower Ley Creek. The No Action alternative also
excludes source control removal action, administrative actions, and monitoring. As required by
CERCLA, periodic reviews would be conducted at 5-year intervals to reassess the long-term
appropriateness of continued No Action.
The No Action alternative would not actively reduce the toxicity, mobility, or volume of the
contamination through treatment. The cancer risks and non-cancer human health hazards and
risks to ecological receptors posed by fish consumption would continue to remain above
acceptable levels and the surface water quality would continue to be degraded.
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Sediment-2: Removal of Sediment to Cleanup Goals
This alternative includes full excavation of sediments exhibiting concentrations exceeding
cleanup goals in all sections of Lower Ley Creek. In the upstream, middle, and downstream
sections of Lower Ley Creek, all sediments with concentrations above cleanup goals would be
excavated. Excavated sediments would be transported to a centralized sediment dewatering area
(SDA) where they would be drained and conditioned for on-site disposal or off-site disposal in a
Resource Conservation and Recovery Act (RCRA)-compliant and, if appropriate, a Toxic
Substance Control Act (TSCA)-compliant disposal facility. However, on-site disposal may
potentially be possible at the Cooper Crouse-Hinds North Landfill or other landfills located
adjacent to Lower Ley Creek.
For this FS, it is assumed that excavation in the dry will be done in the shallower areas of Lower
Ley Creek (i.e., the upstream section of Lower Ley Creek), while excavation in the wet will be
completed in the deeper areas of the creek. After excavation is completed in a particular stream
area, approximately 1 ft of clean backfill would be placed to stabilize the sediment bed and
support habitat replacement/reconstruction. Backfill configurations would be developed for each
excavated section of the creek based on creek conditions such as how fast the creek flows, the
type of creek bottom, and habitat goals.
A variety of monitoring activities would be carried out on land and in the creek throughout
construction of the alternative, including monitoring of water, sediments, air quality and odor,
noise, lighting, and water discharged at the sediment dewatering area. Confirmation sampling
would be conducted after the dredging of the sediments has been completed. No long term site
management plans or institutional control would be required as part of this alternative.
This alternative significantly reduces the risks to human health and the environment from
contaminants at the Site. This conclusion is based on a combination of factors that includes the
area remediated, the volume of sediments removed, and the length of creek affected. The
sediment excavation alternative is the most extensive remedial alternative, and as such provides
the greatest benefits. It serves as the upper bound of the benefits of active remediation of
sediments at Lower Ley Creek.
Sediment-3: Granular Material Sediment Cap
This alternative includes the installation of a granular material (sand) sediment cap over portions
of the upstream and middle sections of Lower Ley Creek and the excavation of contaminated
sediments in portions of the upstream, middle, and downstream sections of Lower Ley Creek.
The capping of the areas with sediments exhibiting concentrations exceeding cleanup goals
would be completed in a manner that maintains the bathymetry of Lower Ley Creek. Excavated
sediments would be transported to a centralized SDA where they would be drained and
conditioned for on-site disposal or off-site disposal in a RCRA-compliant and, if appropriate, a
TSCA-compliant disposal facility. However, on-site disposal may potentially be possible at the
Cooper Crouse-Hinds North Landfill or other landfills located adjacent to Lower Ley Creek.
In areas of the site with low erosion potential (i.e., Old Ley Creek), the granular material
sediment cap includes the following design layer:
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• Isolation/Habitat Layer (2 ft thick).
In areas of the site with high erosion potential (i.e., Lower Ley Creek), the granular material cap
includes the following design layers, from top to bottom:
• Habitat Layer (2 ft thick);
• Armor Layer (0.375 - 2.04 ft thick); and
• Isolation Layer (1.5 - 2 ft thick).
Before the placement of any capping material, excavation of sediment will be conducted to
maintain the current bathymetry of Lower Ley Creek. Therefore, in the upstream section of
Lower Ley Creek, a 6 ft excavation of sediment would be completed before the sediment cap is
installed to maintain the current bathymetry of Lower Ley Creek. Due to this requirement,
sediment caps will only be placed in areas exhibiting contamination deeper than 6 ft bgs in the
upstream section of Lower Ley Creek. Any areas in the upstream section with contamination less
than 6 ft deep will be excavated.
In the middle section of Lower Ley Creek, a 4 ft excavation of sediment would be completed
before the sediment cap is installed to maintain the current bathymetry of Lower Ley Creek. Due
to this requirement, sediment caps will only be placed in areas exhibiting contamination deeper
than 4 ft bgs in the middle section of Lower Ley Creek. Any areas in the middle section with
contamination less than 4 ft deep will be excavated.
For this FS, it is assumed that excavation in the dry will be done in the shallower areas of Lower
Ley Creek (i.e., the upstream section of Lower Ley Creek), while excavation in the wet will be
completed in the deeper areas of the creek.
As part of this alternative, controls would be implemented as part of a site management plan to
restrict excavation activities in the capped sediment areas. Controls would consist of a ban on
dredging in the capped/backfilled areas, signage, fencing, and ensuring that the current fish
advisories for Lower Ley Creek remain in place.
This alternative significantly reduces the risks to human health and the environment from
contaminants at the site. This conclusion is based on a combination of factors that includes the
area remediated, the volume of sediments removed, and the length of creek affected. This
alternative appears to provide a good balance in achieving the RAOs and cleanup goals at costs
comparable with Sediment Alternative 4. This alternative significantly reduces the risks to
human health and the environment from sediment contamination at the site.
Sediment-4: Engineered Bentonite Sediment Cap
This alternative includes the installation of an engineered bentonite sediment cap over the
upstream and middle sections of Lower Ley Creek and the excavation of contaminated sediments
in the downstream section of Lower Ley Creek. The capping of the areas with sediments
exhibiting concentrations exceeding cleanup goals would be completed in a manner that
maintains the bathymetry of Lower Ley Creek. The capping of the sediments in the upstream,
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and middle sections of Lower Ley Creek would consist of a 2.25 ft excavation and backfill with
3 inches of an engineered bentonite cap beneath 24 inches of a sand layer intended to provide
additional bioturbation isolation and benthic restoration capacity. This alternative includes full
excavation of sediments exhibiting concentrations exceeding cleanup goals in the downstream
section of Lower Ley Creek.
Excavated sediments would be transported to a SDA where they would be drained and
conditioned for off-site disposal in a RCRA-compliant and, if appropriate, a TSCA-compliant
disposal facility. However, on-site disposal may potentially be possible at the Cooper Crouse-
Hinds North Landfill or other landfills located adjacent to Lower Ley Creek.
As part of this alternative, controls would be implemented as part of a site management plan to
restrict excavation activities in the capped sediment areas. Controls would consist of a ban on
dredging in the capped/backfilled areas, signage, fencing, and ensuring that the current fish
advisories for Lower Ley Creek remain in place.
This alternative significantly reduces the risks to human health and the environment from
contaminants at the site. This conclusion is based on a combination of factors that includes the
area remediated, the volume of sediments removed, and the length of creek affected. This
alternative appears to provide a good balance in achieving the RAOs and cleanup goals at costs
comparable with Sediment Alternative 3. This alternative significantly reduces the risks to
human health and the environment from sediment contamination at the site.
Sediment-5: Monitored Natural Recovery
For this alternative, no active remediation would be undertaken at the Site. Naturally occurring
sedimentation and microbially mediated dechlorination and degradation of PCBs - collectively
referred to as natural recovery processes - would be relied upon to further reduce risk in the
Lower Ley Creek over time.
A 30-year monitoring program would be developed and implemented. Likely components to the
program would include periodic monitoring of the water column and fish in Lower Ley Creek.
The monitoring program would be reviewed, at a minimum, every 5 years to assess whether
modifications were warranted. It is anticipated that fish consumption advisories would remain in
place until the New York State Department of Health (NYSDOH) determines the advisories are
no longer needed.
ANALYSIS OF REMEDIAL ALTERNATIVES
A detailed evaluation of the soil and sediment remedial alternatives was performed using the
following EPA evaluation criteria:
• Protection of Human Health and the Environment;
• Compliance with applicable or relevant and appropriate requirements (ARARs);
• Long-Term Effectiveness and Performance;
• Reduction of Toxicity, Mobility, or Volume;
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• Short-Term Effectiveness;
• Implementability; and
• Cost.
Below are the estimated costs for the four soil remedial alternatives and the five sediment
remedial alternatives assuming either on-site or off-site disposal of contaminated material:
Soil Remedial Alternatives
Soil Remedial Alternate
Cost (On-site Disposal)
Cost (Ofl-silc Disposal)
Alternative 1
No Action
$ 49,636
$ 49,636
Alternative 2
Excavation of Soil to Meet Cleanup Goals
$ 9,113,494
$ 18,987,191
Alternative 3
Excavation of Southern Swale Soils to Meet
Cleanup Goals and Soil Cap for Northwest
Soils
$ 9,027,261
$ 18,737,968
Alternative 4
Soil Cap Over All Contaminated Soils
$ 7,917,433
$ 16,298,507
Sediment Remedial Alternatives
Sediment Remedial Alternate
Cost (On-site Disposal)
Cost (Off-site Disposal)
Alternative 1
No Action
$ 49,636
$ 49,636
Alternative 2
Removal of Sediment to Cleanup Goals
$ 6,980,035
$ 16,523,685
Alternative 3
Granular Material Sediment Cap
$ 10,129,087
$ 17,563,198
Alternative 4
Engineered Bentonite Sediment Cap
$ 10,154,607
$ 15,348,472
Alternative 5
Monitored Natural Recovery
$ 1,973,038
$ 1,973,038
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FINAL
FEASIBILITY STUDY REPORT
LOWER LEY CREEK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
SYRACUSE, NEW YORK
1.0 INTRODUCTION
This Remedial Investigation/Feasibility Study (RI/FS) for Lower Ley Creek Subsite of the
Onondaga Lake Superfund Site (the Site) is being performed under U.S. Environmental
Protection Agency (EPA) RAC2 Contract Number EP-W-10-007 (Work Assignment Number
007-RICO-024Q) with Los Alamos Technical Associates, Inc. (LATA). HydroGeoLogic, Inc.
(HGL) is a Team Subcontractor to LATA on this contract and has the lead technical role for this
Work Assignment (WA). The Original WA Form (WAF) for the RI/FS to be performed by
LATA for this Site was issued and received on 02 March 2012.
HGL has been tasked by LATA to prepare this Final FS for the Site.
1.1 OBJECTIVES
In accordance with the approved Work Plan dated 15 August 2012, the purpose of this Final FS
is to:
• Establish Remedial Action Objectives (RAO).
• Establish General Response Actions.
• Identify and Screen Applicable Remedial Technologies.
• Develop Remedial Alternatives in accordance with the National Contingency Plan
(NCP).
• Screen Remedial Alternatives for Effectiveness, Implementability, and Cost.
• Assess each individual alternative against the evaluation criteria.
• Perform a comparative analysis of all options against the evaluation criteria.
1.2 REPORT ORGANIZATION
This Final FS is organized as follows:
• Section 1 - Introduction;
• Section 2 - Site Background;
• Section 3 - Risk Assessment Overview;
• Section 4 - Conceptual Site Model;
• Section 5 - General Scoping of the FS;
• Section 6 - General Response Actions and Applicable Screening Technologies;
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• Section 7 - Identification and Screening of Remedial Alternatives;
• Section 8 - Remedial Alternative Evaluation; and
• Section 9 - Comparative Analysis of Remedial Alternatives.
This report also includes the following appendices:
• Appendix A - Summary of Federal and State Applicable or Relevant and Appropriate
Requirements (ARARs) and To Be Considered (TBCs);
• Appendix B - Development of Soil and Sediment Preliminary Remediation Goals
(PRGs);
• Appendix C - Remedial Alternative Cost Estimates;
• Appendix D - Site Photographs; and
• Appendix E - Sand and Armor Sediment Capping Details.
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2.0 SITE BACKGROUND
2.1 SITE LOCATION AND DESCRIPTION
The Site (CERCLIS ID No. NYD986913580) consists of the lower 2 miles of Lower Ley Creek,
beginning at the upstream portion of the Route 11 (a.k.a. Brewerton Road) Bridge and ending
downstream at Onondaga Lake (Figure 2.1). The Site also includes the Old Ley Creek Channel,
originally a portion of the original Ley Creek prior to its rerouting in the 1970s. The Old Ley
Creek Channel is a remnant of Lower Ley Creek adjacent to the Salina Landfill. The Site is a
subsite of the Onondaga Lake Superfund Site, which was listed on the National Priorities List
(NPL) on 16 December 1994. Lower Ley Creek passes through the Salina Landfill and under the
7th North Street Bridge and Interstate 81 bridges (Figure 2.2). The banks of the stream channel
are near vertical in most areas, and the channel is very well defined. The bottom of the stream is
dominated by soft sediment with very little stone or other hard surfaces. Much of the stream is
shallow, but there are sections where the water depth may be 8-10 feet (ft) deep, particularly
downstream of the 7th North Street Bridge. The creek, in general, is narrower and shallower
upstream of the 7th North Street Bridge, and wider and deeper downstream of 7th North Street
Bridge. The immediate banks of the stream are bordered predominantly by herbaceous
vegetation. Some woody shrubs are also mixed in with herbaceous vegetation and sections of
the bank are wooded. Beyond the narrow strip of vegetation, the creek is surrounded by
manufacturing operations, parking lots, a landfill, and railroad tracks that parallel and are a short
distance from much of the southern bank. The creek trends north and then southwest in the last
500 ft before passing under the railroad tracks where it enters Onondaga Lake. The site is
located within the urbanized area of Eastern Syracuse, New York. Photographs of the site are
included in Appendix D.
2.1.1 Site History
The development of railroads and the Erie Canal System allowed industry and settlement to
quickly grow in Eastern Syracuse, New York. Many of these industries were focused around
and near Onondaga Lake and included various chemical and pharmaceutical manufacturers
among other industries. The industrial nature of this area, as well as the infrastructure and other
development, influenced the site and contributed to its current condition.
Assessments have been performed or are currently being performed at a number of potential
subsites in the general area to determine whether they contributed to the contamination of
Onondaga Lake. The Onondaga Lake Superfund Site includes the lake itself, seven major and
other minor tributaries, and various upland sources of contamination. The aerial footprint of the
lake is approximately 4.5 square miles.
Prior to the early 1970s, poor channel conditions and large impermeable areas in the watershed
caused extensive flooding of Ley Creek. These flooding events led to the formation of the Ley
Creek Drainage District and the clearing and dredging of Ley Creek. Dredging of Ley Creek
was performed by the Onondaga County Department of Drainage and Sanitation. In 1970, the
section of the creek between the 7th North Street Bridge and Route 11 was dredged. In 1971,
portions of Ley Creek between the 7th North Street Bridge and Onondaga Lake were dredged. In
1975, Ley Creek was dredged from Townline Road (approximately 1.5 miles north of the Site) to
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Onondaga Lake. In 1983, a section of Ley Creek north of the Site (Townline Road to Route 11)
was dredged. Dredged material (i.e., spoils) generated during these dredging activities was
placed along the banks of Ley Creek. Prior to this dredging of the creek discussed above, Ley
Creek did not flow through the Salina Landfill.
There are several properties that are known to be either contributors or potential contributors of
contaminants to Ley Creek. These include: the General Motors (GM) Former Inland Fisher
Guide (IFG) Facility and Ley Creek Deferred Media Site; the GM Ley Creek Poly chlorinated
Biphenyls (PCB) Dredgings Site; and the Town of Salina Landfill, which surrounds Lower Ley
Creek just downstream of Route 11/Brewerton Road. The GM-IFG Facility, the Ley Creek
Deferred Media Site, and the GM Ley Creek PCB Dredgings Site are located upstream of this
Site.
The Town of Salina Landfill is shown in Figure 2.2. A Record of Decision (ROD) for the Salina
Landfill was signed in 2007. The ROD included plans for the installation of a 6 New York
Codes, Rules and Regulations (NYCRR) Part 360 cap, installation of storm water collection and
drainage improvements, and installation of a groundwater/1 eachate collection trench to the north
and south of Lower Ley Creek. An amended ROD for the Town of Salina Landfill was issued in
September 2010 and included the consolidation of the landfill and excavation of the 5 acre
portion of the south side of Ley Creek. The remedial activities began in 2011 and are expected to
be completed in 2013.
2.1.2 Site Physical Characteristics
The following discussion of the physical characteristic of the Site is taken from the Lockheed
Martin Scientific, Engineering, and Analytical Services (SERAS) Field Activities Summary
Report, Lower Ley Creek Superfund Site (SERAS, 2012) and the Old Ley Creek Final Remedial
Investigation Report (EA Science and Technology [EA], 2010).
2.1.2.1 Surface Features
Ley Creek flows through urban developed East Syracuse. Along the 2 miles of Lower Ley
Creek (the Site), the creek flows through a landfill, under several bridges, along a railroad track,
adjacent to several businesses, and near a major shopping mall. The bed of the creek is well
channeled with steep sides, and the creek depth ranges from 1-14 ft. However, the creek is
relatively shallow in most locations, ranging from only 3-5 ft deep over much of its length. The
location of the original streambed has been altered by human activity, particularly where it flows
through the Town of Salina Landfill. In addition, the channel was widened and altered by man
before 1980 to address channel conditions causing extensive flooding. The bottom of the stream
is mostly composed of soft sediment, with very little areas of stone or riffle.
The topography at Old Ley Creek is irregular having been modified through re-routing of the
channel and dumping of waste along the banks of the old channel. Old Ley Creek was formerly a
wetland complex that extended from the northeastern shore of Onondaga Lake to just south of
the village of Mattydale. The extreme northern portion of this wetland complex was used as the
Town of Salina Landfill. Landfilling operations appear to have encroached to the banks of the
Old Ley Creek Channel. The U.S. Fish and Wildlife Service has also mapped a wetland that
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encompasses the Old Ley Creek Channel site from the edge of the Town of Salina Landfill
parcel to a point just east of State Route 11 (see Figure 2.3).
2.1.2.2 Land Use
The land surrounding Lower Ley Creek is mostly used for industrial purposes. The surrounding
area has been urbanized for many decades and contains numerous industries, a landfill, roads,
businesses, homes, and other infrastructure. However, some ecologically sensitive areas are
directly adjacent to Lower Ley Creek.
The creek itself is not used commercially, although it is easily accessible for fishing and other
recreation. Access to this site is unrestricted, and the property is adjacent to a public
thoroughfare. However, site access is difficult due to thick vegetation. Flow in the channel does
not support an attractive fishery, making trespassing and direct contact with contaminated
materials unlikely. There are currently fish advisories in place for Onondaga Lake and its
tributaries which includes Ley Creek. There does not seem to be any other controls (i.e., fencing,
signage) currently in place for the Site.
The Old Ley Creek Channel is the former channel for Ley Creek. Ley Creek was rerouted in the
early-1970s, turning the channel into a tributary for the new channel. The Old Ley Creek
Channel has been used as a disposal area for miscellaneous materials (i.e., tires, scrap metal,
furniture). The sources of this material are unknown. The Old Ley Creek Channel property is
currently owned by Plaza East. The parcel is approximately 3.5-acres and is zoned as
commercial.
2.1.2.3 Climate
The climate around the Site is temperate continental. Due to Lake Ontario, the weather patterns
in the area yield a more moderated air temperature relative to other areas at the same latitude.
The mean annual temperature is 50.6 degrees Fahrenheit (°F), with an average maximum daily
temperature of 59.8°F and an average daily minimum temperature of 41.4°F (National Oceanic
and Atmospheric Administration [NOAA], 2011). Record temperatures range from 101°F in the
summer months to -26°F in the midwinter months. The average first occurrence of freezing
temperatures in the fall is around November 15, and the average last occurrence of freezing
temperatures in the spring is April 8. Moisture enters the area primarily via low-pressure
systems that move through the St. Lawrence Valley toward the Atlantic Ocean. Yearly
precipitation averages approximately 48 inches and is distributed fairly evenly throughout the
year. Syracuse area winds are predominantly from the west and northwest.
2.1.2.4 Geology
The bedrock geology in the area of Lower Ley Creek consists of sedimentary rock units from the
Paleozoic-age Salina Group, which, in order of oldest to youngest, consists of the Vernon
Formation, the Syracuse Formation, Camillus Shale, and the Bertie Formation. The Vernon
Formation, consisting of red and green shale, underlies Onondaga Lake and is the thickest single
formation in Onondaga County. This layer consists of approximately 500 to 600 ft of grey, red,
and green mudstones that are relatively soft and erodible interspersed with gypsum seams. Most
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of this layer is fairly impermeable. In areas to the south of Onondaga Lake, the Syracuse
Formation overlies the Vernon Formation. The Syracuse Formation varies from approximately
150 to 220 ft thick and consists of shale, gypsum, and rock salt. Groundwater flows to the north
toward Onondaga Lake and is the source of naturally occurring brines in the area. The
unconsolidated deposits overlying the bedrock around Onondaga Lake vary in thickness, with
much of the lake underlain by approximately 100 ft of deposits, which thicken to approximately
328 ft at the mouth of Onondaga Creek at the southern end of the lake. Most of these deposits
are glacial in origin but quite variable in size and origin. Naturally occurring materials found at
the surface may include the glacial deposits, or deposits of more recent origin such as clay, peat,
and marl formed in and at the edges of the lake. The area around the lake is mostly fill material
and other debris. The glacial deposits found beneath the lake also extend beyond the lake
margins and fill the major drainage channels leading into and out of the lake. Deposits within
these channels are primarily outwash in origin and consist of sand and gravel, with an
interbedded fine component. These outwash deposits are locally heterogeneous and receive
recharge from upland areas from both groundwater and surface water flow. Organically rich
sediments occur in much of the southern portion of the lake.
2.1.2.5 Soils
The surface soils surrounding Onondaga Lake consist of glacial origin deposits including till,
outwash, alluvial, and glacio-lacustrine sediments. Above the unconsolidated sediments in many
upland areas near the site are fill deposits composed of peat, cinders, ash, and other wastes.
Significant amounts of soil erode into the streams surrounding the lake during heavy storms.
Human activity has altered the natural soil surrounding most of the lake and most of the original
soils are no longer found.
2.1.2.6 Surface-Water Hydrology
Onondaga Lake receives surface runoff from a drainage basin of approximately 250 square
miles. Surface water flows into the lake via six tributaries: Ninemile Creek, Onondaga Creek,
Ley Creek, Harbor Brook, Bloody Brook, and Sawmill Creek. A small amount of additional
water is added to the lake through two industrial conveyances. Ninemile and Onondaga Creeks
account for most of the inflow to the lake, together comprising approximately 62 percent (%) of
the total inflow for the period from 1971 to 1989. Ley Creek accounts for approximately 8% of
the total water inflow to the lake.
Water flows westerly in Lower Ley Creek towards Lake Onondaga. The movement of water
within the stream is generally consistent. There are no areas of rock or riffle, although flow
increases after storm events. The 100-year floodplain and wetland areas adjacent to Lower Ley
Creek are shown in Figure 2.3.
2.1.2.7 Hydrogeology
Groundwater discharge to surface channels accounts for most of the stream flow in the
Onondaga Lake Basin. Groundwater discharge accounts for 56% of stream flow in Ley Creek.
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Based on well logs available from drilling conducted in support of the Town of Salina Landfill,
overburden in the vicinity of the Old Ley Creek Channel consists of waste/fill, clay, silt, and silty
clay at the surface with a combination of sand, gravel, and till at depth. Groundwater in the
overburden is from 8 to 12 ft below ground surface (bgs). Evaluations of groundwater flow
patterns indicate that groundwater flow is moving radially toward Ley Creek to the north and
west of Old Ley Creek.
2.1.2.8 Ecology
Historically, Onondaga Lake was a moderately productive mesotrophic lake with some dissolved
nutrients and fresh to slightly brackish water. Water in the lake is greenish, as is typical of
mesotrophic lakes, likely a result of high concentrations of algae. There is evidence of a much
more diverse and different fish community in and around Onondaga Lake in the past (SERAS,
2012). Historical fish surveys indicate a population consisting of approximately 90% carp and
described Onondaga Lake as a warm-water fish community with similar growth rates as other
warm-water lakes in the northeastern United States (SERAS, 2012).
In the vicinity of the lake, Ley Creek likely supports a fish community similar to the other large
tributaries. Fish sampling has been performed as part of investigative activities associated with
GM's Former IFG Facility located approximately 3.5 miles upstream of the lake (1.5 miles
upstream of the Site). The primary fish species observed as part of those investigations,
conducted in 1985 and 1992, included bluegill, pumpkinseed, shiners, bullhead and carp.
In November 2009, fish sampling in Lower Ley Creek was performed as part of the EPA
SERAS/Environmental Response Team (ERT) Investigation. The fish caught included several
very large (3 to 6 pound) carp, many smaller carp, sunfish, white suckers, creek chubs, pike, one
brown trout, and an assortment of small "minnow" types and miscellaneous young fish.
2.1.2.9 New York State Wetland SYW-12
New York State (NYS) Wetland SYW-12, also known as Murphy's Island, is an abandoned 36
acre lot along the southeastern shoreline of Onondaga Lake that is a culturally important area to
the Onondaga Nation. All the remediation alternatives in this Draft FS have controls in place
that will ensure that Murphy's Island will not be affected by any remediation activities.
2.2 PREVIOUS SITE ACTIVITIES AND INVESTIGATIONS
2.2.1 Lower Ley Creek Investigations
The NYS Department of Environmental Conservation (NYSDEC) and the Onondaga County
Department of Health collected three soil samples adjacent to the north bank of Ley Creek along
the Salina Landfill and four surface water samples from the same stretch of Ley Creek and
drainage ditches north and east of the landfill in 1986. PCBs were detected in the soil samples
collected adjacent to Ley Creek. In 1987, NUS Corporation collected five soil samples from the
main fill area north of Ley Creek, and three surface water and three sediment samples from Ley
Creek. These samples consisted of one surface water and one sediment sample from an upstream
location in Ley Creek (west of Route 11), one surface water and one sediment sample alongside
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the landfill, and one surface water and one sediment sample just downstream of the landfill in
Ley Creek. The soil samples contained polyaromatic hydrocarbon compounds (PAH), metals,
volatile organic compounds (VOC) and pesticides in low levels, but no PCBs. In general,
surface water and sediment samples collected downstream from the landfill did not contain
higher concentrations of contaminants than the samples collected upstream of the landfill.
Limited NYSDEC sampling in 1987 and 1997 indicated the presence of PCBs at hazardous
waste levels in both the former channel sediments and subsurface soils. In addition, the 1997
former channel sediment sampling showed levels of heavy metals exceeding the NYSDEC Fish
& Wildlife Severe Effect Levels (SEL). Ley Creek channel sediments were sampled in 1998 as
part of the Salina Landfill RI/FS, and were found to contain levels of PCBs at greater than 80
parts per million (ppm), chromium at levels greater than 1,700 ppm, and other heavy metals
exceeding their respective SELs.
2.2.1.1 Old Lev Creek Channel Investigation
In 2010, the NYSDEC tasked EA Engineering, P.C., and its affiliate EA, to perform a RI at the
Old Ley Creek Channel (EA, 2010). The Old Ley Creek Channel is located west of the
intersection of Factory Avenue and Wolf Street (State Route 11) in the town of Salina, Onondaga
County, New York. The approximately 3.5-acre site is within an overgrown and wooded area
adjacent to the banks of the Old Ley Creek Channel between Route 11 and Ley Creek (Figure
2.2).
The Old Ley Creek Channel is approximately 1,350 ft in length and flows from northeast to
southwest draining to Ley Creek. The Town of Salina Landfill is located west and northwest of
the Old Ley Creek Channel. The landfill began operations in the 1950s and active land filling
operations ceased in 1974-1975. During its operation, the landfill received domestic,
commercial, and industrial wastes. Hazardous waste, including 640 tons of paint sludge, and 22
tons of waste paint thinner and reducer from GM's IFG Division were disposed of at the landfill.
Closure via a soil cover cap was completed in 1982. During the early 1970s, in an effort to limit
flooding in the area, the U.S. Army Corps of Engineers (USACE) re-routed Ley Creek through
the landfill area (NYSDEC, 2009a). The re-routing of the creek adjacent to Route 11 separated a
fragment of the landfill between the new course of Ley Creek and the Old Ley Creek Channel.
The analytical results of the Old Ley Creek Channel RI exhibited:
• VOCs, semi-volatile organic compounds (SVOC), metals, pesticides, and PCBs were
detected in groundwater but exhibited limited impact. Some metals were detected at
concentrations greater than their respective NYSDEC Water Quality Standards.
• Metals, pesticides, and PCBs were present in surface water during two of the sampling
rounds at concentrations greater than their respective NYSDEC Water Quality Standards.
• SVOCs, pesticides, PCBs, and metals were present in soils above NYSDEC unrestricted
use soil criteria from the surface to several ft below grade with the highest concentrations
being within the first 2 ft. Only limited low-level impacts to soils by VOCs were
identified.
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• VOCs, SVOCs, pesticides, PCBs, and metals were present in sediment above NYSDEC
sediment criteria from the surface to 2 ft below grade.
Based on the results of the RI, several factors have resulted in impacts to environmental media at
the Old Ley Creek Channel. Historical land-filling activities from the 1950s through the 1970s
at the Town of Salina Landfill are one of the potential sources of impacts to the area. Soil,
groundwater, surface water, and sediment have been impacted by PCBs, heavy metals, and
organic compounds. The analytical results collected during completion of the RI also confirmed
that soil, surface water, groundwater, and sediment have been impacted by the migration of
contaminants to the site from upstream sources, specifically from the flow of Ley Creek.
2.2.2 Current Activities at the Former Town of Salina Landfill
During a site visit in October 2012, the former Town of Salina Landfill was in the process of
being capped. Work was being led by Clough, Harbour & Associates (CHA) under the direction
of the NYSDEC. The entire section of the landfill south of Lower Ley Creek with PCBs less
than 50 ppm was relocated north of Lower Ley Creek in 2011. Material with 50 ppm PCBs or
greater was properly disposed of in an off-site Toxic Substances Control Act (TSCA) landfill.
Except for a 50-ft section in the southeast corner of the relocation effort, this landfill excavation
did not intersect with Lower Ley Creek or the Old Ley Creek Channel. The 50-ft section that did
intersect with Lower Ley Creek and/or the Old Ley Creek Channel contained soils and sediment
with PCB concentrations less than 50 ppm and are capped under the completed section of the
Town of Salina Landfill closure system.
PCB contaminated soil with concentrations greater than 50 ppm and up to 333 ppm were
excavated and shipped off-site to a TSCA landfill. Soils with less than 50 ppm PCBs were placed
on the north side of Lower Ley Creek on the Town of Salina Landfill, and were capped in 2012.
Generally speaking, PCB-contaminated material with concentrations greater than 1 ppm was
removed from the 4 acres south of Ley Creek during the consolidation effort.
2.3 NATURE AND EXTENT OF CONTAMINATION
This section discusses the results of the EPA SERAS/ERT Investigation of Lower Ley Creek and
the results of the Old Ley Creek Channel RI performed by EA.
2.3.1 Lower Ley Creek
During the most recent investigation at Lower Ley Creek (SERAS, 2012), EPA SERAS-ERT
collected fish tissue samples, surface water samples, soil samples, and sediment samples to
characterize the nature and extent of contamination at the Site.
To assist with the determination of remedial alternatives for soil, site soils have been separated
into two areas (Southern Swale Soils and Northwest Soils). These two areas are shown on Figure
2.4. This separation was made because there are specific remedial challenges associated with
each area. While the Northwest Soil area has two large buried pipelines to consider, remediation
of the Southern Swale Soil area may require limited wetland restoration.
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To assist with the determination of remedial alternatives for sediment, the 2-mile stretch of the
Lower Ley Creek Subsite has been separated into three sections (upstream, middle, and
downstream). These three sections are shown on Figure 2.5. This separation was made because
the downstream section of the Site exhibits lower concentrations of contaminants and a smaller
extent of contamination than the upstream or middle sections of the Site. In addition, the
upstream and middle sections of the site exhibit distinctive stream characteristics. While the
upstream section of Lower Ley Creek meanders, the middle section of the creek is relatively
straight. The upstream portion of Lower Ley Creek extends from upstream of the Route 11
Bridge to its intersection with the 7th North Street Bridge. The upstream section also includes
sediments associated with the Old Ley Creek Channel. The middle section of Lower Ley Creek
extends from its intersection with the 7th North Street Bridge to approximately 2,000 ft southwest
of the intersection (near the Alliance Bank Stadium). The downstream section of Lower Ley
Creek extends from approximately 2,000 ft southwest of the 7th North Street Bridge intersection
to its discharge into Onondaga Lake.
2.3.1.1 Fish Tissue
The fish tissue samples exhibited detectable concentrations of metals, organic compounds, PCBs,
and dioxins/furans. Ecological risks exist from concentrations of dioxins and PCBs in the fish
tissue. In addition, human health risks exist from the potential consumption of contaminated fish
from Lower Ley Creek. The primary human health risk drivers in the fish tissue are PCBs,
arsenic, and mercury.
2.3.1.2 Surface Water
The surface water samples exhibited detections of metals, VOCs, and base/neutral/acid organic
compounds (BNA). No metals or VOCs were detected above NYSDEC Water Quality
Standards. BNAs were detected at or above their respective NYSDEC Water Quality Standards
at several surface water sample locations.
PCBs were not detected in surface water collected during this investigation. However, surface
water sample results associated with baseline monitoring program for the Lake Bottom Subsite
of the Onondaga Lake Superfund Site collected in 2011 (samples collected by Honeywell)
exhibited PCB concentrations ranging from 0.048 to 0.23 micrograms per liter (|ig/L), which is
above the NYSDEC Water Quality PCB Standard of 0.09 |ig/L when used as a human water
source. For human fish consumption, 1 x 10"6 |ig/L is the NYSDEC Water Quality PCB
Standard.
2.3.1.3 Sediments
Sediment samples were collected along the entire 2-mile length of the Lower Ley Creek Site.
Pesticides, metals, cyanide, PCBs, VOCs, BNAs, and dioxins/furans were detected in the
sediment samples. Pesticides, metals, mercury, PCBs, VOCs, and BNAs were detected above
their respective unrestricted use NYS sediment criteria. Cyanide and all the dioxins/furans
detected in sediment samples have no NYS sediment criteria for comparison. However, some
dioxins/furans in sediment were detected above the EPA preliminary remediation goal for
dioxins in residential soil.
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The cross sections locations for Old Ley Creek and Lower Ley Creek are shown in Figure 2.6.
Cross Sections for Old Ley Creek are shown in Figures 2.7 and 2.8. Figures 2.9 to 2.12 exhibit
cross sections for the Northern Upstream Section (Figure 2.9), Southern Upstream Section
(Figure 2.10), Middle Section (2.11), and Downstream Section (Figure 2.12) of Lower Ley
Creek. Each cross section presents the maximum concentrations in sediments by sample location
for PCBs, mercury, benzo(a)pyrene, and total chromium.
In sediment, metals (particularly cadmium, chromium, and nickel), BNAs, PCBs, and some
pesticides may be an ecological risk to aquatic plants and benthic invertebrates. The primary
human health risk drivers in sediment are BNAs. Specific BNA human health drivers include
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, dibenzo(a,h)
anthracene, and indeno(l,2,3-cd)pyrene.
The highest metal concentrations in sediment appear to be in the middle and upstream portions
of Lower Ley Creek, with decreasing concentrations towards Onondaga Lake. The highest
BNA, PCB, and pesticide concentrations in sediment also appear to be in the middle and
upstream portions of Lower Ley Creek, with decreasing concentrations towards Onondaga Lake.
2.3.1.4 Soils
Soil samples were collected along the banks and dredged spoils areas adjacent to Lower Ley
Creek. Soil samples exhibited detections of pesticides, metals, cyanide, PCBs, VOCs, BNAs,
and dioxins/furans. Pesticides, metals, mercury, PCBs, VOCs, and BNAs were detected above
their respective unrestricted use NYS soil criteria. Although the dioxins/furans detected in soil do
not have NYS soil criteria for comparison, some dioxins/furan analytical results were above the
EPA PRG for dioxins in residential soil. Figures 2.13 to 2.24 present the maximum
concentrations in soil by sample location for major contaminant drivers in three general depth
intervals (surface soil, shallow subsurface soil, and deep subsurface soil). Major contaminant
drivers include: PCBs (Figures 2.13 to 2.15), mercury (Figures 2.16 to 2.18), benzo(a)pyrene
(Figures 2.19 to 2.21), and total chromium (Figures 2.22 to 2.24).
The primary human health risk drivers in soils are PCBs, BNAs, and total chromium. The
highest PCB concentrations in soil appear to be associated with swale sampling, which was
conducted just south of where Old Ley Creek enters Lower Ley Creek. Elevated PCB
concentrations were also found in areas where spoils associated with the dredging of Lower Ley
Creek were reportedly deposited, especially on the south side of Lower Ley Creek just north of
its intersection with the 7th North Street Bridge. The highest BNA concentrations in soil appear
to be associated with spoils associated with the dredging of Lower Ley Creek, especially on the
west side of Lower Ley Creek just north its intersection with 1-81. The highest total chromium
concentrations in soil appear to be found in areas where spoils associated with the dredging of
Lower Ley Creek were reportedly deposited, especially on the north and south side of Lower Ley
Creek just north of its intersection with the 7th North Street Bridge.
The ecological risks associated with soil contamination were not evaluated as part of the baseline
ecological risk assessment (BERA) prepared by EPA SERAS-ERT in 2012. However, the soil
PRGs developed in this FS are protective of ecological receptors.
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2.3.1.5 Summary
The major areas of contamination in soil are present where spoils associated with the dredging of
Lower Ley Creek were reportedly deposited, especially on the north and south side of Lower Ley
Creek just north of its intersection with the 7th North Street Bridge. Soil contamination extends
from the surface to as deep as 14 ft bgs. The major areas of contamination in sediment are in the
upstream and middle portions of Lower Ley Creek, with decreasing concentrations towards
Onondaga Lake. Sediment contamination extends from the surface to as deep as 8 ft below the
water-sediment interface (bwsi). The contamination in the sediment is likely influencing the
contamination also present in fish tissue and surface water samples.
2.3.2 Old Ley Creek Channel
This section briefly discusses the results of the Old Ley Creek Channel RI.
2.3.2.1 Soil Investigation
The subsurface and surface soil analytical results indicate that soil at the site is impacted by
SVOCs, pesticides, PCBs, and metals. Only limited low-level impacts to soils by VOCs were
identified. PCB impacts are the most wide spread in both areal and vertical extents.
2.3.2.2 Sediment Investigation
The sediment analytical results indicate that sediment at the site is impacted by VOCs, SVOCs,
pesticides, PCBs, and metals. With the exception of vinyl chloride concentrations greater than
Human Health criteria at SED-03, only limited low-level impacts to sediment by VOCs were
identified. PCB and pesticide impacts are the most wide-spread in both areal and vertical extents.
2.3.2.3 Groundwater Investigation
The groundwater analytical results indicate that concentrations of the metals antimony, iron,
magnesium, manganese, selenium, and sodium were detected at concentrations greater than their
respective NYSDEC Water Quality Standards. Analysis of groundwater at the site indicates that
there are no impacts from VOCs, SVOCs, pesticides, or PCBs.
2.3.2.4 Surface Water Investigation
The surface water analytical results indicate that metals, pesticides, and PCBs were detected at
concentrations greater than their respective NYSDEC Water Quality Standards. Analysis of
surface water at the site indicates that there are no impacts from VOCs or SVOCs.
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3.0 RISK ASSESSMENT OVERVIEW
A risk assessment is an evaluation of risk to human and ecological receptors posed by the
presence of chemicals at a site if no remedial action is performed. A summary of the human
health risk assessment (HHRA) and the BERA is provided in this section. The HHRA and BERA
were completed in 2012 as part of the EPA SERAS-ERT Field Activities Summary Report,
Lower Ley Creek Superfund Site (SERAS, 2012). The objectives of these risk assessments are to
characterize the potential risks associated with exposure to site media.
3.1 HUMAN HEALTH RISK ASSESSMENT
The 2012 HHRA was conducted to evaluate whether chemical concentrations detected in media
at the site pose a significant threat to human health. Chemical concentrations in fish tissue,
surface water, soil, and sediment were screened using the appropriate screening values to select
chemicals of potential concern (COPC) for the HHRA.
3.1.1 Selection of Chemicals of Potential Concern
COPCs were identified based on a screening analysis that uses the EPA regional screening levels
(RSL) (EPA, 2009). Chemicals are selected as COPCs if their maximum detected concentration
in a given medium (sediment, surface water, fish) is greater than the relevant RSL and their
detection frequency is greater than 5%. In addition, all chemicals classified as category A -
known human carcinogens - are selected as COPCs.
3.1.2 Exposure Pathways
Recreational users (both adults and children) and future construction workers are the primary
receptor groups evaluated in the HHRA. Potential exposure pathways include contact with
Lower Ley Creek sediments and surface water via incidental ingestion and dermal contact, as
well as potential consumption of contaminated fish and wildlife.
3.1.3 Non-Cancer Summary
For non-cancer effects, an initial estimate of the total non-cancer risk is derived simply by
summing the hazard values across all chemicals to calculate a hazard index (HI). If the HI is less
than 1, non-cancer risks are not considered to be significant. If the HI is greater than 1, then it
may be appropriate to examine individual chemical hazards and determine their risks and their
effect on the same target tissue or organ system.
3.1.3.1 Recreational Visitor - Adult
3.1.3.1.1 Sediments
The total HI for the adult recreational visitor exposure is above 1 for both the reasonable
maximum exposure (RME) and central tendency exposure (CTE) scenarios, with HI values of 32
and 10, respectively. The exceedances are primarily due to exposures via fish ingestion, with
Aroclor-1254 as the primary risk driver and to a lesser extent Aroclor-1260 and total chromium.
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3.1.3.1.2 Soils
The total HI for the adult recreational visitor is equal to 1 for the RME scenario and less than 1
for the CTE scenario, with an HI value of 0.4.
3.1.3.2 Recreational Visitor - Older Child (6 - <16 years old)
3.1.3.2.1 Sediments
The total HI for the older child recreational visitor is above 1 for both the RME and CTE
scenarios, with HI values of 32 and 8, respectively. The exceedances are primarily due to
exposures via fish ingestion and to a lesser extent via dermal exposure to sediment in Lower Ley
Creek. Risk from ingestion of fish tissue is primarily driven by Aroclor-1254 and to a lesser
extent Aroclor-1260 and total chromium. Risk from dermal exposure to sediment in Lower Ley
Creek is primarily driven by Aroclor-1260.
3.1.3.2.2 Soils
The total HI for the older child recreational visitor is greater than 1 for the RME scenario, with
an HI value of 11. The HI value for the CTE older child recreational visitor is 0.5. Dermal
exposure to Aroclor-1248 is the primary risk driver contributing to the exceedance for the RME
receptor.
3.1.3.3 Recreational Visitor - Younger Child (<6 years old)
3.1.3.3.1 Sediments
The total HI for the younger child recreational visitor is above 1 for both the RME and CTE
scenarios, with HI values of 65 and 18, respectively. The pathway that contributes the greatest
hazard is fish ingestion, although direct contact (ingestion and dermal) with sediment in Lower
Ley Creek or in the Dredge Spoils area also contributes to an HI greater than 1 for the RME
scenario. Risk from ingestion of fish is primarily driven by Aroclor-1254, Aroclor-1260, and
total chromium, and to a lesser extent arsenic and mercury. Risks from direct contact exposure to
sediment are primarily driven by Aroclor-1260 or Aroclor-1248.
3.1.3.3.2 Soils
The total HI for the younger child recreational visitor is greater than 1 for both the RME and
CTE scenarios, with HI values of 24 and 2, respectively. For the RME scenario, the exceedance
is primarily due to direct contact (ingestion and dermal contact) with Aroclor-1248 in the soil.
For the CTE scenario, the exceedance is primarily due to exposure via ingestion of soil, with
Aroclor-1248 as the primary risk driver and to a lesser extent total chromium and cadmium.
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3.1.3.4 Construction Worker - Adult
3.1.3.4.1 Sediments
The total HI for the adult construction worker is below 1 for both the RME and CTE scenarios.
3.1.3.4.2 Soils
The total HI for the adult construction worker is greater than 1 for both the RME and CTE
scenarios, with HI values of 7 and 2, respectively. The exceedances are primary due to direct
contact (ingestion and dermal contact) with Aroclor-1248 in soil.
3.1.4 Cancer Risk Summary
Cancer risks are expressed as the increased risk of developing cancer as a result of a given
exposure to a given chemical. These "excess" cancer risks are summed across all carcinogenic
chemicals and all exposure pathways for each receptor category. In general, EPA considers
excess cancer risks less than 1 in 1 million (expressed as 1E-06) to be so small as to be
negligible, and risks above 1E-04 to be sufficiently large that some action may be necessary.
Excess cancer risks between 1E-04 and 1E-06 are generally evaluated on a case-by-case basis,
and EPA may determine that risks in this range warrant remedial action.
3.1.4.1 Recreational Visitor - Adult
3.1.4.1.1 Sediments
The total cancer risk for the adult recreational visitor is 4E-04 for the CTE scenario and 4E-03
for the RME scenario. The primary risk driver is ingestion of fish tissue, with PCBs, total
chromium, and arsenic contributing the greatest to total risk.
3.1.4.1.2 Soils
The total cancer risk for the adult recreational visitor is 1E-05 for the CTE scenario and 1E-04
for the RME scenario. The primary risk drivers are total chromium via ingestion and
benzo(a)pyrene via dermal exposure to soil.
3.1.4.2 Recreational Visitor - Older Child (6 - <16 years old)
3.1.4.2.1 Sediments
The total cancer risk for the older child recreational visitor is 3E-04 for the CTE scenario and
1E-03 for the RME scenario. The primary risk drivers are PCBs, total chromium, and arsenic via
fish ingestion and benzo(a)pyrene via sediment exposure.
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3.1.4.2.2 Soils
The total cancer risk for the older child recreational visitor is 3E-05 for the CTE scenario and
8E-04 for the RME scenario. The primary risk driver is benzo(a)pyrene via dermal exposure to
soil.
3.1.4.3 Recreational Visitor - Younger Child (<6 years old)
3.1.4.3.1 Sediments
The total cancer risks for the younger child recreational visitor are 5E-04 and 2E-03 for the RME
and CTE scenarios, respectively. Risk drivers include PCBs, total chromium, and arsenic in fish
tissue; and PAHs (e.g., benzo(a)pyrene) in sediments.
3.1.4.3.2 Soils
The total cancer risk for the young child recreational visitor is 1E-04 for the CTE scenario and
2E-03 for the RME scenario. The primary risk driver is benzo(a)pyrene via ingestion and dermal
exposures to soil, and to a lesser extent dibenzo(a,h)anthracene via dermal exposure. Additional
risk drivers in soil are PCBs and total chromium.
3.1.4.4 Construction Worker - Adult
3.1.4.4.1 Sediments
The total cancer risk for the adult construction worker is 2E-06 and 8E-06 for the RME and CTE
scenarios, respectively.
3.1.4.4.2 Soils
The total cancer risk for the adult construction worker is 1E-05 for the CTE scenario and 4E-05
for the RME scenario. The primary risk driver is total chromium via ingestion of soil.
3.1.5 Sediments and Soils Exposure Risks
Table 3.1 and Figure 3.1 summarize the human health risks associated with exposure to
sediments and soil in Lower Ley Creek. It is likely that recreational visitors to the site may be
exposed to both creek sediments and upland soils. Exposure to only soils or only sediments
results in cancer risk estimates above 1E-04 for the RME older child and the RME young child,
and non-cancer HI estimates greater than 1 for the RME older child and both the CTE and RME
young child. These exceedances remain consistent for all of the combined soil/sediment
exposure percentages.
3.2 BASELINE ECOLOGICAL RISK ASSESSMENT
Five assessment endpoints (AE) were selected to evaluate risk to ecological receptors at the Site:
1. Survival;
2. Growth and Reproduction of Aquatic Plants;
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3. Benthic Invertebrates;
4. Fish; and
5. Piscivorous Birds and Mammals.
As part of the BERA conducted in 2012, a screening level ecological risk assessment (SLERA)
compared measured concentrations in abiotic media to conservative screening benchmarks. The
measured (maximum detected) concentration of several inorganics in surface water, and
numerous COPCs measured in surface sediment samples, exceeded their screening benchmarks,
indicating the potential for adverse effects to the aquatic community in Lower Ley Creek.
For the BERA, measured concentrations of selected COPCs in fish tissue were compared with
concentrations reported in the literature that are associated with adverse effects in fish. Dietary
exposure of piscivorous birds and mammals feeding on prey captured from Lower Ley Creek
was also evaluated. Solid-phase toxicity tests were conducted using two invertebrate species.
Risk to the aquatic plant community in Lower Ley Creek was assessed by comparing measured
concentrations of COPCs in surface water with selected surface water quality benchmarks and by
comparing measured concentrations of COPCs in sediment with soil benchmarks for plants.
Exceedances of surface water quality benchmarks and sediment benchmarks suggest potential
risk to aquatic plants, benthic invertebrates, and fish. In sediment, inorganics (particularly
cadmium, total chromium, and nickel), PAHs, PCBs, and some pesticides resulted in
exceedances of screening values, indicating potential risk to aquatic plants and benthic
invertebrates.
Reduced growth was observed in invertebrates exposed to sediment samples collected from
several locations in Lower Ley Creek; significant mortality was observed in one sample. No
significant correlations with measured COPC concentrations in sediment samples were observed
within the test results.
Total equivalent concentrations (TEC) of dioxin in fish tissue collected from Lower Ley Creek
exceeded concentrations reported to be associated with adverse effects in fish.
Piscivorous mammals are at risk from dietary exposure to measured total PCB concentrations in
fish from Lower Ley Creek. It may also be concluded that piscivorous birds are at risk from
dietary exposure to PAHs and potentially total chromium.
The following inorganics were retained as COPCs potentially resulting in direct toxicity to
benthic invertebrates: arsenic, cadmium, total chromium, copper, lead, mercury, nickel, silver,
and zinc. The maximum no-effect concentration observed in the toxicity tests was identified as
the PRG:
• Arsenic, 5.6 milligrams per kilogram (mg/kg);
• Cadmium, 6.4 mg/kg;
• Total Chromium, 94.2 mg/kg;
• Copper, 102 mg/kg;
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• Lead, 87.8 mg/kg;
• Mercury, 0.29 mg/kg;
• Nickel, 34.4 mg/kg;
• Silver, 2.1 mg/kg; and
• Zinc, 342 mg/kg.
Site-specific bioaccumulation factors for PCBs were calculated for forage fish in the upper,
middle and lower sections of Lower Ley Creek. Lowest observed adverse effect level (LOAEL)-
based and no observed adverse effect level (NOAEL)-based sediment concentrations were
calculated to identify a range of sediment PCB concentrations below which adverse effects on
wildlife receptors would not be expected. Sediment concentrations that would result in
calculated hazard quotients (HQ) less than 1.0 for mink (the most sensitive receptor at this site
based on the food chain models) were calculated. The LOAEL-based sediment PCB
concentrations protective of ecological receptors ranged from 0.08 to 2.28 mg/kg. The NOAEL-
based sediment PCB concentrations protective of ecological receptors ranged from 0.01 to 0.23
mg/kg.
Based upon the results, risk characterization, and interpretation, ecological risks exist at the Site
from contaminants in sediments. These contaminants include PAHs and several inorganics,
which may pose a risk via exposure to surface water in addition to exposure to sediment.
Ecological risk exists from concentrations of dioxin-like COPCs in fish tissue, and PCB
concentrations in sediment and forage fish pose a risk to piscivorous mammals. A conceptual site
model for ecological risks is exhibited in Figure 3.2.
The ecological risks associated with soil contamination were not evaluated as part of the BERA
prepared by EPA SERAS-ERT in 2012. However, the soil PRGs developed in this FS are
protective of ecological receptors (Appendix B).
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4.0 CONCEPTUAL SITE MODEL
In order to better develop and evaluate remedial alternatives, a conceptual site model (CSM) was
developed as part of this Draft FS. This CSM identifies the processes and interactions that
typically control the transport and fate of contaminants. Exposure pathways for humans and biota
and human and ecological receptors have been presented and discussed in Section 3.0. Therefore,
this CSM includes an evaluation of the following:
• Sources of Contaminants of Concern;
• Contaminant Transport Pathways; and
• Hydrologic Evaluation.
4.1 CONTAMINANT SOURCES AND TRANSPORT
4.1.1 Sediment Contamination
The initial source of the majority of contamination in Lower Ley Creek was likely the GM-IFG
Facility located upstream of Lower Ley Creek. Contaminants from this site have adhered to the
sediments in Lower Ley Creek and these sediments now serve as a continuing source of
contamination for the water column and biota.
Leachate/contaminated groundwater from the Salina Landfill may also have contributed to
contamination at the Site. However, the current remedy for the Salina Landfill includes a
groundwater/1 eachate collection and pre-treatment system, which should eliminate the Salina
Landfill as a source.
These sediments migrate downstream by both suspended load and bed-load transport. Bedload
transport represents particles that roll or saltate along the river bottom without being brought into
resuspension. Because these particles are not transported into the water column, they have no
effect on the suspended sediment concentration. However, the effects of bed-load transport are
significant because they change the thickness of the sediment bed and increase the rate of
contaminant desorption from the transported sediments into the water column.
The processes that determine the fate of contaminants in Lower Ley Creek may be divided into
two categories: 1) transport and 2) transfer and reaction. Transport is the physical movement of
contaminants caused by the net advective movement of water, mixing, and
resuspension/deposition of solids to which contaminants are adsorbed. It is dependent on the
flow and dispersion characteristics in the water column and the settling velocity and
resuspension rate of the solid particles. Transfer and reaction include movement of contaminants
among air, water, and solid phases of the system, and biological (or biochemical) transformation
or degradation of the contaminants. The processes involved in transfer and reaction include
volatilization, adsorption, dechlorination, bioturbation, and biodegradation. Contaminants are
present in Lower Ley Creek in three phases that interact with each other: freely dissolved; sorbed
to particulate matter or solids; and complexed with dissolved (or colloidal) organic matter.
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These complex sediment and water exchange processes govern the mechanisms that in turn
contribute to bioaccumulation of contaminants in the fish via both benthic and pelagic food
webs. These highly variable and complex processes include sediment resuspension and settling,
biological mixing (bioturbation), sediment bedload transport, anthropogenic disturbances, flood
events, ice-rafting, and other such related processes. The net result of these processes is that, in
general, the distribution of contaminants in the sediments of Lower Ley Creek is fairly random.
However, there does appear to be generally lower contaminant concentrations in sediments in the
downstream section of Lower Ley Creek. Lower contaminant concentrations in the downstream
section of Lower Ley Creek may be due its distance from the major initial source of
contamination at the Site (i.e., the GM-IFG Facility).
Contaminant loss or gain from the sediment can take many forms. Scour, diffusion, groundwater
advection, and biological activity can all potentially remove contaminants from a given location.
Biological activity in the form of anaerobic microbial dechlorination can also serve to decrease
contaminant concentrations in the sediments. Contaminant inventories can be increased chiefly
by deposition, either with sediment contaminated by newly released chemicals or with
redeposited sediments from other contaminated locations.
4.1.2 Soil Contamination
As previously discussed, dredging of Ley Creek was performed in the 1970s and early 1980s.
Dredged material (i.e., spoils) generated during these dredging activities was placed along the
banks of Ley Creek. This dredged material may continue to be a source of contamination to
Lower Ley Creek as contaminants in the soil are leached to the creek. In addition, the soil is
currently a significant source of contamination to the riparian corridor and associated upland
ecological resources.
However, there is significant vegetation along Lower Ley Creek that may be minimizing any
current erosion or transport of soil contaminants to Lower Ley Creek. Although the dredged
material may have been a significant source of contamination to Lower Ley Creek initially, the
revegetation of the banks after the dredging of the Creek has limited the mobility of the soil
contaminants over time. Therefore, it appears that soil contamination along the shoreline of
Lower Ley Creek may have at one time been a significant source of contamination for Lower
Ley Creek, but currently may be a relatively minor source.
4.1.3 Contaminant Persistence
The continued high levels of sediment contamination in Lower Ley Creek indicate that most
contaminants are persistent in the study area and are not being significantly degraded by natural
processes. However, the random distribution of sediment contamination in Lower Ley Creek
indicates that contaminants are being redistributed within the Site. This indicates that the stability
of the sediment deposits cannot be assured. Burial of contaminated sediment by cleaner material
is not occurring universally as high concentrations of contaminants were detected in samples
collected on the top of the sediments (i.e., 0-1 ft bwsi). Although burial of more contaminated
sediment by less contaminated sediment may be occurring at some locations, significant amounts
of contamination may have been re-released to the environment. Therefore, it is likely that
contaminants will continue to be released from Lower Ley Creek sediments.
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4.2 HYDROLOGIC EVALUTION
The Lower Ley Creek watershed is very heavily developed and contains a mix of commercial
and industrial uses. The gradient of Lower Ley Creek is minimal throughout the watershed, and
elevation change as it approaches Onondaga Lake is minimal.
One U.S. Geological Survey (USGS) stream gauge (USGS 04240120) is operated in the Lower
Ley Creek Subsite. This stream gauge is located near Onondaga Lake, where the Onondaga Lake
Parkway (Park Street) crosses Lower Ley Creek (see Figure 2.2).
If a sediment remedial alternative other than "No Action" is selected, a detailed hydrologic
analysis will be necessary in order to determine the effect of the chosen alternative on stream
flow, flooding, and dynamics, appropriate materials and bathymetry for restoration, and long-
term sustainability. This analysis will be performed as part of a remedial design prior to
implementation of a remedial action.
4.2.1 Streamflow Characteristics
Runoff is typically low during the summer and early fall months, except during occasional
frontal storms, and during midwinter when ice-cover forms or a snowpack is present in the
watershed. Flood flows are most common during spring snowmelt, primarily early-March to
mid-April. No temporal lag in flows is discernible using daily data, demonstrating the regional
rather than local nature of flood events.
Streamflow characteristics for the Park Street stream gauge are summarized in Table 4.1.
Monthly mean streamflows for Lower Ley Creek from 2000-2010 are exhibited in Figure 4.1
and peak flow events from 1974-2010 in Lower Ley Creek are shown in Figure 4.2.
4.2.2 Stream Channel Characteristics
To assist with the determination of remedial alternatives for sediment, the 2-mile stretch of the
Lower Ley Creek Subsite has been separated into three sections (upstream, middle, and
downstream). These sections are shown on Figure 2.5. This separation was made because the
downstream section of the Site exhibits much less contamination than the upstream or middle
sections of the Site. In addition, the upstream and middle sections of the Site exhibit distinctive
stream characteristics. This separation forms a useful framework for describing channel
characteristics of Lower Ley Creek. Each section is described qualitatively below:
• Upstream: Extends from just upstream of the Route 11 Bridge to the intersection with
the 7th North Street Bridge. This section has been channelized at the upstream end such
that most of the reach is an oversized, low gradient canal. Substrate in this section range
from sand to clay with some small (1-4 centimeter) stones. Old Ley Creek enters Lower
Ley Creek near the middle of the section and Beartrap Creek enters Lower Ley Creek at
the downstream end of the section. Water depth is variable, but is typically between 2 to
4 ft deep. There are multiple bends and bridge crossings in this section of Lower Ley
Creek.
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• Middle: Extends from the intersection with 7th North Street Bridge to approximately
2,000 ft southwest of the intersection (near the Alliance Bank Stadium). This section
consists of a generally straight, uniform, low gradient stream. Substrate in this section
mostly consists of silt and clays. Water depth in this section is approximately 4 ft deep.
There is only one bridge crossing in this section of Lower Creek.
• Downstream: Extends from approximately 2,000 ft southwest of the 7th North Street
Bridge intersection to the intersection with Onondaga Lake. This section has a low
gradient and substrate in this section mostly consists of silt and clay. Water depth is
variable, but is typically between 8 to 12 ft deep. There are multiple bends and bridge
crossings in this section of Lower Ley Creek.
Although, for the purposes of the FS, the upstream section of Lower Ley Creek includes the Old
Ley Creek Channel, the Old Ley Creek Channel is quite different from Lower Ley Creek in
hydrologic characteristics. While Lower Ley Creek is a functioning creek carrying regular and
occasionally swift flows, Old Ley Creek has little to no flow and is currently functioning as more
of a floodplain. wetland.
4.2.3 Sediment Transport Characterization (Erosion and Depositional Environments)
This sediment transport evaluation considered field evidence of erosion (vertical, unvegetated
banks; scour holes; coarse substrate) or deposition (mid-channel bars, multiple channels, fine-
grained substrate, overbank deposition). In addition, observed depths of unconsolidated sediment
were considered. This evaluation was performed comprehensively for the entire study area, and
is presented in below. However, a more detailed and conservative evaluation of erosion potential
is exhibited in Appendix E.
Most of the Lower Ley Creek channel is considered to be neither erosional nor depositional on
the basis of field evidence (i.e., suspended sediment flux from the bed is likely to be balanced
evenly between erosion and deposition, and material entering the section of the creek as
suspended load can be transported through the section).
Lower Ley Creek is a simple hydrologic system exhibiting low hydraulic gradients, relatively
weak erosional and depositional environments under typical stream flows, and small tributaries.
In addition, Lower Ley Creek exhibits limited variations in the types of unconsolidated sediment
(sand and silt), underlying material (silt and clay), and stream depth. The qualitative field
observations from an experienced field team on the bathymetry and geomorphology of the
stream, along with local knowledge of potential future disruptions to the stream environment
(i.e., ice scouring, flooding, man-made disruptions) are sufficient to make an informed
evaluation and final decision on sediment remedial alternatives.
For sediment cap design, a more conservative and detailed evaluation of erosion potential is
required. This is due to the potential of extreme hydrodynamic conditions (i.e., floods, ice
scouring) causing permanent damage to the sediment cap and creating contaminate releases.
Appendix E details a more conservative evaluation of erosion potential necessary for sediment
cap design.
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5.0 GENERAL SCOPING OF THE FEASIBILITY STUDY
The framework for remedial alternative identification and screening is established under federal
regulations at Title 40: Protection of the Environment, Part 300 - National Oil and Hazardous
Substances Pollution Contingency Plan, Subpart E - Hazardous Substance Response (40 Code of
Federal Regulations [CFR] Part § 300.430).
The primary objective of this FS is to ensure that appropriate remedial alternatives are developed
and evaluated such that relevant information concerning the remedial action options can be
presented to a decision maker and an appropriate remedy selected. Through the process,
potentially suitable remedial technologies and process options, including innovative treatment
technologies, are identified and evaluated. Suitable remedial technologies and process options
are assembled into a range of remedial alternatives.
The range of remedial alternatives consists of treatment options that reduce the toxicity,
mobility, or volume of the hazardous substances, pollutants, or contaminants. As appropriate,
this range includes a remedial alternative that removes or destroys hazardous substances,
pollutants, or contaminants to the maximum extent feasible, and eliminates or minimizes the
need for long-term management. Other alternatives should be considered that, at a minimum,
treat the principal threats posed by the site but vary in the degree of treatment employed and the
quantities and characteristics of the treatment residuals and untreated waste that must be
managed.
Consistent with state and federal guidance, this FS uses a multi-step evaluation process in
identifying applicable remedial technologies for Lower Ley Creek (NYSDEC, 1990; EPA,
1988). The multi-step process helps to ensure that the full range of potentially applicable and/or
available remedial technologies is evaluated and that an adequate range of technologies is
included in developing a manageable set of remedial alternatives for detailed evaluation.
Before proceeding with a description of the evaluation process, it is worthwhile to consider some
important definitions of terms that will be used throughout the remainder of this FS:
Remedial Technology - A discreet remedial technique, control method, tool, or process that
may be useful for addressing some aspect of remediation at a site. A particular remedial
technology may only address one type of contamination, situation, location, or contaminated
matrix (e.g., soils, water, air), and therefore may only be useful in combination with other
technologies or activities.
General Response Action (GRA) - This is a category or group of remedial technologies or
overall processes that have some common element or approach. A GRA usually does not
consider specific techniques or methods of application to a particular site.
Remedial Alternative - A comprehensive remediation scenario intended to provide overall
remediation of a site. Remedial alternatives consist of combinations of remedial technologies
that can be applied to various locations, situations, and/or matrices within the site to provide a
comprehensive approach to remediation of the site. The term "alternative" is used because a
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number of different, alternative approaches to site-wide remediation are normally considered and
compared to each other in the FS evaluation process. Applicable remedial alternatives include
dredging, excavation, capping and monitored natural recovery (MNR).
The evaluation of remedial technologies and alternatives for this FS follow the Technical and
Administrative Guidance Memorandum #4030: Selection of Remedial Actions at Inactive
Hazardous Waste Sites (NYSDEC, 1990) and Guidance for Conducting Remedial Investigations
and Feasibility Studies Under Comprehensive Environmental Response, Compensation, and
Liability Act [CERCLA], Interim Final (EPA, 1988). These two processes are very similar, and
the NYSDEC guidance is consistent with much of the EPA CERCLA guidance.
The overall screening and evaluation process for this FS, which draws from these two
documents, consists of the following steps:
1. Develop ARARs (Section 5.1), RAOs (Section 5.2) and PRGs (Section 5.3);
2. Identify areas and volumes of media that require remedial action (Section 5.4);
3. Develop GRAs and identify remedial technologies (Section 6.0);
4. Screen remedial technologies to eliminate those that cannot be implemented technically
(Section 6.0);
5. Assemble the representative remedial technologies into appropriate remedial alternatives
and conduct preliminary screening of the alternatives (Section 7.0);
6. Evaluate the remedial alternatives (Section 8.0); and
7. Perform a comparative analysis of all remedial alternatives against the evaluation criteria
(Section 9.0).
5.1 IDENTIFICATION OF APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
Section 121(d) of CERCLA, 42 U.S.C. § 9621(d), the NCP, 40 CFR Part 300, and guidance and
policy issued by EPA require that remedies implemented under CERCLA comply with
provisions of ARARs from federal and state environmental and facility siting laws during and at
the completion of the remedial action (RA). ARARs are either "applicable" or "relevant and
appropriate;" both types of requirements are mandatory under CERCLA and the NCP. Only
those state standards that are identified by a state in a timely manner and those that are more
stringent than federal requirements may be applicable or relevant and appropriate (40 CFR §
300.5). These requirements are threshold standards that any selected remedy must meet, unless
an ARAR waiver is invoked.
The remedial alternatives developed and assessed in this FS use the preliminary determination of
ARARs presented in Appendix A.
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5.2 REMEDIAL ACTION OBJECTIVES
RAOs are developed to specify the requirements that the remedial action alternatives must fulfill
to protect human health and the environment. The RAOs developed for the Site are:
Soil RAOs
• Reduce the cancer risks and non-cancer health hazards to human health from the
incidental ingestion of and dermal contact with contaminated soil.
• Prevent migration of contaminants that would result in surface water contamination at
levels that are associated with unacceptable ecological risk.
• Remediation of soil to levels that are of acceptable ecological risk.
Lower Ley Creek RAOs
• Prevent the direct contact with contaminated sediments.
• Reduce the cancer risks and non-cancer health hazards for people eating fish from Lower
Ley Creek by reducing the concentration of contaminants in fish.
• Prevent releases of contaminant(s) from sediments that would result in surface water
levels in excess of ambient water quality criteria.
• Prevent impacts to biota from ingestion/direct contact with sediments causing toxicity or
impacts from bioaccumulation through the marine or aquatic food chain.
• Restore sediments to pre-release/background conditions to the extent feasible.
• Reduce the risks to ecological receptors by reducing the concentration of contaminants in
fish.
• Minimize the current and potential future bioavailability of contaminants in sediments.
Contaminants in sediments may become bioavailable by various mechanisms (e.g., pore
water diffusion, bioturbation, biological activity, benthic food chains, ice jam scour, etc.).
5.3 PRELIMINARY REMEDIATION GOALS
The NCP requires the establishment of PRGs that can be used to select applicable remediation
technologies and to develop remedial alternatives. The PRGs represent the primary goals of the
remedial efforts, and can provide a range of quantitative values to be used during the evaluation
of the various remedial alternatives. The ability of various remedial alternatives to actually
achieve the PRGs was not a factor in their development.
PRGs are defined as the average concentration of a chemical in an exposure unit associated with
a target risk level such that concentrations, at or below the remedial goal (RG), do not pose an
unacceptable risk. PRGs are refined into RGs during the course of the RI/FS process based on
cost, technical feasibility, community acceptance, uncertainty in the baseline risk assessment,
schedule, and other risk management considerations. PRGs were developed based on the
COPCs identified in the HHRA, COPCs identified in the BERA, and site-specific exposure
pathways and receptors.
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PRGs were also developed to address each of the RAOs through the application of a variety of
quantitative measures. Lower Ley Creek has two primary media of concern, sediment and soils,
and two secondary media of concern, surface water and fish tissue. Chemicals that are present in
sediment are available for partitioning into fish tissue and the surface water. Consequently,
actions that address chemicals in sediment will indirectly address chemicals in fish tissue and
surface water. This applies to fish and other aquatic organisms with limited range. These
organisms would be exposed to contaminated sediment for extended periods of time resulting in
an increased probability of partitioning of chemicals in sediment to fish tissue.
COPCs were developed based on the COPCs identified in the HHRA, COPCs identified in the
BERA, and site-specific exposure pathways and receptors. Table 5.1 presents the COPCs
contributing to human health and ecological risks in Lower Ley Creek. Table 5.2 exhibits the
chemical-specific PRGs for soil and Table 5.3 exhibits the chemical-specific PRGs for sediment.
Details on the determination of the PRGs are presented in Appendix B.
5.4 CLEANUP GOALS
As previously discussed in Section 2, the Site is located within a highly urbanized area of
Eastern Syracuse, New York. Lower Ley Creek is surrounded by manufacturing operations,
parking lots, a landfill, railroad tracks, and commercial operations. This has been a
commercial/industrial area for at least 50 years and will continue to be a commercial/industrial
area for the foreseeable future. However, the Site also contains an undeveloped riparian corridor
that includes Old Ley Creek, Lower Ley Creek, and the adjacent wetlands and floodplains
associated with these surface water bodies. Therefore, cleanup goals are based both on
commercial use and the protection of ecological resources.
5.4.1 Sediment Cleanup Goals
As documented in the ROD for the Crouse-Hinds Landfills State Superfund Project (Site No.
734004), located along the southern shore of Lower Ley Creek, the cleanup goal of 1 mg/kg
PCBs in creek sediment is recognized as a previously selected sediment cleanup goal at NYS
Hazardous Waste Sites (NYSDEC, 2011). Therefore, 1 mg/kg PCBs was used as a cleanup goal
for sediments at Lower Ley Creek. Additional areas exhibiting sediments below 1 mg/kg PCBs
were added to the sediment remedial alternatives based on elevated concentrations of other risk
drivers (i.e., chromium and PAHs).
5.4.2 Soil Cleanup Goals
Cleanup goals for soil were based on 6 NYCRR Part 375 Soil Cleanup Objectives (SCO) for
Commercial Use and the Protection of Ecological Resources. Although the area is a riparian
corridor, widespread landfilling exists beneath much of the soil areas and the surrounding land
use is industrial and commercial. For soils shallower than 2 ft bgs, the lower value between
Commercial Use SCOs and Ecological SCOs was used as a cleanup goal. For soils deeper than 2
ft bgs, Commercial Use SCOs were used as cleanup goals as there are very limited ecological
pathways and exposures deeper than 2 ft bgs. Cleanup Goals for soil are exhibited in Table 5.4.
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5.5 IDENTIFY AREA AND VOLUMES OF MEDIA THAT REQUIRE REMEDIAL
ACTION
Consistent with CERCLA guidance, this subsection develops the areas and volumes that may
require remediation based on the cleanup goals. Areas and volumes are developed for each
media (soil and sediment). These areas and volumes will be used to guide the development and
screening of remedial technologies. Please note that these estimated areas and volumes are
preliminary estimates used for cost comparison purposes.
5.5.1 Extent of Contamination in Soil
Table 5.5 presents the volume of soil to be considered for remediation based on exceedances of
the cleanup goals listed in Table 5.4. Soils along the 2-mile stretch of Lower Ley Creek have
been separated into two areas (Southern Swale Soil Area and Northwest Soil Area) to assist with
determining remedial alternatives for the Site.
The existing data set from the Old Ley Creek Channel Final RI Report (EA, 2010) and the
SERAS Field Activity Summary Report (SERAS, 2012) were used to calculate the areal extent of
soils exceeding the relevant cleanup goals. In some cases, the cleanup goals were exceeded at the
deepest extent of the data. Therefore, Table 5.5 provides volumes based on the data available,
lithology, and field observations.
5.5.2 Extent of Contamination in Sediments
Table 5.6 presents the volume of sediment to be considered for remediation based on the
exceedance of 1 mg/kg PCB and other risk drivers at the site. Sediments along the 2-mile stretch
of Lower Ley Creek have been separated into three sections (upstream, middle, and downstream)
to assist with determining remedial alternatives for the Site.
The existing data set from the Old Ley Creek Channel Final RI Report (EA, 2010) and the
SERAS Field Activity Summary Report (SERAS, 2012) were used to calculate the areal extent of
sediments exceeding the relevant cleanup goals. In some cases, the cleanup goals were exceeded
at the deepest extent of the data. Therefore, Table 5.6 provides volumes based on the data
available, sediment lithology, and field observations.
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6.0 GENERAL RESPONSE ACTIONS AND APPLICABLE SCREENING
TECHNOLOGIES
This section includes identification and review of GRAs and potentially applicable remedial
technologies and process options for the contaminated media of concern (sediment and soil).
GRAs are initial broad response actions considered to address the preliminary RAOs for the
contaminated media identified as a concern at the site. GRAs include several remedial
categories, such as containment, removal, disposal, and treatment of contamination for each
medium of concern. Site-specific GRAs are first developed to satisfy the preliminary RAOs for
the contaminated media and then are evaluated as part of the identification and screening of
remedial technologies and process options for the contaminated media.
6.1 GENERAL RESPONSE ACTIONS
The GRAs considered for remediation of the media of concern (sediment and soil) are listed
below:
• No Action;
• Institutional Controls;
• Monitored Natural Restoration;
• Containment and Engineering Controls;
• Removal (dredging/excavating) and Disposal;
• In Situ Treatment; and
• Ex Situ Treatment.
These GRAs and their associated remedial technologies are presented in Table 6.1 and discussed
below from the generally least active (e.g., no action) to the most active.
6.1.1 No Action
Under the no action alternative, no remedial action would be implemented. The no action
alternative reflects Site conditions as described in the baseline risk assessments (SERAS, 2012).
No action was retained as a GRA to serve as a baseline for comparison with other methods,
technologies, and process options.
6.1.2 Institutional Controls
Institutional controls are activities that do not involve active remediation. In most cases, these are
activities, documents, informational devices, or legal restrictions that minimize, limit, or prevent
human exposures to COPCs. This GRA can include physical site activities such as installation of
warning signs, fencing, and surveillance. It can also include purely legal documents and methods
of public communication such as deed restrictions, new regulations, and fishing advisories.
Institutional controls are widely recognized as a potential remedial technology for sediment sites
(EPA, 2002). However, these controls are often only suitable when used in combination with
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other, more active remedial technologies. Further, the NCP preamble states that institutional
controls are not intended to be a substitute for active response measures unless such measures are
not practicable. Thus, institutional controls should be viewed as a means to further reduce risks
where other technologies are infeasible, partially effective, or require some period of time before
they become effective.
EPA has placed institutional controls into four broad categories:
• Governmental Controls;
• Property Controls;
• Enforcement Tools; and
• Informational Devices.
The specific technologies or activities recognized by EPA as most applicable to sediment sites
(EPA, 2002) are:
• Fish consumption advisories and commercial fishing bans;
• Waterway use restrictions; and
• Land use restriction/structure maintenance.
Based on these categories and general information on the creek, institutional controls that may be
applicable to Lower Ley Creek include use restrictions preventing exposure to or disturbance of
sediments or other impacted media, such as:
• Health advisories regarding specific activities; and
• Bans on, or permit requirements for, dredging and/or certain waterfront improvements or
alterations.
As a tributary of Onondaga Lake, Lower Ley Creek is currently under a New York State
Department of Health (NYSDOH) fish advisory. This advisory recommends that women under
age 50 and children under the age of 15 eat no fish of any species. For older women and adult
males, the advisory recommends the following:
• Eat no largemouth and smallmouth bass over 15 inches, carp, channel catfish, white
perch, and walleye;
• Eat up to four meals per month of brown bullhead and pumpkinseed; and
• Eat up to one meal per month of all other fish.
6.1.3 Monitored Natural Recovery
Natural restoration involves allowing natural processes to decrease the concentration, mobility,
bioavailability, toxicity, and/or exposure of chemicals. Generally, it is allowed to occur over a
given time frame and is expected to achieve specified goals within that time frame. Natural
restoration always includes a monitoring component to confirm that decreases in chemical
concentrations or exposures are actually taking place as expected. It also includes contingency
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planning procedures if sufficient natural recovery is not observed. Such contingency planning
might involve a range of activities from additional monitoring to implementing more active
remedial technologies.
MNR can occur through a variety of physical, chemical, and biological processes that act alone
or in combination to reduce chemical concentrations, exposure, and/or mobility in sediments.
MNR usually includes the following primary mechanisms that affect the surface of the sediment
bed:
• Mixing of incoming clean sediments from the water column with creek sediment
chemicals, causing dilution of the chemical concentrations (often the first step before
burial);
• Burial of creek sediments containing chemicals by incoming clean sediments from the
water column;
• Degradation of organic compounds within sediments;
• Reduction of chemical mobility and/or toxicity by conversion to less toxic forms and/or
forms that are more highly adsorbed to creek sediments;
• Diffusion/advection of chemicals to the water column (i.e., loss to the water column); and
• Transport of sediments containing chemicals and dispersion over wider areas at lower
concentrations.
It is important to note that these processes are interrelated and do not always work
synergistically. For example, if sediments from the water column containing high chemical
concentrations are settling onto creek sediments, these chemical inputs may offset any decreases
in sediment chemical concentrations caused by burial, diffusion/advection, and/or degradation.
This is why source control is a necessary first step in any MNR scenario. The last two of these
MNR mechanisms may not always be desirable. Clearly, dispersion of chemicals over wider
adjacent areas or to other media that increases toxicity in those areas and media cannot be
considered natural recovery. Thus, it is important that natural recovery evaluations considering
these processes evaluate the potential impact of substantial reduction in one area or medium to
toxicity and risks elsewhere in the system.
Reduction of chemical mobility and/or toxicity by conversion as well as degradation is highly
dependent on a number of factors, including the type of chemicals present, concentrations of
those chemicals, and the rates of any conversion or degradation processes. Consequently, MNR
may not degrade or reduce the toxicity of contaminated sediments in many circumstances. In
some cases (such as heavy metals), the primary mechanism of MNR is isolation by burial over
time.
6.1.4 Containment and Engineering Controls
Sediment containment technologies can reduce potential exposure to human and ecological
receptors by preventing direct contact with contaminated sediments/soils and reducing the flux of
chemicals into the water column. The most common containment technology is capping.
Variations of capping technology can include:
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• Engineered sediment cap with erosion controls;
• Engineered capping with reactive materials; and
• Thin-layer capping (for sediments and soils).
6.1.4.1 Granular Material Sediment Cap
A granular material sediment cap includes the installation of a granular material (sand) sediment
cap over contaminated sediments. In areas of high erosion potential, granular material sediment
caps consist of an armor stone layer overlying a sand isolation layer. Finally, a 2 ft habitat layer
is placed on top of the cap to facilitate the re-colonization of the stream bottom by native species.
Before the placement of any capping material, excavation of sediment is usually conducted to
maintain the current bathymetry of the water body.
6.1.4.2 Engineered Bentonite Cap
An engineered bentonite cap is designed to hydrate and form a continuous and highly
impermeable isolation layer over contaminated sediments. Engineered bentonite caps are
typically produced for application in relatively shallow, freshwater to brackish, generally
nearshore environments and is comprised of bentonite clay with polymer additives covering a
small aggregate core. The bentonite clay is comprised principally of montmorillonite, and the
proprietary polymer is added to further promote the adhesion and coalescing of clay particles to
the aggregate core. The aggregate core is used essentially for weighting to promote the sinking of
the material to the sediment surface. An engineered bentonite cap functions by hydrating,
swelling, and forming a continuous and highly impermeable isolation layer above contaminated
sediments. After the placement of the bentonite, a 2 ft habitat layer is placed on top of the cap to
facilitate the re-colonization of the stream bottom by native species. Before the placement of any
capping material, excavation of sediment is usually conducted to maintain the current
bathymetry of the water body.
6.1.5 Removal and Disposal
Removal includes dredging/excavating contaminated sediments/soils from their existing location
and consolidating/disposing the sediments/soils in a new location that minimizes the mobility,
exposure, or impacts to human health and the environment. It is one of the most commonly
evaluated and implemented contaminated sediment remediation technologies (EPA, 2002).
Removal and on-site consolidation or off-site disposal are presented in Table 6.1 as separate
GRAs, but in reality, they can only occur in combination.
6.1.5.1 Dredging (Sediments)
Sediment may be removed from a water body using various dredging techniques (Herbich,
2000). Dredging involves mechanically penetrating, grabbing, raking, cutting, and/or
hydraulically scouring the bottom of a water body to dislodge and remove sediment. After the
sediment has been dislodged, it is lifted out of the water body either mechanically, as with a
clamshell bucket, or hydraulically through a pipeline. Dredging at a site can also be based on a
combination of mechanical and hydraulic methods. Hybrid dredges can remove sediments by
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either mechanical or hydraulic means, depending on site conditions. Pneumatic dredges, a subset
of hydraulic dredges, use compressed air systems to remove sediments. Hybrid and pneumatic
dredges are generally less available than purely mechanical or hydraulic systems. In addition,
their historical use at contaminated sediment projects is relatively limited.
6.1.5.2 Excavation (Sediments and Soils)
Dry excavation of sediments involves isolating an area using a temporary dam, removing the
enclosed surface water, and excavating the contaminated sediment with conventional earthwork
equipment. Wet excavation of sediments can also be conducted by excavating the contaminated
sediment while it is submerged in the water using conventional earthwork equipment. The
equipment may need to be placed on support mats to avoid sinking in the soft sediments during
construction. This technique allows a visual verification that the appropriate sediment is being
removed. It also significantly reduces the amount of sediment dewatering required and
eliminates the short-term problem of sediment resuspension in the water column during removal.
Impacted soil along the shores of Lower Ley Creek can also be removed by excavating soil with
conventional earthwork equipment.
6.1.6 In Situ Treatment
In situ treatment can include a number of methods that alter sediments and soils in their existing
environment to reduce chemical concentration, mobility, bioavailability, and/or toxicity. Table
6.1 lists the primary treatment categories. Agents added to the sediment can include energy,
chemicals, microorganisms, or plants. In some cases, the treatment may involve physical mixing
or other manipulation of the media. Some forms of in situ treatment require isolation (via berms
or dams) of the area to be treated to prevent loss of chemicals or other agents to surrounding
areas. In addition, as with any invasive remediation technology, any existing habitats or
biological communities would be impacted in the short-term during in situ treatment
implementation.
6.1.7 Ex Situ Treatment
Table 6.1 reviews the various ex situ treatment technologies in detail; this detailed review is only
summarized in the following text. This technology is often considered separately from removal,
but in reality, ex situ treatment and removal must occur in combination. Once removed and
treated, the sediments/soils must be managed by placement in a suitable location. If the media
have been rendered non-toxic, some form of beneficial reuse can also be considered. Because
removal and placement technologies have been previously described, this subsection focuses on
the treatment phase of such an application.
There is a vast array of different treatment types, and as with in situ treatment, they reduce the
concentration, mobility, bioavailability, and/or toxicity of the chemicals present in the media of
concern. Depending on the physical and chemical characteristics of the media after the treatment
process, sediments and soils might have a variety of end uses or placement options.
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6.2 INFORMATION SOURCES USED TO IDENTIFY REMEDIAL
TECHNOLOGIES
Various databases, technical reports, and publications, were used to identify and evaluate
remedial technologies for use at the Lower Ley Creek site including:
• Superfund Innovative Technology Evaluation (SITE) Program (EPA, 1999);
• Selecting Remediation Techniques for Contaminated Sediment (EPA, 1993);
• Assessment and Remediation of Contaminated Sediments (ARCS) Program Remediation
Guidance Document (EPA, 1994);
• EPA Hazardous Waste Clean-up Information (CLU-IN) web site (EPA, 2000a);
• EPA Remediation and Characterization Innovative Technologies (EPA REACH IT)
database (EPA, 2000b);
• Federal Remediation Technologies Roundtable (FRTR, 1999) web site; and
• Remediation Technologies Network (RTN) Remediation Information Management
System (RIMS) (RIMS, 2000) Database.
The SITE Program was created by EPA to encourage the development and use of innovative
treatment and monitoring technologies. Under the program, EPA works with and supports
technology developers who research, refine, and demonstrate innovative technologies at
hazardous waste sites. SITE demonstration project information is compiled and can be used as a
reference guide on innovative treatment technologies.
The ARCS Program was initiated in 1987 by EPA's Great Lakes National Program Office
(GLNPO) to address sediment contamination in the Great Lakes. The ARCS program consisted
of a 5-year study and demonstration projects relating to the treatment of contaminated sediments.
The ARCS remediation guidance document is a product of the ARCS Program, and was
prepared by the Engineering/Technology Work Group (ETWG), a working committee under the
ARCS Program. The guidance document provides information on the selection, design, and
implementation of sediment remediation technologies, including feasibility evaluation, testing
technologies, and effectiveness at past site projects.
The EPA CLU-IN web site provides information about innovative treatment technologies and
includes descriptions of and contact information for relevant programs and organizations. It also
provides access to publications (e.g., Tech Trends) and other tools useful in technology review
and evaluation.
The EPA REACH IT database combines information from three established EPA databases, the
Vendor Information System for Innovative Treatment Technologies (VISITT) database, the
Vendor Field Analytical and Characterization Technologies System (Vendor FACTS) database,
and the Innovative Treatment Technologies (ITT) database. This database combines vendor-
supplied information with information from the EPA, the U.S. Department of Defense (DOD),
the U.S. Department of Energy (DOE), and state project managers regarding sites at which
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innovative technologies have been implemented, and provides information on over 1,400
remediation technologies and 750 vendors.
The FRTR describes itself as an interagency group seeking to improve the collaborative
atmosphere among federal agencies involved in hazardous waste site remediation. Member
agencies include the DOD, DOE, U.S. Department of the Interior (DOI), U.S. Department of
Commerce (DOC), U.S. Department of Agriculture (DOA), and the EPA. Its web site contains
such information as cost and performance of remedial technologies, results of technology
development and demonstration, and technology optimization and evaluation.
The RIMS 2000 database, owned and operated by the Research Technologies Network, L.L.C.,
contains remedial technology information on nearly 900 technologies. It includes technical paper
abstracts, summaries, and components of remediation efforts undertaken since the inception of
CERCLA in 1980. This information is verified and updated by RTN on a monthly basis to
provide current and objective information on the status of innovative technologies.
These and other resources were used to identify a number of potentially applicable remedial
technologies or process options for dealing with contaminated soils and sediments.
6.3 IDENTIFATION AND SCREENING OF APPLICABLE REMEDIAL
TECHNOLOGIES
During this identification of remedial technologies, a wide range of potential remedial
technologies and process options were reviewed. Based on this review, potential remedies unable
to remediate the contaminated media due to site conditions or the lack of compatibility with the
contaminated media were eliminated from further consideration. The initial identification and
screening of remedial technologies for Lower Ley Creek is presented in Table 6.1. These
technologies were developed based on the GRAs discussed above. These technologies were
screened to ensure that only those technologies applicable to the contaminants present, the
physical matrix, and other site characteristics were considered.
As an initial screening, each of the potentially applicable remedial technologies was evaluated in
terms of effectiveness, implementability, and cost.
6.3.1 Effectiveness
Effectiveness focuses on the degree to which a remediation technology or alternative reduces the
toxicity, mobility, or volume of hazardous substances through treatment and achieves long-term
protection. The effectiveness criterion also considers the degree to which the option complies
with the ARARs, minimizes short-term impacts, and also how quickly it achieves protection.
6.3.2 Implementability
Implementability includes both the technical and administrative feasibility of implementing a
technology process or a remedial alternative. Consideration of implementability with respect to a
remedial technology or a remedial alternative focuses on the administrative implementability of
an option, including necessary permits for off-site actions; the availability of treatment, storage,
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and disposal facilities; and the availability of necessary equipment and skilled workers to
implement a remedial technology or a remedial alternative.
6.3.3 Cost
Cost plays a limited role in the screening stage; only order-of-magnitude costs are developed.
For remediation technologies, processing costs were assumed to include all the costs associated
with the treatment other than capital and mobilization costs. Technologies or remediation
alternatives that may be significantly more costly without any offsetting benefit over comparable
options may be screened out.
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7.0 IDENTIFICATION AND SCREENING OF REMEDIAL
ALTERNATIVES
This section presents the remedial alternatives developed for the Lower Ley Creek Site and an
initial evaluation of these alternatives based on effectiveness, implementability, and cost. In
general, the remedial alternatives were developed to meet Site RAOs for each medium of
concern. These remedial alternatives were developed to:
• Be protective of human health and the environment;
• Attain chemical-specific ARARs (unless a waiver is justified) and can be implemented in
a manner consistent with location-specific and action-specific ARARs;
• Use permanent solutions and alternative treatment technologies to the maximum extent
practicable; and
• Be capable of achieving the RAOs in a cost-effective manner.
Soil and sediment remedial alternatives were developed and screened separately. The proposed
plan will recommend one soil remedial alternative and one sediment alternative.
7.1 SOIL REMEDIAL ALTERNATIVES
Four soil remedial alternatives (including the No Action alternative) were developed for the Site.
These alternatives are presented in Table 7.1.
To assist with the determination of remedial alternatives for soil, site soils have been separated
into two areas (Southern Swale Soils and Northwest Soils) (Figure 2.4). This separation was
made because there are specific remedial challenges associated with each area. While the
Northwest Soil area has two large buried pipelines to consider, remediation of the Southern
Swale Soil area may require limited wetland restoration.
In addition, the alternatives were screened based on the criteria of effectiveness,
implementability, and cost. This initial screening step was performed as required by CERCLA
and the NCP to narrow the field of remedial alternatives that are subject to the detailed analysis
presented in Section 8. The initial screening of all four soil remedial alternatives is presented in
Table 7.2. All soil remedial alternatives passed the screening and were retained for additional
evaluation.
7.1.1 Soil-1: No Action
Soil Alternative 1 is the No Action alternative and is presented for comparison only. The No
Action Alternative consists of refraining from the active application of any remediation
technology to soils of Lower Ley Creek. The No Action alternative also excludes source control
removal action, administrative actions, and monitoring. As required by CERCLA, periodic
reviews will be conducted at 5-year intervals to reassess the long-term appropriateness of
continued No Action.
The RAOs for soil will never be achieved using under this remedial alternative.
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7.1.2 Soil-2: Excavation of Soil to Meet Cleanup Goals
Soil Alternative 2 includes both excavation and installation of a soil cap in select locations. In
the Southern Swale Soil Area, all soil with COPCs above SCOs will be excavated to meet the
cleanup goal. Excavated soils would be disposed of in an off-site RCRA-compliant and, if
appropriate, a TSCA-compliant disposal facility. The extent of the Southern Swale Soil
excavation under Soil Alternative 2 is shown in Figure 7.1. In the Northwest Soil Area, all soils
with COPCs above SCOs will be excavated to meet cleanup goals, except in areas near the two
pipelines are located in the Northwest Soil Area. The extent of the Northwest Soil excavation
and soil cap is shown in Figure 7.2. Based on restrictions imposed on the field sampling team
during the site investigation, it is likely that there will be a 20-ft wide "safety zone" digging
restriction near the pipelines. Therefore, in areas adjacent to and above the pipelines, a soil cap
will be installed above contaminated soil that cannot be excavated. Details on the total volume of
soil to be excavated and the total volume of soil to be capped under this alternative are presented
in Table 7.3.
This alternative includes excavation and off-site disposal of soils with COPCs exceeding cleanup
goals. However, on-site disposal may potentially be possible at the Cooper Crouse-Hinds North
Landfill or additional landfills located adjacent to Lower Ley Creek. Therefore, cost estimates
for this alternative have been estimated for on-site disposal (Appendix C, Table C-l) and off-site
disposal (Appendix C, Table C-3).
Clean backfill will then be placed to bring the excavation back to the original grade. Topsoil will
be placed over disturbed areas and seeded to grow vegetation to reduce or eliminate erosion from
the disturbed areas.
This alternative also includes a soil cap for soils located adjacent to and above the pipelines. The
soil cap will be a 1-fit thick layer of clean soil to isolate the contaminated soils. The soil cap will
be a vegetated habitat layer. A demarcation layer (e.g., non-woven geotextile) will be installed
between the contaminated soil and the soil cap. The soil cap will be seeded to grow vegetation
that will reduce or eliminate erosion from the areas. Vegetation in the soil cap areas will be
restored, including trees and shrubs, to create a riparian buffer. In all areas, an excavation will be
completed before the soil cap is installed so there is no loss of floodplain capacity.
This soil cap serves three functions:
1. It isolates and covers the remaining contaminated soil to prevent movement.
2. It creates a clean soil surface.
3. It reduces the human health and ecological pathways for contact with contaminated soil.
It is estimated that soil RAOs will be achieved in approximately 6 months after initiation of
remedial activities under Soil Alternative 2. This is based on the period of active construction
required to implement this alternative.
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7.1.2.1 Restoration
7.1.2.1.1 Baseline Sampling
Prior to remedial and restoration activities, a baseline survey will be conducted at the site. The
survey will be conducted in the fall, if feasible, and will be used for comparative purposes during
the monitoring phase of restoration activities. The baseline survey will include vegetation
identification and data collection using the line interception method (discussed further below).
In addition, permanent photo locations will be established throughout the restoration area.
Photos will be taken at these locations during the baseline survey and during each of the annual
monitoring events.
7.1.2.1.2 Site Restoration
Restoration activities will be initiated following the completion of remedial activities and will
consist of the re-establishment of native vegetation within the disturbed area. Restoration of the
riparian zone will provide erosion protection for Ley Creek associated with surface water runoff
from the surrounding industrial areas. In addition, utilizing native species within the restoration
activities will create native habitat within the riparian zone. Restoration activities and post-
restoration monitoring activities are described below. Further details and specifications relative
to site restoration will be presented in the remedial design component.
According to the Ecoregions of the United States, the historical regional vegetation for the
project area consisted of native plant species typical of transitional deciduous forests between the
boreal forests and broadleaf deciduous forests. The most abundant trees within this Ecoregion
include oaks, maples, and beech (EPA, 2013). The site currently consists primarily of forbs and
grasses near the bank of Ley Creek and a combination of forbs, grasses, woody shrubs, and
deciduous forest within the riparian area.
Seeding and planting will begin as soon as possible and practicable after the completion of
remedial activities. If feasible, the remedial action will be scheduled so that seeding and planting
will be conducted in the spring or fall in order to maximize planting success. Species
composition will be designed to reflect the existing communities of native species as well as
native communities of the region, and will include a combination of trees, shrubs, forbs, and
grasses. Information relative to the existing species composition will be gathered during the
baseline survey. Accordingly, the desired species composition for the selection of terrestrial
community composition will be finalized during the remedial design and/or after the completion
of the baseline survey. Examples of likely species to be selected are listed below. The tree, shrub,
and grass species are native to either the Eastern Great Lakes ecoregion and/or the state of New
York (NYSDEC, 2005).
Trees: red maple (Acer rubrum), sugar maple (Acer saccharum), red oak (Quercus rubra), and
American beech (Fagus grandifolia)
Shrubs: redosier dogwood (Cornus stolonifera), silky dogwood (Cornus amomum), and highbush
cranberry (Viburnum opulus)
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Grasses: big bluestem (Andropogon gerardii), little bluestem (Andropogon scoparium), and
switchgrass (Panicum virgatum)
The selected tree and shrub species will be planted as seedlings, likely using bare root seedlings.
Trees and shrubs will be planted within the disturbed area at distances greater than an established
distance (e.g., 50 ft) from the bank of Ley Creek. The seedling spacing and the type of nursery
stock to be planted (e.g., bare root, ball and burlap, cuttings, etc.) will be identified within the
restoration plan to be completed within the remedial design.
Grasses will be planted from seed and will be planted throughout the entire disturbed area,
regardless of distance from the bank of Ley Creek. The specific mix, application rate, and type of
seed application (i.e., dry seeding, hydroseeding, etc.) will be identified within the restoration
plan to be completed within the remedial design.
7.1.2.1.3 Success Criteria
To evaluate the effectiveness of restoration efforts, success criteria will be established. These
will likely include a goal of percent survivorship (e.g., 70%), a goal of total percent cover (e.g.,
90%) beginning with the first annual monitoring event, and a minimum number of seeded
species present. Success criteria will be identified within the restoration plan as part of the
remedial design.
Vegetation planted on the cover layer will help stabilize the cover material to prevent movement
into Lower Ley Creek. The final depth of soil removal and thickness of the soil cap will be
refined during the pre-design phase. In addition, this alternative would require a site management
plan to manage the soil cap and the remaining contamination at the site.
7.1.2.2 Monitoring and Controls
Monitoring will be conducted to evaluate the effectiveness of the restoration efforts. The
monitoring program will direct maintenance as needed and document recovery of resources.
Monitoring will likely occur on an annual basis for a 5-year period following the completion of
restoration activities. Annual monitoring events will consist of a vegetation survey conducted
using the line interception method. Annual monitoring events will be conducted in the fall.
Visual meander surveys also will be conducted in the late spring/early summer to document
species composition.
7.1.2.2.1 Sampling Methodology
The baseline and monitoring surveys will consist of collecting vegetative data using the line
interception method (Canfield, 1941). The line interception method is a method of sampling
vegetation based on the measurement of all plants intercepted by the vertical plane of a given
transect. Linear measurements are then made of the intercepts of vegetation along the transect.
Because the monitoring will occur for 5 years, permanent transects will be established within the
restoration area and surveyed each year. A minimum of 12 transects will be established within
the riparian area, each of which will be approximately 150 ft long. Approximately six transects
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will be oriented parallel to Ley Creek, with three transects within the forested area and three
transects within the non-forested area. The remaining six transects will be oriented perpendicular
to Ley Creek.
Vegetative data collected within the survey will be used to determine percent plant cover at
which plant species occur, as well as species composition. This information will be compared to
success criteria, established above, to evaluate the restoration's success and, if necessary, adjust
management practices. The following metrics will be calculated using the vegetative data.
Absolute % Cover (Species-Specific) = Intercept Length (ft)/Transect Length (ft)* 100
Total Cover = Sum of Species Specific Absolute Cover Measurements
Relative % Cover (Species-Specific) = Absolute Cover/Total Cover* 100
Species Composition = Total List of Observed Species
7.1.2.2.2 Percent Survivorship
Percent survivorship is a measure of how many planted seedlings survive after planting.
Because the measure is relative to individual plants, this metric is only applicable to shrubs and
trees. To determine percent survivorship, the number of planted seedlings will be counted during
planting and during each monitoring event. Given the size of the restoration area, counting
individual trees or shrubs across the entire site will not be feasible. Accordingly, percent
survivorship will be calculated from established sample plots within the restoration area. This
data will be used to determine the percentage of planted seedlings that has survived. The size,
location, and frequency of sample plots will be determined within the restoration plan as part of
the remedial design.
7.1.2.2.3 Controls
As part of this alternative, controls will be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Institutional controls could
include, but would not be limited to, potential land-use controls (LUC), environmental
easements, deed notices, and public health advisories.
Additional controls will likely include fencing and signage. Fencing will be installed next to
potential public access locations (i.e., roads) and should not significantly affect the movement of
wildlife.
7.1.3 Soil-3: Excavation of Southern Swale Soils to Meet Cleanup Goals and Soil
Capping of Northwest Soils
Soil Alternative 3 includes both excavation and installation of a soil cap in select locations. In
the Southern Swale Soil Area, all soil with COPCs above cleanup goals will be excavated to
meet the cleanup goal. Excavated soils will be disposed of in an off-site RCRA-compliant and, if
appropriate, a TSCA-compliant disposal facility. The extent of the Southern Swale Soil
excavation under Soil Alternative 3 is shown in Figure 7.1. In the Northwest Soil Area, all soils
with COPCs above cleanup goals would either be excavated or covered with a soil cap. The
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extent of the Northwest Soil excavation and capping is shown in Figure 7.3. Details on the total
volume of soil to be excavated and the total volume of soil to be capped under this alternative are
presented in Table 7.4.
This alternative includes excavation and off-site disposal of soils with COPCs exceeding cleanup
goals. However, on-site disposal may be possible at the Cooper Crouse-Hinds North Landfill or
additional landfills located adjacent to Lower Ley Creek. Therefore, cost estimates for this
alternative have been estimated for on-site disposal (Appendix C, Table C-l) and off-site
disposal (Appendix C, Table C-3).
Clean backfill will then be placed to bring the excavation back to the original grade. Topsoil will
be placed over disturbed areas and seeded to grow vegetation to reduce or eliminate erosion from
the disturbed areas.
This alternative also includes a soil cap for some soils located in the Northwest Soil Area. The
soil cap will be a 1-fit thick layer of clean soil to isolate the contaminated soils. The soil cap will
be a vegetated habitat layer. A demarcation layer (e.g., non-woven geotextile) will be installed
between the contaminated soil and the soil cap. A 2-ft thick habitat layer will be placed above the
soil cap and will be seeded to grow vegetation that would reduce or eliminate erosion from the
areas. Vegetation in the soil cap areas would be restored, including trees and shrubs, to create a
riparian buffer. Periodic reviews will be conducted at 5-year intervals to reassess the long-term
appropriateness of this alternative.
In all areas, an excavation of 3 ft of soil would be completed before the soil cap is installed so
there is no loss of floodplain capacity. Due to this requirement, soil caps will only be placed in
areas exhibiting contamination deeper than 3 ft bgs. Any areas with contamination less than 3 ft
deep will be excavated and replaced with backfill.
This soil cap serves three functions:
1. It isolates and covers the remaining contaminated soil to prevent movement.
2. It creates a clean soil surface.
3. It reduces the human health and ecological pathways for contact with contaminated soil.
It is estimated that soil RAOs will be achieved in approximately 6 months after initiation of
remedial activities under Soil Alternative 3. This is based on the period of active construction
required to implement this alternative.
7.1.3.1 Restoration
7.1.3.1.1 Baseline Sampling
Prior to remedial and restoration activities, a baseline survey will be conducted at the site. The
survey will be conducted in the fall, if feasible, and will be used for comparative purposes during
the monitoring phase of restoration activities. The baseline survey will include vegetation
identification and data collection using the line interception method (discussed further below).
In addition, permanent photo locations will be established throughout the restoration area.
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Photos will be taken at these locations during the baseline survey and during each of the annual
monitoring events.
7.1.3.1.2 Site Restoration
Restoration activities will be initiated following the completion of remedial activities and will
consist of the re-establishment of native vegetation within the disturbed area. Restoration of the
riparian zone will provide erosion protection for Ley Creek associated with surface water runoff
from the surrounding industrial areas. In addition, utilizing native species within the restoration
activities will create native habitat within the riparian zone. Restoration activities and post-
restoration monitoring activities are described below. Further details and specifications relative
to site restoration will be presented in the remedial design component.
According to the Ecoregions of the United States, the historical regional vegetation for the
project area consisted of native plant species typical of transitional deciduous forests between the
boreal forests and broadleaf deciduous forests. The most abundant trees within this Ecoregion
include oaks, maples, and beech (EPA, 2013). The site currently consists primarily of forbs and
grasses near the bank of Ley Creek and a combination of forbs, grasses, woody shrubs, and
deciduous forest within the riparian area.
Seeding and planting will begin as soon as possible and practicable after the completion of
remedial activities. If feasible, the remedial action will be scheduled so that seeding and planting
will be conducted in the spring or fall in order to maximize planting success. Species
composition will be designed to reflect the existing communities of native species as well as
native communities of the region, and will include a combination of trees, shrubs, forbs, and
grasses. Information relative to the existing species composition will be gathered during the
baseline survey. Accordingly, the desired species composition for the selection of terrestrial
community composition will be finalized during the remedial design and/or after the completion
of the baseline survey. Examples of likely species to be selected are listed below. The tree,
shrub, and grass species are native to either the Eastern Great Lakes ecoregion and/or the state of
New York (NYSDEC, 2005).
Trees: red maple (Acer rubrum), sugar maple {Acer saccharum), red oak (Quercus rubra), and
American beech (Fagus grandifolia)
Shrubs: redosier dogwood {Cornus stolonifera), silky dogwood (Cornus amomum), and highbush
cranberry (Viburnum opulus)
Grasses: big bluestem {Andropogon gerardii), little bluestem (Andropogon scoparium), and
switchgrass (Panicum virgatum)
The selected tree and shrub species will be planted as seedlings, likely using bare root seedlings.
Trees and shrubs will be planted within the disturbed area at distances greater than an established
distance (e.g., 50 ft) from the bank of Ley Creek. The seedling spacing and the type of nursery
stock to be planted (e.g., bare root, ball and burlap, cuttings, etc.) will be identified within the
restoration plan to be completed within the remedial design.
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Grasses will be planted from seed and will be planted throughout the entire disturbed area,
regardless of distance from the bank of Ley Creek. The specific mix, application rate, and type of
seed application (e.g., dry seeding, hydroseeding, etc.) will be identified within the restoration
plan to be completed within the remedial design.
7.1.3.1.3 Success Criteria
To evaluate the effectiveness of restoration efforts, success criteria will be established. These
will likely include a goal of percent survivorship (e.g., 70%), a goal of total percent cover (e.g.,
90%) beginning with the first annual monitoring event, and a minimum number of seeded
species present. Success criteria will be identified within the restoration plan as part of the
remedial design.
Vegetation planted on the cover layer will help stabilize the cover material to prevent movement
into Lower Ley Creek. The final depth of soil removal and thickness of the soil cap will be
refined during the pre-design phase. In addition, this alternative would require a site management
plan to manage the soil cap and the remaining contamination at the site.
7.1.3.2 Monitoring and Controls
Monitoring will be conducted to evaluate the effectiveness of the restoration efforts. The
monitoring program will direct maintenance as needed and document recovery of resources.
Monitoring will likely occur on an annual basis for a 5-year period following the completion of
restoration activities. Annual monitoring events will consist of a vegetation survey conducted
using the line interception method. Annual monitoring events will be conducted in the fall.
Visual meander surveys also will be conducted in the late spring/early summer to document
species composition.
7.1.3.2.1 Sampling Methodology
The baseline and monitoring surveys will consist of collecting vegetative data using the line
interception method (Canfield, 1941). The line interception method is a method of sampling
vegetation based on the measurement of all plants intercepted by the vertical plane of a given
transect. Linear measurements are then made of the intercepts of vegetation along the transect.
Because the monitoring will occur for 5 years, permanent transects will be established within the
restoration area and surveyed each year. A minimum of 12 transects will be established within
the riparian area, each of which will be approximately 150 ft long. Approximately six transects
will be oriented parallel to Ley Creek, with three transects within the forested area and three
transects within the non-forested area. The remaining six transects will be oriented perpendicular
to Ley Creek.
Vegetative data collected within the survey will be used to determine percent plant cover at
which plant species occur as well as species composition. This information will be compared to
success criteria, established above, to evaluate the restoration's success and, if necessary, adjust
management practices. The following metrics will be calculated using the vegetative data.
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Absolute % Cover (Species-Specific) = Intercept Length (ft)/Transect Length (ft)* 100
Total Cover = Sum of Species Specific Absolute Cover Measurements
Relative % Cover (Species-Specific) = Absolute Cover/Total Cover* 100
Species Composition = Total List of Observed Species
7.1.3.2.2 Percent Survivorship
Percent survivorship is a measure of how many planted seedlings survive after planting.
Because the measure is relative to individual plants, this metric is only applicable to shrubs and
trees. To determine percent survivorship, the number of planted seedlings will be counted during
planting and during each monitoring event. Given the size of the restoration area, counting
individual trees or shrubs across the entire site will not be feasible. Accordingly, percent
survivorship will be calculated from established sample plots within the restoration area. This
data will be used to determine the percentage of planted seedlings that has survived. The size,
location, and frequency of sample plots will be determined within the restoration plan as part of
the remedial design.
7.1.3.2.3 Controls
As part of this alternative, controls will be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Institutional controls could
include, but would not be limited to, potential LUCs, environmental easements, deed notices, and
public health advisories.
Additional controls will likely include fencing and signage. Fencing will be installed next to
potential public access locations (i.e., roads) and should not significantly affect the movement of
wildlife.
7.1.4 Soil-4: Soil Cap over All Contaminated Soils
Soil Alternative 4 includes the excavation or installation of a soil cap over all soils exhibiting
COPCs above cleanup goals in both the Southern Swale Soil Area and the Northwest Soil Area.
The extent of the excavations and soil caps in the Northwest Soil Area are shown in Figure 7.3
and the extent of the excavations and soil caps in the Southern Swale Soil Area is shown in
Figure 7.4. Details on the total volume of soil to be excavated and the total volume of soil to be
capped under this alternative are presented in Table 7.5.
This alternative includes excavation and off-site disposal of soils within the floodplain.
However, on-site disposal may be possible at the Cooper Crouse-Hinds North Landfill or
additional landfills located adjacent to Lower Ley Creek. Therefore, cost estimates for this
alternative have been estimated for on-site disposal (Appendix C, Table C-l) and off-site
disposal (Appendix C, Table C-3).
This alternative also includes a soil cap for some soils located in the Southern Swale Soil Area
and the Northwest Soil Area. The soil cap will be a 1-ft thick layer of clean soil to isolate the
contaminated soils. The soil cap will be a vegetated habitat layer. A demarcation layer (e.g., non-
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woven geotextile) will be installed between the contaminated soil and the soil cap. A 2-ft thick
habitat layer will be placed above the soil cap and will be seeded to grow vegetation that will
reduce or eliminate erosion from the areas. Vegetation in the soil cap areas will be restored,
including trees and shrubs, to create a riparian buffer. Periodic reviews will be conducted at 5-
year intervals to reassess the long-term appropriateness of this alternative.
In all areas, an excavation of 3 ft of soil will be completed before the soil cap is installed so there
is no loss of floodplain capacity. Due to this requirement, soil caps will only be placed in areas
exhibiting contamination deeper than 3 ft bgs. Any areas with contamination less than 3 ft deep
will be excavated and replaced with backfill.
This soil cap serves three functions:
1. It isolates and covers the remaining contaminated soil to prevent movement.
2. It creates a clean soil surface.
3. It reduces the human health and ecological pathways for contact with contaminated soil.
It is estimated that soil RAOs will be achieved in approximately 6 months after initiation of
remedial activities under Soil Alternative 4. This is based on the period of active construction
required to implement this alternative.
7.1.4.1 Restoration
7.1.4.1.1 Baseline Sampling
Prior to remedial and restoration activities, a baseline survey will be conducted at the site. The
survey will be conducted in the fall, if feasible, and will be used for comparative purposes during
the monitoring phase of restoration activities. The baseline survey will include vegetation
identification and data collection using the line interception method (discussed further below).
In addition, permanent photo locations will be established throughout the restoration area.
Photos will be taken at these locations during the baseline survey and during each of the annual
monitoring events.
7.1.4.1.2 Site Restoration
Restoration activities will be initiated following the completion of remedial activities and will
consist of the re-establishment of native vegetation within the disturbed area. Restoration of the
riparian zone will provide erosion protection for Ley Creek associated with surface water runoff
from the surrounding industrial areas. In addition, utilizing native species within the restoration
activities will create native habitat within the riparian zone. Restoration activities and post-
restoration monitoring activities are described below. Further details and specifications relative
to site restoration will be presented in the remedial design component.
According to the Ecoregions of the United States, the historical regional vegetation for the
project area consisted of native plant species typical of transitional deciduous forests between the
boreal forests and broadleaf deciduous forests. The most abundant trees within this Ecoregion
include oaks, maples, and beech (EPA, 2013). The site currently consists primarily of forbs and
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grasses near the bank of Ley Creek and a combination of forbs, grasses, woody shrubs, and
deciduous forest within the riparian area.
Seeding and planting will begin as soon as possible and practicable after the completion of
remedial activities. If feasible, the remedial action will be scheduled so that seeding and planting
will be conducted in the spring or fall in order to maximize planting success. Species
composition will be designed to reflect the existing communities of native species as well as
native communities of the region, and will include a combination of trees, shrubs, forbs, and
grasses. Information relative to the existing species composition will be gathered during the
baseline survey. Accordingly, the desired species composition for the selection of terrestrial
community composition will be finalized during the remedial design and/or after the completion
of the baseline survey. Examples of likely species to be selected are listed below. The tree,
shrub, and grass species are native to either the Eastern Great Lakes ecoregion and/or the state of
New York (NYSDEC, 2005).
Trees: red maple (Acer rubrum), sugar maple (Acer saccharum), red oak (Quercus rubra), and
American beech (Fagus grandifolia)
Shrubs: redosier dogwood (Cornus stolonifera), silky dogwood (Cornus amomum), and highbush
cranberry (Viburnum opulus)
Grasses: big bluestem (Andropogon gerardii), little bluestem (Andropogon scoparium), and
switchgrass (Panicum virgatum)
The selected tree and shrub species will be planted as seedlings, likely using bare root seedlings.
Trees and shrubs will be planted within the disturbed area at distances greater than an established
distance (e.g., 50 ft) from the bank of Ley Creek. The seedling spacing and the type of nursery
stock to be planted (e.g., bare root, ball and burlap, cuttings, etc.) will be identified within the
restoration plan to be completed within the remedial design.
Grasses will be planted from seed and will be planted throughout the entire disturbed area,
regardless of distance from the bank of Ley Creek. The specific mix, application rate, and type of
seed application (e.g., dry seeding, hydroseeding, etc.) will be identified within the restoration
plan to be completed within the remedial design.
7.1.4.1.3 Success Criteria
To evaluate the effectiveness of restoration efforts, success criteria will be established. These
will likely include a goal of percent survivorship (e.g., 70%), a goal of total percent cover (e.g.,
90%) beginning with the first annual monitoring event, and a minimum number of seeded
species present. Success criteria will be identified within the restoration plan as part of the
remedial design.
Vegetation planted on the cover layer will help stabilize the cover material to prevent movement
into Lower Ley Creek. The final depth of soil removal and thickness of the soil cap will be
refined during the pre-design phase. In addition, this alternative would require a site management
plan to manage the soil cap and the remaining contamination at the site.
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7.1.4.2 Monitoring and Controls
Monitoring will be conducted to evaluate the effectiveness of the restoration efforts. The
monitoring program will direct maintenance as needed and document recovery of resources.
Monitoring will likely occur on an annual basis for a 5-year period following the completion of
restoration activities. Annual monitoring events will consist of a vegetation survey conducted
using the line interception method. Annual monitoring events will be conducted in the fall.
Visual meander surveys also will be conducted in the late spring/early summer to document
species composition.
7.1.4.2.1 Sampling Methodology
The baseline and monitoring surveys will consist of collecting vegetative data using the line
interception method (Canfield, 1941). The line interception method is a method of sampling
vegetation based on the measurement of all plants intercepted by the vertical plane of a given
transect. Linear measurements are then made of the intercepts of vegetation along the transect.
Because the monitoring will occur for 5 years, permanent transects will be established within the
restoration area and surveyed each year. A minimum of 12 transects will be established within
the riparian area, each of which will be approximately 150 ft long. Approximately six transects
will be oriented parallel to Ley Creek, with three transects within the forested area and three
transects within the non-forested area. The remaining six transects will be oriented perpendicular
to Ley Creek.
Vegetative data collected within the survey will be used to determine percent plant cover at
which plant species occur as well as species composition. This information will be compared to
success criteria, established above, to evaluate the restoration's success and, if necessary, adjust
management practices. The following metrics will be calculated using the vegetative data.
Absolute % Cover (Species-Specific) = Intercept Length (ft)/Transect Length (ft)* 100
Total Cover = Sum of Species Specific Absolute Cover Measurements
Relative % Cover (Species-Specific) = Absolute Cover/Total Cover* 100
Species Composition = Total List of Observed Species
7.1.4.2.2 Percent Survivorship
Percent survivorship is a measure of how many planted seedlings survive after planting.
Because the measure is relative to individual plants, this metric is only applicable to shrubs and
trees. To determine percent survivorship, the number of planted seedlings will be counted during
planting and during each monitoring event. Given the size of the restoration area, counting
individual trees or shrubs across the entire site will not be feasible. Accordingly, percent
survivorship will be calculated from established sample plots within the restoration area. This
data will be used to determine the percentage of planted seedlings that has survived. The size,
location, and frequency of sample plots will be determined within the restoration plan as part of
the remedial design.
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7.1.4.2.3 Controls
As part of this alternative, controls will be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Institutional controls could
include, but would not be limited to, potential LUCs, environmental easements, deed notices, and
public health advisories.
Additional controls will likely include fencing and signage. Fencing will be installed next to
potential public access locations (i.e., roads) and should not significantly affect the movement of
wildlife.
7.2 SEDIMENT REMEDIAL ALTERNATIVES
Five sediment remedial alternatives (including the No Action alternative) were developed for the
Site. These alternatives are presented in Table 7.6.
To assist with the determination of remedial alternatives for sediment, the 2-mile stretch of the
Lower Ley Creek Subsite has been separated into three sections (upstream, middle, and
downstream) (Figure 2.5). This separation was made because the downstream section of the Site
exhibits lower concentrations of contaminants and a smaller extent of contamination than the
upstream or middle sections of the Site. In addition, the upstream and middle sections of the site
exhibit distinctive stream characteristics. While the upstream section of Lower Ley Creek
meanders, the middle section of the creek is relatively straight.
The alternatives were screened based on the criteria of effectiveness, implementability, and cost.
This initial screening step was performed as required by CERCLA and the NCP to narrow the
field of remedial alternatives that are subject to the detailed analysis presented in Section 8.0.
The initial screening of all five sediment remedial alternatives is presented in Table 7.7. All
sediment remedial alternatives passed the screening and were retained for additional evaluation.
7.2.1 Sediment-1: No Action
Sediment Alternative 1 is the No Action alternative and is presented for comparison only. The
No Action Alternative consists of refraining from the active application of any remediation
technology to sediments in all three sections of Lower Ley Creek. The No Action alternative also
excludes source control removal action, administrative actions, and monitoring. As required by
CERCLA, periodic reviews will be conducted at 5-year intervals to reassess the long-term
appropriateness of continued No Action.
The RAOs for sediment will never be achieved using under this remedial alternative.
7.2.2 Sediment-2: Removal of Sediments to Cleanup Goals
This alternative includes full excavation of sediments exhibiting COPCs exceeding cleanup goals
in all sections of Lower Ley Creek. Due to the relatively narrow width of the creek, the current,
and the near vertical side walls of the creek channel, excavation of the sediments will be
completed using land based excavators with long reach arms. Turbidity will be mitigated by the
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use of turbidity curtains in the creek downstream of the excavation. Stream bank restoration will
be conducted after the dredging activities were completed. Where there is disturbance to the
stream bank, restoration will need to include restoration of the bank with vegetation to the
maximum extent possible. In areas where slopes are steep or instability is expected,
bioengineering techniques to eliminate rock hardening will be used.
In the upstream, middle, and downstream sections of Lower Ley Creek, all sediments with
COPCs exceeding cleanup goals will be excavated. The extent of the upstream section
excavation under Sediment Alternative 2 is shown in Figure 7.5, the extent of the middle section
excavation under Sediment Alternative 2 is shown in Figure 7.6, and the extent of the
downstream section excavation is shown in Figure 7.7. Details on the total volume of sediment
to be excavated under this alternative are presented in Table 7.8.
For this FS, it is assumed that excavation in the dry will be done in the shallower areas of Lower
Ley Creek (i.e., the upstream section of Lower Ley Creek), while excavation in the wet will be
completed in the deeper areas of the creek.
Excavated sediments would be transported to a SDA where they will be drained and conditioned
for off-site disposal in a RCRA-compliant and, if appropriate, a TSCA-compliant disposal
facility. However, on-site disposal may be possible at the Cooper Crouse-Hinds North Landfill
or other landfills located adjacent to Lower Ley Creek. Therefore, cost estimates for this
alternative have been estimated for on-site disposal (Appendix C, Table C-2) and off-site
disposal (Appendix C, Table C-4).
An evaluation of properties around the Lower Ley Creek resulted in identification of a potential
location for the SDA on the upstream section of Lower Ley Creek, just northeast of the Cooper
Crouse-Hinds Landfill. Prior to the start of dredging, temporary sediment dewatering and water
treatment equipment will be installed on the site. It is also recognized that portions of this site
may have historical significance, therefore use of certain areas of the site have been restricted to
avoid potential impact to any cultural resources that may be present on the site. The use of the
dewatering and support area is temporary. Once work is completed, all equipment and
improvements to the dewatering and support areas will be removed and the site will be restored.
Selection of off-site disposal facilities for the sediments will be based on the PCB concentrations
in the conditioned materials. Sediments with concentrations of PCBs below 50 mg/kg will likely
be accepted in local solid waste disposal facilities or in industrial waste landfills. Sediments with
concentrations of PCBs greater than 50 mg/kg will be disposed of in a TSCA landfill facility.
It is estimated that sediment RAOs will be achieved in approximately 9 months after initiation of
remedial activities under Sediment Alternative 2. This is based on the period of active
construction required to implement this alternative.
7.2.2.1 Restoration
After excavation is completed in a particular stream area, approximately 1 ft of clean backfill
would be placed to stabilize the sediment bed and support habitat replacement/reconstruction, or
further isolate remaining sediments in place. Backfill configurations will be developed for each
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dredged section of the creek based on creek conditions such as how fast the creek flows, the type
of creek bottom, residual contaminant concentrations, and habitat goals. Repair of the habitat
layer will be necessary should the habitat layer be lost or damaged.
7.2.2.1.1 Baseline Sampling
Prior to remedial and restoration activities, a baseline survey will be conducted at the site. The
survey will be conducted in the fall, if feasible, and will be used for comparative purposes during
the monitoring phase of restoration activities. The baseline survey will include sediment
composition, vegetation identification, and benthic invertebrate identification.
7.2.2.1.2 Site Restoration
Restoration activities will be initiated following the completion of remedial activities and will
consist of the re-establishment habitat within the disturbed area. Further details and
specifications relative to site restoration will be presented in the remedial design component.
7.2.2.2 Monitoring
Monitoring will be conducted to evaluate the effectiveness of the restoration efforts. The
monitoring program will direct maintenance as needed and document recovery of resources.
Monitoring will likely occur on an annual basis for a 5 year period following the completion of
restoration activities. Annual monitoring events will consist of a sediment composition,
vegetation survey, and benthic invertebrate survey. Annual monitoring events will be conducted
in the fall.
Fish tissue sampling will be collected annually during the restoration monitoring field activities.
Samples will be analyzed for metals, pesticides, PAHs, and PCBs and the resulting data will be
used to monitor the effectiveness of the remedy in reducing fish tissue concentrations.
A variety of monitoring activities will be carried out on land and in the creek throughout
construction of the alternative, including monitoring of water, sediments, air quality and odor,
noise, lighting, and water discharged at the sediment dewatering area. Confirmation sampling
will be conducted after the dredging of the sediments has been completed. No long term site
management plans or institutional control will be required as part of this alternative.
7.2.2.3 Controls
Although there will be a complete removal of contaminated sediment in this alternative, there
will potentially still be contaminated fish tissue. Therefore, it will be prudent to ensure that the
current fish advisories for Lower Ley Creek remain in place under this alternative. However, it
important to note that fish consumption advisories do not prevent human or ecological exposure
to contaminated fish. The setting and maintenance of fish consumption advisories is determined
by the NYSDOH.
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7.2.3 Sediment-3: Granular Material Sediment Cap
This alternative includes the installation of a granular material (sand) sediment cap over portions
of the upstream and middle sections of Lower Ley Creek and the excavation of contaminated
sediments in portions of the upstream, middle, and downstream sections of Lower Ley Creek.
The capping of the areas with sediments exhibiting COPCs exceeding cleanup goals will be
completed in a manner that maintains the bathymetry of Lower Ley Creek.
In areas of the site with low erosion potential (i.e., Old Ley Creek), the granular material
sediment cap includes the following design layer:
• Isolation/Habitat Layer (2 ft thick).
Based on the evaluation in Appendix E, the capping design in the upstream section of Lower Ley
Creek includes the following design layers, from top to bottom:
• Habitat Layer (2 ft thick);
• Armor Layer (2.0 ft thick); and
• Isolation Layer (2 ft thick).
Based on the evaluation in Appendix E, the capping design in the middle section of Lower Ley
Creek includes the following design layers, from top to bottom:
• Habitat Layer (2 ft thick);
• Armor Layer (0.3875 ft thick); and
• Isolation Layer (1.5 ft thick).
This alternative includes full excavation of sediments exhibiting COPCs exceeding cleanup goals
in the downstream section of Lower Ley Creek. Due to the relatively narrow width of the creek,
the current, and the near vertical side walls of the creek channel, excavation of the sediments will
be completed using land based excavators with long reach arms. Turbidity will be mitigated by
the use of turbidity curtains in the creek downstream of the excavation. Stream bank restoration
will be conducted after the dredging activities were completed. Where there is disturbance to the
stream bank, restoration will need to include restoration of the bank with vegetation to the
maximum extent possible. In areas where slopes are steep or instability is expected,
bioengineering techniques to eliminate rock hardening will be used. A detailed discussion of the
design of the granular material sediment cap is included as Appendix E.
Before the placement of any capping material, excavation of sediment will be conducted to
maintain the current bathymetry of Lower Ley Creek. Therefore, in the upstream section of
Lower Ley Creek, a 6 ft excavation of sediment will be completed before the sediment cap is
installed to maintain the current bathymetry of Lower Ley Creek. Due to this requirement,
sediment caps will only be placed in areas exhibiting contamination deeper than 6 ft bgs in the
upstream section of Lower Ley Creek. Any areas in the upstream section with contamination less
than 6 ft deep will be excavated.
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In the middle section of Lower Ley Creek, a 4 ft excavation of sediment will be completed
before the sediment cap is installed to maintain the current bathymetry of Lower Ley Creek. Due
to this requirement, sediment caps will only be placed in areas exhibiting contamination deeper
than 4 ft bgs in the middle section of Lower Ley Creek. Any areas in the middle section with
contamination less than 4 ft deep will be excavated.
For this FS, it is assumed that excavation in the dry will be done in the shallower areas of Lower
Ley Creek (i.e., the upstream section of Lower Ley Creek), while excavation in the wet will be
completed in the deeper areas of the creek.
Excavated sediments will be transported to a SDA where they would be drained and conditioned
for off-site disposal in a RCRA-compliant and, if appropriate, a TSCA-compliant disposal
facility. However, on-site disposal may be possible at the Cooper Crouse-Hinds North Landfill
or other landfills located adjacent to Lower Ley Creek. Therefore, cost estimates for this
alternative have been estimated for on-site disposal (Appendix C, Table C-2) and off-site
disposal (Appendix C, Table C-4). Periodic reviews will be conducted at 5-year intervals to
reassess the long-term appropriateness of this alternative.
An evaluation of properties around the Lower Ley Creek resulted in identification of a potential
location for the SDA on the upstream section of Lower Ley Creek, just northeast of the Cooper
Crouse-Hinds Landfill. Prior to the start of dredging, temporary sediment dewatering and water
treatment equipment will be installed on the site. It is also recognized that portions of this site
may have historical significance, therefore use of certain areas of the site have been restricted to
avoid potential impact to any cultural resources that may be present on the site. The use of the
dewatering and support area is temporary. Once work is completed, all equipment and
improvements to the dewatering and support areas will be removed and the site will be restored.
Selection of off-site disposal facilities for the sediments will be based on the PCB concentrations
in the conditioned materials. Sediments with concentrations of PCBs below 50 mg/kg will likely
be accepted in local solid waste disposal facilities or in industrial waste landfills. Sediments with
concentrations of PCBs greater than 50 mg/kg will be disposed of in a TSCA landfill facility.
The extent of the upstream section sand/armor sediment cap and excavations under Sediment
Alternative 3 are shown in Figure 7.8, the extent of the middle section sand/armor sediment cap
and excavations under Sediment Alternative 3 are shown in Figure 7.9, and the extent of the
downstream section excavation under Sediment Alternative 3 is shown in Figure 7.7. Details on
the total volume of sediment to be excavated and the total area to be capped under this
alternative are presented in Table 7.9.
Old Ley Creek will only be excavated 2 ft deep before the placement of capping material
because no erosional protection material is required for the Old Ley Creek Channel.
It is estimated that sediment RAOs will be achieved in approximately 9 months after initiation of
remedial activities under Sediment Alternative 3. This is based on the period of active
construction required to implement this alternative.
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7.2.3.1 Restoration
After excavation is completed in a particular stream area, approximately 1 ft of clean backfill
will be placed to stabilize the sediment bed and support habitat replacement/reconstruction, or
further isolate remaining sediments in place. Backfill configurations would be developed for
each dredged section of the creek based on creek conditions such as how fast the creek flows, the
type of creek bottom, residual contaminant concentrations, and habitat goals. Repair of the
habitat layer will be necessary should the habitat layer be lost or damaged.
7.2.3.1.1 Baseline Sampling
Prior to remedial and restoration activities, a baseline survey will be conducted at the site. The
survey will be conducted in the fall, if feasible, and will be used for comparative purposes during
the monitoring phase of restoration activities. The baseline survey will include sediment
composition, vegetation identification, and benthic invertebrate identification.
7.2.3.1.2 Site Restoration
Restoration activities will be initiated following the completion of remedial activities and will
consist of the re-establishment habitat within the disturbed area. Further details and
specifications relative to site restoration will be presented in the remedial design component.
7.2.3.2 Monitoring
Monitoring will be conducted to evaluate the effectiveness of the restoration efforts. The
monitoring program will direct maintenance as needed and document recovery of resources.
Monitoring will likely occur on an annual basis for a 5-year period following the completion of
restoration activities. Annual monitoring events will consist of a sediment composition,
vegetation survey, and benthic invertebrate survey. Annual monitoring events will be conducted
in the fall.
Fish tissue sampling will be collected annually during the restoration monitoring field activities.
Samples will be analyzed for metals, pesticides, PAHs, and PCBs and the resulting data will be
used to monitor the effectiveness of the remedy in reducing fish tissue concentrations.
A variety of monitoring activities will be carried out on land and in the creek throughout
construction of the alternative, including monitoring of water, sediments, air quality and odor,
noise, lighting, and water discharged at the sediment dewatering area. Confirmation sampling
will be conducted after the dredging of the sediments has been completed.
7.2.3.3 Controls
As part of this alternative, controls will be implemented as part of a site management plan to
restrict excavation activities in the capped sediment areas. Controls will consist of a ban on
dredging in the capped/backfilled areas, signage, fencing, and ensuring that the current fish
advisories for Lower Ley Creek remain in place.
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However, it important to note that fish consumption advisories do not prevent human or
ecological exposure to contaminated fish. The setting and maintenance of fish consumption
advisories is determined by the NYS Department of Health. In addition, as Lower Ley Creek has
been dredged in the past to alleviate flooding, it is possible that it may need to be dredged in the
future. Therefore, a ban on dredging in the capped/backfill areas may not be feasible.
7.2.4 Sediment-4: Engineered Bentonite Sediment Cap
This alternative includes the installation of an engineered bentonite sediment cap over the
upstream and middle sections of Lower Ley Creek and the excavation of contaminated sediments
in the downstream section of Lower Ley Creek. The capping of the areas with sediments
exhibiting COPCs exceeding cleanup goals will be completed in a manner that maintains the
bathymetry of Lower Ley Creek.
The capping of the sediments in the upstream, and middle sections of Lower Ley Creek would
consist of a 2.25 ft excavation and backfill with 3 inches of an engineered bentonite cap beneath
24 inches of a sand layer intended to provide additional bioturbation isolation and benthic
restoration capacity. Repair of this habitat layer will be necessary should the habitat layer be lost
or damaged. This alternative includes full excavation of sediments exhibiting COPCs exceeding
cleanup goals in the downstream section of Lower Ley Creek. Due to the relatively narrow width
of the creek, the current, and the near vertical side walls of the creek channel, excavation of the
sediments would be completed using land based excavators with long reach arms. Turbidity will
be mitigated by the use of turbidity curtains in the creek downstream of the excavation. Stream
bank restoration will be conducted after the dredging activities were completed. Where there is
disturbance to the stream bank, restoration will need to include restoration of the bank with
vegetation to the maximum extent possible. In areas where slopes are steep or instability is
expected, bioengineering techniques to eliminate rock hardening will be used.
This engineered bentonite sediment cap design and thickness is based on the EPA Innovative
Technology Evaluation Report (EPA, 2007). Under the EPA SITE Program, the effectiveness of
an engineered bentonite cap was evaluated in the Anacostia River in Washington, DC as an
innovative contaminated sediment capping technology. In addition, engineered bentonite caps
have been successfully deployed as a sediment remediation technology at over 10 sediment
remediation project sites and evaluated at bench-scale at several others. A bentonite cap of 3
inches was used during the EPA SITE Program at the Anacostia River Project in Washington.
DC. The Anacostia River is similar to Lower Ley Creek in depth and velocity; and sediments
exhibited similar contaminants (PCBS, PAHs, metals) and concentrations to those found in
Lower Ley Creek. The data generated during the SITE demonstration suggest that the engineered
bentonite cap is highly stable. In addition, over the course of the 3-year evaluation, it appears
that fine, organic-rich new sediment was deposited in the area, effectively increasing the overall
thickness of the sediment cap. As in the Anacostia SITE demonstration capping project,
engineered bentonite material has been successfully applied at other project sites with a two to
three in application (pre-hydrated) within acceptable tolerances. As stated in the EPA SITE
Report, an erosion protection layer is not required for the engineered bentonite cap due to its
cohesiveness, physical stability, and impermeability.
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For this FS, it is assumed that excavation in the dry will be done in the shallower areas of Lower
Ley Creek (i.e., the upstream section of Lower Ley Creek), while excavation in the wet will be
completed in the deeper areas of the creek.
Excavated sediments will be transported to a SDA where they would be drained and conditioned
for off-site disposal in a RCRA-compliant and, if appropriate, a TSCA-compliant disposal
facility. However, on-site disposal may be possible at the Cooper Crouse-Hinds North Landfill
or other landfills located adjacent to Lower Ley Creek. Therefore, cost estimates for this
alternative have been estimated for on-site disposal (Appendix C, Table C-2) and off-site
disposal (Appendix C, Table C-4). Periodic reviews will be conducted at 5-year intervals to
reassess the long-term appropriateness of this alternative.
An evaluation of properties around the Lower Ley Creek resulted in identification of a potential
location for the SDA on the upstream section of Lower Ley Creek, just northeast of the Cooper
Crouse-Hinds Landfill. Prior to the start of dredging, temporary sediment dewatering and water
treatment equipment will be installed on the site. It is also recognized that portions of this site
may have historical significance, therefore use of certain areas of the site have been restricted to
avoid potential impact to any cultural resources that may be present on the site. The use of the
dewatering and support area is temporary. Once work is completed, all equipment and
improvements to the dewatering and support areas will be removed and the site will be restored.
Selection of off-site disposal facilities for the sediments will be based on the PCB concentrations
in the conditioned materials. Sediments with concentrations of PCBs below 50 mg/kg will likely
be accepted in local solid waste disposal facilities or in industrial waste landfills. Sediments with
concentrations of PCBs greater than 50 mg/kg will be disposed of in a TSCA landfill facility.
This design addresses the possibility that the cap will be subject to damage from ice scour. Also,
cap erosion may result from both normal river flows and less frequent, but high energy, storm
events. Finally, as described further below, because substantial dredging is necessary to install an
engineered cap system in shallow areas, that dredging work may expose more contaminated
sediments than are currently found at the sediment surface; thus additional protection is
warranted. A 24-inch benthic substrate layer will be placed over the bentonite to protect it from
burrowing animals and also to provide a clean substrate for repopulation by benthic organisms.
The extent of the upstream section bentonite sediment cap under Sediment Alternative 4 is
shown in Figure 7.10, the extent of the middle section bentonite sediment cap under Sediment
Alternative 4 is shown in Figure 7.11, and the extent of the downstream section excavation under
Sediment Alternative 4 is shown in Figure 7.7. Details on the total volume of sediment to be
excavated and capped under this alternative are presented in Table 7.10.
It is estimated that sediment RAOs will be achieved in approximately 9 months after initiation of
remedial activities under Sediment Alternative 4. This is based on the period of active
construction required to implement this alternative.
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7.2.4.1 Restoration
After excavation is completed in a particular stream area, approximately 1 ft of clean backfill
will be placed to stabilize the sediment bed and support habitat replacement/reconstruction, or
further isolate remaining sediments in place. Backfill configurations will be developed for each
dredged section of the creek based on creek conditions such as how fast the creek flows, the type
of creek bottom, residual contaminant concentrations, and habitat goals. Repair of the habitat
layer will be necessary should the habitat layer be lost or damaged.
7.2.4.1.1 Baseline Sampling
Prior to remedial and restoration activities, a baseline survey will be conducted at the site. The
survey will be conducted in the fall, if feasible, and will be used for comparative purposes during
the monitoring phase of restoration activities. The baseline survey will include sediment
composition, vegetation identification, and benthic invertebrate identification.
7.2.4.1.2 Site Restoration
Restoration activities will be initiated following the completion of remedial activities and will
consist of the re-establishment habitat within the disturbed area. Further details and
specifications relative to site restoration will be presented in the remedial design component.
7.2.4.2 Monitoring
Monitoring will be conducted to evaluate the effectiveness of the restoration efforts. The
monitoring program will direct maintenance as needed and document recovery of resources.
Monitoring will likely occur on an annual basis for a 5-year period following the completion of
restoration activities. Annual monitoring events will consist of a sediment composition,
vegetation survey, and benthic invertebrate survey. Annual monitoring events will be conducted
in the fall.
Fish tissue sampling will be collected annually during the restoration monitoring field activities.
Samples will be analyzed for metals, pesticides, PAHs, and PCBs and the resulting data will be
used to monitor the effectiveness of the remedy in reducing fish tissue concentrations.
A variety of monitoring activities will be carried out on land and in the creek throughout
construction of the alternative, including monitoring of water, sediments, air quality and odor,
noise, lighting, and water discharged at the sediment dewatering area. Confirmation sampling
will be conducted after the dredging of the sediments has been completed.
7.2.4.3 Controls
As part of this alternative, controls will be implemented as part of a site management plan to
restrict excavation activities in the capped sediment areas. Controls will consist of a ban on
dredging in the capped/backfilled areas, signage, fencing, and ensuring that the current fish
advisories for Lower Ley Creek remain in place.
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However, it important to note that fish consumption advisories do not prevent human or
ecological exposure to contaminated fish. The setting and maintenance of fish consumption
advisories is determined by the NYSDOH. In addition, as Lower Ley Creek has been dredged in
the past to alleviate flooding, it is possible that it may need to be dredged in the future.
Therefore, a ban on dredging in the capped/backfill areas may not be feasible.
7.2.5 Sediment-5: Monitored Natural Recovery
For this alternative, no active remediation will be undertaken at the Site. Naturally occurring
sedimentation and microbially mediated dechlorination and degradation of PCBs - collectively
referred to as natural recovery processes - will be relied upon to further reduce risk in the Lower
Ley Creek over time.
A 30-year monitoring program will be developed and implemented. Likely components to the
program will include periodic monitoring of the water column and fish in Lower Ley Creek. The
monitoring program will be reviewed, at a minimum, every 5 years to assess whether
modifications were warranted. It is anticipated that fish consumption advisories will remain in
place until the NYSDOH determines the advisories are no longer needed.
7.2.5.1 Baseline Sampling
Prior to monitoring activities, a baseline survey will be conducted at the site. The survey will be
conducted in the fall, if feasible, and will be used for comparative purposes during the
monitoring phase. The baseline survey will include sediment composition, vegetation
identification, and benthic invertebrate identification.
7.2.5.2 Monitoring
Monitoring will be conducted to evaluate the effectiveness of the natural recovery of Lower Ley
creek. Monitoring will likely occur on an annual basis for a 30-year period. Annual monitoring
events will consist of a sediment composition, vegetation survey, and benthic invertebrate
survey. Annual monitoring events will be conducted in the fall.
Fish tissue sampling will be collected annually during the monitoring field activities. Samples
will be analyzed for metals, pesticides, PAHs, and PCBs and the resulting data will be used to
monitor the effectiveness of the remedy in reducing fish tissue concentrations.
7.2.5.3 Controls
Controls would consist of signage, fencing, and ensuring that the current fish advisories for
Lower Ley Creek remain in place.
However, it important to note that fish consumption advisories do not prevent human or
ecological exposure to contaminated fish. The setting and maintenance of fish consumption
advisories is determined by the NYSDOH.
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8.0 REMEDIAL ALTERNATIVE EVALUATION
This section presents a detailed description and analysis of each remedial alternative that passed
the effectiveness, implementability, and cost screening evaluation in Tables 7.2 and 7.6. Four
soil remedial alternatives and four sediment remedial alternatives were retained for detailed
analysis. Section 8.1 provides a summary of the detailed analysis process, the nine criteria used
to analyze each remedial alternative, and the manner in which these criteria are applied in this
FS. Sections 8.2 and 8.3 present the detailed analyses of these alternatives.
8.1 EVALUATION PROCESS AND EVALUATION CRITERIA
The NCP provides nine key criteria to address the CERCLA requirements for analysis of
remedial alternatives. The first two criteria are threshold criteria that must be met by each
alternative. The next five criteria are the primary balancing criteria upon which the analysis is
based. The final two criteria are referred to as modifying criteria and are applied, following the
public comment period, to evaluate state and community acceptance.
The two threshold criteria are:
• Overall Protection of Human Health and the Environment; and
• Compliance with ARARs.
The five primary balancing criteria upon which the analysis is based are:
• Long-Term Effectiveness and Permanence;
• Reduction of Toxicity, Mobility or Volume through Treatment;
• Short-Term Effectiveness;
• Implementability; and
• Cost.
The two modifying criteria are:
• State Acceptance; and
• Community Acceptance.
Seven of these nine criteria are described below and employed in the detailed evaluation of
alternatives for remediation of Lower Ley Creek. State acceptance will be addressed by EPA in
the Proposed Plan and ROD, respectively. Community acceptance will be addressed in the ROD.
The detailed evaluation of the soil remedial alternatives for Lower Ley Creek are discussed in
Section 8.2 and presented in Table 8.1. The detailed evaluation of the sediment remedial
alternatives for Lower Ley Creek are discussed in Section 8.3 and presented in Table 8.2. It must
be stressed that the alternatives described in the following analyses are conceptual. Any
characteristics of these alternatives (such as remediation locations, depths, and removal/capping
rates), while based on the available data and information, should be considered preliminary.
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8.1.1 Overall Protection of Human Health and the Environment
This evaluation criterion provides a final assessment as to whether each alternative adequately
protects human health and the environment, and draws on the assessments conducted under other
evaluation criteria, especially long-term effectiveness and permanence, short-term effectiveness,
and compliance with ARARs. As part of determination of protectiveness, the evaluation
describes how risks through each pathway would be eliminated, reduced, or controlled through
treatment, engineering, or institutional controls.
8.1.2 Compliance with ARARs
Alternatives are assessed as to whether they attain federal and state ARARs including:
• Chemical-specific ARARs;
• Location-specific ARARs;
• Action-specific ARARs; and
• Other criteria, advisories, and guidelines, as appropriate.
EPA may select a remedial action that does not attain a particular ARAR under certain
conditions outlined in CERCLA Section 121(d) and the NCP. Preliminary ARARs are provided
in Appendix A. There are no chemical-specific ARARs for sediments. However, there are TBC
values (i.e., NYSDEC sediment screening values).
8.1.3 Long-Term Effectiveness and Permanence
Alternatives are also assessed for the long-term effectiveness and permanence they afford, and
the degree of certainty that the alternative will prove successful. Factors that can be considered,
according to the NCP and RI/FS Guidance, are as follows:
• Long-term reliability and adequacy of the engineering and institutional controls,
including uncertainties associated with land disposal of untreated wastes and residuals;
and
• Magnitude of residual risks in terms of amounts and concentrations of wastes remaining
following implementation of a remedial action, considering the persistence, toxicity,
mobility, and propensity to bioaccumulate of such hazardous substances and their
constituents.
8.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment
CERCLA expresses a preference for remedial alternatives employing treatment that reduces the
toxicity, mobility, or volume of hazardous substances. Relevant factors include:
• The treatment processes that the remedies employ and the materials they will treat;
• The amount of hazardous materials that will be destroyed or treated;
• The degree of expected reduction in toxicity, mobility, or volume;
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• The degree to which the treatment is irreversible;
• The type and quantity of residuals that will remain following treatment, considering the
persistence, toxicity, mobility, and propensity to bioaccumulate of such hazardous
substances and their constituents; and
• Whether the alternative would satisfy the statutory preference for treatment as a principal
element.
8.1.5 Short-Term Effectiveness
The short-term effectiveness of alternatives is assessed considering such appropriate factors as:
• Protection of the community during remedial actions;
• Protection of the workers during remedial actions;
• Potential adverse environmental impacts resulting from construction and implementation;
and
• Time until remedial response objectives (i.e., RAOs and PRGs) are achieved.
For the purposes of this FS, the short-term period is considered to include the time from
initiation of remedial activities, assumed to be in the year 2014, through the alternative-specific
and creek section-specific period for implementation, and a subsequent 1- to 2-year period for
attenuation of residual impacts.
8.1.6 Implementability
The ease or difficulty of implementing the alternatives is assessed by considering the following
factors:
• Technical Feasibility
o Degree of difficulty associated with constructing and operating the technology;
o Expected operational reliability of the technologies;
o Ease of undertaking additional remedial actions, if necessary; and
o Ability to monitor the effectiveness of the alternative.
• Administrative Feasibility
o Need to coordinate with and obtain necessary approvals and permits from other
agencies and offices.
• Availability of Services and Materials
o Availability of necessary equipment and specialists;
o Availability of adequate capacity and location of needed treatment, storage, and
disposal services;
o Availability of prospective technologies; and
o Availability of services and materials, plus the potential for obtaining competitive
bids.
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8.1.7 Cost
Costs for CERCLA evaluation are divided into two principal categories: 1) capital costs, and 2)
annual operations and maintenance (O&M) costs. A number of principal elements of a remedial
alternative may fall into the category of direct and indirect capital costs:
• Construction costs;
• Equipment costs;
• Site development costs;
• Building and services costs;
• Transport and disposal costs;
• Engineering expenses;
• Startup and shakedown costs; and
• Contingency allowances.
Those items not placed into the capital cost category are considered to be O&M costs, among
which are the following:
• Operating labor costs;
• Materials and energy costs;
• Purchased services;
• Administrative and insurance costs; and
• Costs of periodic site reviews.
The estimated costs for each alternative included:
• Capital costs, including both direct and indirect costs;
• Annual operations and maintenance costs; and
• Net present value of capital and O&M costs.
Total estimated costs for each remedial alternative are calculated and presented in Appendix C.
The remedial alternative cost estimates were developed using cost estimating guides, unit cost
estimates from similar projects, and Air Force Civil Engineer Center (AFCEC) Remedial Action
Cost Engineering and Requirements (RACER™) software. These estimates are based on the
estimated quantities for each alternative and are considered accurate to -30 percent to + 50
percent.
8.1.8 State Acceptance
This criterion provides the state - in this case, NYS - with the opportunity to assess any technical
or administrative issues and concerns regarding each of the alternatives. State acceptance will be
addressed by EPA in the Proposed Plan and ROD, respectively.
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8.1.9 Community Acceptance
Issues and concerns the public may have regarding each of the alternatives falls into this
category of evaluation. Community acceptance will be addressed in the ROD.
8.2 SOIL REMEDIAL ALTERNATIVES
8.2.1 Soil-1: No Action
8.2.1.1 Overall Protection of Human Health and the Environment
The No Action alternative would not be protective of human health and the environment,
because this would not actively address the contaminated soils that present unacceptable risks of
exposure to receptors or the release and transport of COPCs at the site. The RAOs or cleanup
goals would not be met under this alternative.
8.2.1.2 Compliance with ARARs
The No Action alternative would not meet chemical-specific ARARs (i.e., RCRA, Clean Water
Act [CWA], etc.) for soils and would not be in compliance with TSCA.
8.2.1.3 Long-Term Effectiveness and Permanence
The No Action alternative would not be effective in meeting the RAOs and PRGs and would not
be effective in addressing risks to human health and the environment. The dominant carcinogenic
and non-carcinogenic risks to human health and ecological receptors posed by the contaminated
soils would continue for several decades under this alternative. This alternative would not
effectively eliminate the potential exposure to contaminants in soil.
8.2.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment
The toxicity and volume of COPCs in soil would not be significantly reduced under the No
Action alternative because no treatment would be conducted. The overall bioavailability and
mobility of contaminants in the soil may be reduced over time as some natural recovery
processes occur.
8.2.1.5 Short-Term Effectiveness
The No Action alternative does not include any physical construction measures in any areas of
contamination and, therefore, would not present any potential adverse impacts to the community
or workers as a result of its implementation.
8.2.1.6 Implementabilitv
The complete deferral of RA would be easily implemented from both technical and
administrative standpoints, as it would only require periodic re-evaluation (every 5 years) of
risks to human health and environment.
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8.2.1.7 Cost
The costs for this alternative are minimal and include no capital costs and only minimal project
management and reporting costs annually and for 5-year reviews. The total present worth of this
alternative is approximately $50,000. A cost breakdown is provided in Appendix C.
8.2.1.8 State Acceptance
Not evaluated.
8.2.1.9 Community Acceptance
Not evaluated.
8.2.1.10 Conclusion
The No Action alternative would not actively reduce the toxicity, mobility, or volume of the
contamination through treatment. The cancer risks and non-cancer human health hazards and
risks to ecological receptors would continue to remain above acceptable levels and the surface
water quality would continue to be degraded.
8.2.2 Soil-2: Excavation of Soil to Meet Cleanup Goals
8.2.2.1 Overall Protection of Human Health and Environment
Excavation to remove impacted soils would provide protection of human health and the
environment by eliminating the exposure pathways associated with impacted soils. Removal of
all contaminated soils would eliminate future potential COPC releases to the creek.
Capping contaminated soils would provide overall protection of human health and the
environment by eliminating the potential human health and ecological exposure pathways
associated with impacted soils. Clean cap material would prevent direct exposure of humans and
ecological receptors to contaminated soil. Erosion control measures on the cap would reduce or
eliminate the potential COPC releases to the creek.
8.2.2.2 Compliance with ARARs
This alternative would comply with chemical-specific, location-specific and action-specific
ARARs (i.e., RCRA, CWA, etc.). Soil caps are routinely installed in compliance with ARARs.
This alternative would also be in compliance with TSCA.
8.2.2.3 Long-Term Effectiveness and Permanence
Removal and off-site disposal/treatment of contaminated soil is a permanent remedy for Lower
Ley Creek soils. Soil excavation is a reliable technology and properly managed landfills provide
reliable controls for long-term management of contaminated soils.
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Utilization of a soil cap is a proven technology for isolating contaminated soils from erosion and
transport to the creek and biota if proper design, placement, and maintenance of the cap are
performed to provide cap effectiveness, continued performance, and reliability. In addition,
controls as part of a site management plan would be implemented to restrict excavation and
construction activities in the soil cap areas. The soil cap would reduce the mobility of
contaminants in the soil but would not affect toxicity or volume of contaminants in the soil or
sediments. Because contamination remains in the soil, a soil cap may be inherently less
protective of human health and the environment in the long term than removal alternatives. Even
though the soil cap concept is designed to avoid failure, damage caused during catastrophic
natural events like major floods cannot be avoided. Damaged cap materials would be repaired
and/or replaced as needed following major natural or man-made events.
As part of this alternative, controls would be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Controls associated with a soil
cap would include signage, fencing, and potential LUCs. The use of multiple controls for this
alternative should increase their effectiveness.
This alternative would provide long-term effectiveness and permanence by eliminating the
potential human health and ecological exposure pathways associated with impacted soil. A site
management plan would be implemented to confirm that the soil cap remains effective over time.
8.2.2.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Removal of contaminated soils would result in reducing the toxicity, mobility, and volume of the
soil. The greater the volume of soil removed, the greater the reduction in toxicity, mobility and
volume of COPCs. Capping relies on isolation rather than treatment to achieve effectiveness.
Natural processes that reduce toxicity such as biological degradation of organic compounds
would continue to occur beneath the soil cap following construction, although these processes
may be insignificant.
8.2.2.5 Short-Term Effectiveness
Physical construction of this alternative could likely be completed in approximately one
construction season. The effects of this alternative during the construction and implementation
phase would potentially include:
• Impact to local property owners during soil removals and capping;
• Impact to local pipelines during soil removals and capping;
• Additional potential risk presented by volatilization of organics during excavation and
materials handling;
• Potential for increased stormwater runoff and erosion during excavation activities;
• The off-site transport of contaminated soil could potentially adversely affect local traffic
and may pose the potential for traffic accidents, which in turn could result in releases of
hazardous substances;
• Potential for on-site worker and transportation accidents associated with remedial
construction; and
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• Potential for on-site workers to receive adverse impacts through dermal contact with
contaminated soil.
Excavation and contaminated media handling may create air emissions and odors through release
of SVOCs and VOCs from the removed materials. However, due to the low levels of VOCs in
Lower Ley Creek, significant odors and air emissions are not expected and odor controls will not
be necessary during remediation activities. Appropriate measures would be taken to minimize
any adverse impacts from soil excavation activities, including measures to prevent transport of
fugitive dust and exposure of workers and downgradient receptors to contamination. All of the
short-term impacts discussed above can be minimized or mitigated by exercising sound
engineering practices, following appropriate health and safety protocols, wearing proper personal
protective equipment (PPE), and adequate monitoring.
8.2.2.6 Implementabilitv
Appropriate soil excavation and capping technologies are readily available and implementable,
and construction procedures are well established. Excavation and capping have been
demonstrated as effective remedial technologies for impacted soils at numerous sites. The
technology, equipment, subcontractors, personnel, and facilities required to successfully
excavate or cap contaminated soils are available in the environmental market place. Guidance
documents are also available from numerous sources, including the EPA and the USACE, on
how to successfully design, construct, and monitor soil cap projects. Short-term and long-term
monitoring as part of a site management plan can be easily implemented to verify effectiveness.
Additional remedial actions can readily be undertaken should the alternative prove to be
ineffective or partially ineffective although greater removal volumes would require either longer
durations or additional dredging and excavation equipment. The presence of two large buried
pipelines in the Northwest Soils area may limit the removal of contaminated soils in that vicinity.
Therefore, in those areas, a soil cap will be installed above contaminated soil that could not be
excavated.
8.2.2.7 Cost
8.2.2.7.1 On-site Disposal
This soil alternative had the highest construction and overall costs among the alternatives
evaluated. The substantial volume of excavation would cost approximately $6.2 million. The
annual operation, maintenance, management and reporting costs would be the lowest of the
alternatives. Total present worth is approximately $9.1 million for this alternative. A detailed
cost breakdown is provided in Appendix C, Table C-l.
8.2.2.7.2 Off-site Disposal
This soil alternative had the highest construction and overall costs among the alternatives
evaluated. The substantial volume of excavation would cost approximately $13.1 million. The
annual operation, maintenance, management and reporting costs would be the lowest of the
alternatives. Total present worth is approximately $19 million for this alternative. A detailed cost
breakdown is provided in Appendix C, Table C-3.
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8.2.2.8 State Acceptance
Not evaluated.
8.2.2.9 Community Acceptance
Not evaluated.
8.2.2.10 Conclusion
This alternative significantly reduces the risks to human health and the environment from soil
contamination at the site. This conclusion is based on a combination of factors that includes the
area remediated and the volume of soils removed. This is the most extensive soil remedial
alternative, and as such provides the greatest benefits at the highest costs. It serves as the upper
bound of the benefits of active remediation of soils at Lower Ley Creek.
8.2.3 Soil-3: Excavation of Southern Swale Soils to Meet Cleanup Goals and Soil Cap for
Northwest Soils
8.2.3.1 Overall Protection of Human Health and Environment
Excavation to remove impacted soils would provide protection of human health and the
environment by eliminating the exposure pathways associated with impacted soils. Removal of
contaminated soils would reduce future potential COPC releases to the creek.
Capping contaminated soils would provide overall protection of human health and the
environment by eliminating the potential human health and ecological exposure pathways
associated with impacted soils. Clean cap material would prevent direct exposure of humans and
ecological receptors to contaminated soil. Erosion control measures on the cap would reduce or
eliminate the potential COPC releases to the creek.
8.2.3.2 Compliance with ARARs
This alternative would comply with chemical-specific, location-specific and action-specific
ARARs (i.e., RCRA, CWA, etc.). Soil caps are routinely installed in compliance with ARARs.
This alternative would also be in compliance with TSCA.
8.2.3.3 Long-Term Effectiveness and Permanence
Removal and off-site disposal/treatment of contaminated soil is a permanent remedy for Lower
Ley Creek soils. Soil excavation is a reliable technology and properly managed landfills provide
reliable controls for long-term management of contaminated soils.
Utilization of a soil cap is a proven technology for isolating contaminated soils from erosion and
transport to the creek and biota if proper design, placement, and maintenance of the cap are
performed to provide cap effectiveness, continued performance, and reliability. In addition,
controls as part of a site management plan would be implemented to restrict excavation and
construction activities in the soil cap areas. The soil cap would reduce the mobility of
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contaminants in the soil but would not affect toxicity or volume of contaminants in the soil or
sediments. Because contamination remains in the soil, a soil cap may be inherently less
protective of human health and the environment in the long term than removal alternatives. Even
though the soil cap concept is designed to avoid failure, damage caused during catastrophic
natural events like major floods cannot be avoided. Damaged cap materials would be repaired
and/or replaced as needed following major natural or man-made events.
As part of this alternative, controls would be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Controls associated with a soil
cap would include signage, fencing, and potential LUCs. The use of multiple institutional
controls for this alternative should increase their effectiveness.
8.2.3.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Removal of contaminated soils would result in reducing the toxicity, mobility, and volume of the
soil. The greater the volume of soil removed, the greater the reduction in toxicity, mobility and
volume of COPCs. Capping relies on isolation rather than treatment to achieve effectiveness.
Natural processes that reduce toxicity such as biological degradation of organic compounds
would continue to occur beneath the soil cap following construction, although these processes
may be insignificant.
8.2.3.5 Short-Term Effectiveness
Physical construction of this alternative could likely be completed in approximately one
construction season. The effects of this alternative during the construction and implementation
phase would potentially include:
• Impact to local property owners during soil removals and capping;
• Impact to local pipelines during soil removals and capping;
• Additional potential risk presented by volatilization of organics during excavation and
materials handling;
• Potential for increased stormwater runoff and erosion during excavation activities;
• The off-site transport of contaminated soil could potentially adversely affect local traffic
and may pose the potential for traffic accidents, which in turn could result in releases of
hazardous substances.
• Potential for on-site worker and transportation accidents associated with remedial
construction; and
• Potential for on-site workers to receive adverse impacts through dermal contact with
contaminated soil.
Excavation and contaminated media handling may create air emissions and odors through release
of SVOCs and VOCs from the removed materials. However, due to the low levels of VOCs in
Lower Ley Creek, significant odors and air emissions are not expected and odor controls will not
be necessary during remediation activities. Appropriate measures will be taken to minimize any
adverse impacts from soil excavation activities, including measures to prevent transport of
fugitive dust and exposure of workers and downgradient receptors to contamination. All of the
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short-term impacts discussed above would be minimized or mitigated by exercising sound
engineering practices, following appropriate health and safety protocols, wearing proper PPE,
and adequate monitoring.
8.2.3.6 Implementabilitv
No administrative difficulties are anticipated in getting the necessary approvals from EPA,
USACE, and NYSDEC for soil removal and the installation of a soil cap.
Appropriate soil excavation and capping technologies are readily available and implementable,
and construction procedures are well established. There appears to be property available for the
land-support areas that would be required for excavation of soils and the installation of a soil
cap. Excavation and capping have been demonstrated as effective remedial technologies for
impacted soils at numerous sites. The technology, equipment, subcontractors, personnel, and
facilities required to successfully excavate or cap contaminated soils are available in the
environmental market place. Guidance documents are also available from numerous sources,
including the EPA and the USACE, on how to successfully design, construct, and monitor soil
cap projects. Short-term and long-term monitoring as part of a site management plan can be
easily implemented to verify effectiveness. Additional remedial actions can readily be
undertaken should the alternative prove to be ineffective or partially ineffective although greater
removal volumes would require either longer durations or additional dredging and excavation
equipment.
8.2.3.7 Cost
8.2.3.7.1 On-site Disposal
This soil alternative had the second highest construction and overall costs among the alternatives
evaluated. The substantial volume of excavation would cost approximately $6.1 million. Total
present worth is approximately $9 million for this alternative. A detailed cost breakdown is
provided in Appendix C, Table C-l.
8.2.3.7.2 Off-site Disposal
This soil alternative had the second highest construction and overall costs among the alternatives
evaluated. The substantial volume of excavation would cost approximately $12.9 million. Total
present worth is approximately $18.7 million for this alternative. A detailed cost breakdown is
provided in Appendix C, Table C-3.
8.2.3.8 State Acceptance
Not evaluated.
8.2.3.9 Community Acceptance
Not evaluated.
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8.2.3.10 Conclusion
This alternative significantly reduces the risks to human health and the environment from soil
contamination at the site. This conclusion is based on a combination of factors that includes the
area remediated and the volume of soils removed. This is the next most extensive and expensive
soil remedial alternative after Soil Alternative 2. This alternative appears to provide a good
balance in achieving the RAOs and cleanup goals at costs that are more moderate as compared to
Soil Alternative 2. This alternative also addresses the most contaminated soils at the Site.
8.2.4 Soil-4: Soil Cap Over All Contaminated Soils
8.2.4.1 Overall Protection of Human Health and Environment
Capping contaminated soils would provide overall protection of human health and the
environment by eliminating the potential human health and ecological exposure pathways
associated with impacted soils. Clean cap material would prevent direct exposure of humans and
ecological receptors to contaminated soil. Erosion control measures on the cap would reduce or
eliminate the potential COPC releases to the creek.
8.2.4.2 Compliance with ARARs
This alternative would comply with chemical-specific, location-specific and action-specific
ARARs (i.e., RCRA, CWA, etc.). Soil caps are routinely installed in compliance with ARARs.
This alternative would also be in compliance with TSCA.
8.2.4.3 Long-Term Effectiveness and Permanence
Utilization of a soil cap is a proven technology for isolating contaminated soils from erosion and
transport to the creek and biota if proper design, placement, and maintenance of the cap are
performed to provide cap effectiveness, continued performance, and reliability. In addition,
controls as part of a site management plan would be implemented to restrict excavation and
construction activities in the soil cap areas. The soil cap would reduce the mobility of
contaminants in the soil but would not affect toxicity or volume of contaminants in the soil or
sediments. Because contamination remains in the soil, a soil cap may be inherently less
protective of human health and the environment in the long term than removal alternatives. Even
though the soil cap concept is designed to avoid failure, damage caused during catastrophic
natural events like major floods cannot be avoided. Damaged cap materials would be repaired
and/or replaced as needed following major natural or man-made events.
As part of this alternative, controls would be implemented as part of a site management plan to
restrict excavation and construction activities in the soil cap areas. Controls associated with a soil
cap would include signage, fencing, and potential LUCs. The use of multiple controls for this
alternative should increase their effectiveness.
This alternative would provide long-term effectiveness and permanence by eliminating the
potential human health and ecological exposure pathways associated with impacted soil.
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8.2.4.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Capping relies on isolation rather than treatment to achieve effectiveness. Natural processes that
reduce toxicity such as biological degradation of organic compounds would continue to occur
beneath the soil cap following construction, although these processes may be insignificant.
8.2.4.5 Short-Term Effectiveness
Physical construction of this alternative could likely be completed in approximately one
construction season. The effects of this alternative during the construction and implementation
phase would potentially include:
• Impact to local property owners during soil capping;
• Impact to local pipelines during soil removals and capping;
• Additional potential risk presented by volatilization of organics during excavation and
materials handling;
• Potential for increased stormwater runoff and erosion during activities;
• Potential for on-site worker and transportation accidents associated with remedial
construction; and
• Potential for on-site workers to receive adverse impacts through dermal contact with
contaminated soil.
Based on experience at other soil capping sites, the impacts are not anticipated to be significant.
Proven, available engineering controls would be employed during the soil cap implementation.
In addition, steps would be taken to minimize the impact to local property owners during the soil
capping process. Appropriate measures would be taken to minimize any adverse impacts from
soil excavation and capping activities, including measures to prevent transport of fugitive dust
and exposure of workers and downgradient receptors to contamination. All of the short-term
impacts discussed above would be minimized or mitigated by exercising sound engineering
practices, following appropriate health and safety protocols, wearing proper PPE, and adequate
monitoring.
8.2.4.6 Implementabilitv
No administrative difficulties are anticipated in getting the necessary approvals from EPA,
USACE, and NYSDEC for the installation of a soil cap.
Appropriate soil capping technologies are readily available and implementable, and construction
procedures are well established. There appears to be property available for the land-support areas
that would be required for the installation of a soil cap. Soil capping has been demonstrated as an
effective remedial technology for impacted soils at numerous sites. The technology, equipment,
subcontractors, personnel, and facilities required to successfully excavate or cap contaminated
soils are available in the environmental market place. Guidance documents are also available
from numerous sources, including the EPA and the USACE, on how to successfully design,
construct, and monitor soil cap projects. Short-term and long-term monitoring as part of a site
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management plan can be easily implemented to verify effectiveness. Additional remedial actions
can readily be undertaken should the alternative prove to be ineffective.
8.2.4.7 Cost
8.2.4.7.1 On-site Disposal
This soil alternative had the lowest construction and overall costs among the active alternatives
evaluated. Total present worth is approximately $7.9 million for this alternative. A detailed cost
breakdown is provided in Appendix C, Table C-l.
8.2.4.7.2 Off-site Disposal
This soil alternative had the lowest construction and overall costs among the alternatives
evaluated. Total present worth is approximately $16.3 million for this alternative. A detailed cost
breakdown is provided in Appendix C, Table C-3.
8.2.4.8 State Acceptance
Not evaluated.
8.2.4.9 Community Acceptance
Not evaluated.
8.2.4.10 Conclusion
This alternative significantly reduces the risks to human health and the environment from soil
contamination at the site. As with Soil Alternative 3, this alternative appears to provide a good
balance in achieving the RAOs and cleanup goals at costs that are more moderate as compared to
Soil Alternative 2.
8.3 SEDIMENT REMEDIAL ALTERNATIVES
8.3.1 Sediment-1: No Action
8.3.1.1 Overall Protection of Human Health and the Environment
The No Action alternative would not be protective of human health and the environment,
because this would not actively address the contaminated sediments that present unacceptable
risks of exposure to receptors or the release and transport of COPCs at the site. The RAOs or
cleanup goals would not be met under this alternative.
8.3.1.2 Compliance with ARARs
There are no chemical-specific ARARs (i.e., RCRA, CWA, etc.) for sediments. However, there
are TBC values (i.e., NYSDEC sediment screening values). The No Action alternative would not
meet these TBCs. This alternative would also not be in compliance with TSCA.
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8.3.1.3 Long-Term Effectiveness and Permanence
The No Action alternative does not provide significant long-term effectiveness. The No Action
alternative would not be effective in meeting the RAOs and cleanup goals and would not be
effective in addressing risks to human health and the environment. The dominant carcinogenic
and non-carcinogenic risks to human health and ecological receptors posed by the contaminated
sediments would continue for several decades under this alternative. The creek would be
expected to continue to improve naturally over time. However, it would not effectively eliminate
the potential exposure to contaminants in sediment. The rate of improvement is unpredictable
and would not be verified due to the lack of monitoring under this alternative.
8.3.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment
The toxicity and volume of COPCs in sediment would not be significantly reduced under the No
Action alternative because no treatment would be conducted. The overall bioavailability and
mobility of contaminants in the sediment may be reduced over time as some natural recovery
processes occur.
8.3.1.5 Short-Term Effectiveness
The No Action alternative does not include any physical construction measures in any areas of
contamination and, therefore, would not present any potential adverse impacts to the community
or workers as a result of its implementation.
8.3.1.6 Implementabilitv
The complete deferral of remedial action would be easily implemented from both technical and
administrative standpoints, as it would only require periodic re-evaluation (every 5 years) of
risks to human health and environment.
8.3.1.7 Cost
The costs for this alternative are minimal and include no capital costs and only minimal project
management and reporting costs annually and for 5-year reviews. The total present worth of this
alternative is approximately $50,000. A costs breakdown is provided in Appendix C.
8.3.1.8 State Acceptance
Not evaluated.
8.3.1.9 Community Acceptance
Not evaluated.
8.3.1.10 Conclusion
The No Action alternative would not actively reduce the toxicity, mobility, or volume of the
contamination through treatment. The cancer risks and non-cancer human health hazards and
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risks to ecological receptors posed by fish consumption would continue to remain above
acceptable levels and the surface water quality would continue to be degraded.
8.3.2 Sediment-2: Removal of All Sediments to Cleanup Goals
8.3.2.1 Overall Protection of Human Health and the Environment
Excavation to remove all impacted sediments would provide protection of human health and the
environment by eliminating the exposure pathways associated with impacted sediments.
Backfilling with clean fill would provide habitat for benthic species to colonize.
8.3.2.2 Compliance with ARARs
There are no chemical-specific ARARs (i.e., RCRA, CWA, etc.) for sediments. However, there
are TBC values (i.e., NYSDEC sediment screening values). Sediment removal would comply
with TBCs. The excavation and backfilling work may result in short-term localized exceedences
of surface water criteria due to suspension of impacted sediment during excavation. However,
the water quality impacts from excavation would meet the substantive water quality requirements
imposed by NYS on entities seeking a dredged material discharge permit under Section 404 of
the CWA. This alternative would also be in compliance with TSCA.
8.3.2.3 Long-Term Effectiveness and Permanence
The removal and off-site disposal/treatment of contaminated sediments is a permanent remedy
for the Site. Sediment excavation is a reliable technology. Removal of sediments would reduce
toxicity, volume, and mobility of contaminants in the creek. Properly managed landfills provide
reliable controls for long-term management of contaminated sediments. Treatability studies may
be required to demonstrate the effectiveness of specific technologies in treating sediments from
Lower Ley Creek.
This alternative would provide long-term effectiveness and permanence by eliminating the
potential human health and ecological exposure pathways associated with impacted sediment.
8.3.2.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Excavation processes would result in reducing the toxicity, mobility, and volume of the
sediment. Treatment of water resulting from the excavation would reduce the toxicity, mobility
and volume of COPCs that are mobilized from the sediment into the water stream. The greater
the volume of sediment removed, the greater the reduction in toxicity, mobility and volume that
would result from these processes.
8.3.2.5 Short-Term Effectiveness
Sediment removal may result in short-term adverse impacts to the creek. These impacts include
exposure of contaminated sediments to the water column, fish, and biota due to resuspension of
sediments during removal and temporary loss of benthos and habitat for the ecological
community in dredged areas. Risks due to resuspension can be minimized through control of
sediment removal rate and use of an appropriate sediment cap. Replacement of the benthic
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habitat would be implemented through addition of a layer of backfill material in excavated areas
after sediment removal. Natural benthic recolonization following a disturbance is rapid, and in
many instances, the process begins within days after perturbation.
Physical construction of this alternative could likely be completed in approximately two
construction seasons. The effects of this alternative during the construction and implementation
phase would potentially include:
• Impact to local property owners during sediment removals;
• Temporary loss of creek habitat;
• Temporary impacts of resuspension of COPCs and potential release into the water
column during excavation;
• Additional potential risk presented by volatilization of organics during excavation and
materials handling;
• The off-site transport of contaminated sediment could potentially adversely affect local
traffic and may pose the potential for traffic accidents, which in turn could result in
releases of hazardous substances.
• Potential for on-site worker and transportation accidents associated with remedial
construction; and
• Potential for on-site workers to receive adverse impacts through dermal contact with
contaminated sediment.
Excavation, contaminated media handling, and dewatering may create air emissions and odors
through release of SVOCs and VOCs from the removed materials. However, due to the low
levels of VOCs in Lower Ley Creek, significant odors and air emissions are not expected and
odor controls will not be necessary during remediation activities. All of the short-term impacts
discussed above would be minimized or mitigated by exercising sound engineering practices,
following appropriate health and safety protocols, wearing proper PPE, and adequate monitoring.
8.3.2.6 Implementabilitv
Equipment and services for sediment removal are available commercially, as are equipment and
services for material handling and off-site transportation. In some areas, specialized excavation
equipment may be required. However, most excavators would be able to dig at least 15 ft bwsi
from the edge of the creek. The potentially large volume of sediments to be removed would
require significant coordination of the excavation efforts, material handling activities, and off-
site transportation logistics. There is sufficient, currently available, off-site land disposal capacity
for both the TSCA-regulated and non-TSCA-regulated fractions of removed sediment. In
addition, there appears to be property available for the land-support areas that would be required
for excavation of sediments.
No administrative difficulties are anticipated in getting the necessary approvals from EPA,
US ACE, and NYSDEC for sediment removal. However, the sediment removal activities will
result in temporary disruption of local businesses during remediation. The difficulty associated
with this disruption is a function both of the total length of shoreline disruption and the value of
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the disturbed area. Although measures to mitigate or prevent impacts and disruptions would be
employed, the local community would experience some measure of inconvenience during
remedial activities. Measures that would be implemented in conjunction with this alternative
category to minimize both short- and long-term disruption include:
• Limited duration of the remediation period (a matter of months at any given location);
• Shoreline stabilization and waterfront restoration;
• Control of sediment removal rates; and
• Use of sediment barriers during sediment removal.
Excavation has been demonstrated as an effective remedial technology for impacted sediments at
numerous sites. Guidance documents are also available from numerous sources, including the
EPA and the USACE, on how to successfully design, construct, and monitor excavation projects.
The technology, equipment, subcontractors, personnel, and facilities required to successfully
complete this alternative are available in the environmental market place. Short-term and long-
term monitoring of this alternative can be easily implemented to verify effectiveness. Additional
remedial actions can readily be undertaken should the alternative prove to be ineffective or
partially ineffective although greater removal volumes would require either longer durations or
additional excavation equipment.
8.3.2.7 Cost
8.3.2.7.1 On-site Disposal
This alternative had the third lowest construction costs and overall costs among the alternatives
evaluated. The excavation would cost approximately $4.7 million. The annual operation,
maintenance, management and reporting costs are the lowest of all the action alternatives. Total
present worth is approximately $6.9 million for this alternative. A detailed cost breakdown is
provided in Appendix C, Table C-2.
8.3.2.7.2 Off-site Disposal
This alternative had the highest construction costs and second highest overall costs among the
alternatives evaluated. The excavation would cost approximately $11.3 million. The annual
operation, maintenance, management and reporting costs are the lowest of all the action
alternatives. Total present worth is approximately $16.5 million for this alternative. A detailed
cost breakdown is provided in Appendix C, Table C-4.
8.3.2.8 State Acceptance
Not evaluated.
8.3.2.9 Community Acceptance
Not evaluated.
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8.3.2.10 Conclusion
This alternative significantly reduces the risks to human health and the environment from
contaminants at the site. This conclusion is based on a combination of factors that includes the
area remediated, the volume of sediments removed, and the length of creek affected. The
sediment excavation alternative is the most extensive remedial alternative, and as such provides
the greatest benefits.
8.3.3 Sediment-3: Granular Material Sediment Cap
8.3.3.1 Overall Protection of Human Health and the Environment
Sediment capping would provide overall protection of human health and the environment by
eliminating the potential human health and ecological exposure pathways associated with
impacted sediment. Clean cap material would prevent direct exposure of humans and ecological
receptors to contaminated sediment. Reduction in direct exposure to COPCs and potential COPC
releases to the water column are expected to reduce risks to fish and to humans and wildlife that
consume fish.
8.3.3.2 Compliance with ARARs
There are no chemical-specific ARARs (i.e., RCRA, CWA, etc.) for sediments. However, there
are TBCs (i.e., NYSDEC sediment screening values). Sediment capping would comply with
TBCs. Sediment caps are routinely installed in compliance with ARARs and TBCs, which would
include the substantive requirements of the dredge and fill permit program under Section 404 of
the CWA. This alternative would also be in compliance with TSCA.
8.3.3.3 Long-Term Effectiveness and Permanence
Capping using a granular sediment and an armor layer (where required) is a proven technology
for isolating contaminated sediments from the water column and biota if proper design,
placement, and maintenance of the cap are performed to provide cap effectiveness, continued
performance, and reliability. Capping would reduce the mobility of contaminants in the creek but
would not affect toxicity or volume of contaminants. Because contamination remains in the
sediment, capping alternatives may be inherently less protective of human health and the
environment in the long term than removal alternatives. Even though the capping concept is
designed to avoid failure, catastrophic natural events like major floods cannot be avoided.
However, the placement of an armor layer in areas potentially susceptible to erosion and
scouring either during baseflow conditions or flooding events minimizes potential failures of this
capping technology. Additionally, damaged cap materials would be repaired and/or replaced as
needed following major natural or made-made events.
Consistent with EPA design guidance for caps, the sediment cap would be designed to withstand
erosional forces resulting from the 100-year return interval storm event. Controls, such as bans
on dredging the capped area, would be implemented as necessary to help ensure the long-term
integrity of the cap. As part of a site management plan, maintenance and monitoring program
would be implemented to confirm that the sediment cap remains effective over time.
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However, it important to note that Lower Ley Creek has been dredged in the past to alleviate
flooding and may need to be dredged in the future. Therefore, a ban on dredging in the
capped/backfill areas may not be feasible.
8.3.3.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Capping relies on isolation rather than treatment to achieve effectiveness. Capping would result
in some reduction in the volume of the impacted sediment due to initial excavation before the
installation of the cap. Natural processes that reduce toxicity such as biological degradation of
organic compounds would continue to occur beneath the cap following construction and would
be monitored as described in Section 7.
8.3.3.5 Short-Term Effectiveness
Sediment capping may cause short-term adverse impacts to the creek. These impacts include
excavation of the benthic community and temporary loss of benthos and habitat for the
ecological community during capping. Replacement of the benthic habitat would be
implemented through addition of appropriate backfill material on top of the cap after cap
placement. Natural benthic recolonization following a disturbance is rapid, and in many
instances the process begins within days after perturbation.
Physical construction of the sediment cap could likely be completed in approximately one
construction season. The effects of this alternative during the construction and implementation
phase would potentially include:
• Temporary loss of creek habitat;
• Temporary impacts associated with sedimentation resulting from cap placement;
• Potential for on-site worker and transportation accidents associated with remedial
construction; and
• Potential for on-site workers to receive adverse impacts through dermal contact with
contaminated sediment.
All of the short-term impacts discussed above would be minimized or mitigated by exercising
sound engineering practices, following appropriate health and safety protocols, wearing proper
PPE, and adequate monitoring. The primary short-term negative ecological impact under this
alternative would be the temporary elimination of benthic macro invertebrate communities.
8.3.3.6 Implementabilitv
Appropriate sediment capping technologies are readily available and implementable, and
construction procedures are well established. Sediment capping using granular material and
armor stone has been demonstrated as an effective remedial technology for impacted sediments
at numerous sites. The technology, equipment, subcontractors, personnel, and facilities required
to successfully complete this alternative are available in the environmental market place. Short-
term and long-term monitoring of this alternative can be easily implemented to verify
effectiveness. Additional remedial actions can readily be undertaken should the alternative
prove to be ineffective or partially ineffective.
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8.3.3.7 Cost
8.3.3.7.1 On-site Disposal
The costs of installing the sediment cap would be approximately $5.4 million. Total present
worth is approximately $10.1 million for this alternative. A detailed cost breakdown is provided
in Appendix C, Table C-2.
8.3.3.7.2 Off-site Disposal
The costs of installing the sediment cap would be approximately $10.6 million. Total present
worth is approximately $17.6 million for this alternative. A detailed cost breakdown is provided
in Appendix C, Table C-4.
8.3.3.8 State Acceptance
Not evaluated.
8.3.3.9 Community Acceptance
Not evaluated.
8.3.3.10 Conclusion
This alternative significantly reduces the risks to human health and the environment from
contaminants at the site. This conclusion is based on a combination of factors that includes the
area remediated, the volume of sediments removed, and the length of creek affected. This
alternative appears to provide a good balance in achieving the RAOs and cleanup goals at costs
comparable with Sediment Alternative 4. This alternative significantly reduces the risks to
human health and the environment from sediment contamination at the site.
8.3.4 Sediment-4: Engineered Bentonite Sediment Cap
8.3.4.1 Overall Protection of Human Health and the Environment
Sediment capping would provide overall protection of human health and the environment by
eliminating the potential human health and ecological exposure pathways associated with
impacted sediment. Clean cap material would prevent direct exposure of humans and ecological
receptors to contaminated sediment. Reduction in direct exposure to COPCs and potential COPC
releases to the water column are expected to reduce risks to fish and to humans and wildlife that
consume fish.
8.3.4.2 Compliance with ARARs
There are no chemical-specific ARARs (i.e., RCRA, CWA, etc.) for sediments. However, there
are TBC values (i.e., NYSDEC sediment screening values). Sediment capping would comply
with these TBCs. Sediment caps are routinely installed in compliance with ARARs and TBCs,
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which would include the substantive requirements of the dredge and fill permit program under
Section 404 of the CWA. This alternative would also be in compliance with TSCA.
8.3.4.3 Long-Term Effectiveness and Permanence
Capping using an engineered bentonite is a proven technology for isolating contaminated
sediments from the water column and biota if proper design, placement, and maintenance of the
cap are performed to provide cap effectiveness, continued performance, and reliability. Capping
would reduce the mobility of contaminants in the creek but would not affect toxicity or volume
of contaminants. Because contamination remains in the sediment, capping alternatives may be
inherently less protective of human health and the environment in the long term than removal
alternatives. Even though the capping concept is designed to avoid failure, catastrophic natural
events like major floods cannot be avoided.
Bentonite cap materials are more resistive to erosional forces in high velocity streams. The
bentonite material can provide substrate for wetland vegetation and habitat for macroinvertebrate
organisms, particularly when additional organic material is incorporated into the engineering
design or as a surficial dressing. Bentonite cap materials are more effective in limiting the
migration of contaminants in sediment compared to more permeable materials such as sand
(EPA, 2007).
However, it is possible that an engineered bentonite cap could act to divert contaminant flux
(fluid or vapor phase) to the periphery of a capped area, potentially biasing and concentrating the
flux of contamination in discrete locations even beyond the original contaminant footprint.
Consistent with EPA design guidance for caps, the sediment cap would be designed to withstand
erosional forces resulting from the 100-year return interval storm event. Controls, such as bans
on dredging the capped area, would be implemented as necessary to help ensure the long-term
integrity of the cap. As part of a site management plan, maintenance and monitoring program
would be implemented to confirm that the sediment cap remains effective over time.
However, it important to note that Lower Ley Creek has been dredged in the past to alleviate
flooding and may need to be dredged in the future. Therefore, a ban on dredging in the
capped/backfill areas may not be feasible.
8.3.4.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Capping relies on isolation rather than treatment to achieve effectiveness. Capping would result
in some reduction in the volume of the impacted sediment due to initial excavation before the
installation of the cap. Natural processes that reduce toxicity such as biological degradation of
organic compounds would continue to occur beneath the cap following construction and would
be monitored as described in Section 7.
8.3.4.5 Short-Term Effectiveness
Sediment capping may cause short-term adverse impacts to the creek. These impacts include
excavation of the benthic community and temporary loss of benthos and habitat for the
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ecological community during capping. Replacement of the benthic habitat would be
implemented through addition of appropriate backfill material on top of the cap after cap
placement. Natural benthic recolonization following a disturbance is rapid, and in many
instances the process begins within days after perturbation.
Physical construction of the sediment cap could likely be completed in approximately one
construction season. The effects of this alternative during the construction and implementation
phase would potentially include:
• Temporary loss of creek habitat;
• Temporary impacts associated with sedimentation resulting from cap placement;
• Potential for on-site worker and transportation accidents associated with remedial
construction; and
• Potential for on-site workers to receive adverse impacts through dermal contact with
contaminated sediment.
All of the short-term impacts discussed above can be minimized or mitigated by exercising
sound engineering practices, following appropriate health and safety protocols, wearing proper
PPE, and adequate monitoring. The primary short-term negative ecological impact under this
alternative would be the temporary elimination of benthic macro invertebrate communities.
8.3.4.6 Implementabilitv
Installation of a bentonite cap can be performed using commonly available equipment and
technologies, including conveyors, excavators, or cranes with clamshell buckets. As a result,
implementation of this technology can be efficient and cost effective.
Sediment capping using engineered bentonite material has been demonstrated as an effective
remedial technology for impacted sediments at numerous sites. Equipment and services for
sediment capping are available commercially. The potentially large volume of material required
for cap construction would require significant coordination of the cap placement, material
handling and transportation activities. There appears to be property available for the land-
support areas that would be required for capping of sediments. Short-term and long-term
monitoring of this alternative can be easily implemented to verify effectiveness. Additional
remedial actions can readily be undertaken, should the alternative prove to be ineffective or
partially ineffective.
8.3.4.7 Cost
8.3.4.7.1 On-site Disposal
The costs of installing the sediment cap would be $5.5 million. Total present worth is
approximately $10.2 million for this alternative. A detailed cost breakdown is provided in
Appendix C, Table C-2.
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8.3.4.7.2 Off-site Disposal
The costs of installing the sediment cap would be $9 million. Total present worth is
approximately $15.3 million for this alternative. A detailed cost breakdown is provided in
Appendix C, Table C-4.
8.3.4.8 State Acceptance
Not evaluated.
8.3.4.9 Community Acceptance
Not evaluated.
8.3.4.10 Conclusion
This alternative significantly reduces the risks to human health and the environment from
contaminants at the site. This conclusion is based on a combination of factors that includes the
area remediated, the volume of sediments removed, and the length of creek affected. This
alternative appears to provide a good balance in achieving the RAOs and cleanup goals at costs
comparable with Sediment Alternative 3. This alternative significantly reduces the risks to
human health and the environment from sediment contamination at the site.
8.3.5 Sediment-5: Monitored Natural Recovery
8.3.5.1 Overall Protection of Human Health and the Environment
MNR of the creek sediments would not eliminate the risks to human health and the environment.
If completed in conjunction with controls it would protect humans by eliminating the potential
human exposure, but would not eliminate the exposures to the environment. Environmental
exposures would be expected to drop due to natural processes in the creek (i.e., sedimentation,
biodegradation).
8.3.5.2 Compliance with ARARs
There are no chemical-specific ARARs for sediments. However, there are TBCs (i.e., NYSDEC
sediment screening values). The MNR alternative would not meet these TBCs.
8.3.5.3 Long-Term Effectiveness and Permanence
This alternative would not likely provide long-term effectiveness and permanence because the
potential human health and ecological exposure pathways associated with impacted sediment
would remain at the site for an extended period of time.
Controls, such as bans on dredging and fishing, would be implemented as necessary until
monitoring confirms the elimination of the contaminant risks.
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8.3.5.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Natural processes that reduce toxicity, such as biological degradation of organic compounds
along with sedimentation to reduce the exposure to the contaminants, would continue to occur in
the creek and be monitored.
8.3.5.5 Short-Term Effectiveness
The MNR alternative does not include any physical construction measures in any areas of
contamination and, therefore, would not present any potential adverse impacts to the community.
Monitoring activities would present temporary health and safety risks to workers that could
easily be addressed with proper work procedures and equipment.
8.3.5.6 Implementabilitv
Short-term and long-term monitoring of this alternative can be easily implemented to verify
effectiveness. Additional remedial actions can readily be undertaken should the alternative
prove to be ineffective or partially ineffective.
8.3.5.7 Cost
The costs for this alternative are relatively low compared to other action alternatives and include
no capital costs. Costs include for this alternative include sampling costs, reporting costs, project
management costs, and costs for 5-year reviews. The total present worth of this alternative is
approximately $2 million. A cost breakdown is provided in Appendix C.
8.3.5.8 State Acceptance
Not evaluated.
8.3.5.9 Community Acceptance
Not evaluated.
8.3.5.10 Conclusion
The MNR alternative would not actively reduce the toxicity, mobility, or volume of the
contamination through treatment. The cancer risks and non-cancer human health hazards and
risks to ecological receptors posed by fish consumption would continue to remain above
acceptable levels and the surface water quality would continue to be degraded.
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9.0 COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES
This section presents a comparative analysis of the four soil remedial alternatives and the five
sediment remedial alternatives developed for the Lower Ley Creek Site. This analysis evaluates
the alternatives against the seven evaluation criteria in comparison to each other. State
acceptance will be addressed by EPA in the Proposed Plan and ROD, respectively. Community
Acceptance will be addressed in the ROD.
9.1 SOIL REMEDIAL ALTERNATIVES
The four soil alternatives are:
• Soil Alternative 1 - No Action;
• Soil Alternative 2 - Excavation of Soil to Meet Cleanup Goals;
• Soil Alternative 3 - Excavation of Southern Swale Soils to Meet Cleanup Goals and Soil
Cap for Northwest Soils; and
• Soil Alternative 4 - Soil Cap Over All Contaminated Soils.
A comparative evaluation of the four soil alternatives is presented in Table 9.1 and discussed
below.
9.1.1 Overall Protection of Human Health and Environment
Alternative 1 is not protective of human health and the environment.
Alternative 2 is the most protective because it removes the most contamination, as some will be
left in place in the vicinity of the pipelines. Alternative 3 is slightly less protective of human
health and the environment because it removes less contaminants from the soils and relies more
on isolation (capping) to eliminate exposure pathways.
Alternative 4 is slightly less protective than Alternatives 2 and 3 because it eliminates the
exposure pathways of soil contaminants via isolation (capping) rather than removing them from
the environment.
9.1.2 Compliance with ARARs
Alternative 1 would not meet chemical-specific ARARs (i.e., RCRA, CWA, etc.) or be in
compliance with TSCA.
Alternatives 2, 3, and 4 would meet the chemical-specific, location-specific, and action-specific
ARARs (i.e., RCRA, CWA, etc.) and be in compliance with TSCA.
9.1.3 Long-Term Effectiveness and Permanence
Alternative 1 would not provide long-term effectiveness or permanence. Under the remaining
alternatives, long-term effectiveness and permanence would depend on the effectiveness of
source control (excavation and capping) measures in maintaining reliable protection for human
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health and the environment once RAOs are met. It is expected that Alternatives 2, 3, and 4 would
provide long-term effectiveness and permanence.
With the exception of Alternative 1, long-term monitoring and the implementation of a site
management plan would ensure the adequacy and reliability of these actions to control untreated
wastes that remain following completion of the remedial action. All Soil Alternatives, with the
exception of the No Action Alternative, would require some degree of long-term monitoring.
However, Alternative 2 would provide the highest degree of long-term effectiveness and
permanence due to the significant reduction in soil contamination via excavation. Alternatives 3
and 4 would require more extensive long-term monitoring activities than Alternative 2 due to
monitoring requirements associated with cap maintenance. Alternative 4 would rely only on
capping and would therefore require the most extensive long-term monitoring.
9.1.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Over a long period of time, natural processes would slightly reduce the toxicity, mobility, and
volume of contaminants in the soil under Alternative 1. However, they would not be reduced
significantly over time and Alternative 1 would not monitor or control these processes.
In comparison with the other alternatives, Alternative 2 would reduce the toxicity, mobility, and
volume of impacted soils the greatest through extensive soil excavation. Alternative 3 would also
reduce a large volume of the contaminated soils in the environment by excavation in the
Southern Swale Soil Area and reduce the mobility of contaminants in the soil by capping in the
Northwest Soil Area.
Alternative 4 reduces the mobility of contaminants through soil capping, but has little effect on
the toxicity and volume of contaminants.
9.1.5 Short-Term Effectiveness
The alternative with the least amount of physical construction and material movement
(Alternative 1) would have the lowest amount of short-term impacts on the environment.
All the active soil alternatives (2, 3, and 4) would result in short-term habitat destruction and
impact to local property owners by either excavation or capping activities. Alternatives 2 and 3
would have the most short-term impacts because excavation activities would elevate short-term
risks for construction workers, impact local property owners, and result in the temporary loss of
habitats. The capping of soils associated with Alternative 4 would have slightly less short-term
impacts than the excavation of contaminated soil proposed in Alternatives 2 and 3.
For all alternatives, appropriate measures would be taken to minimize any adverse impacts from
soil excavation activities, including measures to prevent transport of fugitive dust and exposure
of workers and downgradient receptors to contamination. All of the short-term impacts can be
minimized or mitigated by exercising sound engineering practices, following appropriate health
and safety protocols, wearing proper PPE, and adequate monitoring.
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9.1.6 Implementability
No technical or administrative issues have been identified that would limit the feasibility of
implementing Alternative 1.
Appropriate soil excavation technologies are readily available and implementable for
Alternatives 2 and 3. The size and duration of the removal activities in Alternative 2 would
present more implementation challenges than the other three alternatives.
Appropriate soil capping technologies are readily available and implementable for Alternatives
2, 3, and 4.
Short-term and long-term monitoring as part of a site management plan for Alternatives 2, 3, and
4 can be easily implemented to verify effectiveness. Additional remedial actions can readily be
undertaken, should the alternatives prove to be ineffective or partially ineffective.
9.1.7 Cost
Capital costs for soil removal, off-site transportation, and disposal or treatment are higher
compared to costs involving installation of a soil cap over equivalent target areas. Operation and
maintenance costs for a soil removal alternative will be lower than for implementation of a soil
capping alternative for an equivalent area, as removal-only alternatives do not require long-term
maintenance.
Costs for soil capping alternatives vary primarily with the total area covered. Operation and
maintenance costs for a soil cap alternative will be higher than for a soil removal alternative
involving the same areas because of soil cap maintenance costs, institutional controls, and the
implementation of a site management plan.
9.1.7.1 On-site Disposal
The cost estimates for each soil remedial alternative are detailed in Appendix C, Table C-l. The
alternatives with the least amount of construction and off-site disposal activity are the least costly
to implement. Alternative 1 is the least costly. Alternative 2 includes the largest amount of
excavation and disposal of impacted soils and therefore carries the highest cost. Alternative 3,
which proposes a mix of excavation and capping activities, is the next most costly alternative.
Finally, Alternative 4 (Capping of Soils) is higher in cost than the No Action alternative but is
less costly than the excavation alternatives because of the reduced excavation costs.
9.1.7.2 Off-site Disposal
The cost estimates for each soil remedial alternative are detailed in Appendix C, Table C-3. The
alternatives with the least amount of construction and off-site disposal activity are the least costly
to implement. Alternative 1 is the least costly. Alternative 2 includes the largest amount of
excavation and disposal of impacted soils and therefore carries the highest cost. Alternative 3,
which proposes a mix of excavation and capping activities, is the next costliest alternative.
Finally, Alternative 4 (Capping of Soils) is higher in cost than the No Action alternative but is
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significantly less costly than the excavation alternatives because of the reduced waste disposal
costs.
9.2 SEDIMENT REMEDIAL ALTERNATIVES
The four sediment alternatives are:
• Sediment Alternative 1 - No Action;
• Sediment Alternative 2 - Removal of All Sediments to Cleanup Goals;
• Sediment Alternative 3 - Granular Material Sediment Cap;
• Sediment Alternative 4 - Engineered Bentonite Sediment Cap; and
• Sediment Alternative 5 - Monitored Natural Recovery.
A comparative evaluation of the five sediment alternatives is presented in Table 9.2 and
discussed below.
9.2.1 Overall Protection of Human Health and Environment
Alternative 1 and Alternative 5 are not protective of human health and the environment.
Alternative 2 is the most protective because it provides complete removal of the contaminants
from the environment where possible.
Alternatives 3 and 4 are slightly less protective than Alternative 2 because they eliminate the
exposure pathways of sediment contaminants rather than removing contaminants from the
environment.
9.2.2 Compliance with ARARs
There are no chemical-specific ARARs for sediments. However, there are TBC values (i.e.,
NYSDEC sediment screening values). Alternative 1 and Alternative 5 would not meet TBC
sediment screening values or be in compliance with TSCA.
Sediment removal in Alternative 2 would comply with TBCs and be in compliance with TSCA.
The excavation and backfilling work may result in short-term localized exceedences of surface
water criteria due to suspension of impacted sediment during excavation. However, the water
quality impacts from excavation would meet the substantive water quality requirements imposed
by NYS on entities seeking a dredged material discharge permit under Section 404 of the CWA.
Sediment caps in Alternatives 3 and 4 are routinely installed in compliance with ARARs and
TBCs, which would include the substantive requirements of the dredge and fill permit program
under Section 404 of the CWA.
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9.2.3 Long-Term Effectiveness and Permanence
Alternative 1 and Alternative 5 would not provide long-term effectiveness or permanence.
Alternative 2 provides the most long-term effectiveness and permanence because it permanently
removes all the contaminants in sediments.
Consistent with EPA design guidance for caps, the sediment caps and backfill areas associated
with Alternative 3 and 4 would be designed to withstand erosional forces resulting from the 100-
year return interval storm event. Institutional controls, such as bans on dredging the capped or
backfilled areas, would be implemented as necessary to help ensure the long-term integrity of
these barriers.
With the exception of Alternative 1, long-term monitoring and the implementation of a site
management plan would ensure the adequacy and reliability of these actions to control untreated
wastes that remain. Alternative 2 would require the least amount of long-term monitoring
because all of the contaminated sediments would be removed. Alternatives 3 and 4 would require
the most amount of long-term monitoring because most of the contaminated sediments would be
left in place. A site management plan would needs to be implemented under these alternatives to
ensure the effectiveness and permanence of the sediment caps.
9.2.4 Reduction of Toxicity, Mobility, or Volume through Treatment
Over a long period of time, natural processes would slightly reduce the toxicity, mobility, and
volume of contaminants in the soil under Alternative 1 and Alternative 5. However, they would
not be reduced significantly over time and Alternative 1 would not monitor or control these
processes.
In comparison with the other alternatives, Alternative 2 would reduce the toxicity, mobility, and
volume of impacted soils the greatest through extensive sediment excavation.
Alternatives 3 and 4 reduce the mobility of contaminants through sediment capping, but have
little effect on the toxicity and volume of contaminants.
9.2.5 Short-Term Effectiveness
The alternative with the least amount of physical construction and material movement
(Alternative 1) would have the lowest amount of short-term impacts on the environment.
Alternative 5 would have slightly more short-term impacts on the environment than Alternative
1, but monitoring activities have very low impacts.
Alternatives 2-4 would result in short-term habitat destruction and impact to local property
owners by either excavation or capping activities. Alternative 2 would have the most short-term
impacts because excavation activities would elevate short term risks for construction workers,
impact local property owners, and lead to the temporary loss of habitats. The capping of
sediments associated with Alternatives 3 and 4 would have slightly less short-term impacts than
the excavation of contaminated sediments proposed in Alternative 2.
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For all alternatives, the short-term impacts would be minimized or mitigated by exercising sound
engineering practices, following appropriate health and safety protocols, wearing proper PPE,
and adequate monitoring.
9.2.6 Implementability
No technical or administrative issues have been identified that would limit the feasibility of
implementing Alternative 1 or Alternative 5.
Appropriate sediment excavation technologies are readily available and implementable for
Alternative 2. The size and duration of the removal activities in Alternative 2 would present
more implementation challenges than the other alternatives.
Appropriate sediment capping technologies are readily available and implementable for
Alternatives 3 and 4.
Short-term and long-term monitoring as part of a site management plan for Alternatives 3 and 4
can be easily implemented to verify effectiveness. Additional remedial actions can readily be
undertaken, should the alternatives prove to be ineffective or partially ineffective.
9.2.7 Cost
For the granular/armor sediment capping alternative (Alternative 3), the requirements of 2 ft of
habitat material, armoring requirements, isolation thickness requirements, along with the need to
excavate additional sediments to maintain the bathymetry of the creek, causes this alternative to
be more expensive than the excavation alternative. The requirement of 2 ft of habitat material
above the engineered bentonite capping alternative (Alternative 4), along with the need to
excavate additional sediments to maintain the bathymetry of the creek also causes this alternative
to be more expensive than the excavation alternative (Alternative 2).
O&M costs for a sediment removal alternative will be lower than for implementation of a
capping alternative for an equivalent area, as removal-only alternatives do not require long-term
maintenance. O&M costs for a capping alternative will be higher than for a sediment removal
alternative involving the same areas because of site management costs and, to a lesser extent,
potential cap maintenance required in the long term.
9.2.7.1 On-site Disposal
The cost estimates for each sediment remedial alternative are detailed in Appendix C, Table C-2.
Alternative 1 is the least costly alternative, followed by Alternative 5. Although Alternative 2
includes the largest amount of excavation, the lack of required capping materials for backfill
leads to the overall cost of this alternative being less than the capping alternatives. Alternatives 3
and 4 (Capping of Sediments) are higher in costs than the other alternatives and very similar in
overall costs.
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9.2.7.2 Off-site Disposal
The cost estimates for each sediment remedial alternative are detailed in Appendix C, Table C-4.
Alternative 1 is the least costly alternative, followed by Alternative 5. Although Alternative 2
includes the largest amount of excavation, the lack of required capping materials for backfill
leads to the overall cost of this alternative being less than the Granular Material Cap Alternative
(Alternative 3) but slightly higher than the Engineered Bentonite Cap Alternative (Alternative 4).
Because Capping Alternative 4 requires less sediment removal than Capping Alternative 3, it has
a lower overall cost.
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HGL—Final FS Report—Lower Ley Creek Subsite of the Onondaga Lake Superfund Site, Syracuse, NY
10.0 REFERENCES
Canfield, R.H., 1941. Application of the Line Interception Method in Sampling Range
Vegetation. Journal of Forestry 39: 388-394.
EA Engineering, P.C., and EA Science and Technology (EA), 2010. Final Remedial
Investigation Report, Old Ley Creek Channel Site (7-34-074), Town of Salina, New York.
November.
Federal Remediation Technologies Roundtable (FRTR) Web Site. 1999. Information obtained
from http://www.frtr.gov.
Herbich, J.B., 2000. Handbook of Dredging Engineering. 2nd ed. New York: McGrawHill.
Honeywell, 2004. Onondaga Lake Feasibility Study Report. November
Lockheed Martin Scientific, Engineering, and Analytical Services (SERAS), 2012. SERAS Field
Activity Summary Report, Lower Ley Creek Superfund Site, WA # SER0007 - Trip
Report. January.
National Oceanic and Atmospheric Administration (NOAA), 2011. Annual Climate Report for
Syracuse, NY. Available at: http://www.nws.noaa.gov/climate/getclimate.php?wfo=bgm
New York State Department of Environmental Conservation (NYSDEC), 1990. Technical and
Administrative Guidance Memorandum 4030: Selection of Remedial Actions at Inactive
Hazardous Waste Sites. Available at:
http://www.dec.state.ny.us/website/der/tagms/prtg4030.html.
New York State Department of Environmental Conservation (NYSDEC), 2005. New York State
Revegetation Procedures Manual, Surface Mining Reclamation. May.
New York State Department of Environmental Conservation (NYSDEC), 2009a. Salina Landfill
Fact Sheet No. 5. A Sub-Site of the Onondaga Lake Superfund Site and NYS Superfund
Site Registry No. 7-34-036.
New York State Department of Environmental Conservation (NYSDEC), 2009b. Record of
Decision, Operable Unit 2 of the Geddes Brook/Ninemile Creek Site, Operable Un it 2 of
the Onondaga Lake Bottom Subsite, Onondaga Lake Superfund Site, Onondaga County,
New York. October.
New York State Department of Environmental Conservation (NYSDEC), 2011. Record of
Decision, Crouse-Hinds Landfills, State Superfund project, Syracuse, Onondaga County,
Site No. 734004. March.
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Palermo, M., S. Maynard, J. Miller, and D. Reible, 1998. Guidance for In-Situ Subaqueous
Capping of Contaminated Sediments. USEPA 905-B96-004, Great Lakes National
Program Office, Chicago, Illinois. September.
Remediation Technologies Network Remediation Information Management System (RIMS)
Database. 2000. Owned and Operated by the Research Technologies Network, L.L.C.
provided on http://www.enviroglobe.com.
TAMS Consultants, Inc. 2002. Onondaga Lake Remedial Investigation Report. Prepared with
YEC, Inc. for NYSDEC, Division of Environmental Remediation, Albany, New York
U.S. Army Corps of Engineers (USACE), 1994. Hydraulic Design of Flood Control Channels.
EM 1110-2-1601, US Government Printing Office, Washington, D.C.
U.S. Army Corps of Engineers (USACE), 1998. Guidance for Subaqueous Dredged Material
Capping. Technical Report DOE-1, Washington, D.C. June.
U.S. Environmental Protection Agency (EPA), 1988. Guidance for Conducting Remedial
Investigations and Feasibility Studies under CERCLA, Interim Final. EPA 540/G-89/004,
OSWER 9355.3-01. Available at:
http://www.epa.gov/superfund/resources/remedv/pdf/540g-89004-s.pdf
U.S. Environmental Protection Agency (EPA), 1993. Selecting Remediation Techniques for
Contaminated Sediment. EPA/823/B93/001. June.
U.S. Environmental Protection Agency (EPA), 1994. Assessment and Remediation of
Contaminated Sediments (ARCS) Program Remediation Guidance Document. Great
Lakes National Program Office. EPA-905-B94-003.
U.S. Environmental Protection Agency (EPA), 1999. The Superfund Innovative Technology
Evaluation (SITE) Program: Technology Profiles, Tenth Edition. EPA/540/R-99/500.
U.S. Environmental Protection Agency (EPA), 2000a. Hazardous Waste Clean-up Information
(CLU-IN) Web Site. Provided at http://www.clu-in.org.
U.S. Environmental Protection Agency (EPA), 2000b. Remediation and Characterization
Innovative Technologies (USEPA REACH IT) Database (includes VISITT; Vendor
FACTS; and ITT). Provided at http://www.epareachit.org.
U.S. Environmental Protection Agency (EPA), 2002. A Guide to Developing and Documenting
Cost Estimates During the Feasibility Study. Office of Emergency and Remedial
Response. EPA 540-R-00-002. OSWER 9355.0. Available at
http://www.epa.gov/superfund/resources/remedv/-finaldoc.pdf
U.S. Environmental Protection Agency (EPA), 2005. Contaminated Sediment Remediation
Guidance for Hazardous Waste Sites. EPA-540-R-0-/012. December.
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U.S. Environmental Protection Agency (EPA), 2007. Demonstration of the Aquablok® Sediment
Capping Technology, Innovative Technology Evaluation Report. EPA/540/R-07/008.
U.S. Environmental Protection Agency (EPA), 2009. Regional screening levels for chemical
contaminants at Superfund sites. Summary table. Available at:
http://www.epa.gov/reg3hwmd/risk/human/rb-concentration table/index.htm
U.S. Environmental Protection Agency (EPA), 2013. Ecoregions of North America, available at,
http://www.epa.gov/wed/pages/ecoregions/na eco.htm. Accessed on November 25,
2013.
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FIGURES
-------
HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Lower
Liverpool
Galeville
Lakeland
Onondaga
Lake
Lyncourt
Solvay
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Legend
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City Limit
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Figure 2.1
Site Location
General Location
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Syracuse
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NEW
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Lower Ley Greek Subsite of Onondaga Lake, Syracuse, NT
Figure 2.3
Location of Pipelines,
Floodplain, and Wetlands
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Soil Boundary
Surface Water Course
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Highway
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HGL—FS Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NT
Figure 2.4
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Figure 2.5
Upstream, Middle,
and Downstream Sections
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Legend
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Highway
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and Former Landfill Parcel
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Middle
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Figure 2.6
Cross Section Locations
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HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
A'#
385 —
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375 —
Q
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0-
Chemical Name
Benzo(a)pyrene
Total Chromium
Result
Unit
Starting
Biding
Chemical Name
Result
Result
Unit
0
0,5
Benzo(a)pyrene
4000
ug/kg
Starting
Depth (ft)
Ending
Depth (ft)
Chemical Name
Total Chromium
Starting
Depth (ft)
Ending
Depth (ft)
Chemical Name
Result
Result
Unit
0.5
1
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51
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Starting
Depth (ft)
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Depth (ft)
Chemical Name
Result
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Unit
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Starting
Depth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
4
8
Aroclor-1248
1400
ug/kg
4
8
Mercury
0.31
mg/kg
Starting
Depth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
4
8
Aroclor-1248
7600
ug/kg
4
8
Benzo(a)pyrene
180
ug/kg
4
8
Total Chromium
14.2
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4
8
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Starting
Depth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
4
8
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ug/kg
4
8
Aroclor-1248
170
ug/kg
4
8
Aroclor-1254
140
ug/kg
4
8
Benzo(a)pyrene
4800
ug/kg
4
8
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12
mg/kg
370 —
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Starting
Depth (ft)
Ending
Depth (ft)
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Mercury
Starting
Depth (ft)
Ending
Depth (ft)
Result
Unit
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Benzo(a)pyrene
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Depth (ft)
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Result
Unit
Depth (ft)
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1
2
4,4'-DDT
3000
ug/kg
1
2
Aroclor-1248
300000
ug/kg
1
2
Aroclor-1254
140000
ug/kg
S
De
arting
pth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
12
14
Mercury
0.012
mg/kg
Chemical Name
kU S J' Li. ^ > -J*
Starting
Depth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
12
14
Total Chromium
7.2
mg/kg
12
14
Mercury
0.015
mg/kg
Starting
Depth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
8
12
Aroclor-1248
520
ug/kg
8
12
Total Chromium
24
mg/kg
350-
50
100
150
200
250
m
10
300
Distance (ft)
350
400
450
500
550
¦355
¦350
600
25
50
100
Vertical Scale in Feet
Horizontal Scale in Feet
WGST-SR V-01 \hglgisley_Creek\_MSIW\FS\
Cross_section_A-A '.cdr
12/19/2013 CNL
Source: HGL, EA Engineering
^DSr^
~ HGL
~ HydroGeoLogic, Inc
Boring
SB-17 Sample Location Identification
Lithology Boundary
Legend
Stratigraphy Type:
Top Soil
Fill Material
Peat
Silt and Organics
Silt and Clay
Silt and Sand
WF-(
Notes:
Included data tables represent maximum
concentrations of major risk drivers
Till per boring location.
Highlighted data indicate concentrations
above cleanup goals.
jj,g/kg=micrograms per kilogram
mg/kg=milligrams per kilogram
amsl=above mean sea level
ft=feet
Figure 2.7
Old Ley Creek
N orthea st-Southwest
Cross Section A-A1
-------
HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
B'#
385 —
%
%¦
A
380 —
375 —
370 —
a
o
C3
w
365-
360 —
355 —
350-
Starting
Depth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
0.5
1
4,4'-DDE
1500
ug/kg
0.5
1
4,4'-DDT
1300
ug/kg
0.5
1
Aroclor-1248
100000
ug/kg
0.5
1
Benzo(a)pyrene
4400
ug/kg
0.5
1
Total Chromium
3250
mg/kg
u
1
Starting
Depth (ft)
Ending
Depth (ft)
Chemical Name
Result
Result
Unit
1
2
Mercury
0.5
mg/kg
<0
a
M
-=-=-=-^^P
Starting
Depth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
0
0.5
4,4'-DDE
1600
ug/kg
0
0.5
4,4'-DDT
1600
ug/kg
0
0.5
Aroclor-1248
94000
ug/kg
0
0.5
Total Chromium
2680
mg/kg
Starting
Depth (ft)
Ending
Depth (ft)
Chemical Name
Result
Result
Unit
0.5
1
Mercury
0.79
mg/kg
Starting
Depth (ft)
Biding
Depth (ft)
Chemical Name
Result
Result
Unit
1
2
Benzo(a)pyrene
3400
ug/kg
7.^-i ,
p.i
'o
Jcr
St
-------
HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Entrance of Old Ley Creek
/
Creek Level (Not to Scale)
-------
HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
"r—l~""~—
—T7r.ni: —-mi—— ~-ii: tt7.hl:
~~ E :iizirf-±zi^ pi
- ™ 2™
Benzo(a)pyrene
WGST-SR V-01 \hglgisXLey_Creek\_MSIWXFS\
Cross section _D-Dcdr
1/13/2014 CNL
Source: HGL
HGL
HydroGeoLogic, Inc
R3-11
Boring
Sample Location
Identification
Legend
Lithology Boundary
Estimated Extent of Sediment above
Cleanup Goals
Stratigraphy Type:
Sand/Silt and Organics
Silt and Clay
Notes:
Included data tables represent
maximum concentrations of major
risk drivers per boring location.
Additional information is provided
for deeper borings.
Highlighted data indicate concentrations
above cleanup goals.
jig/kg=micrograms per kilogram
mg/kg=milligrams per kilogram
ND=not detected
ft=feet
Figure 2.10
Lower Ley Creek
Southern Upstream
Cross Section D-D'
Vertical Scale in Feet
1000
Distance (ft)
2400
100
Horizontal Scale in Feet
2000
2200
Creek Level (Not to Scale)
-------
HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
E * Creek Level (Not to Scale)
Starting
Depth
(ft)
Biding
Depth
(ft)
Cem
ical Nam e
Res.,
Result
Unit
0
0.5
8.
.g
"3
u
S
£
£
£
,2
£
I
I
w
.75
Starting
Ending
Res I
—
Depth
(ft)
Depth
(ft)
Chemical Name
Result
Unit
1.5
2
Aroclor-1242
4600
ug/kg
1.5
2
Total Chronium
386
mg/kg
1.5
2
Mercury
0.28
mg/kg
1.5
# # # #
StSSfSSfpT1 ¦ "f ¦"¦ ¦¦¦¦¦¦¦ ¦jS^SS?*
* eh^e:^ ee^ze-^ ih
Starting
Depth
(ft)
I—J I
V
m: —_ini777iii: — 11
5=^==h==-^h^e:
Depth
(ft)
Depth
(ft)
Cemiea.Name
Res.,
Unit
0
0.5
Benzo(a)pyrene
1100
ug/kg
Depth
Depth
Chemical Name
Result
Result
(ft)
(ft)
0.5
1
Mercury
0.16
mg/kg
Starting
Ending
Result
(ft)
(ft)
Unit
1.5
2
Aroclor-1242
3800
ug/kg
1.5
2
Total Chromium
404
mg/kg
Depth
(ft)
Depth
(ft)
Chemical Name
Res.,
Unit
0
0.5
Total Chromium
52.4
mg/kg
0
0.5
Mercury
0.064
mg/kg
0
0.5
Aroclor-1242
420
ug/kg
0
0.5
Benzo(a)pyrene
650
ug/kg
0.5
1
96.6
0.5
1
Mercury
0.15
mg/kg
0.5
1
Aroclor-1242
3300
ug/kg
0.5
1
Aroclor-1248
3400
ug/kg
0.5
1
Benzo(a)pyrene
1500
ug/kg
1.5
2
602
1.5
2
Mercury
0.32
mg/kg
1.5
2
Aroclor-1242
15000
ug/kg
1.5
2
Aroclor-1248
26000
ug/kg
1.5
2
Benzo(a)pyrene
1700
ug/kg
2.5
3
176
2.5
3
Mercury
0.59
mg/kg
2.5
3
Aroclor-1248
260
ug/kg
2.5
3
Benzo(a)pyrene
200
ug/kg
3.5
4
12.2
3.5
4
Mercury
MD
mg/kg
3.5
4
Aroclor-1248
310
ug/kg
3.5
4
Benzo(a)pyrene
65
ug/kg
4.5
5
46.1
4.5
5
Mercury
MD
mg/kg
4.5
5
Aroclor-1248
600
ug/kg
4.5
5
Benzo(a)pyrene
96
ug/kg
5.5
6
17
5.5
6
Mercury
MD
mg/kg
5.5
6
Aroclor-1248
17
ug/kg
5.5
6
Benzo(a)pyrene
10
ug/kg
1000
Distance (ft)
Vertical Scale in Feet
Horizontal Scale in Feet
400
WGST-SR V-01 \hglgis\Ley_Creek\_MSIW\FS\
Cross_section_E-E '.cdr
1/13/2014 CNL
Source: HGL
*•- _ v,
HGL
HydroGeoLogic, Inc
Legend
R2-17
Boring
Sample Location
Identification
Lithology Boundary
Estimated Extent of Sediment above
Cleanup Goals
Stratigraphy Lvpe:
Sand/Silt and Organics
Silt and Clay
Notes:
Included data tables represent
maximum concentrations of major
risk drivers per boring location.
Additional information is provided
for deeper borings.
Highlighted data indicate concentrations
above cleanup goals.
jig/kg=micrograms per kilogram
mg/kg=milligrams per kilogram
ND=not detected
ft=feet
Figure 2.11
Lower Ley Creek
Middle Section
Cross Section E-E'
-------
HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
.75
8.
.g
"3
u
S
¦9
03
£
£
O
d
o
03
>
w
1.5
Onondaga Lake
1-81 Crossing
1.5 —
3 —
4.5
6 —
7.5
9 —
10.5
Creek Level (Not to Scale)
Starting
Depth
(ft)
Ending
Depth
(ft)
Starting
Depth
(ft)
Ending
Value
Value
Benzo(a)pyrene
Benzo( a) pyrene
Mercury
Starting
Depth
(ft)
Ending
Depth
(ft)
Value
Starting
Ending
Depth
(ft)
Mercury
Result
Value
Starting
Ending
Aroclor-1242
Chemical Name
Starting
Depth
(ft)
Ending
Depth
(ft)
Result
Unit
Benzoialpyrene
Chemical Name
Total Chromium
Benzo(a)pyrene
Aroclor-1242
Total Chromium
Benzoialpyrene
Starting
Depth
(ft)
Ending
Depth
(ft)
Total Chromium
rg/kg
Result
Unit
Starting
Depth
(ft)
Ending
Depth
(ft)
Mercury
Chemical Name
Value
Mercury
Benzoialpyrene
Starting
Depth
(ft)
Ending
Depth
(ft)
Total Chromium
Result
Value
Mercury
Benzo(a)pyrene
Starting
Depth
(ft)
Ending
Depth
(ft)
Result
Unit
Starting
Depth
(ft)
Biding
Depth
(ft)
Starting
Depth
(ft)
Ending
Depth
(ft)
Result
Value
Value
Mercury
Benzo(a)pyrene
Starting
Depth
(ft)
Ending
Depth
(ft)
Result
Unit
Chemical Name
Benzo(a)pyrene
Mercury
Benzo(a)pyrene
Mercury
Benzo(a)pyrene
Starting
Depth
(ft)
Ending
Depth
(ft)
Starting
Depth
(ft)
Ending
Depth
(ft)
Result
Unit
Chemical Name
Chemical Name
Mercury
Mercury
Benzo(a)pyrene
Aroclor-1248
Benzo(a)pyrene
Mercury
Mercury
Aroclor-1248
Benzo(a)pyrene
Total Chromium
Mercury
Aroclor-1248
Benzoialpyrene
Total Chromium
Mercury
Aroclor-1248
Benzoialpyrene
1500
Distance (ft)
8.
'"3
C3
£
£
O
o
c3
>
w
—10.5
150
300
600
Vertical Scale in Feet
Horizontal Scale in Feet
WGST-SR V-01 \hglgis\Ley_Creek\_MSIW\FS\
Cross_sectio n_F-F '.cdr
1/13/2014 CNL
Source: HGL
Legend
s-- _ s
V
HGL
HydroGeoLogic, Inc
R2-7
Boring
Sample Location
Identification
Lithology Boundary
Estimated Extent of Sediment above
Cleanup Goals
Stratigraphy Lvpe:
Sand/Silt and Organics
Silt and Clay
Notes:
Included data tables represent
maximum concentrations of major
risk drivers per boring location.
Additional information is provided
for deeper borings.
Highlighted data indicate concentrations
above cleanup goals.
jig/kg=micrograms per kilogram
mg/kg=milligrams per kilogram
ND=not detected
ft=feet
Figure 2.12
Lower Ley Creek
Downstream Section
Cross Section F-F'
-------
Area
£
ll7cDr32
SB-1508 ¦
SW-5
SP-03 I
SP-02
Creek
LLCD-28
LLCD-40
LLCD-29
7 ' ..
rw./
SP^-04
SW-2
LLCD-25
""-O
/\ ••• '• ¦
SP-01
m
LTB&JWsk*
LLCD-34
S6-1501
SB-1502
LLCD-38
LLCD-39
LLCD-21
Area Inset
SS 03
i J-1 K . ; . - §g|
SS 04
„ 1
3/ / SS 07 km
' v- ' ~~.ss" / -
/ SS 26
SS 09
SS 06
SS 24
Alliance Bank
Stadium
SS 29
LLCD.-1
SS 1
SS 30
LLCD-2
SS 17,
\
I SS 31
SS 28
N
JfW\J ' 7
*
370
X ?< 1,000-5,000
O >5,000-10,000
0 >10,000-250,000
>250.000
O
SP-04 Sample Location Identification
Surface Water Course
Road
L Highway
—1—f- Railroad
Notes:
Highest result (aroclor-1242, aroclor-1248, aroclor-1254, or aroclor-1260)
is used for concentration value.
}ig/kg=micrograms per kilogram
PCB=polychlorinated biphenyl
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-13)PCB_Surface. mxd
7/3/2013 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
~ HGL
™ HydroGeoLogic, Inc
-------
SB 1507 SB-1506
2 5 - 3 ft
See Area Inset
SB-1508
2.5 - 3 ft
„o
SB-1509
4.5 - 5 ft
SB-1510
i
IS
SB-T4A
SB-15o/ ,00^
\ '
SB-1504
SB-T1A
SB-1500
SB-1503
4.5-5 ft SB-1501 25-3'ft
4.5 - 5 ft ^ ' A g v
HH i
¦f
m m
m*sk
%
Area Inset
SB 01
4 - 8 fl
SB 04
4- 8 ft
SB05B
SB 03
SB 05
SB05A^\ 0 - 4 ft
2 - 4 ft.
SB 09
SB 05C
4- 8 ft
2 - 4 ft
SB 08
4 - 8 fi
SB 07
4 - 8 ft
OCCCMW-3
2 - 6 ft
SB 11
4-8 ft
¦
OLCCMW-1
SR 10
2-6ft
Alliance Bank
Stadium
*
4 - 8 ft
OLCCMW-2
2 - 6 ft
Sg*SBjl3 4"e fl
SB 17 4- 8 ft
4 - 8 ft
' ,'t SB 16
SB 19 4,8ft
0 - 4 fi
SB i 5
1 Pi 3
L40C
370)
T
HGL—l-'S Report
Lower Ley Greek Sabsite of Onondaga Lake, Syracuse, NT
Figure 2.14
Lower Ley Creek and Old Ley Creek
PCB Concentrations
in Shallow Subsurface Soil
Legend
PCB Concentrations at Soil Sample Locations (|iig/kg):
O <1,000
O >1,000-5,000
O >5,000-10,000
0 >10,000-250,000
>250.000
O
SB-04 Sample Location Identification
4 - 8 ft Depth (Starting - Ending) in feet
Surface Water Course
Road
Highway
-i—' Railroad
Notes:
Highest result (aroclor-1242, aroclor-1248, aroclor-1254, or aroclor-1260)
is used for concentration value.
jj.g/kg=micrograms per kilogram
PCB=polychlorinated biphenyl
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-14)PCB_Shallow. mxd
7/3/2013 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
seo s ta
pro*
~ HGL
™ Hydro Geo Logic, Inc
-------
m
¦m m
SB 01
12 -14 ft
SB 04
23 4ft
$
SB 09
8- 12ft
; am*
r, MH
OCCCMW-3
10 - 14 ft
SB i;
8- 12ft
JMflf
OliCCMW;1
SB 10
10 - 1 -4 ft
SB 12
12 - 14 ft
SB 3
SB 7
8- 2ft
SB 20
SB 16
12 -14 ft
SB 8
*Bfl
6-12 11
SB 1b
8- 12ft
'1,000-5,000
O >5,000-10,000
0 >10,000-250,000
>250.000
O
SB 04 Sample Location Identification
12 -14 ft Depth (starting - ending) in feet
Surface Water Course
Road
Highway
n—' Railroad
Notes:
Highest result (aroclor-1242, aroclor-1248, aroclor-1254, or aroclor-1260)
is used for concentration value.
fj.g/kg=micrograms per kilogram
PCB=polychlorinated biphenyl
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-15)PCB_Deep. mxd
7/3/2013 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
seo s ta
pro*
~ HGL
™ HydroGeoLogic, Inc
-------
See Area Inset
cS
SW-5
SB-1501
SW-6
SP-05
a
a?
¦ B3
LLCD-40
P£Mi ¦?
LLCD-25
38- 500
rd^WM
G°
LLCD-35
SW-3 N
LL CD-44
L" m \»jmr
WICD-27
SB-T4A
SW-2
SP-01 -
LLCD-21 >
Area
LLCD-17
LLCD-14 X
/
I Hi P
I
SS10 /SS2Q//
SS 30
.LCD-
Alliance Bank
N ^Stadium
SS 31
LLCD-2
P
\
I SS 16
mm
r f
SS 4
SS 18
SS 19
tr
x
370)
Feetgg
EBflMi
HGL—FS Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NT
Figure 2.16
Lower Ley Creek and Old Ley Creek
Mercury Concentrations
in Surface Soil
(0-2 Feet Below Ground Surface)
Legend
Mercury Concentrations at Soil Sample Locations
(mg/kg):
o
<0.18
O
>0.18-0.4
O
>0.4-0.8
o
>0.8-2.8
O
>2.8
SP-04 Sample Location Identification
Surface Water Course
Road
L Highway
—1—f- Railroad
Note:
mg/kg=milligrams per kilogram
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-16)Mercury_Surface. mxd
12/20/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
See Area Inset
SW-5
2.523 ft
£
SB-1501
4.5 - 5 ft
SB-T4A
MeyZCreekm
•3?.
H
03
4.5 - 5 ft
¦ A--*' I
M_ I
IB
¦ " aSL ' SIKce^BRBk 0"s
t linn i^^iUlliTi i
L.LCD-25
LLCD-49
7 -'8 ft
3-4ft
SB-T2A
I
SB-1500
\
\tj / SE»«flS« ¦
2.5 - 3 ft
3 - 3.5 ft
SB-Ti1A ...
4.5 - 5 ft
"
SB-T3A
$
2.5 - 3. ft
7/ JfJ
/ > • !
Area Inset
SB 04
SB 01
4 - 8 ft
SB 05E
SB 08
SB 05
4 - 8 fl
SB 03 m
ImozA'tt
4 - 8 ft
SB 09
4 - 8 ft
SB 05A
SB 05C
2 - 4 ft
2 - 4 fl
SB 06
4 - 8 ft
OCCCMW-3
SB 07
4 - 8 ft , SB.1'
2 - 6 ft
Jfgr j .
w
/ 4 - 8 ft
OLCCMW-1/
SB 10
2 - 6 ff
4 - 8 ft
J Alliance Bank
J Stadium
..1 ¦ \- *
/
J tJi/ JSMi
OLCCMW-2
6- 10ft
4 - 8 ft
4-8ft SB 14
SB 17
4- 8 fl
4-8 ft
SB 16
SB 20
SB 19
4 - 8 ft
4-8 ft
SB 15
0 - 4 ft
4 - 8 ft
mmEM
aii
1.40C
370)
Feet
X
. .~< -
HGL—l-'S Report
Lower Ley Greek Sabsite of Onondaga Lake, Syracuse, NT
Figure 2.17
Lower Ley Creek and Old Ley Creek
Mercury Concentrations
in Shallow Subsurface Soil
Legend
Mercury Concentrations at Soil Sample Locations
fmg/kg):
O <0.18
O >0.18-0.4
O >0.4-0.8
^ >0.8-2.8
>2.8
o
SB 01 Sample Location Identification
4 - 8 ft Depth (starting - ending) in feet
Surface Water Course
Road
= Highway
-1—f- Railroad
Note:
mg/kg=milligrams per kilogram
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-17)Mercury_Shallow. mxd
12/20/2013 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
seo s ta
pro*
~ HGL
™ Hydro Geo Logic, Inc
-------
SB 01
12-.14 ft
SB 04
JME1
SB 03 12 -1411
8- 12ft
SB 05
12 -14 ft
SB 09
8- 12 ft
^¦SB08
8- 12 ft
¦
JSBT06
8- 12 ft
SB 07
8- 12ft
H fifil
r 7
OCCCMW-3
10 -14 ft
SB 11
SB 10
/ 8 - 12 ft / ! 0 - 14 ft
OtlCCMW^I
t m /*¦ ^
f.y.
'v_
OLCCMW-2
SB 13
SB 14
SB 17
12 - 14 ft
SB 16
SB 20
SB 18
8 12 ft
12 -14 ft
12 - 14 ft
SB 15
12 - 14 ft
-fft
T T
//G£—FS" Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NT
Figure 2.18
Old Ley Creek
Mercury Concentrations
in Deep Subsurface Soil
Legend
Mercury Concentrations at Soil Sample Locations
fmg/kg):
O <0.18
O >0.18-0.4
O >0.4-0.8
O >0.8-2.8
>2.8
SB 01 Sample Location Identification
12 -14 ft Depth (starting - ending) in feet
Surface Water Course
Road
Highway
¦ '—Railroad
Note:
mg/kg=milligrams per kilogram
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-18)Mercury_Deep. mxd
12/20/2013 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
seo s ta
pro*
~ HGL
™ HydroGeoLogic, Inc
-------
See Areatlnset
500-1,000
O >1,000-2,000
O >2,000-6,000
>6,000
O
SP-04 Sample Location Identification
Surface Water Course
Road
L Highway
—1—f- Railroad
Note:
jLig/kg=micrograms per kilogram
\ \gst-srv- 01 Xhglgis \Ley_C reek\_MSI W\FS\
(2-19)Benzo (a) pyrene Surface, mxd
7/3/2013 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
See Area Inset
„o
* - m L'e wC reeK®
k
LLCD-25
7 *S
- JDVfcSI
\£ j I -ASon
4-5 ft
LLCD-49
3 - 4 ft
x 'A -- . ->
EK£
- • rfer
m
% m
L2 -3
Area Inset
@@®S
HKrl
OCCCMW-3
SB 10
4 - 8 ft
Alliance Bank
Stadium
OLCCMW
y- * V'jii
SB 19
0 - 4 ft
370)
Feetgg
X /.
HGL—l-'S Report
Lower Ley Greek Sabsite of Onondaga Lake, Syracuse, NT
Figure 2.20
Lower Ley Creek and Old Ley Creek
Benzo(a)pyrene Concentrations
in Shallow Subsurface Soil
Legend
Benzo(a)pvrene Concentrations at Soil Sample
Locations (jjg/kgJ:
<500
O >500-1,000
O >1,000-2,000
O >2,000-6,000
>6,000
O
SB 01 Sample Location Identification
4 - 8 ft Depth (starting - ending) in feet
Surface Water Course
Road
Highway
-1—f- Railroad
Note:
fig/kg=micrograms per kilogram
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-20)Benzo(a)pyrene_Shallow. mxd
7/3/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
_ SB 05
¦SOf12ft
¦
V. • HfiT
: ' /
- VI
* >y _-Xj
1-V '.' V: " v » - > '
;£» A M >VV5;ft
~ v
PHI
SB 12 ,
pyfl^i2ft ,
. - V
/J H&*
G*
¦,' ¦ - 'i
' # # 73
,w
r,<
St
Q)
> 1 !Jw
7VT/A
Wa
I®HO
//(//.—/\V Report
Lower Ley Greek Sabsite of Onondaga Lake, Syracuse, NT
Figure 2.21
Old Ley Creek
Benzo(a)pyrene Concentrations
in Deep Subsurface Soil
Legend
Benzo(a)pvrene Concentrations at Soil Sample
Locations (jjg/kgJ:
O <500
O >500-1,000
O >1,000-2,000
O >2,000-6,000
>6,000
SB 04 Sample Location Identification
12 -14 ft Depth (starting-ending) in feet
Surface Water Course
Road
Highway
-t—t- Railroad
Note:
fj.g/kg=micrograms per kilogram
HL/
V
-m.' • v *r —
f
N
WW&MA
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-21 )Benzo(a)pyrene_Deep. mxd
7/3/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
50 100
V,k\ f
A'
STAf]
5t prO"^
~ HGL
3T HydroGeoLogic, Inc
-------
See Area Inset
tfeyjCreekGM
¦Hcd-28 ^
LLCD
o
00
7 ^
H*®! T^vfrX J"7fess.""¦>!>¦*
«. "^SSr*^SL
3*3 LLCD-44
LLCD
SB-T1A
SB-1500
SB-T4A
LLCD-27
• ^fcrf'ZFV' I
n>JT
LLCD
LLCD-21
f9f LLCD-17
J-tt
LLCD-13
LLCD-14
s ? * iK
'i.+ 4 1 rj
Sv#
SS 22 ~~
SS 23
llcd-1 J Alliance Bank
Stadium
ftr jh
8
LLCD-2
>
IKiSifl
SS 31 I
Z_i
370
//(//.—/\V Report
Lower Ley Greek Sabsite of Onondaga Lake, Syracuse, NT
Figure 2.22
Lower Ley Creek and Old Ley Creek
Total Chromium Concentrations
in Surface Soil
(0-2 Feet Below Ground Surface)
Legend
Total Chromium Concentrations at Soil Sample
Locations (mg/kg):
O <41
O >41-100
O >100-400
O >400-1,500
>1,500
SP-04 Sample Location Identification
Surface Water Course
Road
L Highway
—1—f- Railroad
Note:
mg/kg=milligrams per kilogram
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-22)Chromium_Surface. mxd
12/20/2013 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online BingMaps Aerial
~ HGL
™ Hydro Geo Logic, Inc
-------
See Area Inset
SW-5
SB- 50
2.5 - 3 ft
tlSeylCreeKiH
SB-T4A
4.5 - 5 ft
m
03
J
i
LLCD-25
LLCD-49
SB- T3A
7 7'6" x
SB-1500
4.5 - 5 ft
' \ ' '
' / ¦ -
. 2.5-3ft
SB-T1A
4.5 - 5 ft
xi
LLCD-27
4- 5 ft
\
AM
a- mm
"¦{¦£{ fl
. - .
SB 04
SB 01
4 - 8 ft
4 - o ft
SB 05B
x
/
2 - 4 ft
!£! M
- #u ' 1 , , •
SB 09
SB 03
SB 05
4 - 8 ft
0 - 4 ft
SB05A
4 - 8 ft
2 - 4 ft
SB 05C
2 - 4 ft
SB 06
SB 08
4 - 8 ft
HON ' « I
¦¦^OCCCMW-3
4-8 ft
SB 07
4- 8 ft
SB 11
OLCCMW-1
SB 10
4 - 8 ft
2 - 6 ft
4 - 8 ft
;rVv r-Vhf.
/ Alliance Bank
I Stadium
OLCCMW-2
6-10 ft
4-8 ft
SB 3
4-8 ft
SB 4
<3
f 4-8ft
SB 1 J ¦
4"?8 ft
SB 19
SB 20
4- 8 ft
4 - 8 ft
SB 15
mwm
»- nr*
, i
- / /
SB 16
4?8ftl
/
heet
HGL—l-'S Report
Lower Ley Greek Sabsite of Onondaga Lake, Syracuse, NT
Figure 2.23
Lower Ley Creek and Old Ley Creek
Total Chromium Concentrations
in Shallow Subsurface Soil
Legend
Total Chromium Concentrations at Soil Sample
Locations (mg/kg):
O <41
O >41-100
O >100-400
O >400-1,500
>1,500
SB 04 Sample Location Identification
4 - 8 ft Depth (starting - ending) in feet
Surface Water Course
Road
Highway
-t—i- Railroad
Note:
mg/kg=milligrams per kilogram
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-23)Chromium_Shallow. mxd
12/20/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
seo s ta
pro*
~ HGL
™ Hydro Geo Logic, Inc
-------
SB 05
8- 12ft
SB 09
8- 2ft
OCCCMW
¦¦¦
OUCCMW
OLCCMW
SB 12
8- 12ft
*. V 7
¦ i - '-LI7.
IB
;
* *' tF#
IBM
*
//G£—FIS1 Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NT
Figure 2.24
Old Ley Creek
Total Chromium Concentrations
in Deep Subsurface Soil
Legend
Total Chromium Concentrations at Soil Sample
Locations (mg/kg):
O <41
O >41-100
O >100-400
O >400-1,500
>1.500
o
SB 04 Sample Location Identification
12 -14 ft Depth (starting - ending) in feet
Surface Water Course
Road
Highway
is—i~ Railroad
Note:
mg/kg=milligrams per kilogram
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(2-24)Chromium_Deep. mxd
12/20/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Primary Sources
Primary Release
Secondary Sources
Secondary Releases
Media
Exposure Route
Receptors
Excavation of
Sediment and
Placement of
Spoils Along
Edge of Lower
Ley Creek
Historical Discharge
to Lower Ley Creek
from Upstream and
Adjacent Properties
Fish
Sediment
Soil
Ingest ion
Dermal Exposure
Dermal Exposure
Fish Ingestion
Ingestion
Surface
Water
Surface Water
Sediment
Solids and Liquids
from Historical
Discharge
Recreational Visitor-Adult
Recreational Visitor-Older Child
Recreational Visitor-Younger Child
Recreational Visitor-Adult
Recreational Visitor-Older Child
Recreational Visitor-Younger Child
Construction Worker-Adult
Recreational Visitor-Adult
Recreational Visitor-Older Child
Recreational Visitor-Younger Child
Construction Worker-Adult
Recreational Visitor-Adult
Recreational Visitor-Older Child
Recreational Visitor-Younger Child
Construction Worker-Adult
Recreational Visitor-Adult
Recreational Visitor-Older Child
Recreational Visitor-Younger Child
Construction Worker-Adult
WGST-SRV-01 \hglgis\Ley_Creek\_MSIW\FS\
CSM-HHR.cdr
7/3/2013 CNL
Source: HGL
HGL
Figure 3.1
Conceptual Site Model for
Human Health Risks
-------
HGL—FS Report—Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Primary Sources
Primary Release
Media
Receptors
Pathways
Historical Discharge
to Lower Ley Creek
from Upstream and
Adjacent Properties
J
V
Release of Solids and
Liquids to Lower
Ley Creek through
Surface Flow, Seeps,
Groundwater, and
Erosion
A
Sediment
Surface Water
Interstitial Water
V
Biota
Aquatic
- Aquatic Plants
- Benthic Invertebrates
- Fish
Bird/M animals
- Belted Kingfisher
- Great Blue Heron
- M ink
- River Otter
Aquatic Plants
- Direct Contact with Sediment and Surface
Water
Benthic Invertebrates
- Direct Contact with Sediment and
Interstitial Water
- Ingestion of Biota and Sediment
Fish
- Direct Contact with Surface Water
- Ingestion of Biota and Sediment
Bird/Mammals
- Direct Contact with Surface Water
- Ingestion of Biota (Including fish) and Surface Water
Incidental Ingestion of Sediment
WGST-SRV-01 \hglgis\Ley_Creek\_MSIW\FinalRI\
CSM-ER.cdr
7/3/2013 CNL
Source: HGL
HGL
Figure 3.2
Conceptual Site Model for
Ecological Risks
-------
140
120
100
Discharge (cfs)
o
o
O
O
o
o
*—1
o
tH
o
r-H
o
CM
O
CvJ
O
CNJ
o
m
o
ro
o
ro
O
O
O
o
LO
O
LO
o
LO
o
CD
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CD
o
CD
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o
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o
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o
00
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o
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cn
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o
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c
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ro
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Q.
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ro
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ro
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ro
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-
ro
Date
Q_
QJ
CO
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ro
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ro
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a;
CO
c
ro
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2
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ro
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ro
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CD
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c
ro
>-
ro
Q.
O)
CO
11GST-SR V-01 \hglgis\ley_CreeM\_MSMWS
Streamflow _2000-10.cdr
7/3/2013 CNL
Source: HGL
V
HGL
Figure 4.1
Lower Ley Creek
Streamflow Monthly Mean
2000-2010
-------
1600
1400
1200
J£ 1000
TJ
C
O
800
600
400
200
~ Discharge (cfs)
~ ~
~ ~ ~
h-
cn
UD
Is*
cn
00
cn
00
cn
id
oo
cn
oo
oo
cn
o
cn
cn
cn
cn
to
cn
cn
oo
cn
cn
o
o
o
CNJ
f\l ro ^ in
o o o o
o o o o
(M (N fM (N
00
o o
o o
CN CM
cn o
O tH
o o
(N rsi
rHfNrHfNrO'sJ-LnkDr^OOCnO^HfN
I rH t—I t—I r-l
Date
WGST-SR V-01 \hglgis\Ley_Creek\_MSIW\FS\
Streamflow1974-2010.cdr
7/3/2013 CNL
Source: HGL
V
HGL
Figure 4.2
Lower Ley Creek
Streamflow Peak Flow
1974-2010
-------
Area Inset
Town of Salina
IftJHPI &
• ¦ •¦¦• >t '1;
WM*MJ
'l yHf^T M"'
TownldftSalin'aB
Landfill
HKlal
See Area Inset
/ o
/ 5
//
ITeylCmek^M
:
H-I3I
of.Sailna t- •
Former Landfill Parcel
¦¦¦¦¦¦¦
1SH
m'mm
Cooper Crouse-Hinds North Landfill
HGL—FS Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Figure 7.1
Soil Alternatives 2 and 3
Extent of Southern Swale
Soil Excavation
Legend
Soil Sample Location
Surface Water Course
Road
Highway
H—' Railroad
0.5 ft Excavation Extent
50,920 ff
2 ft Excavation Extent - Lower Ley Creek
157,270 ff
2 ft Excavation Extent - Old Ley Creek
81,894 ft2
3 ft Excavation Extent
7,648 ft2
5 ft Excavation Extent
14,462 ft2
6 ft Excavation Extent
25,977 ft2
8 ft Excavation Extent
12,755 ft2
14 ft Excavation Extent
4,333 ft2
Cooper Crouse-Hinds Landfill
Town of Salina Landfill
and Former Landfill Parcel
Notes:
PCB=polychlorinated biphenyl
ppm=part per million
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(7-01 )SoilAlt23_SouthSwale. mxd
1/13/2014 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
llevlCreeki
M.
1
Cooper Crouse-Hinds
North Landfill
* Vrf
w uj.$w
/ y.
yVr*. *1
mvRi 9! 3SJj*?h
.X •" •• -C « " « H
ME mw*».
ft \ 3
J, V J
I V St t fl
\ - i ar.
X v " . >
/ 11
lance Bank
Stadium
IK il.—FS Report
Lower Ley Creek Sabsite of Onondaga Lake, Syracuse, NY
Figure 7.2
Soil Alternative 2
Extent of Northwest
Soil Excavation
Legend
Soil Sample Location
Surface Water Course
Road
= Highway
-t—t- Railroad
Pipeline
2 ft Excavation Extent
642,044 ff
8 ft Excavation Extent
6,702 ft2
Area Around Pipeline Requiring Soil Cap
66,034 ft2
Cooper Crouse-Hinds Landfill
Town of Salina Landfill
and Former Landfill Parcel
Notes:
PCB=polychlorinated biphenyl
ppm=parts per million
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSl W\FS\
(7-02)SoilA lt2_NorthernSoils_PCB. mxd
1/13/2014 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
seo s ta
pro*
~ HGL
™ HydroGeoLogic, Inc
-------
• V7-
IfeTlCreek*
m.
1
Cooper Crouse-Hinds
North Landfill
¦ mtiSm
Cooper Crouse-Hinds
South Landfill
•?A
lance Bank
Stadium
•CC*
¦™f Vl
¦I
t
-------
Area
Sahna
Former Landfill Parcel
Q
Town of Salma
Landfill
See Area Inset
ITeylGreek
Town of^Salina
Former Landfill Parcel ^
V,
*i
Cooper Crouse-Hinds North Landfill
1°
150
300
600|
HGL—FS Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Figure 7.4
Soil Alternative 4
Extent of Southern Swale
Soil Cap
Legend
Soil Sample Location
Surface Water Course
Road
Highway
-•—Railroad
0.5 ft Excavation Extent
50,920 ff
2 ft Excavation Extent - Lower Ley Creek
157,270 ff
2 ft Excavation Extent - Old Ley Creek
81,894 ft2
Soil Cap Extent - Lower Ley Creek
22,109ff
Soil Cap Extent - Old Ley Creek
39,731 ft2
Cooper Crouse-Hinds Landfill
Town of Salina Landfill
and Former Landfill Parcel
Notes:
PCB=polychlorinated biphenyl
ppm=part per million
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(7-04)SoilAlt4_SouthSwale. mxd
1/13/2014 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
HGL—FS Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
' f: Si Ji
Figure 7.5
Sediment Alternative 2
Extent of Upstream Section
Excavation
-
Notes:
PCB=polychlorinated biphenyl
ppm=parts per million
m
X
. \,
l \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(7-05)SedA lt2_Excav. mxd
8/5/2013 CNL
Source: HGL, Ah' Engineering, ESR1,
ArcGIS Online Imagery
v^li1
sta
ST Hydro Geo Logic, Inc
pro^
-------
*
IK il.—FS Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NT
Figure 7.6
Sediment Alternative 2
Extent of Middle Section
Excavation
Legend
Sediment Sample Location
Surface Water Course
Road
Highway
-*—*- Railroad
2 ft Excavation Extent
119,978 ff
3 ft Excavation Extent
16,959 ff
5 ft Excavation Extent
65.029 ff
\ \Gst-srv-01 \hglgis \Ley_C reek\_MSI WXFS\
(7-06)SedAlt2_Excav. mxd
8/6/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
y HGL
™ HydroGeoLogic, Inc
-------
R2-6—©
PV *-
* St" u0 -
^ y /
JTrS P- ,#vr
rW *i*it %: ?
mk m
*f
V
fe, m
V
K v-i
s. <$>
S\d&-'
/igfe?
HSR—#$ Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Figure 7.7
Sediment Alternatives 2, 3, and 4
Extent of Downstream Section
Excavation
Legend
Sediment Sample Location
Surface Water Course
Road
Highway
Railroad
1 ft Excavation Extent
69,697 ff
Notes:
PCB=polychlorinated biphenyl
ppm=parts per million
\ \Gst-srv-01 \hglgis \Ley_C reek\_MSI WXFS\
(7-07)SedAlt234_Downstream. mxd
8/6/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
jfcD STA
2* PROt
y HGL
™ HydroGeoLogic, Inc
-------
# M L '
• "Jr:
Munil
SED 04
f
Ley.Creekf^ ^
- .4
1iitwwM
vtSb
\ u
//G£—iFjS* Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Figure 7.8
Sediment Alternative 3
Extent of Upstream Section
Sand/Armor Sediment Cap
Legend
Sediment Sample Location
Surface Water Course
Road
Highway
-t—<- Railroad
2 ft Excavation Extent
93,066 ff
4 ft Excavation Extent
33,973 ft2
Armor Sediment Cap Extent
119.482ff
Notes:
PCB=polychlorinated biphenyl
ppm=parts per million
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(7-08)SedA lt3_C ap. mxd
1/2/2014 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
HGL—FS Report
Lower Ley Creek Subsite of Onondaga Lake, Syracuse, NY
Figure 7.9
Sediment Alternative 3
Extent of Middle Section
Sand/Armor Sediment Cap
Legend
Sediment Sample Location
Surface Water Course
Road
Highway
-t—*- Railroad
2 ft Excavation Extent
119,978 ff
3 ft Excavation Extent
16,959 ff
Armor Sediment Cap Extent
65,029 ft2
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSl W\FS\
(7-09)SedAlt3_Mid_Cap. mxd
1/2/2014 CNL
Source: HGL, AE Engineering, ESR1,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
j j~; / rYJr ¦ ^ A.
PPBr3B3
-JsM7 \M
' W K M?
1
SED 04
Creekli
R3-12
J
r \
E9S
to
IK il.—FS Report
Lower Ley Creek Sabsite of Onondaga Lake, Syracuse, NY
Figure 7.10
Sediment Alternative 4
Extent of Upstream Section
Bentonite Sediment Cap
Legend
• Sediment Sample Location
Surface Water Course
Road
= Highway
-t—•- Railroad
Extent of Bentonite Sediment Cap
240,397 ft"
Notes:
PCB=polychlorinated biphenyl
ppm=parts per million
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(7-10)SedAlt4_Upstream_Cap. mxd
8/5/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
R2-7
1°
125
250
500
IK il.—FS Report
Lower Ley Creek Sabsite of Onondaga Lake, Syracuse, NY
Figure 7.11
Sediment Alternative 4
Extent of Middle Section
Bentonite Sediment Cap
Legend
• Sediment Sample Location
Surface Water Course
Road
= Highway
-+—Railroad
Extent of Bentonite Sediment Cap
203,559 ft"
Notes:
PCB=polychlorinated biphenyl
ppm=parts per million
\ \gst-srv- 01 \hglgis \Ley_C reek\_MSI W\FS\
(7-11 )SedAlt4_Mid_BentoniteCap. mxd
8/5/2013 CNL
Source: HGL, AE Engineering, ESRI,
ArcGIS Online Imagery
~ HGL
™ Hydro Geo Logic, Inc
-------
TABLES
-------
Table 3.1
Human Health Risk Concerns
Kxposure I'.ilhwin/Medi.i
Non-C .nicer Risk
(.'.nicer Risk
Kxposnre Risk
I'rinum COI't's
Kxposnre Risk
I'rinuin COI't's
Sediments
Recreational Visitor - Adult
Fish ingestion
PCBs and Total Chromium
Fish ingestion
PCBs, Total Chromium, and Arsenic
Recreational Vistor - Older Child (6 - <16 years old)
Fish ingestion and dermal exposure
PCBs and Total Chromium
Fish ingestion and dermal exposure
PCBs, Total Chromium, Arsenic, and
Benzo(a)pyrene
Recreational Vistor - Younger Child (<6 years old)
Fish ingestion, dermal exposure,
ingestion of sediment
PCBs, Total Chromium, Arsenic, and Mercury
Fish ingestion, dermal exposure,
ingestion of sediment
PCBs, Total Chromium, Arsenic, and PAHs
Construction Worker - Adult
None
None
None
None
Soils
Recreational Visitor - Adult
None
None
Direct comaei ^ingestion and dermal; wiih soils
Toial Chromium and Benzoyl)p\reiie
Recreational Vistor - Older Child (6 - <16 years old)
Dermal exposure
PCBs
Dermal exposure
Benzo(a)pyrene
Recreational Vistor - Younger Child (<6 years old)
Direct contact (ingestion and dermal) with soils
PCBs, Total Chromium, and Cadmium
Direct contact (ingestion and dermal) with soils
PCBs, PAHs, and Total Chromium
Construction Worker - Adult
Direct contact (ingestion and dermal) with soils
PCBs
Ingestion of soils
Total Chromium
Notes:
PCBs - polychlorinated biphenyls
COPCs - chemicals of potential concern
PAHs - polcyclic aromatic hydrocarbons
Table 3.1
Human Health Risk Concerns
Page 1 of 1
-------
Table 4.1
Streamflow Characteristics in Lower Ley Creek
I SGS Slre;im (>;uij>c
i s<;s (M240I20 u:v t ri:i:k at park
S I Ri:i: i. SYR ACT Si:. NY
Period of Record
Daily Discharge Data
1972-2011
Monthly Discharge Data
1972-2010
Annual Discharge Data
1973-2010
Peak Streamflow Information
1973-2011
Flow Characteristics
Maximum average daily flow (cfs)
831
Maximum recorded peak flow (cfs)
1410
Date of maximum recorded peak flow
4/16/2011
Minimum average daily flow (cfs)
1.9
Page 1 of 1
-------
Table 5.1
Chemicals of Potential Concern
Contributing to Human Health and Ecological Risks in Lower Ley Creek
Chemiciils «l' I'olonliiil Concern (COI'C's)
Kcolo»k';il
Risk
llnniiin
lle.illh
Sediment
Risk
llnniiin
lle.illh
Soil Risk
Mel ills
Arsenic
X
X
Cadmium
X
Total Chromium
X
X
X
Copper
X
Lead
X
Nickel
X
Mercury
X
X
Silver
X
Zinc
X
Orminii' Compounds
YOCs
Dioxins/Furans
X
X
Polychlorinated Aromatic Compounds (PAHs)
X
X
X
Pesticides
X
Polychlorinated Biphenyls (PCBs)
X
X
X
Page 1 of 1
-------
Table 5.2
Soil Preliminary Remediation Goals
Clu'mic.ils ol' Polcnlfcil
Concern (COI'Cs)
Soil PRCs
Sourcc/Rcccplor
Meliils (iiiivkm
Antimony
0.27
Ecological Risk Screening - Mammals
Barium
330
Ecological Risk Screening - Terrestrial Invertebrates
Cadmium
0.36
Ecological Risk Screening - Mammals
Total Chromium
1
NYSDEC Unrestricted Use Soil Criteria
Copper
28
Ecological Risk Screening - Birds
Lead
11
Ecological Risk Screening - Birds
Manganese
220
Ecological Risk Screening - Plants
Mercury
0.1
EPA Region 5 Ecological Soil Screening
Nickel
38
Ecological Risk Screening - Plants
Selenium
0.52
Ecological Risk Screening - Plants
Silver
4.2
Ecological Risk Screening - Birds
Vanadium
7.8
Ecological Risk Screening - Birds
Zinc
46
Ecological Risk Screening - Birds
I'M Is (/(«¦ k»)
Benzo(a)anthracene
660
Younger Child Recreational Visitor
Benzo(a)pyrene
66
Younger Child Recreational Visitor
Benzo(b)fluoranthene
660
Younger Child Recreational Visitor
Butylbenzylphthalate
239
EPA Region 5 Ecological Soil Screening
Dibenz(a,h)anthracene
66
Younger Child Recreational Visitor
Di-n-butylphtalate
150
EPA Region 5 Ecological Soil Screening
Indeno( 1,2,3-cd)pyrene
500
NYSDEC Unrestricted Use Soil Criteria
Sum of Low Molecular Weight
PAHs
29000
Ecological Risk Screening - Terrestrial Invertebrates
Sum of High Molecular Weight
PAHs
1100
Ecological Risk Screening - Mammals
I'esiicides (/)
Aroclor-1248
100
NYSDEC Unrestricted Use Soil Criteria for PCBs
Aroclor-1260
100
NYSDEC Unrestricted Use Soil Criteria for PCBs
Notes:
Determination of Soil PRGs detailed in Appendix B
PRGs - Preliminary Remediation Goals
mg/kg - milligrams per kilogram
lig/kg - micrograms per kilogram
NYSDEC - New York State Department of Environmental Conservation
PAHs - polycyclic aromatic hydrocarbons
PCBs - poly chlorinated biphenyls
EPA - U.S. Environmental Protection Agency
Page 1 of 1
-------
Table 5.3
Sediment Preliminary Remediation Goals
Chemicals <>r
I'otentiid Concern
Sediment I'KCi
Source/Receptor
(( ()!>( s)
Mciiiis (nig km
Arsenic
1.8
Adult Recreational Visitor
Cadmium
0.6
New York State Sediment Criteria - Lowest Effect Level
Total Chromium
26
New York State Sediment Criteria - Lowest Effect Level
Copper
16
New York State Sediment Criteria - Lowest Effect Level
Lead
31
New York State Sediment Criteria - Lowest Effect Level
Methylmercury
0.011
Sediment PRG for Mink (NOAEL Based)
Mercury
0.15
New York State Sediment Criteria - Lowest Effect Level
Nickel
16
New York State Sediment Criteria - Lowest Effect Level
Silver
1
New York State Sediment Criteria - Lowest Effect Level
Zinc
120
New York State Sediment Criteria - Lowest Effect Level
PAHs Oig/kg)
3-Methylcholanthrene
15
Younger Child Recreational Visitor
Benzo(a)pyrene
66
Younger Child Recreational Visitor
Dibenzo(a,h)anthracene
66
Younger Child Recreational Visitor
Total PAHs
45190
Sediment PRG for Benthic Invertebrates
Pesticides (/<.!¦ km
Dieldrin
11
Adult Recreational Visitor
PCBs (/<<>k«)
Aroclor-1254
0.8
New York State Sediment Criteria - Human Health
Bioaccumulation
Aroclor-1260
0.8
New York State Sediment Criteria - Human Health
Bioaccumulation
Total PCBs
0.8
New York State Sediment Criteria - Human Health
Bioaccumulation
Others (/<«.k«)
Dioxins/Furans
0.029
Sediment PRG for Mink (NOAEL Based)
Notes:
Determination of Sediment PRGs detailed in Appendix B
mg/kg - milligrams per kilogram
lig/kg - micrograms per kilogram
PRG - Preliminary Remediation Goal
NOAEL - No Observed Adverse Effect Level
TSCA - Toxic Substances Control Act
PAHs - polycyclic aromatic hydrocarbons
PCBs - polychlorinated biphenyls
Page 1 of 1
-------
Table 5.4
Soil Cleanup Goals
0-2 ft below ground surface
C hi'inii'iils of I'olciilkil
Soil (k-;iiiii|>
Soil (. riu-rki
( (IIHCI Il <( Oil s)
( ilKll
Mihilv nil:; Uy i
Barium
400
NYSDEC SCO for Commercial Use
Cadmium
4
NYSDEC SCO for Protection of Ecological Resources
Total Chromium
41
NYSDEC SCO for Protection of Ecological Resources
Copper
50
NYSDEC SCO for Protection of Ecological Resources
Lead
63
NYSDEC SCO for Protection of Ecological Resources
Manganese
1600
NYSDEC SCO for Protection of Ecological Resources
Mercury
0.18
NYSDEC SCO for Protection of Ecological Resources
Nickel
30
NYSDEC SCO for Protection of Ecological Resources
Selenium
3.9
NYSDEC SCO for Protection of Ecological Resources
Silver
2
NYSDEC SCO for Protection of Ecological Resources
Zinc
109
NYSDEC SCO for Protection of Ecological Resources
I'M
<> ifiy kyi
Benzo(a)anthracene
5600
NYSDEC SCO for Commercial Use
Benzo(a)pyrene
1000
NYSDEC SCO for Commercial Use
Benzo(b)fluoranthene
5600
NYSDEC SCO for Commercial Use
Dibenz(a, h)anthracene
560
NYSDEC SCO for Commercial Use
Indeno( 1,2,3-cd)pyrene
5600
NYSDEC SCO for Commercial Use
Pesticides (ftg/kg)
DDT and Metabolites
3.3
NYSDEC SCO for Protection of Ecological Resources
Endrin
140
NYSDEC SCO for Protection of Ecological Resources
FClte (ftg/l'S)
Aroclor-1248
1000
NYSDEC SCO for Commercial Use
Aroclor-1260
1000
NYSDEC SCO for Commercial Use
Deeper than 2 ft below ground surface
( heiiiimls ol' r<>U-mi;il
Soil ( k';iini|)
Soil (. riu-ri;i
( onci-rn <( Oil s)
( ilKll
Mi-Lik iiii < JLtJi kyi
Benzo(a)anthracene
5600
NYSDEC SCO for Commercial Use
Benzo(a)pyrene
1000
NYSDEC SCO for Commercial Use
Benzo(b)fluoranthene
5600
NYSDEC SCO for Commercial Use
Dibenz(a, h)anthracene
560
NYSDEC SCO for Commercial Use
Indeno( 1,2,3-cd)pyrene
5600
NYSDEC SCO for Commercial Use
Pesticides (pg/kg)
DDT and Metabolites
47000
NYSDEC SCO for Commercial Use
Endrin
89000
NYSDEC SCO for Commercial Use
It "Us kyi
Aroclor-1248
1000
NYSDEC SCO for Commercial Use
Aroclor-1260
1000
NYSDEC SCO for Commercial Use
Notes:
ft - feet
mg/kg - milligrams per kilogram
/iig/kg - micrograms per kilogram
NYSDEC - New York State Department of Environmental Conservation
SCOs - Soil Cleanup Objectives
PAHs - polycyclic aromatic hydrocarbons
PCBs - polychlorinated biphenyls
Page 1 of 1
-------
Table 5.5
Estimated Area and Volumes for All Chemicals Above Cleanup Goals in Soil
Southern Swale Soils (Old Ley Creek)
Depth of ( oiilamiiialion
III l>»s)
Thickness of
Contaminated lnler\al
(ft)
Areal r.\(en(
(ft2)
Volume of ( onlaminaled Soil in
Depth lnler\al
<(Y)
0-2
2
81,894
6,066
0-6
6
25,977
5,773
2-8
6
12,755
2,834
2-14
12
4,333
1,926
Maximum Areal Extent (ft2)
Total Volume (CY)
Southern Swale Soils (Lower Ley Creek)
Dcplli of ( oiilamiiialion
III l>»s)
Thickness of
( onlaminaled lnlcr\al
(ft)
Areal IaIciiI
(ft2)
Volume of ( onlaminaled Soil in
Dcplli lnlcr\al
<(Y)
0-0.5
0.5
50,920
943
0-2
2
157,270
11,650
0-3
1
7,648
283
2-5
3
14,462
1,607
107,871
16,599
Maximum Areal Extent (ft2)
Total Volume (CY)
Northwest Soils (Lower Ley Creek)
Dcplli of ( oiilamiiialion
(I'l hiis)
Thickness of
( onlaminaled lnlcr\al
(ft)
Areal r.Mcnl
(ft2)
Volume of ( onlaminaled Soil in
Dcplli lnler\al
l(Vl
0-2
2
642,044
47,559
2-8
6
6,702
1,489
208,190
14,483
642,044
49,048
958,105
80,130
Notes:
Cleanup Goals for Soil are shown on Table 5.4
ft - feet
bgs - below ground surface
CY - cubic yards
Maximum Areal Extent (ft2)
Total Volume (CY)
TOTAL AREAL EXTENT OF SOILS ABOVE CLEANUP GOALS (ft2)
TOTAL VOLUME OF SOILS ABOVE CLEANUP GOALS (CY)
Page 1 of 1
-------
Table 5.6
Estimated Area and Volumes for All Chemicals Above Cleanup Goals in Sediment
Upstream Section
l)c|>lh of ( 'oiilamiiialion
(I'l Itusi)
Thickness of
(onlaminaled
Inlcrxal
(ft)
Areal T.\lcnl
(ft2)
Volume of ( onlaminaled
Sedimenl
((A )
0-2
2
93,066
6,894
0-4
4
33,973
5,033
0-8
8
119,482
35,402
Middle Section
Total Areal Extent (ft )
Total Volume (CY)
246,521
47,329
l)c|>lh of ( oiilamiiialion
(I'l Itusi)
Thickness of
(onlaminaled
Inlcrxal
(ft)
Areal T.\lenl
(ft2)
Volume of ( onlaminaled
Sedimenl
(( A )
0-2
2
119,978
8,887
0-3
3
16,959
1,884
0-5
5
65,029
12,042
Downstream Section
Total Areal Extent (ft )
Total Volume (CY)
201,966
22,814
l)c|>lh of ('oiilamiiialion
(I'l hnsi)
Thickness of
(onlaminaled
Inlcrxal
(ft)
Areal T.\lcnl
(ft2)
Volume of ( onlaminaled
Sedimenl
(( A )
0-1
1
69,697
2,581
Total Areal Extent (ft )
Total Volume (CY)
TOTAL AREAL EXTENT OF SEDIMENTS ABOVE CLEANUP GOALS (ft2)
TOTAL VOLUME OF SEDIMENTS ABOVE CLEANUP GOALS (CY)
Notes:
Cleanup Goals for Sediments were based on a 1 milligram per kilogram (mg/kg) PCB concentration
ft - feet
bwsi - below the water-sediment interface
CY - cubic yards
69,697
2,581
518,184
72,724
Page 1 of 1
-------
Table 6.1
Identification and Screening of Remedial Technologies for Lower Ley Creek
(>ener;il Response Act ion
«;r.\)
Kemediiil Technolo»\
\ iiriiilions
KITediveness
Impk'iiK'iikibilil}
Cosls
Overall Screening Conclusion®
No Action
None
None
Would not be effective in meeting RAOs.
Readily implementable. Not likely to be
acceptable to public or regulatory
agencies.
Very Low
Should be retained for comparative
purposes only.
Institutional Controls
Government Controls
Includes controls imposed by
federal, state, or local governments,
such as restrictions on dredging,
surface water usage, etc.
Potentially effective in reducing exposure to
impacted media.
Readily implementable. Not likely to be
acceptable to public or regulatory
agencies except when more active forms
of remediation cannot feasibly provide
complete remediation.
Low
Retained as part of an active
remediation alternative.
Property Controls
Includes deed restrictions. Could
limit shore modifications by property
owners near the creek.
Potentially effective in reducing exposure to
impacted media.
Readily implementable. Not likely to be
acceptable to public or regulatory
agencies except when more active forms
of remediation cannot feasibly provide
complete remediation.
Low
Retained as part of an active
remediation alternative.
Enforcement Tools
Includes actions such as
administrative orders preventing
dredging.
Potentially effective in reducing exposure to
impacted media.
Readily implementable. Not likely to be
acceptable to public or regulatory
agencies except when more active forms
of remediation cannot feasibly provide
complete remediation.
Low
Retained as part of an active
remediation alternative.
Informational Devices
Includes activities such as health
advisories on fish consumption,
listing on registry of contaminated
sites, and swimming bans.
Potentially effective in reducing exposure to
impacted media.
Readily implementable. Not likely to be
acceptable to public or regulatory
agencies except when more active forms
of remediation cannot feasibly provide
complete remediation.
Low
Retained as part of an active
remediation alternative.
Natural Recovery
Monitored Natural Recovery
Always should include a monitoring
plan and contingency plan.
In appropriate systems, can be effective at
reducing chemical concentrations and risks in
physical and biological media. Allows
ongoing short-term risks while remedy is
achieved over a specified time period.
Implementable. Monitoring program and
contingency plan required. Not likely to
be acceptable to public or regulatory
agencies except when more active forms
of remediation cannot feasibly provide
complete remediation.
Low
Retained.
Containment and Engineering
Controls
Capping (sediments)
Engineered sediment cap with
erosion controls as needed.
Effective at physical and chemical isolation of
sediments to reduce potential exposure of
aquatic organisms and people in appropriate
system.
Implementable. Generally more easily
placed in shallower areas. Caps along
exposed shorelines may need aggressive
erosion and stabilization controls such as
armor stones. Difficult to implement on
steep slopes.
High
Retained
liiiginccred capping wiili rcacii\c
materials.
lniio\aii\e technology: ma\ Iv cri'ccii\c fur
physical isolation and treatment. reducing
potential exposure io aquatic organisms.
l'ro\ides alkniak approach to standard
capping lor s\ skins where standard capping
ma\ Iv iiicN'ccii\c.
I'otciitialK iinpleineiitable. depending on
results of bench and pilot siudies. Design
issues similar to cap alieniaii\e. Ma\
require e\ieiisi\e maintenance to replace
rcacii\c materials in some designs.
1 ligli
Not retained due to iniplenieiiiabiliix
issues.
Thin-la\cr capping
I'otciitialK cl'fccii\c in some swenis. Ma\
not in\ol\c complete isolation. so
cl'l'ccii\ciicss ean be less ihan standard
capping.
Iinpleineiitable. Thin laxersean be placed
b\ a \ariei\ of methods. Shoreline slope
design issues similar to standard capping.
Moderate
Not retained due to efl'eeti\eiiess issues.
Table 6.1
Identification and Screening of Remedial Technologies
Page 1 of 4
-------
Table 6.1 (continued)
Identification and Screening of Remedial Technologies for Lower Ley Creek
(»ener;il Response Action
«;r\)
Remedial Technology
\ siriiilions
Kl'fecliveness
Implemenhihilih
Cosls
Oversill Screening Conclusion4
Capping (soils)
Tliin-la\er capping
Potentially effective in some s\ stems. Ma\
not involve complete isolation, so
effectiveness can be less than standard
capping.
Implementable. Thin layers can be placed
by a variety of methods.
Moderate
Retained
Vertical Barrier Containment
Deep soil ini\ing
lil'fcctiu- as a hulraulic barrier to reduce
contaminant lln\ to creek. I'iHernial short-
lerm impacts due in resuspension of
contaminants.
Implcmcmahlc in near shnre. difficult in
deeper waters. Less prnne m cnrrnsimi
and ina\ ha\c mnre strength than
sheeipiliiiL'.
1 ligli
Not retained due to iinpleineniabiliix
issues.
SInrr\ Wall
LlTcctiu- as a hulraulic barrier in reduce
contaminant lln\ in creek. I'otciitial short-
lerm impacis due in resuspeiisimi nf
cniiuiiniiianis.
I'otciitialK iinpleineniable depending nil
waier depih. wall depih. and snil being
displaced.
Moderate
Not retained due to iiiipleiiieniabilit\
issues.
Shceipiling
lil'l'ccthc as a hulraulic barrier m reduce
cniiiainiimiii 11 n\ in creek.
I'otciitialK iinpleineniable near shnre.
although qualitx cnmrnl ina\ be dil'liculi
when installed ihrnugh water and depih
ma\ be an issue.
Mnderaie
Not retained due to iinplemeiiiabiliix
issues.
Sediment Removal (includes
potential best management
practices [BMPs], transport,
and dewatering)
Dredging
Mechanical Dredging
Li'i'cai\e at renin\ing risks related in
chemicals from environment of concern.
Elevated short-term risks from resuspensed
sediments likely in highly contaminated
sediments. Potential long-term impacts from
residual sediment-related chemicals lost to
wider areas.
Iniplenieiiiable, particular!) in shallower
areas. May require implementation of
BMPs that can slow production.
Rehandling and dewatering steps
required in most cases. May need
backfill or additional dredging for slope
stability.
High
Retained
Hydraulic Dredging
Effective at removing risks related to
chemicals from environment of concern.
Elevated short-term risks from resuspensed
sediments (but often less than mechanical)
and entrained water likely in highly
contaminated sediments. Potential long-term
impacts from residual sediment-related
chemicals lost to wider areas. Potential
impacts from discharge water.
Implementable, particularly in shallower
areas. May require implementation of
BMPs that can slow production. May
need backfill or additional dredging for
slope stability. May require specialized
equipment. Water separation and water
treatment would be required. Land
requirements are high for entrained water
and solids handling.
High
Retained
Combination/ Hybrid Mechanical/
Hydraulic Dredging
Effective at removing risks related to
chemicals from environment of concern.
Elevated short-term risks from resuspensed
sediments (often more so for mechanical) and
entrained water likely in highly contaminated
sediments. Potential long-term impacts from
residual sediment-related chemicals lost to
wider areas. Potential impacts from discharge
water.
Implementable, particularly in shallower
areas. May require implementation of
BMPs that can slow production. May
need backfill or additional dredging for
slope stability. May require specialized
equipment. Water separation and water
treatment would be required. Land
requirements are high for entrained water
and solids handling.
High
Retained
Table 6.1
Identification and Screening of Remedial Technologies
Page 2 of 4
-------
Table 6.1 (continued)
Identification and Screening of Remedial Technologies for Lower Ley Creek
(»ener;il Response Action
«;r\)
Remedial Technology
\ siriiilions
Effectiveness
Im plemeiit ii hilil >
Costs
Oversill Screening Conclusion4
hicuinaiic Dredging
liffccmc al rcnio\iiig risks related in
chemicals from cn\ iroiiniciii of concern.
I!lc\atcd shori-tcrni risks from resuspensed
sedimeiils (bin often less ilum mecliaiiical)
and emrained water likely in highly
contaminated sediments. I'nicmial long-ierin
impacis from residual sediment-related
chemicals lost in wider areas. I'oicniial
impacis from discharge waicr less due lo
higher slum coiicciiiraiion.
1 )i IlicLi 11 iinplcniciiiabiliiy. liquipniciii
iioi a\ailable on a commercial scale.
()nl\ feasible in soli, line-grained
material. Xoi feasible in water depths
less than 7 li deep.
Very High
Noi retained due lo iinplcniciiiabiliiy
issues.
Dry Excavation
Mechanical li\ca\ aiion
lifi'ccihc ai removing risks related lo
chemicals from environment of concern.
Fewer short-term chemical impacts than
dredging.
Iniplenieiiiable in shallow ( < 1 ^ fi water
depth) near shore areas. Requires water
diversion structures. Rehandling and
dewatering steps required.
Moderate
Retained.
Soil Removal
Excavation
Mechanical Excavation
Effective at removing risks related to
chemicals from environment of concern
Implementable at stable, near shore
locations.
Moderate
Retained.
Disposal (sediment and soil)
On-Site Consolidation
Solid waste or SDA
Can be effective with proper design and
construction, including liners, caps, and
leachate control. Potential short-term impacts
with rehandling steps.
Implementable. Design approaches
proven. Potentially suitable areas exist
near site. Regulatory and community
acceptance status needs to be finalized
with NYSDEC. Requires extensive long-
term maintenance.
Moderate
Retained.
Off-Site Disposal
Solid waste or hazardous waste
landfill, including Canada.
Can be effective when taken to a properly
designed existing landfill. Potential short-term
impacts with rehandling/transport steps.
Implementable. Suitably permitted
landfills exist. Requires transport of at
least 8 to 170 miles. Requires extensive
long-term maintenance.
Moderate
Retained
Water Management/ Treatment
Potential impacts from discharge water with
and without treatment.
Implementable. Proven technologies
exist.
Moderate
Retained
IJciiclicial Reuse (alter c\ situ
treatment)
liffccmc onl\ with fully ireaied soils and
sedimeiils.
Iniplenieiiiable where ireauneiii is
sul'liciciii.
Moderate
Not retained. Dependent on treatment
technologies that were iioi retained (sec
Ivlow i.
In Situ Treatment
Chemical IJiological
liino\aii\c technology potentially cl'l'ccii\c lor
reducing mobility or io\icity of coiiiainiiianis
in soils, sedimeiils and surface waicr.
I.iniiied iinplcniciiiabiliiy. Technology
not widely pro\en on a large scale.
1 ligli
Noi retained. Too many implementation
issues as compared lo more pro\en
icchiiologics.
I'hyiorcnicdiaiioii
hiiio\ati\c technology potentially cffccii\c
degrading and renio\iiig organics and
rcnio\ ing inorganics.
I.iniiied iniplcinciiiahiliiy. Technology
not pro\cii on a Held scale. Difficult or
impossible to implement on large
amounts of soils and sedimeiils. May
requires niaiiiiciiaiicc through har\csi and
renio\al of plants.
1 ligli
Not retained. Too many implementation
issues as compared to more pro\en
icchiiologics.
Solidification siabi ligation
liino\aii\c technology potentially cl'fccii\c ai
immobili/.iiig and siahili/.iug hca\y ineiaK in
a iioii-lcachablc niairi\. Mosi cffccii\c for
ponds. ri\ers or indiisirial lagoons where llic
ireauneiii area can be isolaled.
Applications to dale idciiiilicd signilicaiu
issues associated wiili implementation.
Inability to control nii\iug conditions and
curing temperature has resulted in no
successful applications. Signilicaiu
scdiniciii rcsuspciisioii would likely
occur.
1 ligli
Not retained. Too many implementation
issues as compared to more pro\cn
icchiiologics.
Table 6.1
Identification and Screening of Remedial Technologies
Page 3 of 4
-------
Table 6.1 (continued)
Identification and Screening of Remedial Technologies for Lower Ley Creek
^General Response Action Remedial Technolo»\
((.«K A) |
\ siriiilions
KITeclivoiu'ss
Impk'iiH'iiliihilih
Cosls
Oversill Screening Conclusion4
Ex Situ Treatment
Thermal Dcsorpiion (including
ihcrmal rctori)
liffccmc for rcnio\al \olalili/.aiioii of organic
cuiisiiiucnis and mercury. Noi cffccii\c for
rcnunal of inosi inorganic compounds, but ii
has Ivcn used lo rcino\c mercury. Potential
shori-icrm impacls with rchaiidling steps.
linplcinciiiablc for some chcinicals. but
mercury \apor conirol is complex.
1 SI: PA rcconiniciids againsi ihcrnial
ircainiciii of mercury due lo difllcullies
iu coiiirolling off gas. Requires iiuincrmis
rchaiidling sk-ps.
1 ligli
Noi retained. Numerous handling and
logisiical steps. I.iniiicd chcinical
applicability.
Incineration Yiirilicaiion
ITfccii\c for dcsiruciion and or rcnunal of
organic constituents. Nm cffccii\c for
dcsiruciion of inorganic compounds. Potential
shori-icrm impacis with ivhandling steps.
PoiciuialK iniplcniciiiablc. On-site
inciiicraiioii typically inccis signilicam
public rcsisiancc. Conirol of mercury
\apors is a sc\crc problem.
1 ligli
Not reiaincd. Nuinermis handling and
logistical steps. Limited chcinical
applicability.
Dechlorination
Potentially cffccii\c in detoxifying specific
ty pes of aromaiic organics. in pariicular
dio\ins and P("lis. Nm cffccii\c for ihc hca\y
mcial C()('s. Potential shori-icrm impacis
with rchaiidling sk-ps.
Ycry difliculi lo iniplcniciii due lo
cNccssiw ainounis of rcagcni required
for chloriiiaicd coinpounds. lack of lull-
scale applications lo date, and lack of
conuncrcial a\ailability. Past applications
haw Ivcn iu conjunction with thermal
ircainiciii.
1 ligli
Not reiaincd. Numerous
implementation issues and limited
chcinical applicability.
Chemical lAiraciion
Potentially cffcctiw for extracting organics
and mcials. including chlorolvn/.cncs and
mercury. The c\iraciion solution is ihcn
ircaicd lo rcinoNc and rcco\cr coiiiainiiianis.
Potential shori-icrm impacis from chemicals
and rchaiidling sk-ps.
Can Iv difliculi lo implement due to
complex ircainiciii requirements for
extraction fluid, lack of lull-scale
applications in dale, and lack of
conuncrcial a\ailability.
1 ligli
Not reiaincd. Numerous
implementation issues and limited
chcinical applicability.
Scdimciii Soil Washing
Potentially cffcctiw physical separation
process fur rcnio\iiig organics and mcials
ihrough separation of line IVaciion. where iliis
fraciiou couiains ihc majority of the
couiamiuaiiou. Potential shon-icrm impacts
from rchaiidling sk-ps.
Yen difliculi io iniplcniciii due lo
complex ircainiciii requirenieuts for
extraction fluid, lack of lull-scale
applications in dale, and lack of
conuncrcial a\ailability.
1 ligli
Not reiaincd. Numerous
implementation issues.
Solidification Stabilization
lilTccmc for impro\iug maicrial handling and
for immobilizing and stabilizing hca\y mcials
iu a iioii-lcachablc niairi\. Stabilizing
mercury iu soils and sediments. fur c\aniplc.
has Ivcn icsicd based on sullldc prccipiiaiion.
Potential shori-icrni impacis from rchaiidling
sicps.
Difliculi to implement. Addition of
solidifying or stabilizing rcagciiis may
increase both \olunie and weight for
disposal or containment.
1 ligli
Not retained. Too many implementation
issues as compared lo more pro\cn
technologies.
IJiological (includes laud
farming and slum phase
biorcincdiatioii)
I:ffccii\c ai biodcgradaiion of simple organic
chcinicals. Nm cffccii\c with transformation
of mercury. May release large \olumes of
\olaiilc chcinicals. Potential shori-icrni
impacis from rchaiidling sk-ps.
Difliculi io iniplcniciii on large scale.
1 ligli
Not reiaincd. Too many implementation
issues as compared to more pro\en
technologies.
Notes:
Highlighted cells indicate remedial technologies that were not retained.
* The overall screening conclusion considers whether the remedial technology should be "retained" for use in developing remedial alternatives in Section 7 (the next step of the evaluation process) or "not retained" for further evaluation.
Table 6.1
Identification and Screening of Remedial Technologies
Page 4 of 4
-------
Table 7.1
Lower Ley Creek Soil Remedial Alternatives
Description
Alternative Soil-I
Alternative Soil-2
Alternative Soil-3
Alternative Soil-4
No Action
Kxcavation of Soil to Meet
Cleanup Goals
l-Acavation ol' Southern Swale Soils to Meet
Cleanup Goals and Soil Cap lor Northwest
Soils
Soil Cap Over All Soils l-Aceedin» Cleanup
Goals
SoulIktii Swale Soils
(Includes Old Le\ ('reck Area)
No Action
Excavate contaminated areas to meet
cleanup goals and backfill near grade.
Limited wetlands restoration.
Excavate contaminated areas to meet cleanup goals
and backfill near grade. Limited wetlands
restoration.
Soil Cap Over Areas Exceeding Cleanup Goals in
Soil1
Norllmesl Soils
No Action
Excavation of contaminated areas to
meet cleanup goals outside of pipeline
areas and soil cap over remaining
contaminated areas.
Soil Cap Over Areas Exceeding Cleanup Goals in
Soil1
Soil Cap Over Areas Exceeding Cleanup Goals in
Soil1
Notes:
1 Soil caps will be approximately 1 ft thick and include a demarcation layer between the contaminated soil and the soil cap.
Table 7.1
Soil Remedial Alternatives
Page 1 of 1
-------
Table 7.2
Development and Initial Screening of Soil Remedial Alternatives
Allern;itive
Description
KITecliveness
Implement
Relative Cost
Comments
Soil 1 - No Action
No soil areas would be remediated.
Not effective in addressing risks.
Implementable
Low
Retained for comparison purposes
Soil 2 - Excavation of Soil to Meet Cleanup
Goals
Southern Swale Soils: Excavate contaminated areas to meet the
cleanup goal and backfill near grade. Limited wetlands restoration.
Northwest Soils: Excavation of contaminated areas to meet cleanup
goals outside of pipeline areas and soil cap over remaining
contaminated areas.
Potentially effective for addressing
chemicals of potential concern (COPCs)
exceeding risks in soil.
Implementable
High
Retained
Soil 3 - Excavation of Southern Swale Soils
to Meet Cleanup Goals and Soil Cap for
Northwest Soils
Southern Swale Soils: Excavate contaminated areas to meet the
cleanup goal and backfill near grade. Limited wetlands restoration.
Northwest Soils: Soil Cap Over Areas Exceeding Restricted Use
Cleanup Goals for Soil.
Potentially effective for addressing
COPCs exceeding risks in soil.
Implementable
Medium - High
Retained
Soil 4 - Soil Cap over All Soils Exceeding
Cleanup Goals
Southern Swale Soils: Soil Cap Over Areas Exceeding Cleanup
Goals for Soil.
Northwest Soils: Soil Cap Over Areas Exceeding Cleanup Goals for
Soil.
Potentially effective for addressing
COPCs exceeding risks in soil.
Implementable
Medium
Retained
Notes:
Soil caps will be approximately 1 ft thick and include a demarcation layer between the contaminated soil and the soil cap.
Table 7.2
Development and Initial Screening of Soil Remedial Alternatives
Page 1 of 1
-------
Table 7.3
Soil Alternative 2 Excavation and Capping Calculations
Southern Swale Soils (Old Ley Creek) - Excavation
Depth of
('oniaminalion
(I'l l»l*S)
Thickness of ( oniaminaled Inienal
(I'D
Areal 1 \icni
(ft2)
\ olume of ( oniaminaled Soil in
Dcplh Inienal
(O )
0-2
2
81,894
6,066
0-6
6
25,977
5,773
2-8
6
12,755
2,834
2-14
12
4,333
1,926
Total Volume (CY) 16,599
Total Aerial Extent of Excavation (ft2) 107,871
Southern Swale Soils (Lower Ley Creek) - Excavation
Dcplh of
( oniaminalion
(I'l l»l*S)
Thickness of ( oniaminaled Inienal
(I'D
Areal 1 \icni
(ft2)
\ olume of ( oniaminaled Soil in
Dcplh humal
«A )
0-0.5
0.5
50,920
943
0-2
2
157,270
11,650
2-3
1
7,648
283
2-5
3
14,462
1,607
Total Volume (CY) 14,483
Total Aerial Extent of Excavation (ft2) 208,190
Northwest Soils - Excavation and Capping
Dcplh of
( oniaminalion
(I'l l»l*S)
Thickness of ( oniaminaled Inienal
(I'D
Areal 1 \icni
(ft2)
\ olume of ( oniaminaled Soil in
Dcplh Inienal
«A )
0-2
2
576,010
42,667
2-8
6
6,702
1,489
Total Volume (CY)
44,157
Total Aerial Extent of Excavation (ft2)
509,976
Areal Extent of Area over Pipelines (ft2)
66,034
TOTAL AREAL EXTENT OF SOIL TO BE CAPPED (ft2)
66,034
TOTAL VOLUME OF SOIL TO BE EXCAVATED (CY)
75,239
TOTAL AREAL EXTENT OF HABITAT RESTORATION (ft2)
892,071
TOTAL VOLUME OF BACKFILL/HABITAT RESTORATION MATERIAL (CY)
75,239
Notes:
Areal Extents are shown on Figure 7.1 and Figure 7.2
ft - feet
bgs - below ground surface
CY - cubic yards
Page 1 of 1
-------
Table 7.4
Soil Alternative 3 Excavation and Capping Calculations
Southern Swale Soils (Old Ley Creek) - Excavation
Di'liih nl <'¦ miiiniiiiiiiiihi ill ligsp
Thickness nl
( iiniaiiiinaii'il linen al
ill i
\ival I .mciii
ill" i
\ mIiiihc nl ( iiiiMiiiiiuli'il Snil in
l)i'|ilh Inicnal
iO i
0-2
2
81,894
6 066
0-6
6
25,977
5,773
2-8
6
12,755
2,834
2-14
12
4,333
1,926
Total Volume (CY) 16,599
Total Aerial Extent of Excavation (ft2) 107,871
Southern Swale Soils (Lower Ley Creek) - Excavation
Di'liih nl ( mil aminaliiin
ill llgsl
Thickness nl
< 'miljininjii'il linen;il
ill i
\lVjl I'.Mi'lll
(in
\ nliiinc nl ( iinMinimiii'il Snil in
Di'liih lnii'i'\al
(< ^ i
0-0.5
0.5
50 9 ^0
943
0-2
2
157,270
11,650
2-3
1
7,648
283
2-5
3
14,462
1,607
Total Volume (CY) 14,483
Total Aerial Extent of Excavation (ft2) 208,190
Northwest Soils - Excavation and Capping
Di'liih nl l''..\c;i\Jlinn 11ii" Cap I'laci'incni
anil llaliiiai Ki'siuiMiinn
ill llgsl
l''.\c;i\jiinn Thickness
ill i
\ival I'.Mi'lll
ill'i
\ illume nl |-'..\cj\ali'il
( imiaininaii'il Snil
i< ^ i
0-2
2
576,010
42,667
Capping over deeper contamination
1
6,702
248
Capping over Pipeline
0
66,034
0
Total Volume of Excavation (CY)
42,916
Total Aerial Extent of Excavation (ft2)
576,010
Areal Extent of Soil Cap Area (ft2)
72,736
TOTAL AREAL EXTENT OF SOIL TO BE CAPPED (ft2)
72,736
TOTAL VOLUME OF SOIL TO BE EXCAVATED (CY)
73,997
TOTAL AREAL EXTENT OF HABITAT RESTORATION (ft2)
892,071
TOTAL VOLUME OF BACKFILL/HABITAT RESTORATION MATERIAL (CY)
73,749
Notes:
Areal Extents are shown on Figure 7.1 and Figure 7.3
ft - feet
bgs - below ground surface
CY - cubic yards
Page 1 of 1
-------
Table 7.5
Soil Alternative 4 Excavation and Capping Calculations
Southern Swale Soils (Old Ley Creek) - Excavation and Capping
Deplli of TAcawilion lor Cap
Placement and llahilal Kesioralion
(I'l hgs)
l'Aca\alion Thickness (ID
Areal TAleiil (I'l2)
\ olimie of TAca\aled
( oiiiaiiiinaled Soil ((^ )
0-2
2
81,894
6,066
Capping over deeper contamination
1
39,731
1,472
Total Volume of Excavation (CY) 7,538
Total Aerial Extent of Excavation (ft2) 107,871
Areal Extent of Soil Cap Area (ft2) 39,731
Southern Swale Soils (Lower Ley Creek) - Excavation and Capping
Depth of l'Aca\alioii lor Cap
riaceineiil and llahilal Kesioralion
(I'l hgs)
l'Aca\alion Thickness (I'D
Areal TAleiil (In
\ oliime of l-Aca\aled
( oiiiaiiiinaled Soil ((^ )
0-0.5
0.5
50,920
943
0-2
2
157,270
11,650
Capping over deeper contamination
1
22,109
819
Total Volume of Excavation (CY) 13,411
Total Aerial Extent of Excavation (ft2) 208,190
Areal Extent of Soil Cap Area (ft2) 22,109
Northwest Soils - Excavation and Capping
Depth of l'Aca\alion lor Cap
riaceiiieiil and llahilal Kesioralion
(I'l hgs)
l'Aca\alion Thickness (ID
Areal TAleiil (In
\ oliime of TAcawiled
( oiiiaiiiinaled Soil ((^ )
O 2
576,010
42,00"
Capping over deeper contamination
1
6,702
248
Capping over Pipeline
0
66,034
0
Total Volume of Excavation (CY)
42,916
Total Aerial Extent of Excavation (ft2)
576,010
Areal Extent of Soil Cap Area (ft2)
72,736
TOTAL AREAL EXTENT OF SOIL TO BE CAPPED (ft2)
134,576
TOTAL VOLUME OF SOIL TO BE EXCAVATED (CY)
63,865
TOTAL AREAL EXTENT OF HABITAT RESTORATION (ft2)
892,071
TOTAL VOLUME OF BACKFILL/HABITAT RESTORATION MATERIAL (CY)
61,326
Notes:
Areal Extents are shown on Figure 7.3 and Figure 7.4
ft - feet
bgs - below ground surface
CY - cubic yards
Page 1 of 1
-------
Table 7.6
Lower Ley Creek Sediment Remedial Alternatives
Description
Alleniiitive Sediment-I
Alternative Scdimenl-2
Alternative Sediment-3
Alternative Sediment-4 1
Alternative Sediment-5
No Action
Kcmov;il of Sediment to Cleanup
(>o;ils
Granular Material Sediment Cap
1
Kn»ineered licnlonitc Sediment
Cap
Monitored Natural Recovery
I pslreiiin Sediments
(Includes Old Le\ Creek ( liminel)
No Action
Removal of Sediment to Cleanup Goals
Excavate and backfill with
granular/armor capping material
design1
Excavate and backfill with engineereed
clay aggregate capping material design1
Monitored Natural Recovery
Middle Sediments
No Action
Removal of Sediment to Cleanup Goals
Excavate and backfill with
granular/armor capping material
design1
Excavate and backfill with engineereed
clay aggregate capping material design1
Monitored Natural Recovery
Downstream Sediments
No Action
Excavate Hot Spots
Excavate Hot Spots
Excavate Hot Spots
Monitored Natural Recovery
Notes:
1 These are approximate depths that will be based on the thickness of capping material design required to isolate the contaminated sediments, provide a suitable habitat for biota, and maintain the current bathymetry of Lower Ley Creek.
All capping alternatives will consider the Conceptual Site Model of the creek,
ft - feet
Table 7.6
Sediment Remedial Alternatives
Page 1 of 1
-------
Table 7.7
Development and Initial Screening of Sediment Remedial Alternatives
AlloriiiiliM'
Description
KITcclncnoss
Implement
UcliitiM' Cost
Comments
Sediment 1 - No Action
No action would be taken on the sediment contamination.
Not effective in addressing risks.
Implementable
Low
Retained for comparison purposes
Sediment 2 - Removal of All Sediments to
Cleanup Goals
UDStrcam Sediments: Removal of contaminated sediments.
Middle Sediments: Removal of contaminated sediments.
Downstream Sediments: Removal of contaminated sediments.
Potentially effective for addressing
chemicals of potential concern (COPCs)
exceeding risks in sediment.
Implementable
High
Retained
Sediment 3 - Granular Material Sediment Can
UDStrcam Sediments: Excavate and backfill with eranular/armor
capping material design and habitat layer.
Middle Sediments: Excavate and backfill with eranular/armor
capping material design and habitat layer.
Downstream Sediments: Removal of contaminated sediments.
Potentially effective for addressing
COPCs exceeding risks in sediment.
Detailed evaluation required to determine
effectiveness of engineered sediment cap.
Implementable
Medium - High
Retained
Sediment 4 - Engineered Bentonite Sediment
Cap
UDStrcam Sediments: Excavate and backfill with an engineered
bentonite material design and habitat layer.
Middle Sediments: Excavate and backfill with an engineered
bentonite material design and habitat layer.
Downstream Sediments: Removal of contaminated sediments.
Potentially effective for addressing
COPCs exceeding risks in sediment.
Detailed evaluation required to determine
effectiveness of engineered sediment cap.
Implementable
Medium - High
Retained
Sediment 5 - Monitored Natural Recoverv
No active remediation would be undertaken at the Site. Natural
recovery processes would be relied upon to further reduce risk in
the Lower Ley Creek over time. A 30-year monitoring program
would be developed and implemented.
Can be effective at reducing chemical
concentrations and risks in physical and
biological media. Allows ongoing short-
term risks while remedy is achieved over
a specified time period.
Implementable
Low-Medium
Retained
Notes:
All sediment capping of the hot spots will be completed in a manner that maintains the current bathymetry of Lower Ley Creek.
Depths of excavation for capping alternatives will be based on the thickness of capping material design required to isolate the contaminated sediments, provide a suitable habitat for biota, and maintain the current bathymetry of Lower Ley Creek.
All capping alternatives will consider the Conceptual Site Model of the creek,
ft - feet
Table 7.7
Development and Initial Screening of Sediment Remedial Alternatives
Page 1 of 1
-------
Table 7.8
Sediment Alternative 2 Excavation Calculations
Upstream Section - Excavation
Depth of
Coiilamiiialion
(I'l Imsi)
Thickness of
Coiilaminaled Inlenal
(ft)
Areal K\leiil
(ft2)
Volume of Coiilaminaled
Sediment
(CY)
0-2
2
93,066
6,894
0-4
4
33,973
5,033
0-8
8
119,482
35,402
Total Areal Extent (ft2) 246,521
Total Volume (CY) 47,329
Middle Section - Excavation
Depth of
Coiilamiiialion
(I'l Imsi)
Thickness of
Coiilaminaled Inlenal
(ft)
Areal K\leiil
(ft2)
Volume of Coiilaminaled
Sediment
(CM
0-2
2
119,978
8,887
0-3
3
16,959
1,884
0-5
5
65,029
12,042
Total Areal Extent (ft2) 201,966
Total Volume (CY) 22,814
Downstream Section - Excavation
Deplli of
Coiilamiiialion
(I'l Imsi)
Thickness of
Coiilaminaled Inlenal
(ft)
Areal K\leiil
(ft2)
Volume of Coiilaminaled
Sediment
(CY)
0-1
1
69,697
2,581
Total Areal Extent (ft2) 69,697
Total Volume (CY) 2,581
TOTAL AREAL EXTENT OF SEDIMENTS TO BE CAPPED (ft2)
TOTAL VOLUME OF BACKFILL SEDIMENT (CY) 19,192
TOTAL VOLUME OF SEDIMENTS TO BE EXCAVATED (CY) 72,724
Notes:
Areal Extents are shown on Figure 7.5, Figure 7.6, and Figure 7.7
ft - feet
bwsi - below the water-sediment interface
CY - cubic yards
Page 1 of 1
-------
Table 7.9
Sediment Alternative 3 Excavation and Capping Calculations
Upstream Section - Excavation and Capping
Deplli of TAca\alion Required lo
Maintain llalhmein of creek
(I'l hwsi)
l'Aca\alion Thickness
(ll)
Areal TAleiil
(ft2)
\ olimie of TAcawiled
Sedimeiil
((^ )
0-2
2
32,111
2,379
0-4
4
33,973
5,033
Capping over deeper contamination
6
119,482
26,552
Total Areal Extent of Sand Cap/Isolation Layer (ft2) 119,482
Total Areal Extent of Armor Cap (ft2) 119,482
Total Volume of Sand Cap/Isolation Layer (CY) 8,851
Total Volume of Armor Cap (CY) 8,851
Total Volume of Excavated Sediment (CY) 33,963
Middle Section - Excavation and Capping
Deplli of r\ca\alion Required lo
Mainiain llalhmein of creek
(I'l hwsi)
l'Aca\alion Thickness
(ll)
Areal TAleiil
(ft2)
\ olimie of l'Aca\aled
Sedimeiil
((^ )
0-2
2
119,978
8,887
0-3
3
16,959
1,884
Capping over deeper contamination
3.875
65,029
9,333
Total Volume of Sand Cap/Isolation Layer (CY) 3,613
Total Areal Extent of Armor Cap (ft2) 65,029
Total Volume of Armor Cap (CY) 903
Total Volume of Excavated Sediment (CY) 20,104
Downstream Section - Excavation
Deplli ol' i :\ca\alioii
(I'l hwsi)
l'Aca\alion Thickness
(ll)
Areal TAleiil
(ft2)
\ oliime of TAca\aled
Sedimeiil
((^ )
0-1
1
69,697
2,581
Total Areal Extent of Sand Cap (ft2)
Total Volume of Sand Cap (CY)
Total Volume of Excavated Sediment (CY) 2,581
TOTAL VOLUME OF SAND CAP (CY) 12,463
TOTAL VOLUME OF Upstream Section (2 ft thick) ARMOR CAP (ft2) 8,851
TOTAL VOLUME OF Middle Section (0.375 ft thick) ARMOR CAP (ft2) 903
TOTAL VOLUME OF 2 ft thick HABITAT LAYER (CY) 33,869
TOTAL VOLUME OF BACKFILL SEDIMENTS in Downstream Section (CY) 2,581
TOTAL VOLUME OF SEDIMENTS TO BE EXCAVATED (CY) 56,649
Notes:
Areal Extents are shown on Figure 7.7, Figure 7.8, and Figure 7.9
ft - feet
bwsi - below the water-sediment interface
CY - cubic yards
Page 1 of 1
-------
Table 7.10
Sediment Alternative 4 Excavation and Capping Calculations
Upstream Section - Capping
Deplli of lAcawilion Required l<>
Maintain Balhmcln ol'creek
(I'l Imsi)
I'Acauilion Thickness
(ft)
Areal TaIciiI
(ft2)
Volume of Kxcauilcd
Scdimcnl
(CY)
0-2.25
2.25
240,397
20,033
Total Areal Extent of Bentonite Cap (ft2) 240,397
Total Volume of Excavated Sediment (CY) 20,033
Middle Section - Capping
Depth of I'Acauilion Required lo
Maintain Balhineln of creek
(I'l Imsi)
K\ca\ alion Thickness
(ft)
Areal TaIciiI
(ft2)
Volume of I'Acawilcd
Sediment
(CY)
0-2.25
2.25
203,559
16,963
Total Areal Extent of Bentonite Cap (ft2) 203,559
Total Volume of Excavated Sediment (CY) 16,963
Downstream Section - Excavation
Depth of I'Acawilion
(I'l Imsi)
K\ca\alion Thickness
(ft)
Areal TaIciiI
(ft2)
Volume of Kxcauilcd
Scdimcnl
(CY)
0-1
1
69,697
2,581
Total Areal Extent of Bentonite Cap (ft2)
-
Total Volume of Excavated Sediment (CY)
2,581
TOTAL AREAL EXTENT OF SEDIMENTS TO BE CAPPED (ft2)
443,956
TOTAL VOLUME OF HABITAT LAYER (2 ft thick) (CY)
32,886
TOTAL VOLUME OF BACKFILL SEDIMENTS in Downstream Section (CY)
2,581
TOTAL VOLUME OF SEDIMENTS TO BE EXCAVATED (CY)
39,578
Notes:
Areal Extents are shwon on Figure 7.7, Figure 7.10, and Figure 7.11
ft - feet
bwsi - below the water-sediment interface
CY - cubic yards
Page 1 of 1
-------
Table 8.1
Detailed Evaluation of Soil Remedial Alternatives for Lower Ley Creek
l^iiliiiilion Crileriii
Soil Allcriiiilne 1
Soil AltcriiiitiM' 2
Soil Allcriiiilhe 3
Soil AlteriiiiliM' 4
No Action
K\c:i\:ilion of Soil (o Meet ( Ionnup (Jonls
K\c:i\iilion of Southern S\\:ile Soils to Meet
(Iciimip (ionls iinil Soil ("sip lor Northwest
Soils
Soil ("sip (her All ( (>nl:iniin;ilcil Soils
Overall Protection of Human Health and the Environment
The No Action alternative would not be
protective of human health and the
environment, because this would not
actively address the contaminated soils
that present unacceptable risks of
exposure to receptors or the release and
transport of COPCs at the site. The
RAOs or PRGs would not be met under
this alternative.
• Excavation of contaminated soils would
provide protection of human health and the
environment by eliminating the exposure
pathways associated with impacted soils.
Removal would also eliminate future potential
COPC releases to the creek.
• Capping contaminated soils would provide
overall protection of human health and the
environment by eliminating the potential
human health and ecological exposure
pathways associated with impacted soils.
Clean cap material would prevent direct
exposure of humans and ecological receptors to
contaminated soil. Erosion control measures
on the cap would reduce or eliminate the
potential COPC releases to the creek.
• Excavation of contaminated soils would provide
protection of human health and the environment
by eliminating the exposure pathways associated
with impacted soils. Removal would also
eliminate future potential COPC releases to the
creek.
• Capping contaminated soils would provide
overall protection of human health and the
environment by eliminating the potential human
health and ecological exposure pathways
associated with impacted soils. Clean cap
material would prevent direct exposure of
humans and ecological receptors to
contaminated soil. Erosion control measures on
the cap would reduce or eliminate the potential
COPC releases to the creek.
• Capping contaminated soils would provide
overall protection of human health and the
environment by eliminating the potential human
health and ecological exposure pathways
associated with impacted soils. Clean cap
material would prevent direct exposure of
humans and ecological receptors to contaminated
soil. Erosion control measures on the cap would
reduce or eliminate the potential COPC releases
to the creek.
Compliance with ARARs
There are chemical-specific ARARs for
soils. The No Action alternative would
not meet these ARARs.
• This alternative would comply with chemical-
specific, location-specific and action-specific
ARARs.
• Soil caps are routinely installed in compliance
with ARARs.
• This alternative would comply with chemical-
specific, location-specific and action-specific
ARARs.
• Soil caps are routinely installed in compliance
with ARARs.
• This alternative would comply with chemical-
specific, location-specific and action-specific
ARARs.
• Soil caps are routinely installed in compliance
with ARARs.
Long-Term Effectiveness and Permanence
This alternative does not provide
significant long-term effectiveness.
This alternative would not effectively
eliminate the potential exposure to
contaminants in soil. The rate of
improvement is unpredictable and would
not be verified due to the lack of
monitoring under this alternative.
• This alternative would provide long-term
effectiveness and permanence by eliminating
the potential human health and ecological
exposure pathways associated with impacted
soil.
• A site management plan would be
implemented to confirm that the soil cap
remains effective overtime.
• This alternative would provide long-term
effectiveness and permanence by eliminating
the potential human health and ecological
exposure pathways associated with impacted
soil.
• A site management plan would be implemented
to confirm that the soil cap remains effective
overtime.
• This alternative would provide long-term
effectiveness and permanence by eliminating the
potential human health and ecological exposure
pathways associated with impacted soil.
• A site management plan would be implemented
to confirm that the soil cap remains effective over
time.
Reduction of Toxicity, Mobility, or Volume through
Treatment
The toxicity and volume of COPCs in
soil would not be significantly reduced
under the No Action alternative because
no treatment would be conducted. The
overall bioavailability and mobility of
contaminants in the soil may be reduced
over time as some natural recovery
processes occur.
• Removal of contaminated soils would result in
reducing the toxicity, mobility, and volume of
the soil. The greater the volume of soil
removed, the greater the reduction in toxicity,
mobility and volume of COPCs.
• Capping relies on isolation rather than
treatment to achieve effectiveness. Natural
processes that reduce toxicity such as
biological degradation of organic compounds
would continue to occur beneath the soil cap
following construction, although these
processes may be insignificant.
• Removal of contaminated soils would result in
reducing the toxicity, mobility, and volume of
the soil. The greater the volume of soil
removed, the greater the reduction in toxicity,
mobility and volume of COPCs.
• Capping relies on isolation rather than
treatment to achieve effectiveness. Natural
processes that reduce toxicity such as biological
degradation of organic compounds would
continue to occur beneath the soil cap
following construction, although these
processes may be insignificant.
• Capping relies on isolation rather than treatment
to achieve effectiveness. Natural processes that
reduce toxicity such as biological degradation of
organic compounds would continue to occur
beneath the soil cap following construction,
although these processes may be insignificant.
Table 8.1
Detailed Evaluation of Soil Alternatives
for Lower Ley Creek
Page 1 of 3
-------
Table 8.1 (continued)
Detailed Evaluation of Soil Remedial Alternatives for Lower Ley Creek
i:\iiliiiition ( riteriii
Soil AlleriiiiliM' 1
Soil AlUTiiiiliM' 2
Soil Altcriiiithc 3
Soil Altcriiiithc 4
No Action
K\c:i\:ilion of Soil to Meet ( Ionnup (lo:ils
K\c:i\iition of Southern S\\:ile Soils to Meet
(Iciiniip (¦ o;iIs iincl Soil ("sip lor Northwest
Soils
Soil ("sip (her All ('onl:imin;ilcd Soils
Short-Term Effectiveness
The No Action alternative does not
include any physical construction
measures in any areas of contamination
and, therefore, would not present any
potential adverse impacts to the
community or workers as a result of its
implementation.
• Physical construction of this alternative could
likely be completed in approximately one
construction season. The effects of this
alternative during the construction and
implementation phase would potentially
include:
o Impact to local property owners during soil
removals and capping;
o Impact to local pipelines during soil
removals and capping;
o Additional potential risk presented by
volatilization of organics during excavation
and materials handling;
o Potential for on-site worker and
transportation accidents associated with
remedial construction; and
o Potential for on-site workers to receive
adverse impacts through dermal contact
with contaminated soil.
• Excavation and contaminated media handling
may create air emissions and odors through
release of SVOCs and VOCs from the
removed materials. However, significant odors
and air emissions are not expected. This
short-term impact may be minimized or
mitigated through engineering controls
including controlled excavation, wearing
proper PPE, and adequate monitoring.
• Physical construction of this alternative could
likely be completed in approximately one
construction season. The effects of this
alternative during the construction and
implementation phase would potentially
include:
o Impact to local property owners during soil
removals and capping;
o Impact to local pipelines during soil
removals and capping;
o Additional potential risk presented by
volatilization of organics during excavation
and materials handling;
o Potential for on-site worker and
transportation accidents associated with
remedial construction; and
o Potential for on-site workers to receive
adverse impacts through dermal contact with
contaminated soil.
• Excavation and contaminated media handling
may create air emissions and odors through
release of SVOCs and VOCs from the removed
materials. However, significant odors and air
emissions are not expected. This short-term
impact may be minimized or mitigated through
engineering controls including controlled
excavation, wearing proper PPE, and adequate
monitoring.
• Physical construction of this alternative could
likely be completed in approximately one
construction season. The effects of this alternative
during the construction and implementation phase
would potentially include:
o Impact to local property owners during soil
removals and capping;
o Impact to local pipelines during soil removals
and capping;
o Additional potential risk presented by
volatilization of organics during excavation
and materials handling;
o Potential for on-site worker and transportation
accidents associated with remedial
construction; and
o Potential for on-site workers to receive adverse
impacts through dermal contact with
contaminated soil.
• Based on experience at other soil capping sites,
the impacts are not anticipated to be significant.
Proven, available engineering controls would be
employed during the soil cap implementation. In
addition, steps would be taken to minimize the
impact to local property owners during the soil
capping process.
Table 8.1
Detailed Evaluation of Soil Remedial Alternatives
for Lower Ley Creek
Page 2 of 3
-------
Table 8.1 (continued)
Detailed Evaluation of Soil Remedial Alternatives for Lower Ley Creek
i:\iiliiiition ( riteriii
Soil AlleriiiiliM' 1
Soil AI(criiii(iM> 2
Soil AhcriiiiliM' 3
Soil Allcriiiilhc 4
No Action
K\c:i\:ilion of Soil (o Meet ( Ionnup (lo:ils
K\c:i\iilion of Southern S\\:ile Soils to Meet
(Iciiniip (¦ o;iIs iincl Soil ("sip lor Northwest
Soils
Soil ("sip (her All C ont:imin:ilcil Soils
Implementability
The No Action alternative would be
easy to implement as there are no
activities to undertake.
• Appropriate soil excavation and capping
technologies are readily available and
implementable, and construction procedures
are well established. Excavation and capping
have been demonstrated as effective remedial
technologies for impacted soils at numerous
sites. The technology, equipment,
subcontractors, personnel, and facilities
required to successfully excavate or cap
contaminated soils are available in the
environmental market place. Guidance
documents are also available from numerous
sources, including the USEPA and the
USACE, on how to successfully design,
construct, and monitor soil cap projects.
• Short-term and long-term monitoring as part of
a site management plan can be easily
implemented to verify effectiveness.
Additional remedial actions can readily be
undertaken should the alternative prove to be
ineffective or partially ineffective although
greater removal volumes would require either
longer durations or additional dredging and
excavation equipment.
• The presence of two large buried pipelines in
the Northwest Soils area may limit the removal
of contaminated soils in that vicinity.
Therefore, in those areas, a soil cap will be
installed above contaminated soil..
• Appropriate soil excavation and capping
technologies are readily available and
implementable, and construction procedures are
well established. Excavation and capping have
been demonstrated as effective remedial
technologies for impacted soils at numerous
sites. The technology, equipment,
subcontractors, personnel, and facilities
required to successfully excavate or cap
contaminated soils are available in the
environmental market place. Guidance
documents are also available from numerous
sources, including the USEPA and the USACE,
on how to successfully design, construct, and
monitor soil cap projects.
• Short-term and long-term monitoring as part of
a site management plan can be easily
implemented to verify effectiveness.
Additional remedial actions can readily be
undertaken should the alternative prove to be
ineffective or partially ineffective although
greater removal volumes would require either
longer durations or additional dredging and
excavation equipment.
• Appropriate soil capping technologies are readily
available and implementable, and construction
procedures are well established. Soil capping has
been demonstrated as an effective remedial
technology for impacted soils at numerous sites.
The technology, equipment, subcontractors,
personnel, and facilities required to successfully
excavate or cap contaminated soils are available
in the environmental market place. Guidance
documents are also available from numerous
sources, including the USEPA and the USACE,
on how to successfully design, construct, and
monitor soil cap projects.
• Short-term and long-term monitoring as part of a
site management plan can be easily implemented
to verify effectiveness. Additional remedial
actions can readily be undertaken should the
alternative prove to be ineffective.
Cost (On-site Disposal)1
$ 49,636
$9,113,494
$ 9,027,261
$ 7,917,433
Cost (Off-site Disposal)1
$ 49,636
$ 18,987,191
$ 18,737,968
$ 16,298,507
State Acceptance
Not Evaluated
Not Evaluated
Not Evaluated
Not Evaluated
Community Acceptance
Not Evaluated
Not Evaluated
Not Evaluated
Not Evaluated
Notes:
1 Cost calculations for each alternative are presented in Appendix C
COPC - chemical of potential concern
RAO - remedial action objective
PRO - preliminary remediation goal
ARAR - applicable or relevant and appropriate requirement
CWA - Clean Water Act
EPA - U.S. Environmental Protection Agency
SVOC - semi-volatile organic compound
VOC - volatile organic compound
PPE - personal protective equipment
USACE - U.S. Army Corps of Engineers
Table 8.1
Detailed Evaluation of Soil Remedial Alternatives
for Lower Ley Creek
Page 3 of 3
-------
Table 8.2
Detailed Evaluation of Sediment Remedial Alternatives for Lower Ley Creek
K\iiliiiili()ii Criteriii
Soil Altcriiiilne 1
Sediment Ahcrn;iti\c 2
Sediment Allcriiiilne 3
Sediment Ahcrn;iti\c 4
Sediment Allcriiiilne 5
No Action
Rcmo\:il of All Sediments to
('lesimip (io;ils
(ii'iinuhir Miileriid Sediment ("sip
Kn»inccred lientonite Sediment ("sip
Monitored N;itur;il Reco\erv
Overall Protection of Human Health and
the Environment
The No Action Alternative
would not be protective of
human health and the
environment, because this
would not actively address the
contaminated sediments that
present unacceptable risks of
exposure to receptors or the
release and transport of COPCs
at the site. The RAOs or PRGs
would not be met under this
alternative.
Excavation to remove all impacted
sediments would provide protection of
human health and the environment by
eliminating the exposure pathways
associated with impacted sediments.
Backfilling with clean fill would provide
habitat forbenthic species to colonize.
Sediment capping would provide overall protection
of human health and the environment by
eliminating the potential human health and
ecological exposure pathways associated with
impacted sediment. Clean cap material would
prevent direct exposure of humans and ecological
receptors to contaminated sediment. Reduction in
direct exposure to COPCs and potential COPC
releases to the water column are expected to reduce
risks to fish and to humans and wildlife that
consume fish
Sediment capping would provide overall
protection of human health and the
environment by eliminating the potential
human health and ecological exposure
pathways associated with impacted
sediment. Clean cap material would prevent
direct exposure of humans and ecological
receptors to contaminated sediment.
Reduction in direct exposure to COPCs and
potential COPC releases to the water column
are expected to reduce risks to fish and to
humans and wildlife that consume fish
MNR of the creek sediments would not
eliminate the risks to human health and
the environment. If completed in
conjunction with controls it would
protect humans by eliminating the
potential human exposure, but would
not eliminate the exposures to the
environment. Environmental exposures
would be expected to drop due to
natural processes in the creek (i.e.,
sedimentation, biodegradation).
Compliance with ARARs
There are no chemical-specific
ARARs for sediments.
However, there are TBCs (i.e.,
NYSDEC sediment screening
values). The No Action
alternative would not meet these
TBCs.
• There are no chemical-specific ARARs
for sediments. However, there are TBCs
(i.e., NYSDEC sediment screening
values). Sediment removal would
comply with TBCs.
• The excavation and backfilling work
may result in short-term localized
exceedences of surface water criteria
due to suspension of impacted sediment
during excavation. However, the water
quality impacts from excavation would
meet the substantive water quality
requirements imposed by New York
State on entities seeking a dredged
material discharge permit under Section
404 of the CWA.
• There are no chemical-specific ARARs for
sediments. However, there are TBCs (i.e.,
NYSDEC sediment screening values). Sediment
capping would comply with TBCs.
• Sediment caps are routinely installed in
compliance with ARARs and TBCs, which would
include the substantive requirements of the dredge
and fill permit program under Section 404 of the
CWA.
• There are no chemical-specific ARARs
for sediments. However, there are TBCs
(i.e., NYSDEC sediment screening
values). Sediment capping would comply
with TBCs.
• Sediment caps are routinely installed in
compliance with ARARs and TBCs,
which would include the substantive
requirements of the dredge and fill permit
program under Section 404 of the CWA.
There are no chemical-specific ARARs
for sediments. However, there are
TBCs (i.e., NYSDEC sediment
screening values). The MNR
alternative would not meet these TBCs.
Long-Term Effectiveness and Permanence
This alternative does not
provide significant long-term
effectiveness. The creek would
be expected to continue to
improve naturally over time.
However, it would not
effectively eliminate the
potential exposure to
contaminants in sediment. The
rate of improvement is
unpredictable and would not be
verified due to the lack of
monitoring under this
alternative.
This alternative would provide long-term
effectiveness and permanence by
eliminating the potential human health and
ecological exposure pathways associated
with impacted sediment.
• Consistent with EPA design guidance for caps,
the sediment cap would be designed to withstand
erosional forces resulting from the 100-year
return interval storm event. Controls, such as
bans on dredging the capped area, would be
implemented as necessary to help ensure the long-
term integrity of the cap.
• As part of a site management plan, maintenance
and monitoring program would be implemented
to confirm that the sediment cap remains effective
over time.
• Consistent with EPA design guidance for
caps, the sediment cap would be designed
to withstand erosional forces resulting
from the 100-year return interval storm
event. Controls, such as bans on dredging
the capped area, would be implemented as
necessary to help ensure the long-term
integrity of the cap.
• As part of a site management plan, a
maintenance and monitoring program
would be implemented to confirm that the
sediment cap remain effective over time.
• This alternative would not likely
provide long-term effectiveness and
permanence because the potential
human health and ecological
exposure pathways associated with
impacted sediment would remain at
the site for an extended period of
time.
• Controls, such as bans on dredging
and fishing, would be implemented
as necessary until monitoring
confirms the elimination of the
contaminant risks.
Table 8.2
Detailed Evaluation of Sediment Alternatives
for Lower Ley Creek
Page 1 of 3
-------
Table 8.2 (continued)
Detailed Evaluation of Sediment Remedial Alternatives for Lower Ley Creek
K\iiliiiili()ii Criteriii
Soil Altcriiiilne 1
Sediment Allcrn;ilne 2
Sediment Altcriiiilne 3
Sediment Altcriiiitne 4
Sediment Altcriiiilne 5
No Action
Rcmo\:il of All Sediments to
C'le;mii|) (io:ils
(ii'iinuhir Miiteriid Sediment ("sip
Kn»inccred lientonite Sediment C:ip
Monitored N;itur;il Reco\erv
Reduction of Toxicity, Mobility, or Volume
through Treatment
The toxicity and volume of
COPCs in sediment would not
be significantly reduced under
the No Action alternative
because no treatment would be
conducted. The overall
bioavailability and mobility of
contaminants in the sediment
may be reduced over time as
some natural recovery processes
occur.
Excavation processes would result in
reducing the toxicity, mobility, and
volume of the sediment. Treatment of
water resulting from the excavation would
reduce the toxicity, mobility and volume
of COPCs that are mobilized from the
sediment into the water stream. The
greater the volume of sediment removed,
the greater the reduction in toxicity,
mobility and volume that would result
from these processes.
Capping relies on isolation rather than treatment to
achieve effectiveness. Capping would result in
some reduction in the volume of the impacted
sediment due to initial excavation before the
installation of the cap. Natural process that reduce
toxicity such as biological degradation of organic
compounds would continue to occur beneath the
cap following construction, although these
processes may be insignificant and would not be
monitored or verified.
Capping relies on isolation rather than
treatment to achieve effectiveness. Capping
would result in some reduction in the volume
of the impacted sediment due to initial
excavation before the installation of the cap.
Natural process that reduce toxicity such as
biological degradation of organic compounds
would continue to occur beneath the cap
following construction, although these
processes may be insignificant and would
not be monitored or verified.
Natural processes that reduce toxicity,
such as biological degradation of
organic compounds along with
sedimentation to reduce the exposure to
the contaminants, would continue to
occur in the creek and be monitored.
Short-Term Effectiveness
The No Action alternative does
not include any physical
construction measures in any
areas of contamination and,
therefore, would not present any
potential adverse impacts to the
community or workers as a
result of its implementation.
• Physical construction of this alternative
could likely be completed in
approximately two construction
seasons. The effects of this alternative
during the construction and
implementation phase would potentially
include:
o Impact to local property owners
during sediment removals;
o Temporary loss of creek habitat;
o Temporary impacts of resuspension
of COPCs and potential release into
the water column during excavation;
o Additional potential risk presented by
volatilization of organics during
excavation and materials handling;
o Potential for on-site worker and
transportation accidents associated
with remedial construction; and
o Potential for on-site workers to
receive adverse impacts through
dermal contact with contaminated
sediment.
• Excavation, contaminated media
handling, and dewatering may create air
emissions and odors through release of
SVOCs and VOCs from the removed
materials. However, significant odors
and air emissions are not expected.
This short-term impact may be
minimized or mitigated through
engineering controls including
controlled excavation, wearing proper
PPE, and adequate monitoring.
• Physical construction of the sediment cap could
likely be completed in approximately one
construction season. The effects of this
alternative during the construction and
implementation phase would potentially include:
o Impact to local property owners during
sediment removals;
o Temporary loss of creek habitat;
o Temporary impacts of resuspension of COPCs
and potential release into the water column
during excavation;
o Additional potential risk presented by
volatilization of organics during excavation
and materials handling;
o Potential for on-site worker and transportation
accidents associated with remedial
construction; and
o Potential for on-site workers to receive adverse
impacts through dermal contact with
contaminated sediment.
• Excavation, contaminated media handling, and
dewatering may create air emissions and odors
through release of SVOCs and VOCs from the
removed materials. However, significant odors
and air emissions are not expected. This short-
term impact may be minimized or mitigated
through engineering controls including controlled
excavation, wearing proper PPE, and adequate
monitoring.
• The primary short-term negative ecological
impact under this alternative would be the
temporary elimination of benthic macro
invertebrate communities.
• Physical construction of the sediment cap
could likely be completed in
approximately one construction season.
The effects of this alternative during the
construction and implementation phase
would potentially include:
o Impact to local property owners during
sediment removals;
o Temporary loss of creek habitat;
o Temporary impacts of resuspension of
COPCs and potential release into the
water column during excavation;
o Additional potential risk presented by
volatilization of organics during
excavation and materials handling;
o Potential for on-site worker and
transportation accidents associated with
remedial construction; and
o Potential for on-site workers to receive
adverse impacts through dermal contact
with contaminated sediment.
• Excavation, contaminated media
handling, and dewatering may create air
emissions and odors through release of
SVOCs and VOCs from the removed
materials. However, significant odors and
air emissions are not expected. This
short-term impact may be minimized or
mitigated through engineering controls
including controlled excavation, wearing
proper PPE, and adequate monitoring.
• The primary short-term negative
ecological impact under this alternative
would be the temporary elimination of
benthic macro invertebrate communities.
• The MNR alternative does not
include any physical construction
measures in any areas of
contamination and, therefore, would
not present any potential adverse
impacts to the community.
• Monitoring activities would present
temporary health and safety risks to
workers that could easily be
addressed with proper work
procedures and equipment.
Table 8.2
Detailed Evaluation of Sediment Alternatives
for Lower Ley Creek
Page 2 of 3
-------
Table 8.2 (continued)
Detailed Evaluation of Sediment Remedial Alternatives for Lower Ley Creek
K\iiliiiili()ii (rileriii
Soil Allcriiiilne 1
Sediment Allern;iti\e 2
Sediment Allcriiiilnc 3
Sediment Allcrn:itne 4
Sediment Allcriiiilnc 5
No Action
Rcmo\:il of All Sediments to
C'le;mii|) (io:ils
(ii'iinuhir M:iteri;il Sediment ("sip
Kn»ineered lientonite Sediment C:ip
Monitored N;ilur;il Reco\erv
Implementability
The No Action alternative
would be easy to implement as
there are no activities to
undertake.
• Appropriate excavation and sediment
backfilling technologies are readily
available and implementable, and
construction procedures are well
established. Excavation has been
demonstrated as an effective remedial
technology for impacted sediments at
numerous sites. Guidance documents
are also available from numerous
sources, including the EPA and the
USACE, on how to successfully design,
construct, and monitor excavation
projects. The technology, equipment,
subcontractors, personnel, and facilities
required to successfully complete this
alternative are available in the
environmental market place.
• Short-term and long-term monitoring of
this alternative can be easily
implemented to verify effectiveness.
Additional remedial actions can readily
be undertaken should the alternative
prove to be ineffective or partially
ineffective although greater removal
volumes would require either longer
durations or additional excavation
equipment.
• Appropriate sediment capping technologies are
readily available and implementable, and
construction procedures are well established.
Sediment capping using granular material and
armor stone has been demonstrated as an effective
remedial technology for impacted sediments at
numerous sites. The technology, equipment,
subcontractors, personnel, and facilities required
to successfully complete this alternative are
available in the environmental market place.
• Short-term and long-term monitoring of this
alternative can be easily implemented to verify
effectiveness. Additional remedial actions can
readily be undertaken should the alternative prove
to be ineffective or partially ineffective.
• Appropriate sediment capping
technologies are readily available and
implementable, and construction
procedures are well established. Sediment
capping using engineered bentonite
material has been demonstrated as an
effective remedial technology for
impacted sediments at numerous sites.
The technology, equipment,
subcontractors, personnel, and facilities
required to successfully complete this
alternative are available in the
environmental market place.
• Short-term and long-term monitoring of
this alternative can be easily implemented
to verify effectiveness. Additional
remedial actions can readily be
undertaken should the alternative prove to
be ineffective or partially ineffective.
Short-term and long-term monitoring
of this alternative can be easily
implemented to verify effectiveness.
Additional remedial actions can readily
be undertaken should the alternative
prove to be ineffective or partially
ineffective.
Cost (On-site Disposal)1
$ 49,636
$ 6,980,035
$ 10,129,087
$ 10,154,607
$ 1,973,038
Cost (Off-site Disposal)1
$ 49,636
$ 16,523,685
$ 17,563,198
$ 15,348,472
$ 1,973,038
State Acceptance
Not evaluated
Not evaluated
Not evaluated
Not evaluated
Not evaluated
Community Acceptance
Not evaluated
Not evaluated
Not evaluated
Not evaluated
Not evaluated
Notes:
1 Cost calculations for each alternative are presented in Appendix C
COPC - chemical of potential concern
RAO - remedial action objective
PRO - preliminary remediation goal
ARAR - applicable or relevant and appropriate requirement
CWA - Clean Water Act
EPA - U.S. Environmental Protection Agency
SVOC - semi-volatile organic compound
VOC - volatile organic compound
PPE - personal protective equipment
USACE - U.S. Army Corps of Engineers
TBC - To-Be-Considered
NYSDEC - New York State Department of Environmental Conservation
Table 8.2
Detailed Evaluation of Sediment Alternatives
for Lower Ley Creek
Page 3 of 3
-------
Table 9.1
Comparative Evaluation of Soil Remedial Alternatives for Lower Ley Creek
Evaluation Criteria
Comparative Evaluation
Overall Protection of Human Health and the
Environment
• Alternative 1 is not protective of human health and the environment.
• Alternative 2 is the most protective because it completely removes the contaminants from the environment where possible. Alternative 3 is slightly less
protective of human health and the environment because it removes less contaminants from the soils and relies more on isolation (capping) to eliminate
exposure pathways.
• Alternative 4 is slightly less protective than Alternatives 2 and 3 because it eliminates the exposure pathways of soil contaminants via isolation (capping)
rather than removing them from the environment.
Compliance with ARARs
• Alternative 1 would not meet chemical-specific ARARs or be in compliance with TSCA.
• Alternatives 2, 3, and 4 would meet the chemical-specific, location-specific, and action-specific ARARs and be in compliance with TSCA.
Long-Term Effectiveness and Permanence
• Alternative 1 would not provide long-term effectiveness or permanence. Under the remaining alternatives, long-term effectiveness and permanence would
depend on the effectiveness of source control (excavation and capping) measures in maintaining reliable protection for human health and the environment
once RAOs are met. It is expected that Alternatives 2, 3, and 4 would provide long-term effectiveness and permanence.
• With the exception of Alternative 1, long-term monitoring and the implementation of a site management plan would ensure the adequacy and reliability of
these actions to control untreated wastes that remain following completion of the remedial action. All Soil Alternatives, with the exception of the No Action
Alternative, would require some degree of long-term monitoring. However, Alternative 2 would provide the highest degree of long-term effectiveness and
permanence due to the significant reduction is oil contamination via excavation. Alternatives 3 and 4 would require more extensive long-term monitoring
activities than Alternative 2 due to monitoring requirements associated with cap maintenance. Alternative 4 would rely only on capping and would therefore
require the most extensive long-term monitoring.
Reduction of Toxicity, Mobility, or Volume
through Treatment
• Over a long period of time, natural processes would slightly reduce the toxicity, mobility, and volume of contaminants in the soil under Alternative 1.
However, they would not be reduced significantly over time and Alternative 1 would not monitor or control these processes.
• In comparison with the other alternatives, Alternative 2 would reduce the toxicity, mobility, and volume of impacted soils the greatest through extensive soil
excavation. Alternative 3 would also reduce a large volume of the contaminated soils in the environment by excavation in the Southern Swale Soil Area and
reduce the mobility of contaminants in the soil by capping in the Northwest Soil Area.
• Alternative 4 reduces the mobility of contaminants through soil capping, but has little effect on the toxicity and volume of contaminants.
Short-Term Effectiveness
• The alternative with the least amount of physical construction and material movement (Alternative 1) would have the lowest amount of short-term impacts on
the environment.
• All the active soil alternatives (2, 3, and 4) would result in short-term habitat destruction and impact to local property owners by either excavation or capping
activities. Alternatives 2 and 3 would have the most short-term impacts because excavation activities would elevate short term risks for construction workers,
impact local property owners, and result in the temporary loss of habitats. The capping of soils associated with Alternative 4 would have slightly less short-
term impacts than the excavation of contaminated soil proposed in Alternatives 2 and 3.
• For all alternatives, appropriate measures would be taken to minimize any adverse impacts from soil excavation activities, including measures to prevent
transport of fugitive dust and exposure of workers and downgradient receptors to contamination. All of the short-term impacts can be minimized or mitigated
by exercising sound engineering practices, following appropriate health and safety protocols, wearing proper PPE, and adequate monitoring.
Implementability
• No technical or administrative issues have been identified that would limit the feasibility of implementing Alternative 1.
• Appropriate soil excavation technologies are readily available and implementable for Alternatives 2 and 3. The size and duration of the removal activities in
Alternative 2 would present more implementation challenges than the other three alternatives.
• Appropriate soil capping technologies are readily available and implementable for Alternatives 2, 3, and 4.
• Short-term and long-term monitoring as part of a site management plan for Alternatives 2, 3, and 4 can be easily implemented to verify effectiveness.
Additional remedial actions can readily be undertaken, should the alternatives prove to be ineffective or partially ineffective.
Table 9.1
Comparative Evaluation of Soil Alternatives
for Lower Ley Creek
Page 1 of 2
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Table 9.1 (continued)
Comparative Evaluation of Soil Remedial Alternatives for Lower Ley Creek
Evaluation Criteria
Comparative Evaluation
Cost
• Capital costs for soil removal, off-site transportation, and disposal or treatment are higher compared to costs involving installation of a soil cap over
equivalent target areas. Operation and maintenance costs for a soil removal alternative will be lower than for implementation of a soil capping alternative for
an equivalent area, as removal-only alternatives do not require long-term maintenance.
• Soil cap installation costs are also included as part of this remedial alternative. Costs for soil capping alternatives vary primarily with the total area covered.
Operation and maintenance costs for a soil cap alternative will be higher than for a soil removal alternative involving the same areas because of soil cap
maintenance costs, institutional controls, and the implementation of a site management plan.
• On-site Disposal
o The cost estimates for each soil remedial alternative are detailed in Appendix C, Table C-l. The alternatives with the least amount of construction and
off-site disposal activity are the least costly to implement. Alternative 1 is the least costly. Alternative 2 includes the largest amount of excavation and
disposal of impacted soils and therefore carries the highest cost. Alternative 3, which proposes a mix of excavation and capping activities, is the next
costliest alternative. Finally, Alternative 4 (Capping of Soils) is higher in cost than the no action alternative but is less costly than the excavation
alternatives because of the reduced excavation costs.
• Off-site Disposal
o The cost estimates for each soil remedial alternative are detailed in Appendix C, Table C-3. The alternatives with the least amount of construction and
off-site disposal activity are the least costly to implement. Alternative 1 is the least costly. Alternative 2 includes the largest amount of excavation and
disposal of impacted soils and therefore carries the highest cost. Alternative 3, which proposes a mix of excavation and capping activities, is the next
costliest alternative. Finally, Alternative 4 (Capping of Soils) is higher in cost than the no action alternative but is significantly less costly than the
excavation alternatives because of the reduced waste disposal costs.
Notes:
RAO - remedial action objective
ARAR - applicable or relevant and appropriate requirement
PPE - personal protective equipment
TSCA - Toxic Substances Control Act
Table 9.1
Comparative Evaluation of Soil Remedial Alternatives
for Lower Ley Creek
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Table 9.2
Comparative Evaluation of Sediment Remedial Alternatives for Lower Ley Creek
Evaluation Criteria
( omnaralive K va 1 ua 1 ion
Overall Protection of
Human Health and the
Environment
• Alternative 1 is not protective of human health and the environment.
• Alternative 2 is the most protective because it provides complete removal of the contaminants from the environment where possible.
• Alternatives 3 and 4 are slightly less protective than Alternative 2 because they eliminate the exposure pathways of sediment contaminants rather than removing contaminants from the
environment.
• Alternative 5 is not protective of human health and the environment
Compliance with ARARs
• There are no chemical-specific ARARs for sediments. However, there are TBC values (i.e., NYSDEC sediment screening values). Alternative 1 would not meet TBC sediment
screening values or be in compliance with TSCA.
• Sediment removal in Alternative 2 would comply with TBCs and be in compliance with TSCA. The excavation and backfilling work may result in short-term localized exceedences of
surface water criteria due to suspension of impacted sediment during excavation. However, the water quality impacts from excavation would meet the substantive water quality
requirements imposed by New York State on entities seeking a dredged material discharge permit under Section 404 of the CWA.
• Sediment caps in Alternatives 3 and 4 are routinely installed in compliance with ARARs and TBCs, which would include the substantive requirements of the dredge and fill permit
program under Section 404 of the CWA.
• There are no chemical-specific ARARs for sediments. However, there are TBC values (i.e., NYSDEC sediment screening values). Alternative 5 would not meet TBC sediment
screening values or be in compliance with TSCA.
Long-Term Effectiveness
and Permanence
• Alternative 1 would not provide long-term effectiveness or permanence. Alternative 2 provides the most long-term effectiveness and permanence because it permanently removes all
the contaminants in sediments.
• Consistent with EPA design guidance for caps, the sediment caps and backfill areas associated with Alternatives 3 and 4 would be designed to withstand erosional forces resulting from
the 100-year return interval storm event. Institutional controls, such as bans on dredging the capped or backfilled areas, would be implemented as necessary to help ensure the long-
term integrity of these barriers.
• With the exception of Alternative 1, long-term monitoring and the implementation of a site management plan would ensure the adequacy and reliability of these actions to control
untreated wastes that remain. Alternative 2 would require the least amount of long-term monitoring because all of the contaminated sediments would be removed. Alternatives 3 and 4
would require the most amount of long-term monitoring because most of the contaminated sediments would be left in place. A site management plan would needs to be implemented
under these alternatives to ensure the effectiveness and permanence of the sediment caps.
• Alternative 5 would not provide long-term effectiveness or permanence.
Reduction of Toxicity,
Mobility, or Volume through
Treatment
• Over a long period of time, natural processes would slightly reduce the toxicity, mobility, and volume of contaminants in the sediment under Alternative 1. However, they would not be
reduced significantly over time and Alternative 1 would not monitor or control these processes.
• In comparison with the other alternatives, Alternative 2 would reduce the toxicity, mobility, and volume of impacted soils the greatest through extensive sediment excavation.
• Alternatives 3 and 4 reduce the mobility of contaminants through sediment capping, but have little effect on the toxicity and volume of contaminants.
• Over a long period of time, natural processes would slightly reduce the toxicity, mobility, and volume of contaminants in the sediment under Alternative 5 and this alternative would
monitor and control these processes.
Short-Term Effectiveness
• The alternative with the least amount of physical construction and material movement (Alternative 1) would have the lowest amount of short-term impacts on the environment.
• All the other alternatives would result in short-term habitat destruction and impact to local property owners by either excavation or capping activities. Alternative 2 would have the most
short-term impacts because excavation activities would elevate short term risks for construction workers, impact local property owners, and lead to the temporary loss of habitats. The
capping of sediments associated with Alternatives 3 and 4 would have slightly less short-term impacts than the excavation of contaminated sediments proposed in Alternative 2.
• For all alternatives, the short-term impacts would be minimized or mitigated by exercising sound engineering practices, following appropriate health and safety protocols, wearing
proper PPE, and adequate monitoring.
• Alternative 5 does not include any physical construction measures in any areas of contamination and, therefore, would not present any potential adverse impacts to the community.
Table 9.2
Comparative Evaluation of Sediment Alternatives
for Lower Ley Creek
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Table 9.2 (continued)
Comparative Evaluation of Sediment Remedial Alternatives for Lower Ley Creek
Evaluation Criteria
Comparative Evaluation
Implementability
• No technical or administrative issues have been identified that would limit the feasibility of implementing Alternative 1.
• Appropriate sediment excavation technologies are readily available and implementable for Alternative 2. The size and duration of the removal activities in Alternative 2 would present
more implementation challenges than the other alternatives.
• Appropriate sediment capping technologies are readily available and implementable for Alternatives 3 and 4.
• Short-term and long-term monitoring as part of a site management plan for Alternatives 3 and 4 can be easily implemented to verify effectiveness. Additional remedial actions can
readily be undertaken, should the alternatives prove to be ineffective or partially ineffective.
• Short-term and long-term monitoring for Alternative 5 can be easily implemented to verify effectiveness. Additional remedial actions can readily be undertaken should the alternative
prove to be ineffective or partially ineffective.
Cost
• For the granular/armor sediment capping alternative (Alternative 3), the requirements of 2 ft of habitat material, armoring requirements, isolation thickness requirements, along with the
need to excavate additional sediments to maintain the bathymetry of the creek; causes this alternative to be more expensive than the excavation alternative.
• The requirement of 2 ft of habitat material above the engineered bentonite capping alternative (Alternative 4), along with the need to excavate additional sediments to maintain the
bathymetry of the creek causes this alternative to be more expensive than the excavation alternative (Alternative 2).
• Operation and maintenance costs for a sediment removal alternative will be lower than for implementation of a capping alternative for an equivalent area, as removal-only alternatives
do not require long-term maintenance.
• Operation and maintenance costs for a capping alternative will be higher than for a sediment removal alternative involving the same areas because of site management costs and, to a
lesser extent, potential cap maintenance required in the long term.
• The cost estimates for each sediment remedial alternative are detailed in Appendix C. There are significant relevant differences between the alternatives depending on on-site disposal
of contaminated sediment or off-site disposal.
• On-site Disposal
o The cost estimates for each sediment remedial alternative are detailed in Appendix C, Table C-2. Alternative 1 is the least costly alternative, followed by Alternative 5. Although
Alternative 2 includes the largest amount of excavation, the lack of required capping materials for backfill leads to the overall cost of this alternative being less than the capping
alternatives. Alternatives 3 and 4 (Capping of Sediments) are higher in costs than the other alternatives. Capping Alternative 4 and Capping Alternative 3 have very similar overall
costs.
• Off-site Disposal
o The cost estimates for each sediment remedial alternative are detailed in Appendix C, Table C-4. Alternative 1 is the least costly alternative, followed by Alternative 5. Although
Alternative 2 includes the largest amount of excavation, the lack of required capping materials for backfill leads to the overall cost of this alternative being less than the Granular
Material Cap Alternative (Alternative 3) but slightly higher than the Engineered Bentonite Cap Alternative (Alternative 4). Because Capping Alternative 4 requires less sediment
removal than Capping Alternative 3, it has a lower overall cost.
Notes:
ARAR - applicable or relevant and appropriate requirement
CWA - Clean Water Act
PPE - personal protective equipment
TBC - To-Be-Considered
NYSDEC - New York State Department of Environmental Conservation
MNR - Monitored Natural Recovery
Table 9.2
Comparative Evaluation of Sediment Alternatives
for Lower Ley Creek
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APPENDIX A
Identification of Federal and State Applicable or Relevant and Appropriate
Requirements (ARARs) and To Be Considered (TBCs)
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TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION 1-1
2.0 ARAR AM) TBC IDENTIFICATION 2-1
2.1 CHEMICAL-SPECIFIC ARARs AND TBCs 2-1
2.1.1 Air 2-1
2.1.2 Biota 2-1
2.1.3 Sediment 2-1
2.1.4 Federal—Safe Drinking Water Act Regulations, 40 CFRPart 141 2-1
2.1.5 Federal—Clean Water Act Regulations, 40 CFR Part 129 2-2
2.1.6 State—New York State Regulations, 6 NYCRR Parts 608, 700-706 2-2
2.2 LOCATION-SPECIFIC ARARs AND TBCs 2-4
2.2.1 Federal—Executive Order No. 11988, Floodplain Management, 42
Federal Register 26951 (May 25, 1977) 2-4
2.2.2 Federal—Executive Order No. 11990, Protection of Wetlands, 42
Federal Register 26961 (May 25, 1977) 2-4
2.2.3 Federal—EPA Regulations, 40 CFR Part 6, Subpart A 2-5
2.2.4 Federal—Fish and Wildlife Coordination Act, 16 USC § 662 Summary 2-5
2.2.5 Federal—Fish and Wildlife Coordination Act Regulations, 40 CFR §
6.302 2-6
2.2.6 Federal—National Historic Preservation Act Regulations, 36 CFR Part
800 2-6
2.2.7 State—New York State Freshwater Wetlands Law Regulations, 6
NYCRR Parts 662-665 2-6
2.2.8 State-New York State Regulations, 6 NYCRR § 373-2.2 - 100-Year
Floodplain 2-7
2.2.9 State—New York State Regulations, 6 NYCRR Part 182 2-8
2.2.10 Endangered Species Act, 16 USC §§ 1531 et. seq 2-9
2.2.11 Federal—Clean Water Act Regulations, 33 CFR Parts 320- 330 and 40
CFR Part 230 and 231 2-11
2.3 ACTION-SPECIFIC ARARs AND TBCs 2-12
2.3.1 Federal—Toxic Substances Control Act Regulations, 40 CFRPart 761 2-13
2.3.2 Federal—Clean Air Act Regulations, 40 CFR Parts 52, 60, 61 and 63 2-13
2.3.3 Federal—Resource Conservation and Recovery Act Regulations, 40
CFR Part 257 2-14
2.3.4 Federal RCRA, 40 CFR Parts 261, 262, and Subparts B, F, G, J, K, L,
N, S, X of Part 264, 265, and 268 (with separate reference to 40 CFR §
262.11, 262.34, 264.13(b), and 264.232) 2-15
2.3.5 Federal RCRA, 62 Federal Register 25997 (May 12, 1997) 2-16
2.3.6 Federal—CWA Regulations, 33 CFR Parts 320 - 330 and 40 CFR Part
230 and 231 2-17
2.3.7 Federal—Clean Water Act Regulations, 40 CFR Parts 121, 122, 125,
401 and 403.5 2-19
2.3.8 Federal—Safe Drinking Water Act Regulations, 40 CFR Parts 144 -147.... 2-20
2.3.9 Federal—U. S. Department of Transportation Regulations, 40 CFR
Parts 170 et. seq 2-20
2.3.10 State—New York Regulations, 6 NYCRR Part 360 2-21
2.3.11 State-New York Regulations, 6 NYCRR Parts 361, 364, 370-376 2-22
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Section Page
2.3.12 State-New York Regulations, 6 NYCRR Parts 200, 202, 205, 207,
211, 212, 219 and 257 2-23
2.3.13 State—New York Regulations, 6 NYCRR Part 608 2-23
2.3.14 State—New York Regulations, 6 NYCRR Parts 700-706 2-26
2.3.15 State-New York, 6 NYCRR Parts 750-758 2-27
2.3.16 State—New York State Environmental Conservation Law, Article 17,
Title 5 2-28
2.3.17 State—New York State Environmental Conservation Law § 11-0503 2-28
2.3.18 Local-Local County or Municipal Pretreatment Requirements, Local
Regulations 2-29
LIST OF TABLES
Table A-l Chemical-Specific Potential Applicable or Relevant and Appropriate Requirements
Table A-2 Chemical-Specific Potential Criteria, Advisories and Guidance To Be Considered
Table A-3 Location-Specific Potential Applicable or Relevant and Appropriate Requirements
Table A-4 Location-Specific Potential Criteria, Advisories and Guidance To Be Considered
Table A-5 Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Table A-6 Action-Specific Potential Criteria, Advisories and Guidance To Be Considered
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LIST OF ACRONYMS AND ABBREVIATIONS
ARAR
applicable or relevant and appropriate requirements
CAA
Clean Air Act
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act
CEQ
Council of Environmental Quality
CESQG
conditionally exempt small quantity generator
CFR
Code of Federal Regulations
CWA
Clean Water Act
DDT
di chl orodiphenyltri chl oroethane
DEC
Department of Environmental Conservation
DOT
U.S. Department of Transportation
ECL
Environmental Conservation Law
EPA
U.S. Environmental Protection Agency
ESA
Endangered Species Act
FWCA
Fish and Wildlife Coordination Act
HMTA
Hazardous Materials Transportation Act
LDR
land disposal restrictions
NCP
National Contingency Plan
NEPA
National Environmental Policy Act
NESHAP
National Emission Standards for Hazardous Air Pollutants
NHPA
National Historic Preservation Act
NPDES
National Pollutant Discharge Elimination System
NYCRR
New York Codes, Rules and Regulations
NYSFWL
New York State Freshwater Wetlands Law
PCB
polychlorinated biphenyls
ppm
parts per million
RAA
remedial action alternatives
RAO
remedial action objectives
RCRA
Resource Conservation and Recovery Act
RI
Remedial Investigation
SCA
sediment consolidation area
SPDES
State Pollution Discharge Elimination System
SWDA
Safe Drinking Water Act
TBC
To Be Considered
TSCA
Toxic Substances Control Act
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LIST OF ACRONYMS AND ABBREVIATIONS
US ACE U.S. Army Corps of Engineers
USC United States Code
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APPENDIX A
IDENTIFICATION OF FEDERAL AND STATE
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
AND TO BE CONSIDERED
LOWER LEY CREEK SUBSITE OF THE
ONONDAGA LAKE SUPERFUND SITE, SYRACUSE, NY
1.0 INTRODUCTION
The remediation of Lower Ley Creek is subject to federal and state environmental statutes and
regulations designated for Lower Ley Creek in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) process for determining
applicable or relevant and appropriate requirements (ARAR). Section 121(d)(1) of CERCLA,
Title 42 of the United States Code (USC), Section 9621(d)(1), 42 USC § 9621(d)(1), requires
that response actions attain a degree of cleanup that assures protection of human health and the
environment.
CERCLA also requires that response actions at least attain federal ARARs as well as any state
ARARs that are more stringent than federal ARARs (unless an ARAR waiver becomes
necessary). The National Contingency Plan (NCP) regulations, Title 40 of the Code of Federal
Regulations (CFR) Part 300, [40 CFR § 300.435(b)(2)] which implement CERCLA's cleanup
requirements, generally require ARAR compliance. Three categories of potentially applicable
federal and state requirements and guidance were reviewed for this site: (1) chemical-specific;
(2) location-specific; and (3) action-specific ARARs and To Be Considered (TBC). These are
the same requirements assessed for each site regulated under CERCLA. CERCLA (42 USC §
9621(d)) and the NCP (40 CFR § 300.400(e)) provide that permits are not required for on-site
response actions under CERCLA. The U.S. Environmental Protection Agency (EPA) has
interpreted this exemption to "to waive the requirement to obtain a permit but not the substantive
requirements that would be applied through permits." (see, e.g., Management of Remediation
Waste Under CERCLA, EPA, October 1998).
In addition to ARARs, advisories, criteria, or guidance may be evaluated as TBC regulatory
items. The NCP provides that the TBC category may include advisories, criteria, or guidance
that were developed by EPA, other federal agencies, states, or local governments that may be
useful in devising CERCLA remedies. These TBCs are not promulgated and, therefore, are not
legally enforceable standards such as ARARs.
Consistent with EPA guidance, ARAR development and designation is a necessarily iterative
process.
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2.0 ARAR AND TBC IDENTIFICATION
2.1 CHEMICAL-SPECIFIC ARARs AND TBCs
Chemical-specific ARARs are numerical values, established by promulgated standards, which
are required to be used to set acceptable concentrations of chemicals that may be found in or
discharged to the environment. Potential federal and state chemical-specific ARARs and TBCs
associated with a remedial action for Lower Ley Creek are listed in Tables A-l and A-2,
respectively. These tables list each chemical-specific ARAR for this response action and provide
a citation and a brief description and/or comment on the intended operation of that ARAR or
TBC, where warranted.
The analysis of chemical-specific ARARs is provided below in the order provided in the
Remedial Investigation (RI) Report:
2.1.1 Air
There are no promulgated chemical-specific ARARs for air.
2.1.2 Biota
There are no promulgated chemical-specific ARARs for biota.
2.1.3 Sediment
There are no promulgated chemical-specific ARARs for sediment.
2.1.4 Federal—Safe Drinking Water Act Regulations, 40 CFR Part 141
Summary
The Safe Drinking Water Act (SWDA) is intended to protect human health from contaminants
through a system of drinking water standards measured at the tap (i.e., the National Primary
Drinking Water Regulations), as well as through a number of other provisions that do not pertain
to this site.
Analysis
The groundwater in the vicinity is considered potential potable water; therefore, the maximum
contaminant levels and maximum contaminant level goals are relevant and appropriate.
For Lower Ley Creek, these SDWA standards are not applicable because they do not meet all the
necessary jurisdictional requirements. Neither the creek surface water nor groundwater that
eventually reaches the creek is used as a source of potable water. In addition, there is no
existing plan to use Lower Ley Creek as a future source of potable water because there are other
more suitable and readily available sources of potable water for the Syracuse area. Local water
users receive public water from the Onondaga County Water Authority. The municipal water
supply for Onondaga County comes from Otisco and Skaneateles Lakes and from Lake Ontario,
all of which are located more than twenty miles away from Lower Ley creek. In addition, the
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New York State Atlas of Community Water System Sources does not list any municipal or
non-municipal community water supply intakes in Onondaga County that could be impacted by
Lower Ley Creek.
ARAR Determination
The SDWA and the SDWA regulations will be treated as a potential relevant and appropriate
chemical-specific ARAR for the on-site Lower Ley Creek remediation.
2.1.5 Federal—Clean Water Act Regulations, 40 CFR Part 129
Summary
Part 129 of the federal Clean Water Act (CWA) regulations provides six specific Toxic Pollutant
Effluent Standards that apply to the owners or operators of a building, structure, facility, or
installation. Toxic Pollutant Effluent Standards in the federal CWA are provided for
aldrin/dieldrin, dichlorodiphenyltrichloroethane (DDT), endrin, toxaphene, benzidene and
polychlorinated biphenyls (PCB), all of which adhere readily to sediment particles and are
typically non-detectable in water samples.
Analysis
The CWA regulations may be relevant and appropriate for aldrin/dieldrin, DDT, endrin,
toxaphene, benzidene, and PCBs detected in Lower Ley Creek.
For Lower Ley Creek, these CWA regulations rely on the National Pollutant Discharge
Elimination System (NPDES) permit program to implement the related prohibition on the point
source discharge of these pollutants. As such, these CWA regulations are not applicable
because they do not meet all the necessary jurisdictional requirements.
ARAR Determination
Based on the analysis above, the CWA and the CWA regulations in 40 CFR Part 129 regulations
are relevant and appropriate chemical-specific ARARs for purposes of the on-site Lower Ley
Creek remediation.
2.1.6 State—New York State Regulations, 6 NYCRR Parts 608, 700-706
Summary
Part 608 includes the requirement to obtain a State Pollution Discharge Elimination
System (SPDES) permit for certain discharges in any navigable waters of the State (6
New York Codes, Rules, and Regulations [NYCRR] 608.5). The standards for issuance
of such a permit are general in nature and include environmental impacts and effect on
water quality (6 NYCRR 608.7 and 8).
The regulations in Parts 700 - 706 include water quality classifications, standards and
guidance values.
Part 700 provides definitions and describes collection and sampling procedures.
Part 701 establishes classifications for surface waters and groundwater.
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Part 702 establishes the deviation and use of these standards and guidance values.
Part 703 establishes surface water and groundwater quality standards and groundwater
effluent limitations.
Part 704 establishes criteria for thermal discharges.
Part 705 contains references.
Part 706 establishes additional procedures for the derivation of standards and guidance
values that are protective of aquatic life from acute and chronic effects.
Analysis
Substantive provisions of 6 NYCRR Part 608 that appear relevant and appropriate in the
context of this on-site response action are:
o Section 608.6(a) (requiring development and submission of a sufficiently detailed
construction plan with a map).
o Section 608.9(a) (requiring that construction or operation of facilities that may
result in a discharge to navigable waters demonstrate compliance with CWA §§
301-303, 306 and 307 and 6 NYCRR § 751.2 (prohibited discharges) and 754.1
(effluent prohibitions; effluent limitations and water quality-related effluent
limitations; pretreatment standards; standards of performance for new sources.)
Parts 700 and 705 are not applicable or relevant and appropriate because they are
administrative or procedural in nature.
In Part 701, the descriptions of the classifications assigned to waters of the State,
including the classifications assigned to the creek, as well as a general prohibition on any
discharge that impairs the receiving water for its assigned best usages are relevant and
appropriate ARARs.
Part 702 includes procedures used for deriving water quality standards and guidance
values, which are not applicable or relevant and appropriate because they are
administrative or procedural in nature.
Part 703 includes general and chemical-specific water quality standards and is relevant
and appropriate.
Part 704 would not be relevant and appropriate to alternatives involving dredging,
dewatering and discharge to the creek because no thermal discharges are otherwise
anticipated as a result of the cleanup of the site.
Part 706 includes procedures for developing water quality standards and guidance values
to protect aquatic life which are not applicable or relevant and appropriate because they
are administrative or procedural in nature.
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ARAR Determination
Substantive provisions of 6 NYCRR §§ 608.6(a) and 608.9(a) are potential relevant and
appropriate chemical-specific ARARs for the on-site response. In addition, substantive
provisions in Parts 703 and 704 are potential relevant and appropriate chemical-specific ARARs
for the on-site response.
2.2 LOCATION-SPECIFIC ARARs AND TBCs
Location-specific ARARs may restrict the conduct of activities or concentrations of hazardous
substances based solely on the particular characteristics of a site. Potential federal and state
location-specific ARARs and TBCs considered in connection with the Lower Ley Creek
response action are listed in Tables A-3 and A-4, respectively. These tables list each
location-specific ARAR, and provide a regulatory citation and brief description and/or comment
on the intended operation of that ARAR or TBC, where warranted. The determination of the
potential use of each recommended ARAR is summarized in the status column of each table.
2.2.1 Federal—Executive Order No. 11988, Floodplain Management, 42 Federal Register
26951 (May 25,1977)
Summary
This Executive Order provides the circumstances where federal executive agencies should
manage floodplains.
Analysis
This Executive Order is technically a TBC. It is applicable because the EPA is a federal
executive agency. The Executive Order also is relevant and appropriate because federal money is
expected to be used for this cleanup.
ARAR Determination
Federal Executive Order 11988 is a TBC for the Lower Ley Creek remediation.
2.2.2 Federal—Executive Order No. 11990, Protection of Wetlands, 42 Federal Register
26961 (May 25,1977)
Summary
This Executive Order provides the circumstances where federal executive agencies should
protect wetlands.
Analysis
This Executive Order is technically a TBC. It is applicable because the EPA is a federal
executive agency. The Executive Order also is relevant and appropriate because federal money is
expected to be used for this cleanup.
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ARAR Determination
This Federal Executive Order is a TBC for the Lower Ley Creek remediation.
2.2.3 Federal—EPA Regulations, 40 CFR Part 6, Subpart A
Summary
These regulations describe EPA procedures for implementing the requirements of the Council of
Environmental Quality (CEQ) on the National Environmental Policy Act (NEPA.)
Analysis
These EPA regulations may be relevant and appropriate for purposes of enhancing the NCP
process, depending on the location of on-site remedial action alternatives (RAA). Subpart A of
Part 6 is not applicable because these EPA regulations are intended to implement NEPA and the
related CEQ regulations in 40 CFR Parts 1500-1517; however, NEPA and the NEPA regulations
are inapplicable here since CERCLA and the NCP solely govern this remediation.
ARAR Determination
Subpart A of 40 CFR Part 6 will be treated as a potential relevant and appropriate
location-specific ARAR for on-site response at Lower Ley Creek depending on the
circumstances.
2.2.4 Federal—Fish and Wildlife Coordination Act, 16 USC § 662 Summary
The Fish and Wildlife Coordination Act (FWCA) requires consultation with the U.S. Fish and
Wildlife Service whenever a public or private agency, under a federal permit or license, seeks to
impound, divert, deepen, control, or modify any body of water.
Analysis
Substantive, non-procedural, non-permit related provisions of 16 USC § 662 may be relevant and
appropriate as a location-specific ARAR for the on-site response, depending on the remedial
action objectives (RAO) and location(s) chosen for cleanup of the site. The permit-related
requirements of Section 662 are not applicable because this statute is predicated on a FWCA
permit being required as well as the FWCA directly controlling any of the specified actions that
might lawfully proceed.
ARAR Determination
Section 662 may be applicable or relevant and appropriate as a location-specific ARAR for any
off-site response that may occur as part of remediation of the site, depending on the location(s)
chosen for managing site residuals.
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2.2.5 Federal—Fish and Wildlife Coordination Act Regulations, 40 CFR § 6.302
Summary
This federal statute requires EPA to apply Executive Order 11990, Protection of Wetlands,
Executive Order 11988, Floodplain Management, the EPA Policy to Protect Environmentally
Significant Agricultural Lands, the Coastal Zone Management Act, and the Wild and Scenic
Rivers Act in EPA administrative programs in circumstances where these apply.
Analysis
This regulation is neither applicable nor relevant and appropriate as a potential location-specific
ARAR for this site because there are no wild and scenic rivers, coastal barriers, wilderness areas
or significant agricultural lands on-site.
ARAR Determination
These FWCA regulations are not a location-specific ARAR for the Lower Ley Creek
remediation.
2.2.6 Federal—National Historic Preservation Act Regulations, 36 CFR Part 800
Summary
The National Historic Preservation Act (NHPA) was adopted to implement the NHPA and to
preserve for public use historic and cultural sites of national significance by requiring federal
agencies, among other things, to preserve all historic properties that they own and control, notify
the federal Department of the Interior of projects that will cause the loss of significant historic
materials, and request preservation assistance from the Department of the Interior.
Analysis
Whether cultural resources exist along the Lower Ley Creek riparian corridor continues to be
assessed. A Stage IA cultural resource survey may need to be performed for the project area.
ARAR Determination
Until contrary information becomes known, the NHPA regulations will be treated as applicable
location-specific ARARs for the Lower Ley Creek remediation.
2.2.7 State—New York State Freshwater Wetlands Law Regulations, 6 NYCRR Parts 662
-665
Summary
Part 662 of New York State Freshwater Wetlands Law (NYSFWL) provides interim permit
procedures for freshwater wetlands. Part 663 provides the state freshwater wetland permit
requirements. Part 664 provides the state freshwater wetlands maps and classification
procedures. Part 665 provides the state regulatory procedures for local government
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implementation of the Freshwater Wetlands Act and statewide minimum land-use regulations for
freshwater wetlands.
Analysis
Substantive provisions of 6 NYCRR Parts 662-664 may be relevant and appropriate as
potential location-specific ARARs for on-site response, depending on the locations
chosen for cleanup actions.
Provisions of 6 NYCRR Parts 662-665 may be applicable as potential location-specific
ARARs for off-site remedial actions.
The permit-related requirements of Parts 662 and 663 are not applicable because these
regulations are predicated on the NYSFWL being directly controlling, and on a FWCA
permit being required before any of the specified actions might lawfully proceed.
In Part 664, the mapping and classification procedures are not applicable on-site because
they are designed to further the permitting system, which is inapplicable on-site.
Part 665 is neither applicable nor relevant and appropriate because the EPA is not a local
government, and local government wetland or land-use regulations are not ARARs under
CERCLA.
Other aspects of these regulations may be ARARs, depending on the circumstances, as described
below.
ARAR Determination
Substantive, non-procedural, non-permit related provisions of 6 NYCRR Parts 662-664 may be
relevant and appropriate as potential location-specific ARARs for on-site response, depending on
the RAOs and location(s) chosen for cleanup of the site. Provisions of 6 NYCRR Parts 662-665
may be applicable or relevant and appropriate as location-specific ARARs for any off-site
response that may occur as part of remediation of the site, depending on the location(s) chosen
for managing site residuals.
2.2.8 State—New York State Regulations, 6 NYCRR § 373-2.2 - 100-Year Floodplain
Summary
Section 373-2.2 is part of 6 NYCRR Subpart 373-2, the Final Status Standards for Owners and
Operators of Hazardous Waste Treatment, Storage and Disposal Facilities. Subsection 3732.2(j)
provides that hazardous waste facilities located in the 100-year floodplain must be designed,
constructed, and operated to prevent washout in a 100-year flood, except in limited
circumstances with the Department of Environmental Conservation's (DEC's) approval.
Analysis
Substantive, non-procedural, non-permit related provisions of 6 NYCRR § 373-2.2(j) may be
relevant and appropriate as a location-specific ARAR for the on-site response, depending on the
RAAs and location(s) chosen for cleanup of the site. Provisions of 6 NYCRR § 373-2.2 may be
applicable or relevant and appropriate as location-specific ARARs for any off-site response that
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may occur as part of remediation of the site, depending on the location(s) chosen for managing
site residuals.
Subsection 373-2.2(j) is not applicable because the state is not the regulating authority under
CERCLA at this site and any hazardous substance facility constructed on-site will not be directly
subject to state hazardous waste regulation and control.
Other aspects of these regulations may be ARARs, depending on the circumstances, as described
below.
ARAR Determination
Substantive provisions of 6 NYCRR §373-2.2 may be relevant and appropriate as a
location-specific ARAR for the on-site response, depending on the RAAs and location(s) chosen
for cleanup of the site.
2.2.9 State—New York State Regulations, 6 NYCRR Part 182
Summary
Part 182 provides references in Section 182.1.
Section 182.2 provides definitions.
Section 182.3 prohibits the taking, importing, transporting, possessing or selling of any
endangered or threatened species of fish or wildlife without a DEC permit.
Section 182.4 provides license and permit procedures.
Section 182.5 provides special rules for the importing or possession of an alligator,
caiman or crocodile.
Section 182.6 designates certain endangered species, threatened species and species of
special concern in the state.
Section 182.7 establishes special rules for lake sturgeon.
Analysis
Substantive, non-procedural, non-permit related provisions of 6 NYCRR §§ 182.3 and
182.6 may be relevant and appropriate as location-specific ARARs for the on-site
response, depending on the RAOs and location(s) chosen for cleanup of the site.
Provisions of 6 NYCRR § 182.3, 182.4 and 182.6 may be applicable or relevant and
appropriate as location-specific ARARs for any off-site response that may occur as part
of remediation of the site, depending on the RAOs and location(s) where site residuals
are to be managed.
Sections 182.1 and 182.2 are not ARARs because they are purely administrative or
procedural in nature.
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The substance of the non-permit/license- related portions of Section 182.3 is not
applicable on-site because they are designed to further the permitting system, which is
inapplicable on-site.
Provisions of Section 182.5 for alligators, caimans, and crocodiles are not ARARs
because these species are not found at, nor do they have appropriate habitat within Lower
Ley Creek throughout any of their life cycles.
For similar reasons, the Section 182.7 special provisions for lake sturgeon are not an
ARAR.
The Section 182.6 classification system is not applicable on-site because they are
designed to further the permitting system, which is inapplicable on-site.
Other aspects of these regulations may be ARARs, depending on the circumstances, as described
below.
ARAR Determination
Substantive provisions of 6 NYCRR §§ 182.3 and 182.6 may be relevant and appropriate
as location-specific ARARs for the on-site response, depending on the RAOs and
location(s) chosen for cleanup of the site.
Provisions of 6 NYCRR §§ 182.3, 182.4 and 182.6 may be applicable or relevant and
appropriate as location-specific ARARs for any off-site response that may occur as part
of remediation of the site, depending on the RAOs and location(s) where site residuals
are to be managed.
2.2.10 Endangered Species Act, 16 USC §§ 1531 et. seq.
Summary
The Endangered Species Act (ESA) consists of:
A statement of Congressional findings and declaration of purposes (16 USC § 1531).
• Definitions (16 USC § 1532).
A general description of the process for determination of endangered species and
threatened species (16 USC § 1533).
Establishes a process to promote the acquisition of land for the preservation of
endangered species and threatened species (16 USC § 1534).
A process to promote state, interagency and international cooperation on endangered
species and threatened species issues (16 USC §§ 1535 - 1537).
A process for implementation of the Convention on International Trade in Endangered
Species of Wild Fauna and Flora (16 USC § 1537a).
Prohibited acts with respect to endangered species and threatened species (16 USC §
1538).
Exceptions to the ESA (16 USC § 1539).
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Penalties and enforcement of the ESA (16 USC § 1540).
Review of endangered plants (16 USC § 1541).
Authorization for appropriations (16 USC § 1542).
• Construction of the ESA with the Marine Mammal Protection Act (16 USC § 1543).
Provides for an annual accounting of Federal and State expenditures for the conservation
of endangered or threatened species (16 USC § 1544).
Analysis
The prohibition in Section 1538 of certain acts with respect to endangered species and
threatened species constitutes substantive environmental protection requirements, which
are relevant and appropriate requirements.
The permit-related requirements of Section 1539 are not applicable because these
requirements are predicated on ESA being directly controlling, and on an ESA permit
being required before any of the specified actions might lawfully proceed. However,
other aspects of Section 1539 may be relevant and appropriate as location-specific
ARARs, depending on the circumstances, as described below.
Sections 153 l-1537a and 1540-1544 are not cleanup standards, standards of control, and
other substantive environmental protection requirements, criteria, or limitations
promulgated under Federal environmental or state environmental or facility siting law.
ARAR Determination
The prohibitions in Section 1538 of certain acts with respect to endangered species and
threatened species are applicable as a potential location-specific ARAR for the Lower Ley Creek
site remediation.
Sections 153l-1537a and 1540-1544 are not applicable or relevant and appropriate
location-specific ARARs.
Substantive provisions of Section 1539 may be relevant and appropriate as a location-specific
ARAR for the on-site response, depending on the RAOs and the relationship to critical habitat at
the site.
The provisions of Section 1539 also may be applicable or relevant and appropriate as a
location-specific ARAR for any off-site response that may occur as part of remediation of the
site, depending on the location(s) chosen for managing site residuals and relationship to off-site
critical habitat.
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2.2.11 Federal—Clean Water Act Regulations, 33 CFR Parts 320- 330 and 40 CFR Part 230
and 231
Summary
In 33 CFR:
Part 320 establishes the U.S. Army Corp of Engineers' (USACE) general regulatory
policies.
Part 321 establishes requirements for permits for dams and dikes in navigable waters of
the United States.
Part 322 establishes requirements for permits for structures or work in or affecting
navigable waters of the United States.
Part 323 provides definitions that pertain to the CWA Section 404 program for discharges
of dredged or fill material and specifies the activities that do not require permits.
Part 324 establishes requirements for permits for ocean dumping of dredged materials.
Part 325 establishes requirements for the processing of USACE permits.
Part 326 establishes requirements for enforcement of wetland dredge and fill permits.
Part 327 establishes requirements for hearings on wetland dredge and fill permits.
Part 328 establishes the definition of waters of the United States.
Part 329 establishes the definition of navigable waters of the United States.
Part 330 establishes the nationwide permit program.
In Title 40 of the CFR:
Part 230 sets forth the CWA Section 404(b)(1) guidelines for specification of disposal
sites for dredged or fill material, and implements 33 USC § 1344 for the review of
proposed discharges of dredged or fill material into navigable waters.
Part 231 sets forth the CWA Section 404(c) requirements for EPA's procedures
prohibiting or withdrawing the specification, or denying, restricting, or withdrawing the
use for specification of any defined area as a disposal site for dredged or fill material.
Analysis
Substantive aspects of the statement of regulatory policy in 33 CFR 320 and the
guidelines in 40 CFR Part 230 may be relevant and appropriate location-specific
requirements depending on the RAA.
Part 324 is not an action-specific ARAR because this site is not located on an ocean.
Parts 231 and 325 are not location-specific ARARs because they are procedural in nature.
Parts 326 and 327 are not location-specific ARARs because they only relate to
enforcement or hearing procedures.
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While not applicable, the regulatory definitions or exclusions from CWA dredge and fill
regulations in Parts 323, 328, 329 and 330 may be relevant and appropriate
location-specific requirements depending on the RAA.
Parts 321 and 322 are not applicable location-specific ARARs at this CERCLA site
because these regulations are predicated on the CWA regulations being directly
controlling and on a CWA permit being required before any of the specified actions
might lawfully proceed. However, it is solely CERCLA that controls actions at this site;
other laws may pertain to this site only to the extent allowed by 42 USC § 9621(d), and
the NCP in 40 CFR § 300.400(e) explicitly provides that permits are not required for
on-site response actions under CERCLA. Therefore, all permit-related requirements of
Parts 321 and 322 are not applicable as location-specific ARARs the on-site response
actions.
Other aspects of these standards may be ARARs, depending on the circumstances, as described
below.
ARAR Determination
Substantive provisions of Parts 321 and 322 may be relevant and appropriate as
location-specific ARARs for the on-site response, depending on the RAOs and
technology chosen for cleanup of the site.
Provisions of Parts 321-323, 329-330 may be applicable or relevant and appropriate as
location-specific ARARs for any off-site response that may occur as part of remediation
of the site, depending on the technologies chosen for cleanup of the site.
2.3 ACTION-SPECIFIC ARARs AND TBCs
Action-specific ARARs generally set performance or design standards, controls, or restrictions
on particular types of activities. To develop technically feasible alternatives, applicable
performance or design standards must be considered during the development of all reasonable
response action alternatives. The precise action-specific ARARs for this site will be subsequently
determined based upon the technology or technologies chosen to remediate the site.
Potential federal and state action-specific ARARs and TBCs evaluated in connection with this
response action are listed in Tables A-5 and A-6, respectively. These tables list each
action-specific ARAR and TBC for remediation of Lower Ley Creek and provide a regulatory
citation and a brief description and/or comment on the intended operation of each ARAR or
TBC, where warranted. The determination of the potential use of each recommended ARAR is
provided in the status column of each table.
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2.3.1 Federal—Toxic Substances Control Act Regulations, 40 CFR Part 761
Summary
Toxic Substance Control Act (TSCA) Part 761 generally contains the federal regulations on the
manufacturing, processing, and distribution of certain toxic substances in commerce and use
prohibitions and includes in pertinent part:
Section 761.65 establishing the TSCA requirement for PCB storage for disposal.
• Section 761.70 establishing the TSCA requirement for PCB incineration.
Section 761.71 establishing the TSCA requirement for disposal of PCBs in high
efficiency boilers.
Section 761.72 establishing the TSCA requirement for disposal of PCBs in scrap metal
recovery ovens and smelters.
Section 761.75 establishing the TSCA requirement for disposal of PCBs in chemical
waste landfills.
Analysis
The PCB regulations in 40 CFR §§ 761.65-761.75 are applicable because some of the creek
sediment samples analyzed contain more than 50 parts per million (ppm) of PCBs, which is the
trigger concentration for PCB spill remediation to occur. None of the non-PCB regulations in
Part 761 are applicable because they do not meet the necessary jurisdictional requirements since
none of those substances were detected at the site at close to the actionable levels listed in these
regulations. Other aspects of these regulations may be ARARs, depending on the circumstances,
as described below.
Substantive, non-procedural, non-permit related provisions of 40 CFR §§ 761.65-761.75 may be
relevant and appropriate as an action-specific ARARs for the on-site response, depending on the
RAOs and technology chosen for cleanup of the site. Provisions of 40 CFR §§ 761.65-761.75
may be applicable or relevant and appropriate as action-specific ARARs for any off-site response
that may occur as part of remediation of the site, depending on the technologies chosen for
cleanup of the site.
ARAR Determination
Substantive provisions of 40 CFR §§ 761.65-761.75 may be relevant and appropriate as an
action-specific ARAR for the on-site response, depending on the RAOs and technology chosen
for cleanup of the site. Provisions of 40 CFR §§ 761.65-761.75 may be applicable or relevant
and appropriate as action-specific ARARs for any off-site response that may occur as part of
remediation of the site, depending on the technologies chosen for cleanup of the site.
2.3.2 Federal—Clean Air Act Regulations, 40 CFR Parts 52, 60, 61 and 63
In Clean Air Act (CAA) Regulations:
Summary
Part 52 provides the federal regulations that govern the approval and promulgation of
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state implementation plans.
Part 60 provides the federal standards that govern performance for new stationary
sources.
Part 61 provides National Emission Standards for Hazardous Air Pollutants (NESHAP)
for a variety of chemicals; and Part 63 provides NESHAPs for additional chemicals.
Analysis
Substantive, non-procedural, non-permit related provisions of Parts 60, 61 and 63 may be
relevant and appropriate as action-specific ARARs for the on-site response, depending on
the RAOs and technology chosen for cleanup of the site.
Provisions of Parts 60, 61 and 63 may be applicable or relevant and appropriate as
action-specific ARARs for any off-site response that may occur as part of remediation of
the site, depending on the technologies chosen for cleanup of the site.
The Part 52 regulations are neither applicable nor relevant and appropriate because the
approval and promulgation of state implementation plans bear no relationship to
remediating Lower Ley Creek.
The permit-related requirements of Parts 60, 61 and 63 are not applicable because these
regulations are predicated on the CAA being directly controlling and on a CAA permit
being required before any of the specified actions might lawfully proceed.
Other aspects of these regulations may be ARARs, depending on the circumstances, as described
below.
ARAR Determination
Substantive provisions of Parts 60, 61 and 63 may be relevant and appropriate as an
action-specific ARAR for the on-site response, depending on the RAOs and technology chosen
for cleanup of the site. Provisions of Parts 60, 61 and 63 may be applicable or relevant and
appropriate as action-specific ARARs for any off-site response that may occur as part of
remediation of the site, depending on the technologies chosen for cleanup of the site.
2.3.3 Federal—Resource Conservation and Recovery Act Regulations, 40 CFR Part 257
Summary
Resource Conservation and Recovery Act (RCRA) Regulations, Part 257, Subpart A, sets forth
the federal criteria for classification of solid waste disposal facilities and practice; and Subpart B
provides disposal standards for the receipt of conditionally exempt small quantity generator
(CESQG) wastes at non-municipal, non-hazardous waste disposal units.
Analysis
The regulations in Subpart B of Part 257 are neither applicable nor relevant and appropriate
because CESQG wastes are not expected to be a subject of the on-site remediation of Lower Ley
Creek. The permit-related requirements of Part 257, Subpart A, also are not applicable because
these regulations are predicated on RCRA being directly controlling at this site and on a RCRA
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permit being required before any of the specified actions might lawfully proceed. However, it is
solely CERCLA that controls at this site; other laws may pertain to this site only to the extent
allowed by 42 USC §9621(d), and the NCP in 40 CFR §300.400(e) explicitly provides that
permits are not required for on-site response actions under CERCLA. Therefore, all
permit-related requirements of Part 257, Subpart A, are not applicable as action-specific ARARs
for the on-site response actions.
Other aspects of these regulations may be ARARs, depending on the circumstances, as described
below.
ARAR Determination
Substantive, non-procedural, non-permit related provisions of Part 257, Subpart A, may be
relevant and appropriate as an action-specific ARAR for the on-site response, depending on the
RAOs and technology chosen for cleanup of the site. Provisions of Part 257, Subpart A, may be
applicable or relevant and appropriate as action-specific ARARs for any off-site response that
may occur as part of remediation of the site, depending on the technologies chosen for cleanup of
the site.
2.3.4 Federal RCRA, 40 CFR Parts 261, 262, and Subparts B, F, G, J, K, L, N, S, X of
Part 264, 265, and 268 (with separate reference to 40 CFR § 262.11, 262.34,
264.13(b), and 264.232)
Summary
Part 261 provides the federal regulations on the identification and listing of hazardous
waste.
Part 262 provides the federal standards for generators of hazardous waste.
Part 264 sets forth the standards for owners and operators of hazardous waste treatment,
storage and disposal facilities.
o Subpart B provides general facility standards.
o Subpart F concerns releases from solid waste management units.
o Subpart G provides facility closure and post-closure procedures.
o Subpart J provides the hazardous waste management procedures for tank systems.
o Subpart K provides the hazardous waste management procedures for surface
impoundments.
o Subpart L provides the hazardous waste management procedures for waste piles.
o Subpart N provides the hazardous waste management procedures for landfills.
o Subpart S provides the corrective action procedures for solid waste management
units.
o Subpart X provides the hazardous waste management procedures for
miscellaneous units.
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Part 265 sets forth the interim status standards for owners and operators of hazardous
waste treatment, storage, and disposal facilities.
o Subpart B provides general facility standards.
o Subpart F concerns ground-water monitoring.
o Subpart G provides facility closure and post-closure procedures.
o Subpart J provides the hazardous waste management procedures for tank systems.
o Subpart K provides the hazardous waste management procedures for surface
impoundments.
o Subpart L provides the hazardous waste management procedures for waste piles.
o Subpart N provides the hazardous waste management procedures for landfills.
o Note that there are no Subparts S or X in Part 265 as suggested in the RI.
Part 268 sets forth the federal land disposal restrictions (LDR) for hazardous wastes, and
Subpart C provides the more specific prohibitions on hazardous waste land disposal.
Analysis
Substantive, non-procedural, non-permit related provisions of Part 261, 262, 264, 265, and 268
may be relevant and appropriate as an action-specific ARAR for the on-site response, depending
on the RAOs and technology chosen for cleanup of the site.
Provisions of Part 261, 262, 264, 265, and 268 may be applicable or relevant and appropriate as
action-specific ARARs for any off-site response that may occur as part of remediation of the site,
depending on the technologies chosen for cleanup of the site.
The permit-related requirements of Part 261, 262, 264, 265, and 268 are not applicable because
these regulations are predicated on RCRA being directly controlling at this site and on a RCRA
permit being required before any of the specified actions might lawfully proceed.
Other aspects of these regulations may be ARARs, depending on the circumstances, as described
below.
ARAR Determination
Substantive provisions of Part 261, 262, 264, 265, and 268 may be relevant and appropriate as an
action-specific ARAR for the on-site response, depending on the RAOs and technology chosen
for cleanup of the site. Provisions of Part 261, 262, 264, 265 and 268 may be applicable or
relevant and appropriate as action-specific ARARs for any off-site response that may occur as
part of remediation of the site, depending on the technologies chosen for cleanup of the site.
2.3.5 Federal RCRA, 62 Federal Register 25997 (May 12,1997)
Summary
The May 12, 1997, Federal Register notice published at 62 Federal Register 25997 primarily
contains EPA's decision not to finalize the proposed Phase IV land disposal restriction
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provisions, but it does include some changes to the definition of solid waste for mineral
processing materials that could impact the land disposal of mineral processing wastes.
Analysis
This final rulemaking is neither applicable nor relevant and appropriate because the land disposal
of mineral processing wastes does not appear to be relevant to the remediation of Lower Ley
Creek.
ARAR Determination
This final rule is not an action-specific ARAR or TBC for the Lower Ley Creek remediation.
2.3.6 Federal—CWA Regulations, 33 CFR Parts 320 - 330 and 40 CFR Part 230 and 231
Summary
In 33 CFR:
Part 320 establishes the USACE's general regulatory policies.
Part 321 establishes requirements for permits for dams and dikes in navigable waters of
the United States.
Part 322 establishes requirements for permits for structures or work in or affecting
navigable waters of the United States.
Part 323 provides definitions that pertain to the CWA Section 404 program for discharges
of dredged or fill material and specifies the activities that do not require permits.
Part 324 establishes requirements for permits for ocean dumping of dredged materials.
Part 325 establishes requirements for the processing of USACE permits.
Part 326 establishes requirements for enforcement of wetland dredge and fill permits.
Part 327 establishes requirements for hearings on wetland dredge and fill permits.
Part 328 establishes the definition of waters of the United States.
Part 329 establishes the definition of navigable waters of the United States.
Part 330 establishes the nationwide permit program.
In Title 40 of the CFR:
Part 230 sets forth the CWA Section 404(b)(1) guidelines for specification of disposal
sites for dredged or fill material, and implements 33 USC § 1344 for the review of
proposed discharges of dredged or fill material into navigable waters.
Part 231 sets forth the CWA Section 404(c) requirements for EPA's procedures
prohibiting or withdrawing the specification, or denying, restricting, or withdrawing the
use for specification of any defined area as a disposal site for dredged or fill material.
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Analysis
Substantive aspects of the statement of regulatory policy in 33 CFR 320 and the
guidelines in 40 CFR Part 230 may be relevant and appropriate action-specific
requirements depending on the RAA.
Part 324 is not an action-specific ARAR because this site is not located on an ocean.
Parts 231 and 325 are not action-specific ARARs because they are procedural in nature.
Parts 326 and 327 are not action-specific ARARs because they only relate to enforcement
or hearing procedures.
While not applicable, the regulatory definitions or exclusions from CWA dredge and fill
regulations in Parts 323, 328, 329 and 330 may be relevant and appropriate
action-specific requirements depending on the RAA.
Parts 321 and 322 are not applicable action-specific ARARs at this CERCLA site
because these regulations are predicated on the CWA regulations being directly
controlling and on a CWA permit being required before any of the specified actions
might lawfully proceed. However, it is solely CERCLA that controls actions at this site;
other laws may pertain to this site only to the extent allowed by 42 USC § 9621(d), and
the NCP in 40 CFR § 300.400(e) explicitly provides that permits are not required for
on-site response actions under CERCLA. Therefore, all permit-related requirements of
Parts 321 and 322 are not applicable as action-specific ARARs the on-site response
actions.
There are no promulgated regulations regarding the design and construction of the sediment
consolidation area (SCA). Nonetheless, portions of CWA that regulate the discharge of dredge
material could impact the design of the SCA. For example, section 230.10(b)(1), which
prohibits the disposal of dredged material that violates water quality standards, after
consideration of disposal site dilution and dispersion, would apply to the effluent or runoff
discharged from the SCA. Section 230.10(c)(1) requires consideration of effects on municipal
water supplies. Section 230.11 requires consideration of a broad range of possible effects from
proposed dredged material discharges.
The US ACE and EPA have jointly prepared a guidance document for management of
contaminated dredged material (EPA/USACE [1992]) Evaluating Environmental Effects of
Dredged Material Management Alternatives - A Technical Framework. EPA 8420B-92-008,
Office of Water, Washington, D.C. Notably, this guidance document specifies that when
contaminated dredged material is placed in confined disposal facilities, an analysis of pathways
of concern must be completed to determine if treatment or site control measures (such as liners,
caps, groundwater pumping, or leachate control systems) are required. This guidance, as well as
other guidance documents, such as US ACE (2003) are considered TBCs for the SCA.
ARAR Determination
Substantive provisions of Parts 321 and 322 may be relevant and appropriate as action-specific
ARARs for the on-site response, depending on the RAOs and technology chosen for cleanup of
the site. Provisions of Parts 321-323, 329-330 may be applicable or relevant and appropriate as
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action-specific ARARs for any off-site response that may occur as part of remediation of the site,
depending on the technologies chosen for cleanup of the site.
In addition, the following are recommended as TBCs:
USACE, Notice on Issuance of Nationwide Permits, 67 Federal Register 2020 (January
15, 2002).
• Letter from William R. Adriance, Chief Permit Administrator, to Richard Tomer and
Paul G. Leuchner, Chiefs of the New York and Buffalo Districts of USACE, re. Section
401 Water Quality Certification, January 15, 2002 Nationwide Permits (Mar. 15, 2002).
2.3.7 Federal—Clean Water Act Regulations, 40 CFR Parts 121,122,125, 401 and 403.5
Summary
Part 121 establishes state certification procedures for requiring a federal license or permit
under the CWA.
• Part 122 implements the NPDES permits.
Part 125 establishes criteria and standards for the NPDES system.
Part 401 establishes effluent guidelines and standards.
Section 403.5 establishes national pretreatment standards and prohibited discharges
within the NPDES system.
Analysis
Substantive, non-procedural, non-permit related provisions of Parts 121, 122, 125, 401
and Section 403.5 may be relevant and appropriate as an action-specific ARAR for the
on-site response, depending on the RAOs and technology chosen for cleanup of the site.
Provisions of Parts 121, 122, 125, 401 and Section 403.5 may be applicable or relevant
and appropriate as action-specific ARARs for any off-site response that may occur as part
of remediation of the site, depending on the RAOs and technology chosen for cleanup of
the site.
The permit-related requirements of Parts 121, 122, 125, 401 and Section 403.5 are not
applicable because these regulations are predicated on the CWA NPDES requirements
being directly controlling at this site and on a CWA NPDES permit being required before
any of the specified actions might lawfully proceed.
Other aspects of these regulations may be ARARs, depending on the circumstances, as
described below.
ARAR Determination
Substantive provisions of Parts 121, 122, 125, 401 and Section 403.5 may be relevant and
appropriate as an action-specific ARAR for the on-site response, depending on the RAOs and
technology chosen for cleanup of the site. Provisions of Parts 121, 122, 125, 401 and Section
403.5 may be applicable or relevant and appropriate as action-specific ARARs for any off-site
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response that may occur as part of remediation of the site, depending on the RAOs and
technology chosen for cleanup of the site.
2.3.8 Federal—Safe Drinking Water Act Regulations, 40 CFR Parts 144 -147
Summary
Part 144 establishes the SDWA underground injection control program; Part 145 establishes the
state underground injection control program; Part 146 establishes the underground injection
control program criteria and standards; and Part 147 sets forth the applicable underground
injection control program in each state.
Analysis
These regulations are neither applicable nor relevant and appropriate for the cleanup of Lower
Ley Creek, because the underground injection control regulations are predicated on protecting
groundwater that is used or may potentially be used as a public drinking water supply. The
groundwater adjacent to Lower Ley Creek is not used for any potable purpose and there are no
plans for potable use in the future. Of equal significance, none of the remedies being evaluated
for the on-site remediation of Lower Ley Creek are expected to involve the underground
injection of wastes, sediments, materials or waters.
ARAR Determination
The SDWA regulations in 40 CFR Parts 144-147 are not action-specific ARARs for the Lower
Ley Creek remediation.
2.3.9 Federal—U.S. Department of Transportation Regulations, 40 CFR Parts 170 et. seq.
Summary
Part 170 provides the U.S. Department of Transportation (DOT) procedures for carrying out
DOT's duties under the Hazardous Materials Transportation Act (HMTA). Part 171 provides
general information, regulations and definitions in connection with the DOT HMTA.
Analysis
Substantive, non-procedural, non-permit related provisions of DOT's HMTA regulations may be
relevant and appropriate as an action-specific ARAR for the on-site response, depending on the
RAOs and technology chosen for cleanup of the site. Provisions of DOT's HMTA regulations
may be applicable or relevant and appropriate as action-specific ARARs for any off-site response
that may occur as part of remediation of the site, depending on the technologies chosen for
cleanup of the site.
The permit-related requirements of DOT's HMTA regulations are not applicable on-site because
these regulations are predicated on the DOT's HMTA regulations being directly controlling at
this site and on a DOT HMTA manifest being required before any of the specified actions might
lawfully proceed. Other aspects of these regulations may be ARARs, depending on the
circumstances, as described below.
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ARAR Determination
Substantive provisions of DOT's HMTA regulations may be relevant and appropriate as an
action-specific ARAR for the on-site response, depending on the RAOs and technology chosen
for cleanup of the site. Provisions of DOT's HMTA regulations may be applicable or relevant
and appropriate as action-specific ARARs for any off-site response that may occur as part of
remediation of the site, depending on the technologies chosen for cleanup of the site.
2.3.10 State—New York Regulations, 6 NYCRR Part 360
Summary
Part 360 provides New York's general provisions for the regulation of solid waste management
facilities. The Part 360 regulations also regulate the beneficial use of material that would
normally be regulated as a "solid waste."
Analysis
Some aspects of these regulations may be relevant and appropriate depending on the
circumstances. The permit-related requirements of Part 360 are not applicable on-site because
these regulations are predicated on the New York's solid waste management facility regulations
being directly controlling and on a New York solid waste management facility permit being
required before any of the specified actions might lawfully proceed. As described above in
Subsection 2.3.6 (Federal—CWA Regulations, 33 CFR Parts 320-330 and 40 CFR Parts 230 and
231), design and construction of an on-site SCA.
As described above in Section 2.3.6 (Federal—CWA Regulations, 33 CFR Parts 320-330 and 40
CFR Parts 230 and 231), design and construction of an on-site SCA would comply with
applicable or relevant and appropriate portions of the CWA and its implementing regulations,
along with guidance issued by the EPA and USACE. Thus, design and construction of the SCA
would provide protection to the same human populations and environmental endpoints as would
a solid waste facility designed under 6 NYCRR Part 360. Unlike the solid waste regulations
prepared for facilities that handle a wide range of municipal and industrial solid wastes, the
CWA regulations and guidance documents were prepared specifically for management of
contaminated dredged materials.
In situations where there are competing applicable or relevant and appropriate requirements, the
best approach is to select those ARARs that are most germane to the remedial alternative under
consideration. In the case of the SCA, the CWA regulations and EPA and USACE guidance
documents are the most relevant. They were specifically designed for management of
contaminated dredged material and include a system of laboratory tests, analytical methods and
design criteria that would provide protection to human health and the environment.
ARAR Determination
Substantive provisions of 6 NYCRR Part 360 may be relevant and appropriate as action-specific
ARARs for the on-site response, depending on the RAOs and technology chosen for cleanup of
the site. Provisions of 6 NYCRR Part 360 may be applicable or relevant and appropriate as
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action-specific ARAR for any off-site response that may occur as part of remediation of the site,
depending on the technologies chosen for cleanup of the site.
2.3.11 State-New York Regulations, 6 NYCRR Parts 361, 364, 370-376
Summary
Part 361 provides the New York regulations for the siting of industrial hazardous waste
facilities.
Part 364 provides New York's waste transporter permits regulations.
Part 370 provides the New York general hazardous management system regulations.
Part 371 provides New York's regulations for the identification and listing of hazardous
wastes.
Part 372 provides the New York hazardous waste manifest system regulations and related
standards for generators, transporters and facilities.
Part 373 provides the New York interim status standards for owners and operators of
hazardous waste facilities.
Part 375 provides the New York inactive hazardous waste disposal sites regulations,
manifest system regulations, and related standards for generators, transporters and
facilities.
Part 376 provides the New York land disposal restrictions regulations.
Analysis
Substantive, non-procedural, non-permit related provisions of 6 NYCRR Parts 361, 364, 370-376
may be relevant and appropriate as action-specific ARARs for the on-site response, depending
on the RAOs and technology chosen for cleanup of the site. Provisions of 6 NYCRR Parts 361,
364, 370-376 may be applicable or relevant and appropriate as action-specific ARARs for any
off-site response that may occur as part of remediation of the site, depending on the technologies
chosen for cleanup of the site.
The permit-related requirements of Parts 361, 364, 370-376 are not applicable because these
regulations are predicated on the New York's hazardous waste regulations being directly
controlling and on a New York hazardous waste permit being required before any of the
specified actions might lawfully proceed. Other aspects of these regulations may be ARARs,
depending on the circumstances, as described below.
ARAR Determination
Substantive provisions of 6 NYCRR Parts 361, 364, 370-376 may be relevant and appropriate as
action-specific ARARs for the on-site response, depending on the RAOs and technology chosen
for cleanup of the site. Provisions of 6 NYCRR Parts 361, 364, 370-376 may be applicable or
relevant and appropriate as action-specific ARARs for any off-site response that may occur as
part of remediation of the site, depending on the technologies chosen for cleanup of the site.
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2.3.12 State-New York Regulations, 6 NYCRR Parts 200, 202, 205, 207, 211, 212, 219 and
257
Summary
Part 200 provides the general provisions of the state's air resources regulations.
Part 202 provides the state regulations for air emissions verification.
Part 205 provides the state architectural surface coatings regulations.
Part 207 provides the state regulatory control measures for air pollution episodes.
Part 211 provides the general state prohibitions.
Part 212 provides the general process emission sources regulations.
Part 219 provides the state's incinerator regulations.
Part 257 provides specific state air quality standards.
Analysis
Substantive, non-procedural, non-permit related provisions of 6 NYCRR Parts 200, 202, 205,
207, 211, 212, 219 and 257 may be relevant and appropriate as action-specific ARARs for the
on-site response, depending on the RAOs and technology chosen for cleanup of the site.
Provisions of 6 NYCRR Parts 200, 202, 205, 207, 211, 212, 219 and 257 may be applicable or
relevant and appropriate as action-specific ARARs for any off-site response that may occur as
part of remediation of the site, depending on the technologies chosen for cleanup of the site.
The permit-related requirements of Parts 200, 202, 205, 207, 211, 212, 219 and 257 are not
applicable here because these regulations are predicated on the New York's air resources
regulations being directly controlling and on a New York air emissions permit being required
before any of the specified actions might lawfully proceed. Other aspects of these regulations
may be ARARs, depending on the circumstances, as described below.
ARAR Determination
Substantive provisions of 6 NYCRR Parts 200, 202, 205, 207, 211, 212, 219 and 257 may be
relevant and appropriate as action-specific ARARs for the on-site response, depending on the
RAOs and technology chosen for cleanup of the site. Provisions of 6 NYCRR Parts 200, 202,
205, 207, 211, 212, 219 and 257 may be applicable or relevant and appropriate as action-specific
ARAR for any off-site response that may occur as part of remediation of the site, depending on
the technologies chosen for cleanup of the site.
2.3.13 State—New York Regulations, 6 NYCRR Part 608
Summary
Part 608 provides the New York regulations for the use and protection of state waters.
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Analysis
Substantive, non-procedural, non-permit related provisions of 6 NYCRR Part 608 may be
relevant and appropriate as action-specific ARARs for the on-site response, depending on the
RAOs and technology chosen for cleanup of the site. Provisions of 6 NYCRR Part 608 may be
applicable or relevant and appropriate as action-specific ARARs for any off-site response that
may occur as part of remediation of the site, depending on the technologies chosen for cleanup of
the site.
The permit-related requirements of Part 608 are not applicable here because these regulations are
predicated on the New York's water use and protection regulations being directly controlling and
on a New York water use permit being required before any of the specified actions might
lawfully proceed. Other aspects of these regulations may be ARARs, depending on the
circumstances, as described below.
As noted above in the chemical-specific ARAR section, dredged or fill material and dredge
return water discharged into waters of the state are generally exempt from SPDES permit
requirements. Therefore, the most relevant and appropriate regulations to govern the discharge of
treated supernatant water from the SCA after dredging are state and federal CWA Section 404
regulations. The following paragraphs described how this discharge would be regulated under
these regulations.
For non-CERCLA sites, dredge return water is regulated under Section 404 of the Clean Water
Act and does not require and SPDES permit [6 NYCRR § 750-1.5(a)(7): see Final Revisions to
the Clean Water Act Regulatory Definitions of "Fill Material" and "Discharge of Fill
Material", 67 Federal Register 31129, 31135 (May 9, 2002)]. Dredged material is defined as
"material that is excavated or dredged from water of the United States." 33 CFR 323.2(c).
Because the water from the SCA would be dredged from Lower Ley Creek falls within the
definition of dredge material, it should be treated as such. The US ACE, to which authority over
dredge and fill discharge permits has been delegated under the Clean Water Act, has stated that
return water is regulated as a discharge of dredged material.
The substantive requirements of 33 CFR Parts 320 and 323 and 40 CFR Part 230 would apply to
the return water discharge. These requirements may be met by showing that (a) the proposed
discharge would fall within the substantive requirements for obtaining a general nationwide
permit for dredging, or (b) the substantive standards applied to individual dredging permits
would be achieved. Additionally, the water discharge would need to meet the substantive water
quality requirements imposed by New York State or entities seeking a dredged material
discharge permit under Section 404 of the CWA. Thus, an applicant for a water quality
certification must demonstrate that the discharge would meet applicable effluent limits and water
quality standards in 6 NYCRR 608.
As specified in the federal regulations, discharge of dredged material will only be prohibited "if
after consideration of disposal site dilution and dispersion, it causes or contributes to the
violation of any applicable state water quality standard or violates any applicable toxic effluent
limit." 40 CFR § 230.10(b). Moreover, the regulations state that a discharge of dredged
material will not be permitted only if there is a practical alternative that would have less adverse
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environmental impact (40 CFR § 230.10(a)). Here the term "practicable" is defined as
"available and capable of being done after taking into account cost, existing technology, and
logistics in light of overall project purposes. " 40 CFR § 230.3. Also, any discharge of dredged
materials must not cause or contribute to significant degradation of the waters of the United
States (40 CFR § 230.10(c)). An evaluation of significant degradation would be based on a
number of determinations and evaluations including the following:
Impacts on the physical and chemical characteristics of the aquatic ecosystem;
Impacts on the biological characteristics of the ecosystem;
Impacts on wildlife refuges, wetlands, and mudflats and other sensitive areas; and
Impacts on human use of the water system.
The USACE has issued two nationwide permits that may be ARARs. Nationwide Permit 38
applies to "specific activities required to effect the containment, stabilization, or removal of
hazardous or toxic waste materials that are performed, ordered, or sponsored by a government
agency with established legal or regulatory authority... [as well as] court ordered remedial
action plans or related settlementsDepartment of the Army, Corps of Engineers, Issuance of
Nationwide Permits: Notice 67 Federal Register 2019, 2085 (Jan. 15, 2002). Because New
York State has issued a statewide water quality certification for discharges that qualify for this
nationwide permit, water quality certification is presumptive. Nationwide Permit 16 covers
discharges of return water from upland contained disposal areas, irrespective of the purpose for
which dredging was undertaken [.Department of the Army, Corps of Engineers. Issuance of
Nationwide Permits: Notice, 67 Federal Register 2019, 2081 (Jan. 15, 2002)]. A discharge that
meets the requirements for this nationwide permit must still meet the substantive state water
quality certification standards, but may do so after consideration of site dilution and dispersion in
accordance with 40 CFR § 230.10(b).
Additionally, state regulations pertaining to dredging projects may be ARARs. 6 NYCRR
Section 608.8 provides the basis for issuance of a State dredge or fill permit. That provision
states that a permit should be issued if the project is (a) reasonable and necessary; (b) will not
endanger the health, safety, or welfare of the people of New York; and (c) will not cause
unreasonable, uncontrolled, or unnecessary damage to natural resources of the state. Discharge
of supernatant water will not have substantial adverse impact on water quality outside the work
area. It likely will not result in significant additional exceedances of water quality standards
beyond those already resulting from dredging within the work area. Section 608.9 requires that
any dredging project obtain state certification that it meets water quality standards and effluent
limits under Section 401 of the CWA. However, Section 608.9 does not require that such
standards be met at the point of discharge and does not contradict the mandates of the federal
regulations that disposal site dilution and dispersion be taken into account.
ARAR Determination
Substantive provisions of 6 NYCRR Part 608 may be relevant and appropriate as action-specific
ARARs for the on-site response, depending on the RAOs and technology chosen for cleanup of
the site. Provisions of 6 NYCRR Part 608 may be applicable or relevant and appropriate as
action-specific ARARs for any off-site response that may occur as part of remediation of the site,
depending on the technologies chosen for cleanup of the site.
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2.3.14 State—New York Regulations, 6 NYCRR Parts 700-706
Summary
The regulations in Parts 700-706 include water quality classifications, standards and
guidance values.
Part 700 provides definitions and describes collection and sampling procedures.
Part 701 establishes classifications for surface waters and groundwater.
Part 702 establishes the deviation and use of these standards and guidance values.
Part 703 establishes surface water and groundwater quality standards and groundwater
effluent limitations.
Part 704 establishes criteria for thermal discharges.
Part 705 contains references.
Part 706 establishes additional procedures for the derivation of standards and guidance
values that are protective of aquatic life from acute and chronic effects.
Analysis
Parts 700 and 705 are not applicable or relevant and appropriate because they are
administrative or procedural in nature.
In Part 701, the descriptions of the classifications assigned to waters of the State,
including the classifications assigned to the creek, as well as a general prohibition on any
discharge that impairs the receiving water for its assigned best usages are relevant and
appropriate ARARs.
Part 702 includes procedures used for deriving water quality standards and guidance
values which are not applicable or relevant and appropriate because they are
administrative or procedural in nature.
Part 703 includes general and chemical-specific water quality standards and is relevant
and appropriate.
Part 704 would not be relevant and appropriate to alternatives involving dredging,
dewatering and discharge to the creek because no thermal discharges are otherwise
anticipated as a result of the cleanup of the site.
Part 706 includes procedures for developing water quality standards and guidance values
to protect aquatic life, which are not applicable or relevant and appropriate because they
are administrative or procedural in nature.
Parts 700-706 are not applicable ARARs because all the necessary jurisdictional
requirements are not met in the context of potential on-site response actions.
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ARAR Determination
Substantive provisions of Parts 703 and 704 are potential relevant and appropriate action-specific
ARARs for the on-site response.
2.3.15 State-New York, 6 NYCRR Parts 750-758
Summary
Part 750 provides general regulatory provisions for the SPDES.
Part 751 specifies the required SPDES permits.
Part 752 provides SPDES permit application and data requirements.
Part 753 provides notice and public participation requirements for SPDES permits.
Part 754 specifies required provisions for SPDES permits.
Part 755 provides requirements for the duration and reissuance of SPDES permits.
Part 756 provides the monitoring, recording and reporting requirements for SPDES
permits and schedules for compliance.
Part 757 provides the process for modification, suspension and revocation of SPDES
permits and schedules for compliance.
Part 758 provides supporting references.
Analysis
Substantive, non-procedural, non-permit related provisions of 6 NYCRR Parts 750-758 may be
relevant and appropriate as action-specific ARARs for the on-site response, depending on the
RAOs and technology chosen for cleanup of the site. Provisions of 6 NYCRR Parts 750-758
may be applicable or relevant and appropriate as action-specific ARARs for any off-site response
that may occur as part of remediation of the site, depending on the technologies chosen for
cleanup of the site.
The permit-related requirements of Parts 750-758 are not applicable because these regulations
are predicated on the New York SPDES regulations being directly controlling and on a New
York SPDES permit being required before any of the specified actions might lawfully proceed.
Other aspects of these regulations may be ARARs, depending on the circumstances, as described
below.
ARAR Determination
Substantive provisions of 6 NYCRR Parts 750-758 may be relevant and appropriate as
action-specific ARARs for the on-site response, depending on the RAOs and technology chosen
for cleanup of the site. Provisions of 6 NYCRR Parts 750-758 may be applicable or relevant and
appropriate as action-specific ARARs for any off-site response that may occur as part of
remediation of the site, depending on the technologies chosen for cleanup of the site.
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2.3.16 State—New York State Environmental Conservation Law, Article 17, Title 5
Summary
Environmental Conservation Law (ECL) Title 5 consists of:
• Section 17-0501, the general prohibition against pollution;
• Section 17-0503, the prohibition against pollution of waters of a marine district;
• Sectionl7-0505, the prohibition against certain acts without permit;
• Section 17-0507, the prohibition against modification of wastes discharged through an
existing outlet or point source without permit;
• Section 17-0509, minimum treatment required; and
• Section 17-0511, restrictions on discharge of sewage, industrial waste or other waste.
Analysis
Substantive, non-procedural, non-permit related provisions of Sections 17-0501, 17-0503,
17-0505, 17-507, 17-0509 and 17-0511 may be relevant and appropriate as action-specific
ARARs for the on-site response, depending on the RAOs and technology chosen for cleanup of
the site. Provisions of Sections 17-0501, 17-0503, 17-0505, 17-507, 17-0509 and 17-0511 may
be applicable or relevant and appropriate as action-specific ARAR for any off-site response that
may occur as part of remediation of the site, depending on the technologies chosen for cleanup of
the site.
The permit-related requirements of Sections 17-0501, 17-0503, 17-0505, 17-507, 17-0509 and
17-0511 are not applicable here because these statutes are predicated on the New York ECL
being directly controlling and on a New York ECL permit being required before any of the
specified actions might lawfully proceed. Other aspects of these statutes may be ARARs,
depending on the circumstances, as described below.
ARAR Determination
Substantive provisions of Sections 17-0501, 17-0503, 17-0505, 17-507, 17-0509 and 17-0511
may be relevant and appropriate as action-specific ARARs for the on-site response, depending
on the RAOs and technology chosen for cleanup of the site. Provisions of Sections 17-0501,
17-0503, 17-0505, 17-507, 17-0509 and 17-0511 may be applicable or relevant and appropriate
as action-specific ARAR for any off-site response that may occur as part of remediation of the
site, depending on the technologies chosen for cleanup of the site.
2.3.17 State—New York State Environmental Conservation Law § 11-0503
Summary
Section 11-0503 prohibits the polluting of streams by certain substances in quantities that are
injurious to fish and protected wildlife and waterfowl.
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Analysis
Substantive, non-procedural, non-permit related provisions of Section 11-0503 may be relevant
and appropriate as action-specific ARARs for the on-site response, depending on the RAOs and
technology chosen for cleanup of the site. Provisions of Section 11-0503 may be applicable or
relevant and appropriate as action-specific ARARs for any off-site response that may occur as
part of remediation of the site, depending on the technologies chosen for cleanup of the site.
This statute is predicated on the New York ECL being directly controlling. However, it is
solely CERCLA that controls actions at this site; other laws may pertain to this site only to the
extent allowed by 42 USC §9621(d). Therefore, the requirements of Section 11-0503 are not
applicable as an action-specific ARAR for the on-site response actions. Other aspects of this
statute may be ARARs, depending on the circumstances, as described below.
ARAR Determination
Substantive provisions of Section 11-0503 may be relevant and appropriate as action-specific
ARARs for the on-site response, depending on the RAOs and technology chosen for cleanup of
the site. Provisions of Section 11-0503 may be applicable or relevant and appropriate as
action-specific ARAR for any off-site response that may occur as part of remediation of the site,
depending on the technologies chosen for cleanup of the site.
2.3.18 Local-Local County or Municipal Pretreatment Requirements, Local Regulations
Summary
If water from remedial cleanup work was sent to a publicly-owned water treatment facility,
County or municipal pretreatment regulations would apply.
Analysis
CERCLA, the NCP, and EPA guidance do not allow for consideration of local regulations as an
ARAR for the on-site cleanup of a CERCLA site. Therefore, County or municipal pretreatment
regulations and other local regulations are not an action-specific ARAR for purposes of the
Lower Ley Creek remediation. However, provisions of county or municipal pretreatment
regulations and other local regulations may apply, according to their own terms, to the off-site
transport, final disposal or treatment of remediation wastes from the site.
ARAR Determination
County or municipal pretreatment regulations and other local regulations are not an
action-specific ARAR for purposes of the Lower Ley Creek remediation.
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TABLES
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Table A-l
Chemical-Specific Potential Applicable or Relevant and Appropriate Requirements
Mcdin m/Aiit liorit \
Ciliilion
Sliilus lor I S
Kc(|iiimm'iil S\nopsis
WATER
Clean Water Act 40 [Federal
Water Pollution Control Act;
as amended], 33 USC §§ 1251-
1387
40 CFR Part
129
Part 129 is a potential
relevant and appropriate
chemical-specific ARAR
for purposes of on-site
response.
Toxic Pollutant Effluent Standards
for aldrin/dieldrin, DDT, endrin,
toxaphene, benzidene and PCBs.
Safe Drinking Water Act, 42
USC §§ 300f -300j-26
40 CFR Part
141
Part 141 is a potential
relevant and appropriate
chemical-specific ARAR
for purposes of on-site
response.
National Primary Drinking Water
Regulations
New York State ECL Article
15, Title 3 and Article 17,
Titles 3 and 8
Part 608 includes the requirement to
obtain a SPDES permit for certain
discharges in any navigable waters of
the State (6 NYCRR 608.5). The
regulations contained in 6 NYCRR
Parts 700 - 706 include water quality
classifications, standards and
guidance values.
6 NYCRR Part
608
Relevant and appropriate
are Section 608.6(a) and
608.9(a).
Note that:
• Section 608.6(a) requires
development and submission of a
sufficiently detailed construction plan
with a map);
• Section 608.9(a) requires that
construction or operation of facilities
that may result in a discharge to
navigable waters demonstrate
compliance with CWA §§ 301 - 303,
306 and 307 and 6 NYCRR §§ 751.2
(prohibited discharges) and 754.1
(effluent prohibitions; effluent
limitations and water quality-related
effluent limitations; pretreatment
standards; standards of performance
for new sources.)
6 NYCRR Part
700
Part 700 is not applicable
or relevant and
appropriate because it is
administrative or
procedural in nature.
Part 700 provides definitions and
describes collection and sampling
procedures.
Page 1 of 3
-------
Table A-l
Chemical-Specific Potential Applicable or Relevant and Appropriate Requirements
Mc(liiim/Aiilhoril\
Ciliilion
Sliilus lor I S
Kc(|iiimiH'iil S\nopsis
New York State ECL Article
15, Title 3 and Article 17,
Titles 3 and 8
(continued)
6 NYCRR Part
701
Part 701 classifications
of waters of the State as
well as a general
prohibition on any
discharge that impairs
the receiving water for its
assigned best usages are
relevant and appropriate.
Part 701 establishes classifications
for surface waters and groundwater.
6 NYCRR Part
702
Part 702 procedures for
deriving water quality
standards and guidance
values are not applicable
or relevant and
appropriate because they
are administrative or
procedural in nature.
Part 702 establishes the deviation and
use of these standards and guidance
values.
6 NYCRR Part
703
Part 703 includes general
and chemical-specific
water quality standards
that are relevant and
appropriate.
Part 703 establishes surface water
and groundwater quality standards
and groundwater effluent limitations.
6 NYCRR Part
704
Part 704 potentially only
be relevant and
appropriate to
alternatives involving
dredging, dewatering at
elevated temperatures
and discharge to the
creek at elevated
Part 704 establishes criteria for
thermal discharges.
6 NYCRR Part
705
Part 705 is are not
applicable or relevant
and appropriate because
it is administrative or
procedural in nature.
Part 705 contains reference sources
for related regulations.
6 NYCRR Part
706
Part 706 procedures for
developing water quality
standards and guidance
values are not applicable
or relevant and
appropriate because they
are administrative or
procedural in nature.
Part 706 establishes additional
procedures for the derivation of
standards and guidance values that
are protective of aquatic life from
acute and chronic effects.
Page 2 of 3
-------
Table A-l
Chemical-Specific Potential Applicable or Relevant and Appropriate Requirements
Mcdiiim/Aiit liorit \
Ciliilion
Siiiius lor I S
Kc(|iiimiH'iil S\nopsis
AIR
No promulgated chemical-specific ARARs identified for air.
SEDIMENT
No promulgated chemical-specific ARARs identified for sediment.
BIOTA
No promulgated chemical-specific ARARs identified for fish (biota). The FDA limits (e.g., 1 ppm mercury, 2
ppm PCBs) are not based on federal or state environmental law.
Notes:
ARAR = Applicable or Relevant and Appropriate Requirements
CFR = Code of Federal Regulations
CWA = Clean Water Act
ECL = Environmental Conservation Law
DDT = dichlorodiphenyltrichloroethane
FDA = Food and Drug Administration
NYCRR = New York Codes, Rules, and Regulations
PCB = polychlorinated biphenyl
ppm = parts per million
SPDES = State Pollution Discharge Elimination System
Page 3 of 3
-------
Table A-2
Chemical-Specific Potential Criteria, Advisories and Guidance
To Be Considered
Mcriiiim/Aiilhorilt
( ihilion
Sliilus
lor I S
Ki'(|iiimm'nl S\nopsis
BIOTA
International Joint
Commission - United
States and Canada
Great Lakes Water Quality
Agreement of 1978, as
amended
TBC
The concentration of total PCBs in fish tissue
(whole fish, wet weight basis) should not exceed
0.1 |ig/g for the protection of birds and animals that
consume fish. Criterion for mercury is 0.5 |ig/g
mercury in whole fish [wet weight basis].
NOAA - Damage
Assessment Center
Reproductive,
Developmental and
Immunotoxic Effects of
PCBs in Fish: A Summary
of Laboratory and Field
Studies, March 1999
(Monosson, E.)
TBC
The effective concentrations for reproductive and
developmental toxicity fall within the ranges of the
PCB concentrations found in some of the most
contaminated fish. There are currently an
insufficient number of studies to estimate the
immunotoxicity of PCBs in fish.
Improper functioning of the reproductive system
and adverse effects on development may result
from adult fish liver concentrations of 25 to 71 ppm
Aroclor 1254.
PCB Congener BZ #77: 0.3 to 5 ppm (wet wt) in
adult fish livers reduces egg deposition, pituitary
gonadotropin, and gonadosomatic index, alters
retinoid concentration (Vitamin A), and reduces
larval survival. 1.3 ppm in eggs reduces larval
survival.
DEC Division of Fish
and Wildlife
Niagara River Biota
Contamination Project: Fish
Flesh Criteria for
Piscivorous Wildlife,
Technical Report 87-3, July
1987, pp. 41-48 and Table
26 (Newell et al.)
TBC
Provides a method for calculating concentrations of
organochlorines in fish flesh for the protection of
wildlife. The fish flesh criterion is 0.11 mg/kg wet
wt for PCBs, 3 mg/kg for dioxin/furans, and 0.33
mg/kg for hexachlorobenzene.
SEDIMENT
EPA Office of
Emergency and
Remedial Response
Guidance on Remedial
Actions for Superfund Sites
with PCB Contamination,
EP A/540/G- 90/007,
August 1990 (OSWERDir.
No. 9355.4-01).
TBC
Provides guidance in the investigation and remedy
selection process for PCB-contaminated Superfund
sites. Provides preliminary remediation goals for
various contaminated media, including sediment
(pp. 34-36) and identifies other considerations
important to protection of human health and the
environment.
NOAA - Damage
Assessment Office
Development and
Evaluation of Consensus-
Based Sediment Effect
TBC
Estuarine, freshwater and saltwater sediment effects
concentrations for total PCBs: Threshold Effect
Concentration: 0.04 mg/kg
Concentrations for PCBs in
the Hudson River,
MacDonald Environmental
Services Ltd., March 1999
Mid-range Effect Concentration: 0.4 mg/kg
Extreme Effect Concentration: 1.7 mg/kg
Page 1 of 3
-------
Table A-2
Chemical-Specific Potential Criteria, Advisories and Guidance
To Be Considered
Mcriiiim/Aiilhorilt
( ihilion
Sliilus
lor I S
Ki'(|iiimm'nl S\nopsis
NOAA (compilation of
other literature sources
for SQGs)
SQRTs for Organics
TBC
Tables with screening concentrations for inorganic
and organic contaminants.
EPA Great Lakes
National Program
Office, ARCS Program
Calculation and Evaluation
of Sediment Effect
Concentrations for the
Amphipod Hyalella azteca
and the midge Chironomus
riparius, EPA 905-R96-008,
September 1996
TBC
Provides SECs, which are defined as the
concentrations of a contaminant in sediment below
which toxicity is rarely observed and above which
toxicity is frequently observed.
DEC Division of Fish,
Wildlife and Marine
Resources
Technical Guidance for
Screening Contaminated
Sediment, January 1999
TBC
Includes a methodology to establish sediment
criteria for the purpose of identifying contaminated
sediments. Provides sediment quality screening
values for non-polar organic compounds, such as
PCBs, and metals to determine whether sediments
are contaminated (above screening criteria) or
clean (below screening criteria). Screening values
are not cleanup goals. Also discusses the use of
sediment criteria in risk management decisions.
SOIL
DEC-Division of
Environmental
Remediation
Technical Administrative
Guidance Memorandum No.
94- Remediation HWR-
4046
TBC
Recommended Soil Cleanup Objectives
Page 2 of 3
-------
Table A-2
Chemical-Specific Potential Criteria, Advisories and Guidance
To Be Considered
Mcriiiim/Aiilhorilt
( ihilion
Sliilus
lor I S
Ki'(|iiimm'nl S\nopsis
WATER
International Joint
Commission - United
States and Canada
Great Lakes Water Quality
Agreement of 1978, as
amended
TBC
The concentration of total PCBs in fish tissue
(whole fish, wet weight basis) should not exceed
0.1 |ig/g for the protection of birds and animals that
consume fish. Criterion for mercury is 0.5 |ig/g
mercury in whole fish [wet weight basis].
EPA
EPA Safe Drinking Water
Act
TBC
MCLs
EPA
EPA Federal Register,
Volume 57, No. 246,
December 22. 1992
TBC
Ambient Water Quality Criteria
DEC
DEC TOGS 1.1.2
TBC
New York State Groundwater Effluent Limitations
AIR
DEC
New York Air Cleanup
Criteria, January 1990
TBC
Provides guidance for the control of ambient air
contaminants in New York State.
Notes:
ARCS = Assessment and Remediation of Contminated Sediment
DEC = Department of Environmental Conservation
EPA = U.S. Environmental Protection Agency
MCL = maximum contaminant level
mg/kg = milligrams per kilogram
NOAA = National Oceanic and Atmospheric Administration
PCB = polychlorinated biphenyl
ppm = parts per million
SEC = sediment effect concentrations
SQG = Sediment Quality Guidelines
SQRT = Screening Quick Reference Table
TBC = To Be Considered
|ig/g = micrograms per gram
Page 3 of 3
-------
Table A-3
Location-Specific Potential Applicabe or Relevant and Appropriate Requirements
Mi-
-------
Table A-3
Location-Specific Potential Applicabe or Relevant and Appropriate Requirements
Mi-
-------
Table A-3
Location-Specific Potential Applicabe or Relevant and Appropriate Requirements
Mi-
-------
Table A-3
Location-Specific Potential Applicabe or Relevant and Appropriate Requirements
Mi-
-------
Table A-3
Location-Specific Potential Applicabe or Relevant and Appropriate Requirements
Mi-
-------
Table A-4
Location-Specific Potential Criteria, Advisories and Guidance
To Be Considered
Mctliii in/An I litiril>
Ciliilion
Sliilus
lor I S
Kc(|iiimiH*iil S\nopsis
EPA
Statement of Procedures on
Floodplain,
Management and Wetlands
Protection, January 1979
TBC
Requires Federal agencies to evaluate the
potential effects of actions it may take in a
floodplain to avoid adversely impacting
floodplains wherever possible and to ensure
that its planning programs and budget requests
reflect consideration of flood hazards and
floodplain management.
EPA Office of Solid
Waste and Emergency
Response
Policy on Floodplains and
Waste and Wetland
Assessments for CERCLA
Actions, August 1985
TBC
Superfund actions must meet the substantive
requirements of the Floodplain Management
Emergency Executive Order (E.O. 11988) and
the Protection of Response 1985 Wetlands
Executive Order (E.O. 11990) (see Table 9-3:
Location-Specific ARARs). This memorandum
discusses situations that require preparation of
a floodplain or wetlands assessment and the
factors that should be considered in preparing
an assessment for response actions taken
pursuant to Section 104 or 106 of CERCLA.
For remedial actions, a floodplain/wetlands
assessment must be incorporated into the
analysis conducted during the planning of the
remedial action.
Executive Order No.
11988, 42 Fed. Reg.
26951 (May 25, 1977)
Floodplain Management
TBC
Executive Order describes the circumstances
where federal agencies should manage
floodplains.
Executive Order No.
11990, 42 Fed. Reg.
26961 (May 25, 1977)
Protection of Wetlands
TBC
Executive Order describes the circumstances
where federal agencies should manage
wetlands.
Notes:
ARAR = Applicable or Relevant and Appropriate Requirement
CERLCA = Comprehensive Environmental Response, Compensation and Liability Act
E.O. = Executive Order
EPA = U.S. Environmental Protection Agency
TBC = To Be Considered
Page 1 of 1
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
Section 10, Rivers and
Harbors Act, 33 USC §
403
33 CFR Parts 320 -
330
Substantive portions
of 33 CFR Parts 321 ¦
322 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
U.S. Army Corps of Engineers approval is
generally required to excavate or fill, or in any
manner to alter or modify the course, location,
condition, or capacity of the channel of any
navigable water of the United States.
Clean Air Act, 42 USC
s/s 7401 et seq. (1970)
40 CFR Part 52
Not an action-
specific ARAR for
purposes of this on-
site response.
Approval and Promulgation of Implementation
Plans
Clean Air Act, 42 USC
s/s 7401 et seq. (1970)
40 CFR Part 60
Substantive portions
of 40 CFR Part 60
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Standards of Performance for New
Stationary Sources
Clean Air Act, 42 USC
s/s 7401 et seq. (1970)
40 CFR Parts 61
and 63
Substantive portions
of 40 CFR Parts 61
and 63 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Part 61- National Emission Standards for
Hazardous Air Pollutants.
Part 63 - National Emission Standards for
Hazardous Air Pollutants for Source Categories.
Section 402 of the
Clean Water Act
40 CFR Parts 121,
122, 125, 401 and
403.5
Substantive portions
of 40 CFR Parts 121,
122, 125, 401 and
403.5 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Provisions related to the implementation of the
National Pollutant Discharge Elimination
System (NPDES) program
Page 1 of 9
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
Safe Drinking Water
Act
40 CFR Parts 144 -
147
Substantive portions
of 40 CFR Parts 144 ¦
147 are not action-
specific ARARs for
purposes of on-site
response.
SDWA underground injection control program
Section 404(b) of the
Clean Water Act
40 CFR Part 230
Substantive portions
of 40 CFR Part 230
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Guidelines for Specification of Disposal Sites
for Dredged or Fill Material. Except as
otherwise provided under Clean Water Act
Section 404(b)(2), no discharge of dredged or
fill material shall be permitted if there is a
practicable alternative to the proposed discharge
which would have less adverse impact on the
aquatic ecosystem, so long as the alternative
does not have other significant adverse
environmental consequences. Includes criteria
for evaluating whether a particular discharge site
may be specified.
Section 404(c) of the
Clean Water Act,
33 USC § 1344(b)
33 CFR Parts 320,
323, 325, 329 and
330
Substantive portions
of 33 CFR Parts 320,
323 325, 329 and
330 are potential
relevant and
appropriate
action-specific
ARARs for purposes
of on-site response.
These regulations apply to all existing,
proposed, or potential disposal sites for
discharges of dredged or fill materials into U.S.
waters, which include wetlands. Includes special
policies, practices, and procedures to be
followed by the U.S. Army Corps of Engineers
in connection with the review of applications for
permits to authorize the discharge of dredged or
fill material into waters of the United States
pursuant to Section 404 of the Clean Water Act.
Resource Conservation
and Recovery Act
40 CFR Part 257
Substantive portions
of 40 CFR Part 257
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Criteria for Classification of Waste
Disposal Facilities
Page 2 of 9
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
Resource Conservation
and Recovery Act 42
USC s/s 6901 et seq.
(1976) Subtitle C -
Wastes
40 CFR Part 261
Substantive portions
of 40 CFR Parts 261
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Identification and listing of hazardous waste
Resource Conservation
and Recovery Act 42
USC s/s 6901 et seq.
(1976)
40 CFR Part 262
Substantive portions
of 40 CFR Part 262
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Standards applicable to generators of hazardous
waste
Resource Conservation
and Recovery Act 42
USC s/s 6901 et seq.
(1976)
40 CFR §262.11
Substantive portions
of 40 CFR § 262.11
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Hazardous waste determination
Resource Conservation
and Recovery Act, 42
USC s/s 6901 et seq.
(1976)
40 CFR Part
262.34
Substantive portions
of 40 CFR § 262.34
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Standards for Hazardous Waste
Generators, 90-Day Accumulation Rule
Page 3 of 9
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
Resource Conservation
and Recovery Act, 42
USC s/s 6901 et seq.
(1976)
40 CFR Part 264
and 265, Subparts
B-264.10-.19
F-264.90-.101
G-264.110-.120
J-264.190-.200
S-264.550-.555
X-264.600-.603
Substantive portions
of the referenced
Subparts of Parts 264
and 265 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Standards for Owners/Operators of Hazardous
Waste Treatment, Storage and Disposal
Facilities.
B- General Facility Standards F- Releases from
Solid Waste Management Units
G- Closure and Post Closure
J- Tank Systems
S- Special Provisions for Cleanup
X- Miscellaneous Units
Section 3004 of the
Resource Conservation
and Recovery Act
(Solid Waste Disposal
Act, as amended), 42
USC
§6924
40 CFR § 264.
13(b)
Substantive portions
of 40 CFR
§264.13(b) are
potential relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Owner or operator of a facility that treats, stores
or disposes of hazardous wastes must develop
and follow a written waste analysis plan.
Resource Conservation
and Recovery Act, 42
USC s/s 6901 et seq.-
1976
40 CFR Part 264
and 265, Subparts
K-264.220-.232
L-264.250-.259
N-264.300-.317
Substantive portions
of the referenced
Subparts of Parts 264
and 265 are potential
relevant and
appropriate
action-specific
ARARs for purposes
of on-site response.
Standards for Owners/Operators of Hazardous
Waste Treatment, Storage and Disposal
Facilities.
K- Surface Impounds
L-Waste Piles
N- Landfills, Subtitle C
Section 3004 of the
Resource Conservation
and Recovery Act, as
amended, 42 USC §
6924
40 CFR § 264.232
Substantive portions
of 40 CFR § 264.232
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Owners and operators shall manage all
hazardous waste placed in a surface
impoundment in accordance with 40
CFR Subparts BB (Air Emission Standards for
Equipment Leaks) and CC (Air Emission
Standards for Tanks, Surface Impoundments and
Containers).
Page 4 of 9
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
Resource Conservation
and Recovery Act,
42 USC s/s 6901 et
seq. (1976)
40 CFR Part 268
Substantive portions
of 40 CFR Part 268
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Land disposal restrictions
C- Prohibitions on Land Disposal
Toxic Substances
Control Act (TSCA),
Title 1,15 USC § 2605
40 CFR Part 761
Substantive portions
of 40 CFR Part 761
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Polychlorinated biphenyls (PCBs)
manufacturing, processing, distribution in
commerce, and use prohibitions
Hazardous Materials
Transportation Act, as
amended, 49 USC §§
5101-5127
49 CFR Part 170.
Substantive portions
of 49 CFR Part 170
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Transport of hazardous materials program
procedures.
Hazardous Materials
Transportation Act, as
amended, 49 USC §§
5101-5127
49 CFR Part 171
Substantive portions
of 49 CFR Part 171
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
Department of Transportation Rules for
Transportation of Hazardous Materials,
including procedures for the packaging, labeling,
manifesting and transporting
of hazardous materials.
Resource Conservation
and Recovery Act,
42 USC s/s 6901 et
seq. (1976)
62 Fed. Reg.
25997 and 63 Fed.
Reg. 65874
Not an action-
specific ARAR for
purposes of this on-
site response.
Subtitle C, Phase IV Supplemental Proposal on
Land Disposal of Mineral Processing Wastes (62
FR 25997), and Hazard Remediation Waste
Management requirements (63 FR 65874).
Page 5 of 9
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
New York State ECL
Article 17, Title 5
Substantive portions
of 17-0501, 17-0503,
17-0505, 17-0507,
17-0509 and 17-0511
are potential relevant
and appropriate
action-specific
ARARs for purposes
of on-site response.
It shall be unlawful for any person, directly or
indirectly, to throw, drain, run or otherwise
discharge into such waters organic or inorganic
matter that shall cause or contribute to a
condition in contravention of applicable
standards identified at 6 NYCRR § 701.1.
New York State ECL
Article 11, Title 5
NY ECL § 11-
0503
Substantive portions
of 11-0503 are
potential relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Fish & Wildlife Law against water pollution. No
deleterious or poisonous substances shall be
thrown or allowed to run into any public or
private waters in quantities injurious to fish life,
protected wildlife, or waterfowl inhabiting those
waters, or injurious to the propagation of fish,
protected wildlife, or waterfowl therein.
New York State ECL
Article 19, Title 3 - Air
Pollution Control Law.
Promulgated pursuant
to the Federal Clean
Air Act, 42 USC §
7401
6 NYCRR Parts
200, 202, 205,
207,211,212,
219, and 257.
Substantive portions
of 6 NYCRR Parts
200, 202, 205,
207,211,212,
219, and 257 are
potential relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Air Pollution Control Regulations. The
emissions of air contaminants that Jeopardize
human, plant, or animal life, or is ruinous to
property, or causes a level of discomfort is
strictly prohibited.
New York State ECL
Article 27, Title 7
6 NYCRR Part
360
Substantive portions
of 6 NYCRR Part
360 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Solid Waste Management Facilities New York
State regulations for design, construction,
operation, and closure requirements for solid
waste management facilities.
Page 6 of 9
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
New York State ECL
Article 27, Title 11
6 NYCRR Part
361
Substantive portions
of 6 NYCRR Part
361 are potential
relevant and
appropriate
action-specific
ARARs for purposes
of on-site response.
Siting of Industrial Hazardous Waste Facilities
establishes criteria for siting industrial hazardous
waste treatment, storage and disposal facilities.
Regulates the siting of new industrial hazardous
waste facilities located wholly or partially within
New York State. Identifies criteria by which the
facilities siting board will determine whether to
approve a proposed industrial hazardous waste
facility.
New York State ECL
Article 27, Title 3
6 NYCRR Part
364
Substantive portions
of 6 NYCRR Part
364 are potential
relevant and
appropriate
action-specific
ARARs for purposes
of on-site response.
Standards for Waste Transportation Regulations
governing the collection, transport and delivery
of regulated wastes, including hazardous wastes.
New York State ECL
Article 27, Title 9
6 NYCRR Parts
370 and
371
Substantive portions
of 6 NYCRR Parts
370 and 371 are
potential relevant and
appropriate
action-specific
ARARs for purposes
of on-site response.
New York State regulations for activities
associated with hazardous waste Management.
New York State ECL
Article 3, Title 3;
Article 27, Titles 7 and
9
6 NYCRR Part
372
Substantive portions
of 6 NYCRR Part
372 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Hazardous Waste Manifest System and Related
Standards for Generators, Transporters and
Facilities. Includes Hazardous Waste Manifest
System requirements for generators,
transporters, and treatment, storage or disposal
facilities, and other requirements applicable to
generators and transporters of hazardous waste.
Page 7 of 9
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
New York State ECL
Article 3, Title 3;
Article 27, Titles 7 and
9
6 NYCRR Part
373
Substantive portions
of 6 NYCRR Part
373 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Hazardous Waste Manifest System and Related
Standards for Generators, Transporters and
Facilities. Includes Hazardous Waste Manifest
System requirements for generators,
transporters, and treatment, storage or disposal
facilities, and other requirements applicable to
generators and transporters of hazardous waste.
New York State ECL
Article 27 Title 13
6 NYCRR Part
375
Substantive portions
of 6 NYCRR Part
375 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on-site
response.
Inactive Hazardous Waste Disposal Sites.
Establishes standards for the development and
implementation of inactive hazardous waste
disposal site remedial programs.
New York State ECL
Article 27, Title 9
6 NYCRR Part
376
Substantive portions
of 6 NYCRR Part
376 are potential
relevant and
appropriate
action-specific
ARARs for purposes
of on-site response.
Land Disposal Restrictions. PCB wastes
including dredge spoils containing PCBs greater
than 50 ppm must be disposed of in accordance
with federal regulations at 40 CFR Part 761.
New York State ECL
Article 15, Title 5, and
Article 17, Title 3
6 NYCRR Part
608
Substantive portions
of 6 NYCRR Part
608 are potential
relevant and
appropriate action-
specific ARARs for
purposes of on- site
response.
Use and Protection of Waters.
A permit is required to change, modify, or
disturb any protected stream, its bed or banks, or
remove from its bed or banks sand or gravel or
any other material; or to excavate or place fill in
any of the navigable waters of the state. Any
applicant for a federal license or permit to
conduct any activity which may result in any
discharge into navigable waters must obtain a
State Water Quality Certification under Section
401 of the Federal Water Pollution Control Act.
33 USC § 1341
Page 8 of 9
-------
Table A-5
Action-Specific Potential Applicable or Relevant and Appropriate Requirements
Medium/.Xulhoriit
( iliiliun
Sliilus l'«r I S
Ki'(|iiiivmcnl S\uopsis
New York State ECL,
Article 1. Title 1,
Article 3 Title 3,
Article 15 Title 3,
Article 17 Title 1, 3,
and 8
6 NYCRR Part
700-706
Substantive portions
of 6 NYCRR Parts
701 and 703 are
potential relevant and
appropriate
action-specific
ARARs for purposes
of on-
site response.
New York limitations on discharges of sewage,
industrial waste or other wastes.
New York State ECL
Article 17, Title 8
6 NYCRR Parts
750-758
Substantive portions
of 6 NYCRR Parts
750 - 758 are
potential relevant and
appropriate
action-specific
ARARs for purposes
of on-site response.
New York SPDES Requirements Standards for
Storm Water Runoff, Surface Water, and
Groundwater Discharges, In general, no person
shall discharge or cause a discharge to NY State
waters of any pollutant without a permit under
the New York SPDES program.
Local County or
Municipality
Pretreatment
Requirements
Local regulations
Not an action-
specific ARAR for
purposes of this on-
site response.
Local regulations
Notes:
ARAR = Applicable or Relevant and Appropriate Requirements
CFR = Code of Federal Regulations
ECL = Environmental Conservation Law
NPDES = National Pollutant Discharge Elimination System
NYCRR = New York Codes, Rules, and Regulations
PCB = polychlorinated biphenyl
ppm = parts per million
SPDES = State Pollution Discharge Elimination System
SDWA = Safe Drinking Water Act
Page 9 of 9
-------
Table A-6
Action-Specific Potential Criteria, Advisories, and Guidance to Be Considered
Mi'diiim/
Anl Iki i~il\
Cihiliiin
Si;iIlls l'iil-
IS
Ki'(|iiimiU'iil S\ nopsis
EPA
Covers for Uncontrolled
Hazardous Waste Sites
(EPA/540/2-85-002; September
1985)
TBC
Covers for Uncontrolled Hazardous Waste
Sites should include a vegetated top cover, middle
drainage layer, and low permeability layer.
EPA
Rules of Thumb for Superfund
Remedy Selection (EPA 540-R-97
013, August 1997)
TBC
Describes key principles and expectations, as well
as "best practices" based on program experience for
the remedy selection process under Superfund.
Major policy areas covered are risk assessment and
risk management, developing remedial alternatives,
and groundwater response actions.
EPA
Land Use in the CERCLA
Remedy Selection Process
(OSWER Directive No. 9355.7-
04, May 1995)
TBC
Presents information for considering land use in
making remedy selection decisions at NPL sites.
EPA
Principles for Managing
Contaminated Sediment Risks at
Hazardous Waste Sites (OSWER
Directive 9285.6-08, February
2002)
TBC
Presents risk management principles that site
managers should consider when making risk
management decisions at contaminated sediment
sites.
EPA
Contaminated Sediment Strategy
(EPA-823-R-98- 001, April 1998)
TBC
Establishes an Agency-wide strategy for
contaminated sediments, with the following four
goals: 1) prevent the volume of contaminated
sediments from increasing; 2) reduce the volume of
existing contaminated sediment; 3) ensure that
sediment dredging and dredged material disposal
are managed in an environmentally sound manner;
and 4) develop scientifically sound sediment
management tools for use in pollution prevention,
source control, remediation, and dredged material
management.
EPA
Contaminated Sediment
Remediation Guidance for
Hazardous Waste Sites (OSWER
9355.0-85 draft November
2002)
TBC
Provides technical and policy guidance for
addressing contaminated sediment sites nationwide
primarily associated with
CERCLA actions.
EPA
Developing Remedial Action
Objectives and Cleanup Levels
for Contaminated Sediment Sites
addressed Under CERCLA,
October 2012
TBC
Provides technical and policy guidance under
CERCLA for addressing determing remedial action
objectives and cleanup requirements at sediment
sites.
Page 1 of 3
-------
Table A-6
Action-Specific Potential Criteria, Advisories, and Guidance to Be Considered
Mi'diiim/
Anl Iki i~il\
Cihiliiin
Si;iIlls l'iil-
IS
Ki'(|iiimiU'iil S\ nopsis
EPA
Structure and Components of Five-
Year Reviews (OSWER Directive
9355.7- 02, May 1991)
Supplemental Five-Year Review
Guidance (OSWER Directive
9355.7-02A, July 1994)
Second Supplemental Five-Year
Review Guidance (OSWER
9355.7-03A, December 1995)
TBC
Provides guidance on conducting Five-Year
Reviews for sites at which hazardous substances,
pollutants, or contaminants remain on-site above
levels that allow for unrestricted use and unlimited
exposure. The purpose of the Five-Year Review is
to evaluate whether the selected response action
continues to be protective of public health and the
environment and is functioning as designed.
EPA
40 CFR Part 50
TBC
Clean Air Act, National Ambient Air
Quality Standards
USACE
USACE, Notice on Issuance of
Nationwide Permits, 67 Fed. Reg.
2020 (Jan. 15, 2002).
TBC
DEC
Letter from William R. Adriance,
Chief Permit Administrator, to
Richard Tomer and Paul G.
Leuchner, Chiefs of the New
York and Buffalo Districts of
USACE, re. Section 401 Water
Quality Certification, January 15,
2002 Nationwide Permits (Mar.
15, 2002).
TBC
DEC
New York Guidelines for Soil
Erosion and Sediment Control
TBC
DEC
Air Guide 1 - Guidelines for the
Control of Toxic Ambient Air
Contaminants, 2000
TBC
Provides guidance for the control of toxic ambient
air contaminants in New York State. Current
annual guideline concentrations for PCBs are 0.01
(ig/m3 for inhalation of evaporative congeners
(Aroclor 1242 and below) and 0.002 ng/m3 for
inhalation of persistent highly chlorinated
congeners (Aroclor 1248 and above) in the form of
dust or
aerosols.
DEC
Technical and Operational
Guidance Series (TOGS) 1.1.1
Ambient Water
TBC
Provides guidance for ambient water quality
standards and guidance values for pollutants
DEC
TOGS 1.2.1 Industrial SPDES
Permit Drafting Strategy for
Surface Waters
TBC
Provides guidance for writing permits for
discharges of wastewater from industrial facilities
and for writing requirements equivalent to SPDES
permits for discharges from remediation sites.
Page 2 of 3
-------
Table A-6
Action-Specific Potential Criteria, Advisories, and Guidance to Be Considered
Mi'diiim/
Anl Iki i~il\
Cihiliiin
Si;iIlls l'iil-
IS
Ki'(|iiimiU'iil S\ nopsis
DEC
TOGS 1.3.1 Waste Assimilative
Capacity Analysis & Allocation
for Setting
TBC
Provides guidance to water quality control
engineers in determining whether discharges to
water bodies have a reasonable potential to violate
water quality standards and guidance values.
DEC
TOGS 1.3.2 Toxicity Testing in
the SPDES Permit Program
TBC
Describes the criteria for deciding when toxicity
testing will be required in a permit and the
procedures which should be followed when
including toxicity testing requirements in a permit.
DEC
TOGS 2.1.1, Guidance on
Groundwater Contamination
Strategy
TBC
DEC,
Division of
Environ-
mental
Remedi-
ation
Technical and Administrative
Guidance Memorandum (TAGM)
4031 Fugitive Dust Suppression
and Particulate Monitoring
Program at Inactive Hazardous
Waste Sites
TBC
Provides guidance on fugitive dust suppression and
particulate monitoring for inactive hazardous waste
sites.
DEC
Interim Guidance on Freshwater
Navigational Dredging, October
1994
TBC
Provides guidance for navigational dredging
activities in freshwater areas.
DEC
Division of
Fish,
Wildlife and
Marine
Resources
Fish and Wildlife Impact Analysis
for Inactive Hazardous Waste
Sites, October 1994
TBC
Provides rationale and methods for sampling and
evaluating impacts of a site on fish and wildlife
during the remedial investigation and other stages
of the remedial process
DEC TAGM
3028
"Contained-In Criteria for
Environmental Media (November
30, 1992).
TBC
Provides "contained-in" concentrations/ action
levels for environmental media and the basis for
these criteria.
Notes:
CERLCA = Comprehensive Environmental Response, Compensation and Liability Act
CFR = Code of Federal Regulations
DEC = Department of Environmental Conservation
EPA = U.S. Environmental Protection Agency
NPL = National Priority List
OSWER = Office of Solid Waste and Emergency Response
PCB = polychlorinated biphenyl
SPDES = State Pollution Discharge Elimination System
TBC = To Be Considered
TAGM = Technical and Administrative Guidance Memorandum
TOGS = Technical and Operational Guidance Series
USACE = U.S. Army Corps of Engineers
Page 3 of 3
-------
APPENDIX B
Development of Soil and Sediment PRGs
-------
APPENDIX B
DEVELOPMENT OF SOIL AND SEDIMENT
PRELIMINARY REMEDIATION GOALS
LOWER LEY CREEK SUBSITE OF THE
ONONDAGA LAKE SUPERFUND SITE, SYRACUSE, NY
1.0 PRG CALCULATION SUMMARY
This appendix presents the information and rationale used in the identification of PRGs for the
FS. PRGs were calculated following the assumptions and information (e.g., exposure
assumptions, ingestion rates, etc.) presented in the HHRA and BERA. The Human Health and
Ecological PRGs are presented in Table 1 and Table 2, respectively. The Human Health and
Ecological PRG calculations are detailed in Tables l.A through l.J and Tables 2.A through
2.F, respectively.
1.1 HUMAN HEALTH PRGS
PRGs were calculated for exposure to all identified site COCs in site soil, sediment, and fish
tissue. Site COCs were identified as contaminants contributing a cancer risk exceeding 1E-05
to a cumulative cancer risk greater than 1E-04, or a contaminant that contributed substantially
to a non-cancer target organ hazard index (HI) greater than 1. Identification was based on the
reasonable maximum exposure (RME) scenarios. To be consistent with the baseline HHRA,
the inhalation exposure route was not considered in the PRG calculations. Because inhalation
generally contributes negligibly to overall risk, this approach is appropriate.
1.1.1 Soil
The following COCs were identified for the site soil: benzo(a)anthracene, benzo(a)pyrene,
benzo(b)fluoranthene, dibenzo(a,h)anthracene, indeno(l,2,3-c,d)pyrene, chromium, PCB-
1248, and PCB-1260. The majority of the COCs were identified because of excessive
contributions to cumulative cancer risks. PCB-1260 was identified solely because of
contributions to non-cancer hazards.
For each of these COCs, PRGs were calculated for the following receptors: Adult Recreational
Visitor, Older Child Recreational Visitor (6 to 16 years old), Younger Child Recreational
Visitor (less than 6 years old), and Construction Worker. Calculated soil PRGs for these
receptors are presented in Table 1, along with the New York Remedial Program Soil Cleanup
Objectives. These values were compared to the calculated PRGs to identify the most
conservative proposed cleanup level for each COC (most conservative PRG is shaded).
1.1.2 Sediment
The following COCs were identified in site sediment for at least one site receptor: 3-
methylcholanthrene, benzo(a)pyrene, dibenzo(a,h)anthracene, PCB-1260, and vanadium. For
LT2005
U.S. EPA Region 2
B-l-1
HGL 5/15/2013
-------
HGL—Appendix B—Lower Ley Creek Subsite of the Onondaga Lake Superfund Site, Syracuse, NY
each of these COCs (where applicable), PRGs were calculated for the following receptors:
Adult Recreational Visitor, Older Child Recreational Visitor (6 to 16 years old), and Younger
Child Recreational Visitor (less than 6 years old). PRGs were not calculated for the
Construction Worker because no COCs were identified for this receptor. Calculated sediment
PRGs for these receptors are presented in Table 1. New York sediment screening values (for
sediment direct contact) are not available. Accordingly, the most conservative calculated PRG
is identified as the proposed PRG for each COC (most conservative PRG is shaded).
1.1.3 Fish Tissue
The following COCs were identified for exposure to fish tissue: PCB-1254, PCB-1260, total
PCBs, total dioxins/furans (as TEQ), dieldrin, arsenic, chromium, and mercury. For these
COCs, PRGs were calculated for the Adult Recreational Visitor, Older Child Recreational
Visitor (6 to 16 years old), and Younger Child Recreational Visitor (less than 6 years old).
PRGs were not calculated for the Construction Worker because this exposure pathway was
identified as incomplete.
After the calculation of fish tissue PRGs (mg/kg fish tissue), an associated sediment PRG
concentration (mg/kg sediment) was calculated using site-specific biota-sediment accumulation
factors (BSAFs). This sediment PRG concentration is protective of the fish ingestion pathway.
Site-specific BSAFs were calculated by dividing the fish tissue exposure point concentration
(EPC) for each contaminant by the sediment EPC. These EPCs (95% UCLs) were obtained
from the Lower Ley Creek BERA. The calculation of fish tissue PRGs is detailed in Tables
l.H through l.J.
Calculated fish tissue PRGs (in both mg/kg of fish tissue and mg/kg of sediment) are presented
in Table 1. Also presented in Table 1 are the New York Sediment Screening Criteria for
Human Health Bioaccumulation (mg/kg of sediment). These values were compared to the
calculated PRGs to identify the most conservative proposed cleanup level for each COC (most
conservative PRG is shaded).
1.2 ECOLOGICAL PRGS
Ecological PRGs were calculated or identified for the ecological receptors and sediment COCs
identified in the BERA. These PRGs are summarized in Table 2. In addition, soil at Lower
Ley Creek was evaluated with respect to ecological receptors to determine the extent of
potential risk associated with exposure of ecological receptors to site surface soil. These
evaluations are discussed below.
1.2.1 Sediment
Ecological receptors identified within the BERA as having potential risk from exposure to site
sediment include upper level trophic receptors (piscivorous mammals and birds) and benthic
invertebrates. For upper trophic level receptors, PRGs were calculated (using a food web) to
be protective of the mink (piscivorous mammal) and belted kingfisher (piscivorous bird).
These two receptors were the most conservative of the four evaluated in the BERA. The food
LT2005
U.S. EPA Region 2
B-l-2
HGL 5/15/2013
-------
HGL—Appendix B—Lower Ley Creek Subsite of the Onondaga Lake Superfund Site, Syracuse, NY
web calculations (presented in Table 2.A) incorporated direct contact with sediment (ingestion
of sediment), bioaccumulation of sediment in fish tissue (ingestion of fish tissue), and direct
contact with surface water (ingestion of surface water). All exposure parameters for the food
web calculations (e.g., sediment ingestion rates, diet composition, body weight, etc.) were
obtained from the BERA. To provide risk management information, two PRGs were
calculated for each COC: one based on the LOAEL and one based on the NOAEL. The
BSAFs were calculated from the sediment and fish tissue concentrations presented in the
Several inorganics and total PAHs were identified within the BERA (benchmark screening) as
posing a potential threat to benthic invertebrates via exposure to site sediment. These COCs
include arsenic, cadmium, chromium, copper, lead, mercury, nickel, silver, zinc, and total
PAHs. Within the BERA, "no effect" concentrations were identified via toxicity testing for
each of the identified COCs. These concentrations are presented in detail in Table 2.B and are
identified as the proposed PRGs for the benthic invertebrate receptor.
The food web and benthic invertebrate PRGs are summarized in Table 2. Also presented in
Table 2 are the New York Sediment Screening Criteria for Metals, for Benthic Aquatic Life
(Chronic Toxicity), and for Wildlife Bioaccumulation. These values were compared to the
calculated PRGs to identify the most conservative proposed cleanup level for each COC (most
conservative PRG is shaded).
Because soil was not evaluated in the BERA, this PRG evaluation also evaluated potential risk
to ecological receptors from exposure to site soil. For this evaluation, maximum surface soil
concentrations of all detected analytes (obtained from the Human Health Risk Assessment,
Table 2s) were compared to benchmark values protective of ecological receptors. This
evaluation is presented in Table 2.C. Benchmark values were obtained from U.S. EPA Eco-
SSLs, New York Soil Cleanup Objectives for Protection of Ecological Resources, and U.S.
EPA Region 5 Ecological Soil Screening Levels. Precedence was given to the Eco-SSLs in
the screening process.
As shown in Table 2.C, the maximum detected soil concentration of the following analytes
exceeded the associated benchmark screening level:
BERA.
1.2.2 Soil
Antimony
Barium
Lead
Cadmium
Chromium
Copper
Metals
Organics
Butylbenzylphthalate
Di-n-butylphthalate
Endrin
DDT and Metabolites
PCB-1248
PCB-1260
Manganese
Mercury
High molecular weight PAHs
Low molecular weight PAHs
LT2005
U.S. EPA Region 2
B-l-3
HGL 5/15/2013
-------
HGL—Appendix B—Lower Ley Creek Subsite of the Onondaga Lake Superfund Site, Syracuse, NY
Metals Organics
• Nickel
• Selenium
• Silver
• Vanadium
• Zinc
The vanadium and manganese results may reflect natural soil conditions. In addition,
maximum barium, selenium, and dibutyl phthalate concentrations only slightly exceeded their
screening values. It is unlikely these analytes would pose a significant ecological threat.
LT2005
U.S. EPA Region 2
B-l-4
HGL 5/15/2013
-------
Table 1
Human Health Risk-based Cleanup Values
Summary Table
Le\ Creek - Soil
CAS Number
Constituent
Lower Le\ Creek Soil LPC
ulili/.ed in III IRA
(nmkm
New York Remedial
Program Soil Cleanup
Objectives
(lll!> ki>)
Proposed Lower Le\ Creek PR(j -
Adull Recreational Visitor
(nmkm
Proposed Lower Le\ Creek PR(i -
Older Child Recreational Visitor
(nmkm
Proposed Lower Le\ Creek PR(j -
Younger Child Recreational Visitor
(nmkm
Proposed Lower Le\ Creek PR(« -
Construction Worker
dim km
Cancer Non-Cancer
Cancer Non-Cancer
Cancer Non-Cancer
Cancer Non-Cancer
COCs
Benzo(a)anthracene
9.2
1
—
—
1.7
—
() Mi
—
—
—
Benzo(a)pyrene
5.8
1
1.8
—
0.17
—
O.OWi
—
—
—
Benzo(b)fluoranthene
6.1
1
—
—
1.7
—
() (\<\
—
—
—
Dibenzo(a,h)anthracene
0.96
0.33
—
—
0.17
—
n.nwi
—
—
—
Indeno(l ,2,3-c,d)pyrene
3.3
n 5
—
—
1.7
—
0.66
—
—
—
Chromium
275
1
83
5,360
42
4,441
6.5
574
—
—
Aroclor 1260
0.1
—
—
2.0
0.57
1.7
0.3
—
—
Aroclor 1248
11
0.1
6.1
11
2.0
0.57
1.7
0.3
17
2.0
Le\ Creek - Sediinenl (l)irecl Conlacl)
CAS Nuinher
Constituent
Lower Le\ Creek Sediinenl
LPC ulili/.ed in III IRA
mm km
New York Remedial
Program Soil Cleanup
Objectives
(nmkm
Proposed l-ower Lev Creek PR(« -
Adult Recreational Visitor
(inukm
Proposed Lower Le\ Creek PR(i -
Older Child Recreational Visitor
(nmkm
Proposed Lower Le\ Creek PR(i -
Yoiumer Child Recreational Visitor
(nmkm
Cancer Non-Cancer
Cancer Non-Cancer
Cancer Non-Cancer
COCs
56-49-5
3-Methylcholanthrene
5.7
-
—
—
0.96
—
0.15
—
50-32-8
Benzo(a)pyrene
8.9
-
1.8
—
0.17
—
n.nwi
—
53-70-3
Dibenzo(a,h)anthracene
0.73
-
—
—
—
—
I) (IMi
—
11096-82-5
Aroclor 1260
18
-
~
-
2.0
1.1
1.7
0 Sy
Lc\ Creek - Sediinenl (Bioacciimiilalion inlo Tisli Tissue)
CAS Nuinher
Constituent
Lower Le\ Creek I'isli
Tissue LPC ulili/.ed in
III IRA
dim k:> in lisli tissue)
New York Sediment
Criteria - Human Health
Bioaacumulalioir'
dim in sediment)
Proposed Lower Le\ Creek PR(i -
Adull Recreational \ isilor
(ni«i k«i in sediinenl)
Proposed Lower Le\ Creek PR(« -
Older Child Recreational \ isilor
dim. k:> in sediment)
Proposed Lower Le\ Creek PR(i -
\ oiumer Child Recreational \ isiior
(nm,l\!> in sediinenl)
Cancer Non-Cancer
Cancer Non-Cancer
Cancer Non-Cancer
COCs
11097-69-1
Aroclor-125 4
1.2
()()()(IN
—
0.0027
—
0.0034
—
0.0018
11096-82-5
Aroclor-1260
0.58
()()()(IN
—
0.30
—
0.37
—
0.19
—
Total PCBs
1.3
()()()(IN
0.49
—
1.8
—
1.6
—
1746-01-6
Total D/F, as TEQ
0.0000035
-
ooooi )51
0.00023
0.00019
0.00028
0.00016
0.00015
60-57-1
Dieldrin
0.017
0.1
0.011
0.36
0.039
0.45
0.034
0.23
7440-38-2
Arsenic
1.4
6b
1.8
34
6.5
42
5.7
22
7440-47-3
Chromium
44
!<¦>
62
3,999
77
4,960
38
2,581
7439-97-6
Mercury
0.48
0.15h
2.4
-
3.0
-
1.6
Notes:
a = Organic sediment screening values obtained from Table 1: Sediment Criteria for Non-polar Organic Compounds in "Technical Guidance for Screening Contaminated Sediments, New York State Department of Environmental
Conservation, January 1999."
b = Metals sediment screening values obtained from Table 2: Sediment Criteria for Metals in "Technical Guidance for Screening Contaminated Sediments, New York State Department of Environmental Conservation, January 1999."
EPC = Exposure Point Concentration.
PRG = Preliminary Remdiation Goal.
= Lowest proposed PRG
— = not available or not applicable
Page 1 of 1
-------
Table l.A
Human Health Risk-Based Cleanup Values
Lower Ley Creek Soil
Adult Recreational Visitor (> 16 years)
\dnll lUii uilioiiiil \ isilor i -
(oiisiinii'iil
Soil i; 1 *( I lili/.i-d
in IIIIK \
I'l'oposl'd
( k;uui|) VjiIiii-
i niji k«i
'I'iii'Kii Orjiiin
Kiri-plor
Siviiiiiio
ll;i/;ii (l Index
\on-( ;iniir Kisk
Benzo(a)pyrene
5.82
--
-
--
Chromium
275
5,360
Gastrointestinal
1
Aroclor 1248
11.41
11
Whole body
1
( IIIK'IT Kisk
Benzo(a)pyrene
5.82
1.77
--
l.E-05
Chromium
275
83.4
--
l.E-05
Aroclor 1248
11.41
6.14
--
l.E-05
I'!\|)omiiv I'iiiiiiiKUi s I lili/.i-d in IIIIK \
I'iiniiniii'i'
Diiinilion
I nils
V;iliu-
CF
Unit Conversion
Factor for Soil
kg/mg
0.000001
IR
Ingestion Rate of
Soil
mg/day
100
FI
Fraction Ingested
from Soil
unitless
1
EF
Exposure
Frequency
days/year
143
ED
Exposure Duration
years
30
SA
Skin Surface Area
for Dermal
Absorption
cm2/day
5,700
AF
Soil to Skin
Adherence Factor
mg/cm2
0.3
BW
Body Weight
kg
70
AT-NC
Averaging Time -
Non-Cancer
days
10,950
AT-C
Averaging Time -
Cancer
days
25,550
Ingestion Intake Multiplier - Non-Cancer
day 1
5.59687E-07
Dermal Intake Multiplier - Non-Cancer
day 1
9.57065E-06
Ingestion Intake Multiplier - Cancer
day 1
2.40E-07
Dermal Intake Multiplier - Cancer
day 1
4.10E-06
( lKiiiii;il-S|K(.ilii I'iiniini'li'i-s I lili/id in IIIIK \ - \on-( ;iikvi"
( lainiiiil til'
I'oknlul
( 'oniirn
<>r;il KID
(>r;il Absorption
Llikkno lor
Di-niiiil
iiinilk'ssi
Absorbed KID
lor Dirniiil
Dirniiil Vbsorpiion liiilor
\ illlll'
I nils
\ illlll'
I nils
V;iliu-
I nils
COCs
Benzo(a)pyrene
-
mg/kg-day
1
~
mg/kg-day
1.3E-01
Unitless
Chromium
3.0E-03
mg/kg-day
0.025
7.5E-05
mg/kg-day
-
Aroclor 1248
2.0F.-05
mg/kg-day
1
2.0E-05
mg/kg-day
I.4F.-0I
Unitless
Cliuniuil-SpirilK' I'iiriinuii-rs I iili/i-d in IIIIK \ - (iiiuw
( iK-miiiil ol'
I'lik-nliiil
( (lllll l ll
()i;il ( SI
()i;il \l>soi°|)lion
lillkiuio lor
l)i'i-in;il
< iinil k-ssi
Vbsorbi'd CSI-'
lor Dirniiil
Dii niiil \bsorplion l;klor
Yiiliii'
I nils
Villlll'
I nils
V;iliu-
I nils
COCs
Benzo(a)pyrene
7.3E+00
(mg/kg-day)"1
1
7.3E+00
(mg/kg-day)-1
1.3E-01
Unitless
Chromium
5.0E-01
(mg/kg-day)-1
0.025
2.0E+01
(mg/kg-day)-1
~
Aroclor 1248
2.0E+00
(mg/kg-day)-1
1
2.0E+00
(mg/kg-day)-1
1.4E-01
Unitless
Page 1 of 1
-------
Table l.B
Human Health Risk-Based Cleanup Values - Lower Ley Creek Soil
Older Child Recreational Visitor (6 to 16 years)
( >lll'T < llllll l\> r|-i'.lln>ll.ll \ Mlm- ift III 16 Vi-.ll'>.!
< llll-lllll>-|ll
"Mill l.l'f 1 lili/'il
in IIIIK \
Proposed
Cleanup Value
(tug/kg)
l.il'L"-l 'Ml1.ill
l\i-i->-|i|ii|-
¦V'-n.iriii
1 I.i/.iiiI IihI'A
Non-Cancer Risk
Benzo(a)anthracene
9.2
Benzo(a)pyrene
5.82
Benzo(b)fluoranthene
6.13
Dibenzo(a,h)anthracene
0.96
Indeno( 1,2,3-c,d)PVrene
3.31
Chromium
275
4,441
Gastrointestinal
1
Aroclor 1260
0.57
Whole Body
0.5
Aroclor 1248
11.41
0.57
Whole Body
0.5
Cancer Risk
Benzo(a)anthracene
9.2
1.66
l.E-05
Benzo(a)pvrene
5.82
0.17
l.E-05
Benzo(b)fluoranthene
6.13
1.66
l.E-05
Dibenzo(a,h)anthracene
0.96
0.17
l.E-05
Indeno( 1,2,3-c ,d)pyrene
3.31
1.66
l.E-05
Chromium
275
42.39
l.E-05
Aroclor 1260
2.00
l.E-05
Aroclor 1248
11.41
2.00
l.E-05
|-\|HMI|V I'.ll. 1 llll/'ll III IIIIK \
IMiniliuii
1 ml-
Value
IR
Ingestion Rate of
Soil
mg/day
100
FI
Fraction Ingested
from Soil
unitless
1
EF
Exposure Frequency
days/year
143
ED
Exposure Duration
years
10
SA
Skin Surface Area
for Dermal
Absorption
cm2/day
5,400
AF
Soil to Skin
Adherence Factor
mg/cm2
3.3
BW
Body Weight
kg
58
AT-NC
Averaging Time -
Non-Cancer
days
3,650
AT-C
Averaging Time -
Cancer
days
25,550
IRS-S-Adj
Age-Adjusted
Ingestion Rate of
Soil
mg-yr/day-kg
28.1
SSAF-Adj
Age-Adjusted Soil
to Skin Adherence
Factor
mg-yr/day-kg
3,574.9
Ingestion Intake Multiplier - Non-Cancer
dav 1
6.75484E-07
Dermal Intake Multiplier - Non-Cancer
day"1
0.000120371
Ingestion Intake Multiplier - Cancer
day"1
9.65E-08
Dermal Intake Multiplier - Cancer
day"1
1.72E-05
< li> niii-al-'s|i> i-ilii- r.ir.ini' l' i>. 1 lili/' tl in IIIIK \ - Nnii-( .iiii-i r
i lii'inii-.il
ill I*i4>-llll.ll
( mii'i-rn
Oral KID
<>i-.il \li»ii|-|ilniii
Hlli'h-lli-v |u|-
iM'inal iiinil
\li»ui-lii.il Kll>
Im- D> riiial
iM'inal \li»iii-|iliini 1 .iilm-
\ aim
1 nil'.
\alu-
1 nil*.
\alu-
1 nil-
COCs
Benzo(a)anthracene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Benzo(a)pyrene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Benzo(b)fluoranthene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Dibenzo(a,h)anthracene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Indeno( 1,2,3-c ,d)pyrene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Chromium
3.0E-03
mg/kg-day
0.025
7.5E-05
mg/kg-day
Unitless
Aroclor 1260
2.0E-05
mg/kg-day
1
2.0E-05
mg/kg-day
0.14
Unitless
< li' inii-.il-^|i' iilii- l'ai-aiiii'|i |-» 1 lili/' tl
in IIIIK \ - < aiii-i-r
< li' inii-.il
• •1 l*i 4 •-III l.il
( iiiii'i iii
(>ral < M
Oral \li»ui-|iliiiii
l-.l 1 ii-i'-iii-v |ui-
iMinal iiinil
Miniii Ii. iI ( s| Im- Di-rmal
iM-mal \li«ni-|iliini 1 .iilm-
\ aim
1 nil -
\ alii.
1 ml-
\alu-
1 nil-
COCs
Benzo(a)anthracene
7.30E-01
(mg/kg-day)"1
1
7.30E-01
(mg/kg-day)"1
0.13
Unitless
Benzo(a)pyrene
7.30E+ 00
(mg/kg-day)"1
1
7.30E+ 00
(mg/kg-day)"1
0.13
Unitless
Benzo(b)fluoranthene
7.30E-01
(mg/kg-day)"1
1
7.30E-01
(mg/kg-day)"1
0.13
Unitless
Dibenzo(a,h)anthracene
7.30E+ 00
(mg/kg-day)"1
1
7.30E+ 00
(mg/kg-day)"1
0.13
Unitless
Indeno( 1,2,3-c ,d)pyrene
7.3E-01
(mg/kg-day)"1
1
7.3E-01
(mg/kg-day)"1
0.13
Unitless
Chromium
5.0E-01
(mg/kg-day)"1
0.025
2.0E + 01
(mg/kg-day)"1
Unitless
Aroclor 1260
2.0E + 00
(mg/kg-day)"1
1
2.0E + 00
(mg/kg-day)"1
0.14
Unitless
Aroclor 1248
2.0E + 00
(ma/ka-dav)"1
1
2.0E + 00
(ma/ka-dav)"
0.14
Unitless
Page 1 of 1
-------
Table l.C
Human Health Risk-Based Cleanup Values - Lower Ley Creek Soil
Younger Child Recreational Visitor (< 6 years)
< liilil Kcrl c.iliuii.il \im|ii| i Ii w.iisi
< ullsliliiciil
Snii r if i nii/tti
in IIIIU \
Proposed
Cleanup Value
(tug'kg)
1 all L'H OlLMII
|{lT<|>IOI
Sifll.ll III
1 I.I/.II ll llllltA
\n||-< ;||Ka(i Uisk
Benzo(a)anthracene
9.2
Benzo(a)pvrene
5.82
Benzo(b)fluoranthene
6.13
Dibenzo(a,h)anthracene
0.96
[ndeno(l ,2,3-c,d)pvrene
3.31
Chromium
275
574
Gastrointestinal
1
Aroclor 1260
0.30
Whole Body
0.5
Aroclor 1248
11.41
0.30
Whole Body
0.5
< .IIKTI klsk
9.2
0.66
l.E-05
Benzo(a)pvrene
5.82
0.066
l.E-05
Benzo(b)fluoranthene
6.13
0.66
l.E-05
Dibenzo(a,h)anthracene
0.96
0.066
l.E-05
[ndeno(l ,2,3-c,d)pYrene
3.31
0.66
l.E-05
Chromium
275
6.54
l.E-05
Aroclor 1260
1.72
l.E-05
Aroclor 1248
11.41
1.72
l.E-05
l-\p«>Miic r.ir.uiH-lt-is 1 lili/cfl iii IIIIU \
r.ii-.iiii«i«i
Ot'liinliiiii
1 nils
\ .line
CF
Unit Conversion
Factor for Soil
kg/mg
0.000001
IR
Ingestion Rate of Soil
mg/day
200
FI
Fraction Ingested
from Soil
unitless
1
EF
Exposure Frequency
days/year
143
ED
Exposure Duration
years
6
SA
v) r\ i i i ouiiatc ruta
for Dermal
cm2/day
2,800
AF
Soil to Skin
Adherence Factor
mg/cm2
2.8
BW
Body Weight
kg
15
AT-NC
Averaging Time -
Non-Cancer
days
2,190
AT-C
Averaging Time -
Cancer
days
25,550
IRS-S-Adj (0-2 years)
Age-Adjusted
Ingestion Rate of Soil
mg-yr/day-kg
39.7
IRS-S-Adj (2-6 years)
Age-Adjusted
Ingestion Rate of Soil
mg-yr/day-kg
49.8
SSAF-Adj (0-2 years)
Age-Adjusted Soil to
Skin Adherence
Factor
mg-yr/day-kg
1,702.7
SSAF-Adj (2-6 years)
Age-Adjusted Soil to
Skin Adherence
Factor
mg-yr/day-kg
2,375.3
Ingestion Intake MultipHer - Non-Cancer
day"1
5.22374E-06
Dermal Intake Multiplier - Non-Cancer
day"1
0.000204771
Ingestion Intake MultipHer - Cancer
day"1
4.48E-07
Dermal Intake Multiplier - Cancer
day"1
1.76E-05
< Ih-iiik-.iI-S|)(viIk- r.ii-.inififis 1 lih/t-tl in IIIIU \ - Nmi-< .iik-i-i
< lu-IIIK-.ll
iii ruiiiiii.li
< niu-t'l II
Oi-.il UN)
Or.il \ltsin piiuii
Mlu-it'iu-v Im
Dei lll.il ¦lilllllt'Ssi
\Iisii| lied KID
|n| On lllill
l>fl lll.ll \ltsii| |)||u|| I'.li-lnl
\ .ilut-
1 nils
\ illllt-
1 nils
Villi.
1 nils
COCs
Benzo(a)anthracene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Benzo(a)pyrene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Benzo(b)fluoranthene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Dibenzo(a,h)anthracene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Indeno(l ,2,3-c,d)pyrene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Chromium
3.0E-03
mg/kg-day
0.025
1.0E-01
mg/kg-day
Unitless
Aroclor 1260
2.0E-05
mg/kg-day
1
2.0E-05
mg/kg-day
0.14
Unitless
< Ih-iiik-.iI-S|)(viIk- I'.ir.imt-it-i s 1 lili/tfl in 1II IK \ - < .iik-i-i
< lit-mu-.il
•ll l*«ili-iili.il
< nlK-l'l II
Ol'.il ( sl-
Or.il \ltsin pimii
Mlu-iciu-v 11 ii
Dt'l lll.ll ¦Illllllt'SSI
\Its*n lit'd < Sl-
im Drllll.ll
l>t-i iii.il \l»sni plum l'.K-lni
X.ilut-
1 nils
\ .lllli
1 nils
\.ilm
1 nils
COCs
7.301 v-01
7.301 v-01
0.13
I llilloss
Benzo(a)pyrene
7.30E+00
(mg/kg-day)"1
1
7.30E+00
(mg/kg-day)"1
0.13
Unitless
Benzo(b)fluoranthene
7.30E-01
(mg/kg-day)"1
1
7.30E-01
(mg/kg-day)"1
0.13
Unitless
Dibenzo(a,h)anthracene
7.30E+00
(mg/kg-day)"1
1
7.30E+00
(mg/kg-day)"1
0.13
Unitless
Indeno(l ,2,3-c,d)pyrene
7.3E-01
(mg/kg-day)"1
1
7.3E-01
(mg/kg-day)"1
0.13
Unitless
Chromium
5.0E-01
(mg/kg-day)"1
0.025
2.0E+01
(mg/kg-day)"1
Unitless
Aroclor 1260
2.0E+00
(mg/kg-day)"1
1
2.0E+00
(mg/kg-day)"1
0.14
Unitless
Aroclor 1248
2.0E+00
(ma/ka-dav)"
1
2.0E+00
(ma/ka-dav)"
0.14
Unitless
Page 1 of 1
-------
Table l.D
Human Health Risk-Based Cleanup Values - Lower Ley Creek Soil
Adult Construction Worker
\dnll Ki'iri'iilion;il Visitor i -- lfi\i-;irsi
Soil lilt
Kivi-plor
Consiiliiuil
1 lili/.i-d in
Ch'unup Value
Tiii'Sli-l Oi'iuin
Siui;irio
IIIIK \
(mi; kxl
ll;i/;ii(l lii(k-\
\on-(';iniir Kisk
Aroclor 1248
11.41
1.95
None
'
Cillll'lT Kisk
Aroclor 1248
11.41
17
--
I.E-05
I a|)omiiv I'iii iiiiKli.i s I lili/i-d in IIIIK \
I'iiiiiimkT
Diiinilion
I nils
V.ilui-
CF
Unit Conversion
Factor for Soil
kg/mg
0.000001
IR
Ingestion Rate of
Soil
mg/day
330
FI
Fraction Ingested
from Soil
unitless
1
EF
Exposure
Frequency
days/year
250
ED
Exposure Duration
years
2
SA
Skin Surface Area
for Dermal
Absorption
cm2/day
5,700
AF
Soil to Skin
Adherence Factor
mg/cm2
0.9
BW
Body Weight
kg
70
AT-NC
Averaging Time -
Non-Cancer
days
730
AT-C
Averaging Time -
Cancer
days
25,550
Ingestion Intake Multiplier - Non-Cancer
day"1
3.22896E-06
Dermal Intake Multiplier - Non-Cancer
day"1
5.01957E-05
Ingestion Intake Multiplier - Cancer
day"1
9.23E-08
Dermal Intake Multiplier - Cancer
day"1
1.43E-06
( luinii;il-S|)(.iirii I'iiniiniii'iN I |ili/.i-d in IIIIK \ - \on-(';iiRi-r
(luiniiiil
ol' I'oli'iiliiil
Orcil KID
(> r: 11 \hsoi-|)|ion
Llikkno loi"
Vhsoi'hi'd KID
lor Di l iii;il
Ikrniiil \hsoi'|)iion I'iiilor
(oiKvm
V;iliu-
I nils
Dirni;il iiinilk'ssi
\;ilur
I nils
V;iliu-
I nils
COCs
Aroclor 1248
2.0F.-05
mg kg-day
1 .OF.+ 00
2.0F.-05
mg kg-day
I.4F.-0I
TTnilless
('liunii;il-S|)irirk-
I':ir:iiikii-|N I |ili/.i-d in IIIIK \ - (iiiuiT
ClK'ink';il
Oral ( SI
()i°;il \l)soi'|)|ion
Ahsorhi'd ( SI lor Dirni;il
Di-rniiil \l)siii |)iinn I'iK'ior
ol' I'oIuiImI
LMiikno lor
(oikitii
V;iliu-
I nils
Du'iikiI iiinilk'ssi
Villlll'
I nils
Villlll'
I nils
COLS
Aroclor 1248
2.0E+00
(mg/kg-day)-l
1.0E+00
2.0E+00
(mg/kg-day)-l
1.4E-01
Unitless
Page 1 of 1
-------
Table l.E
Human Health Risk-Based Cleanup Values - Lower Ley Creek Sediment
Adult Recreational Visitor (> 16 years)
\dnll Ki'iri'iilion;il Visitor i -- 16 \i-;irsi
Si'riimuil l l'(
I'lll/tllMtl
Kivi-plor
(oiiMil Ik-ill
I lili/.i-d in
Cleanup I dine
Till'Sll-l Ol'siilll
Scuiiino
IIIIK \
hat
ll;i/;ii(l lii(k\
\on-(';iniir Risk
]icn/.o(a)p\rcnc
8.888
-
-
( iiiKir Kisk
]icn/.o(a)p\rcnc
8.888
I..S
0.00001
I'!\|)omiiv I'iii iiiiKUi s I lili/i-d in IIIIK \
PillilllKkr
Diiinilion
I nils
Viilni-
CF
Unit Conversion
Factor for
Sediment
kg/mg
0.000001
IR
Ingestion Rate of
Sediment
mg/day
100
FI
Fraction Ingested
from Sediment
unitless
1
EF
Exposure
Frequency
days/year
143
ED
Exposure Duration
years
30
SA
Skin Surface Area
for Dermal
Absorption
cm2/day
5,700
AF
Sediment to Skin
Adherence Factor
mg/cm2
0.3
BW
Body Weight
kg
70
AT-NC
Averaging Time -
Non-Cancer
days
10,950
AT-C
Averaging Time -
Cancer
days
25,550
Ingestion Intake Multiplier - Non-Cancer
day"1
5.59687E-07
Dermal Intake Multiplier - Non-Cancer
day"1
9.57065E-06
Ingestion Intake Multiplier - Cancer
day"1
2.40E-07
Dermal Intake Multiplier - Cancer
day"1
4.10E-06
( luniii;il-S|)(.iirii I'iiiiiiiKkis I lili/i-d in IIIIK \ - \on-(';iiRi-r
(luniiiiil
ol' I'oknliiil
(OIKITII
()i ;il KID
()i;il Vhsorplion
Llikkno lor
Ikrniiil iiinilk'ssi
Vhsorhi'd KID
lor Di-rniid
Du°ni;il \l)soi-|)|ion l iiiloi"
Villiii-
I nils
\;ilur
I nils
ViiIik-
I nils
C 1 )(
licn/.o(a)p\ rene |
1 1 -
1.3i:-01 | I Jnillcss
( lKiiiii;il-S|)(.iilii I'iiiiiiiKkis I lili/i-d in IIIIK \ - ( ;uuvr
(luniiiiil
ol' I'oknliiil
(OIKITII
()i;il ( SI
()r;il \l)soi°|)lion
LMiikno lor
1 >(.-rin;il iiinilk'ssi
Ahsorhi-d ( SI lor Dirni;il
Di-rniiil Vhsorplion liiclor
Villiii-
I nils
V;diu-
I nils
\;l lilt-
I nils
COCs
Benzo(a)pyrene
7.3E+00
(mg/kg-day)"1
1
7.3E+00
(mg/kg-day)-1
1.3E-01
Unitless
Page 1 of 1
-------
Table l.F
Human Health Risk-Based Cleanup Values - Lower Ley Creek Sediment
Older Child Recreational Visitor (6 to 16 years)
Older ( hilri Kiriv;iiiun;il \ Kiior ifi i«» 16 mmim
( onsiii iii'iii
Si'iliiiii'iii Wl
I lili/i'ri in
IIIIR \
h'H/tOM'tl
< leiim//' \ d/iic
Oil"
Tjirai-i Ory;in
Rircpior
So'iiJirin
ll;i/.;ir
CF
Unit Conversion
Factor for
Sediment
kg/mg
0.000001
JR
Ingestion Rate of
Sediment
mg/day
100
FI
Fraction Ingested
from Sediment
unitless
1
EF
Exposure
Frequency
days/year
143
ED
Exposure Duration
years
10
SA
Skin Surface Area
for Dermal
Absorption
cm2/day
5,400
AF
Sediment to Skin
Adherence Factor
mg/cm2
3.3
BW
Body Weight
kg
58
AT-NC
Averaging Time -
Non-Cancer
days
3,650
AT-C
Averaging Time -
Cancer
days
25,550
IRS-S-Adj
Age-Adjusted
Ingestion Rate of
Sediment
mg-yr/day-kg
28.1
SSAF-Adj
Age-Adjusted
Sediment to Skin
Adherence Factor
mg-yr/day-kg
3,574.9
Ingestion Intake Multiplier - Non-Cancer
day"1
6.75484E-07
Dermal Intake Multiplier - Non-Cancer
day"1
0.000120371
Ingestion Intake Multiplier - Cancer
day"1
9.65E-08
Dermal Intake Multiplier - Cancer
day"1
1.72E-05
< hi'iiikMl-Spirilk' I'iinimi'UTs I lili/cd in IIIIR \ - \on-C;inoT
( 'hi'ink'ul
o| I'oU'iiimI
( ono'i n
Or;il RID
Or;il Ahsor|)iion
l.llkk'iio lor
l)iTin;il Miniili'ssi
Ahsui'hi'd RID
lor l)i'i in;il
IKtiikiI \I>s<»r|>iion huior
\ illlH'
I nils
\ ;iliu>
I nils
\ illiic
I nils
COCs
3 -M ethy lcholoanthrene
-
mg/kg-day
1
-
mg/kg-day
-
Unitless
Benzo(a)pyrene
~
mg/kg-day
1
-
mg/kg-day
0.13
Unitless
Aroclor 1260
2.0E-05
mg/kg-day
1
2.0E-05
mg/kg-day
0.14
Uniilcss
( 'hi'iiik'ul-Siurilk'
I'liriinii'iiTs ( iili/i'd in IIIIR \ - Cjiiiot
( 'hi'ink'ul
o| IN»icmi;il
( ono'i n
Onil csr
Onil \l)s<»i |)iion
I'.llkk'iio lor
Di'i nuil Miniili'ssi
\I>mh'Ih'(I ( SI lor Dt'i niiil
l)iTin;il \bsor|>iion hulor
\ illlll'
I nils
\ ;iliu>
I nils
Valui*
I nils
COCs
3 -M ethy lcholoanthrene
2.20E + 01
(mg/kg-day)"1
1
2.20E + 01
(mg/kg-day)"1
-
Unitless
Benzo(a)pyrene
7.30E + 00
(mg/kg-day)"1
1
7.30E + 00
(mg/kg-day)"1
0.13
Unitless
Aroclor 1260
2.0E + 00
fme/ke-davV1
1
2.0E + 00
(ms/ks-dav)4
0.14
Unitless
Page 1 of 1
-------
Table l.G
Human Health Risk-Based Cleanup Values - Lower Ley Creek Soil
Younger Recreational Recreational Visitor (< 6 years)
<»iiii**i-i Child Ki-i-ii-.ili<»iiiil Nisilui
i •' h Vi-.il m
Si.ll 1 IT
Proposed
Ki-i-rplni
< Hllslllllilll
1 llll/.id III
Cleanup Value
1 ill lil'l < )| L'.lll
Si i'll.ll |H
IIIIK \
(W/Cffaf)
II.1/.11(1 IlldlA
Nuii-('.iikii KisK
3-Mclir> luliolaiillirciic
Benzo(a)pyrene
8.888
Dibenzo(a,h)anthracene
0.73
Aroclor 1260
18
0.59
Whole Body
1
Vanadium
13
Kidneys
1
( "all 11*1*1 K|s|\
3-Methylcholanthrene
5.7
0.15
1 .E-05
Benzo(a)pyrene
8.888
0.066
1 .E-05
Dibenzo(a,h)anthracene
0.73
0.066
1 .E-05
Aroclor 1260
18
1.7
1 .E-05
Vanadium
1 .E-05
1- Npusiii i- |\,| iiiiii-ii-i s 1 lili/.i-d iii 1II IK \
I'.ii I.|| uil>
< >1 .ll \ llSI l| |)||H||
Ml'ii-ii'iii-v I'hi
1 >1-1 iii.il niiiilli-ssi
\hs..ilil(| Ull>
I'hi Diiiii.iI
Oi l lll.ll \Iishi plinn l .ll lHI
\ .iliu-
1 nils
\ .iliu-
1 nils
\ illllr
1 nils
PCBs
3-Methylcholanthrene
mg/kg-day
1
mg/kg-day
Unitless
Benzo(a)pyrene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Dibenzo(a,h)anthracene
mg/kg-day
1
mg/kg-day
0.13
Unitless
Aroclor 1260
2.0E-05
mg/kg-day
1
2.0E-05
mg/kg-day
0.14
Unitless
Vanadium
7.0F.-05
1.8F.-06
Uniilcss
< 'liiiiiii-.il-spi'i-irii-
I'.ii iiiin-li-i s 1 lili/.i-t
in 1II IK \ - < '.MKi i
< 'lu-iiiii-iil
Hi' 1 ** *11*1 ll iall
< HlK i l ||
ni.iirsl-
< >1 .ll Mtsoi |)liu||
Ml'ii-ii'iii-v I'hi
1 >1-1 lllill • llllll li-ssi
\lisui hid < ^1- I'hi |>m iii.iI
l>M lll.ll \Iishi plinli l-.ll-lHl
\ .iliu-
1 nils
\ .iliu
1 nils
\ .llllr
1 nils
PCBs
3-Methylcholanthrene
2.20E+01
(mg/kg-day)"1
1
2.20E+01
(mg/kg-day)"1
Unitless
Benzo(a)pyrene
7.30E+00
(mg/kg-day)"1
1
7.30E+00
(mg/kg-day)"1
0.13
Unitless
Dibenzo(a,h)anthracene
7.30E+00
(mg/kg-day)"1
1
7.30E+00
(mg/kg-day)"1
0.13
Unitless
Aroclor 1260
2.0E+00
(mg/kg-day)"1
1
2.0E+00
(mg/kg-day)"1
0.14
Unitless
Vanadium
(ma/ka-dav)"1
0.026
(ma/ka-dav)"1
Unitless
Page 1 of 1
-------
Table l.H
Human Health Risk-Based Cleanup Values - Lower Ley Creek Fish Tissue
Adult Recreational Visitor (> 16 years)
Adiih Kirrmliniiiil \isiinr i ^ Ifr xmrsi
( njisiiiin-ill
Hs|| 1 issllr l.l'C '
I lili/i-H in
IIIIK \
/*ro/>o\at
( Ira imp \ aluv
(ma hi>
\aliiinnl)
hitfutwil (ituim/»
\ aluc (nix hi>Jhh
liwiir)
1 ;il'l!l-| < >I'!MII
Kirrplnr
Sa-iMNn
ll;i/iii (l IimIcn
Nn||-( JIIKI'I" Kisk
Aroclor-1254
1.179
0.0027
0.028
Whole Body
0.5
Aroclor-1260
0.58
0.30
0.028
Whole Body
0.5
Total Aroclors
1.348
-
-
--
--
Total D/F, as TEQ
3.47E-06
0.00023
2.0E-06
Reproduction/
Thyroid in Neonates
1
Dieldrin
0.0167
0.36
0.14
Liver
1
Arsenic
1.419
33.9
0.84
Skin
1
Chromium
43.68
3999
8.4
Gastrointestinal
1
Mercury
0.478
2.44
0.28
Developmental
1
Cjiikit Kisk
Aroclor-1254
1.179
-
-
-
-
Aroclor-1260
0.58
--
--
--
--
Total Aroclors
1.348
0.49
0.033
-
l.E-05
Total D/F, as TEQ
3.47E-06
5.09E-05
4.4E-07
--
l.E-05
Dieldrin
0.0167
0.011
0.0041
-
l.E-05
Arsenic
1.419
1.76
0.044
--
l.E-05
Chromium
43.68
62.2
0.13
-
l.E-05
Mercury
0.478
-
-
--
l.E-05
|-.\|HiMin- I'illMllirlrl's 1 lili/1'd in IIIIK.\
I'illMliii-lii'
IMIiiilinii
I nils
\ ;illlr
CF
Factor for Fish
kg/g
0.001
IR
Ingestion Rate of
Fish Tissue
g fish/day
25
FI
Fraction Ingested
from Fish Tissue
unitless
1
EF
Exposure
Frequency
days/year
365
ED
Exposure Duration
years
30
BW
Body Weight
kg
70
AT-NC
Averaging Time -
Non-Cancer
days
10,950
AT-C
Averaging Time -
Cancer
days
25,550
Ingestion Intake Multiplier - Non-Cancer
day"1
3.57E-04
Ingestion Intake Multiplier - Cancer
day"1
1.53E-04
( lii-iiik;il-S|>ivilK I'iinniirUTs I lili/id in IIIIK \ -
\n||-( JIIKIT
( lu-iiiiiJil
nl I'nll'llliill
( nlKVI'll
<>r:il Kli>
\ :illlr
I nits
COCs
Aroclor-1254
2.0E-05
mg/kg-day
Aroclor-1260
2.0E-05
mg/kg-day
Total Aroclors
2.0E-05
mg/kg-day
Total D/F, as TEQ
7.0E-10
mg/kg-day
Dieldrin
5.0E-05
mg/kg-day
Arsenic
3.0E-04
mg/kg-day
Chromium
3.0E-03
mg/kg-day
Mercury
1.0E-04
mg/kg-day
( lii'ini«.iil-S|nril]«.- I'iiiMini-liTs I lili/i-d in IIIIK \ -
( lii-iiiiiiil
n| l'iilfiili:il
( iiiia-ni
Onil CM-
\ :iliu-
I nits
COCs
Aroclor-1254
2.00E+00
(mg/kg-day)"1
Aroclor-1260
2.00E+00
(mg/kg-day)"1
Total Aroclors
2.00E+00
(mg/kg-day)"1
Total D/F, as TEQ
1.50E+05
(mg/kg-day)"1
Dieldrin
1.60E+01
(mg/kg-day)"1
Arsenic
1.50E+00
(mg/kg-day)"1
Chromium
0.5
(mg/kg-day)"1
Mercury
--
(mg/kg-day)"1
l-isli
Si-diiiu-iil
('iiiii/riilniliiiii
('iHKTiilniliiiii
r.s\i
I CI. inn: kui
I CI. inn: ki:i
Aroclor-1254
0.2446
0.024
10.19166667
Aroclor-1260
0.1013
1.093
0.092680695
Total Aroclors
0.3125
4.645
0.067276642
Total D/F, as TEQ
0.000048
0.00561
0.00855615
Dieldrin
0.00363
0.0094
0.386170213
Arsenic
0.21
8.4647
0.024808912
Chromium
0.36
171.3727
0.002100685
Mercury
0.04
0.3481
0.114909509
Page 1 of 1
-------
Table 1.1
Human Health Risk-Based Cleanup Values - Lower Ley Creek Fish Tissue
Older Child Recreational Visitor (6 to 16 years)
< >l In |f> M'.II'SI
Cnlislllllilil
l lsll 1 Isslli- 1' IV
I lili/i-tl III
IIIIK \
Proposed
Cleanup Value
(mg-kg
sediment)
Proposed Cleanup
Value (/n% kg fish
tissue)
I.iri»il
0.5
Aroclor-1260
0.58
0.37
0.035
Whole Body
0.5
Total Aroclors
1.348
-
-
-
-
Total D/F, as TEQ
3.47E-06
2.84E-04
2.4E-06
Thyroid in
1
Dieldrin
0.0167
0.45
0.17
Liver
1
Arsenic
1.419
42
1.0
Skin
1
Chromium
43.68
4960
10
Gastrointestinal
1
Mercury
0.478
3.0
0.35
Developmental
1
( .IIU'lT Kisk
Aroclor-1254
1.179
-
-
-
-
Aroclor-1260
0.58
-
-
-
-
Total Aroclors
1.348
1.8
0.12
-
l.E-05
Total D/F, as TEQ
3.47E-06
1.89E-04
1.6E-06
-
l.E-05
Dieldrin
0.0167
0.039
0.015
-
l.E-05
Arsenic
1.419
6.5
0.16
-
l.E-05
Chromium
43.68
77
0.16
-
l.E-05
Mercury
0.478
-
-
--
l.E-05
I-\|)usiiri- r.ir.iiiK-UTs I lili/rH in IIIIK \
r.ii'.iiiii-li-r
lUliiiiiiuii
I nils
\ .ilin-
CF
Unit Conversion
Factor for Fish
Tissue
kg/g
0.001
IR
Ingestion Rate of
Fish Tissue
g fish/day
16.7
FI
Fraction Ingested
from Fish Tissue
unitless
1
EF
Exposure
Frequency
days/year
365
ED
Exposure Duration
years
10
BW
Body Weight
kg
58
AT-NC
Averaging Time -
Non-Cancer
days
3,650
AT-C
Averaging Time -
Cancer
days
25,550
Ingestion Intake Multiplier - Non-Cancer
day"1
2.88E-04
Ingestion Intake Multiplier - Cancer
day"1
4.11E-05
Clirillli-.ll-'s|M'i-irir r.ll'.lllK'UTs ( llll/i'd ill IIIIK \-
N"ll-( ".lliriT
(llilllli-.ll
••r i*«»ii-iiiliii
('< *1 ll'i'l'l 1
Or.il KID
\ iilni-
I nils
COCs
Aroclor-1254
2.0E-05
mg/kg-day
Aroclor-1260
2.0E-05
mg/kg-day
Total Aroclors
2.0E-05
mg/kg-day
Total D/F, as TEQ
7.0E-10
mg/kg-day
Dieldrin
5.0E-05
mg/kg-day
Arsenic
3.0E-04
mg/kg-day
Chromium
3.0E-03
mg/kg-day
Mercury
1.0E-04
mg/kg-day
( lli,lllli~.ll-st|H,ririr r.H.IIIK li ls ( llll/i'd ill IIIIK \-
('.llll-l'l'
Clii'iiiii-.il
n|' |*«»li-||llill
('< *1 ll'i'l'l 1
nr.H cs|-
\ iiliii-
I nils
COCs
Aroclor-1254
2.00E+00
(mg/kg-day)"1
Aroclor-1260
2.00E+00
(mg/kg-day)"1
Total Aroclors
2.00E+00
(mg/kg-day)"1
Total D/F, as TEQ
1.50E+05
(mg/kg-day)"1
Dieldrin
1.60E+01
(mg/kg-day)"1
Arsenic
1.50E+00
(mg/kg-day)"1
Chromium*
0.5
(mg/kg-day)"1
Mercury
--
(mg/kg-day)"1
*The age-dependent adjustment factor was used to account for mutagenic effects.
llsll
V
-------
Table l.J
Human Health Risk-Based Cleanup Values - Lower Ley Creek Fish Tissue
Younger Child Recreational Visitor (< 6 years)
^•iiiil'i-i Child Ki-iiiiiliHii.il \isiini ¦ f>w-;iisi
< HllslHllllll
I- ish i issiu-1- r< *
1 lili/rd mi
IIIIK \
|*i i i|h isi'd
< li .iiiii|) \ .ilui-
¦ IIIL» kli
si'dlllll lll ¦
1*1 HpHSl-d < U-.lllllp
\ .lllll' 'MIL1 kli llsll
llsslll'
1 .11 L'l l < >1 LMII
Klllplul
Vi-ii.n in I I.i/.ii d
IndiA
Nn||-< ".llll l l Klsk
Whole Bod>
Aroclor-1260
0.58
0.19
0.018
Whole Body
0.5
Total Aroclors
1.348
Total D/F, as TEQ
3.47E-06
0.00015
1.3E-06
Reproduction/
Thyroid in Neonates
1
Dieldrin
0.0167
0.23
0.09
Liver
1
Arsenic
1.419
22
0.54
Skin
1
Chromium
43.68
2581
5.4
Gastrointestinal
1
Mercury
0.478
1.6
0.18
Developmental
1
< allll'lT Risk
Aroclor-1254
1.179
Aroclor-1260
0.58
Total Aroclors
1.348
1.6
0.11
l.E-05
Total D/F, as TEQ
3.47E-06
0.00016
1.4E-06
l.E-05
Dieldrin
0.0167
0.034
0.013
l.E-05
Arsenic
1.419
5.7
0.14
l.E-05
Chromium
43.68
38
0.079
l.E-05
Mercury
0.478
l.E-05
1- Npusiii i- |\,| .uni-li-i s 1 lili/.i'd iii 1II IK \
I'.ii .uni-li-i
DiTiinliiiii
1 nils
\. ilui
CF
Unit Conversion
Factor for Fish
Tissue
kg/g
0.001
IR
Ingestion Rate of
Fish Tissue
g fish/day
8.3
FI
Fraction Ingested
from Fish Tissue
unitless
1
EF
Exposure
Frequency
days/year
365
ED
Exposure Duration
years
6
BW
Body Weight
kg
15
AT-NC
Averaging Time -
Non-Cancer
days
2,190
AT-C
Averaging Time -
Cancer
days
25,550
Ingestion Intake Multiplier - Non-Cancer
day"1
5.53E-04
Ingestion Intake Multiplier - Cancer
day"1
4.74E-05
< iii'iiiii.ii-spi'i-irii- i*iii iiiiii-ii-i s i nii/.i'd in 1111 k \ -
\n||-< '.llll l l
< llllllll-.il
n|' 1 ** *11*1 ll i.il
< Hlll l l ||
(>I.|| KID
\ .iliu
1 nils
COCs
Aroclor-1254
2.0E-05
mg/kg-day
Aroclor-1260
2.0E-05
mg/kg-day
Total Aroclors
2.0E-05
mg/kg-day
Total D/F, as TEQ
7.0E-10
mg/kg-day
Dieldrin
5.0E-05
mg/kg-day
Arsenic
3.0E-04
mg/kg-day
Chromium
3.0E-03
mg/kg-day
Mercury
1.0E-04
mg/kg-day
< iii'iiiii.ii-spi'i-irii- i*iii iiiiii-ii-i s i nii/.i'd in 1111 k \ -
('.iiuii
< liillilr.il
u|' 1
< Hlll l l II
Ol.ll < S|
\ .lllll
1 nils
COCs
Aroclor-1254
2.00E+00
(mg/kg-day)"1
Aroclor-1260
2.00E+00
(mg/kg-day)"1
Total Aroclors
2.00E+00
(mg/kg-day)"1
Total D/F, as TEQ
1.50E+05
(mg/kg-day)"1
Dieldrin
1.60E+01
(mg/kg-day)"1
Arsenic
1.50E+00
(mg/kg-day)"1
Chromium*
0.5
(mg/kg-day)"1
Mercury
(ma/ka-dav)"1
*The age-dependent adjustment factors were used to account for mutagenic effects.
1- ish
Si'dllllllll
< Hiirinli.ilinii
< '(•iiri iili iilinn
lis\l
I I'L uiv-km
11'L iIIik Kk'
Aroclor-1254
0.2446
0.024
10.19166667
Aroclor-1260
0.1013
1.093
0.092680695
Total Aroclors
0.3125
4.645
0.067276642
Total D/F, as TEQ
0.000048
0.00561
0.00855615
Dieldrin
0.00363
0.0094
0.386170213
Arsenic
0.21
8.4647
0.024808912
Chromium
0.36
171.3727
0.002100685
Mercury
0.04
0.3481
0.114909509
Page 1 of 1
-------
Table 2
Ecological Risk-based Cleanup Values
Summary Tables
Lower Le\ Creek - lxolo»ic;il PRGs - Sediment
CAS Number
Constituent
Lower Le\ Creek
Sediment EPC
utilized in liERA
New York
Sediment Criterisi
Met sils'1
(mj>/k»)
New York
Sediment Criterisi
lienthic Aqnsitic Lile
Chronic Toxicity1'
(m»/k}> in sediment)
New York
Sediment Criterisi
Wildlife
liiosimimulsilion'
(m»/k» in sediment)
Proposed
Lower Le\ Creek
Sediment PRG lor
Helled kingfisher
(LOAEL lisised)
Proposed
Lower Le\ Creek
Sediment PRG lor
lielted kingfisher
(NOAEL lisised)
Proposed
Lower Le\ Creek
Sediment PRG lor
Mink
(LOAEL lisised)
Proposed
Lower Le\ Creek
Sediment PRG lor
Mink
(NOAEL lisised)
Proposed
Lower Le\ Creek
Sediment PRG lor
lien 1 hie
Invertebrsites
COCs
7440-38-2
Arsenic
19
6
-
-
-
-
-
-
5.6
7440-43-9
Cadmium
107
0.6
-
-
-
-
-
-
6.4
7440-47-3
Chromium
1090
26
-
-
-
-
-
-
94.2
7440-50-8
Copper
433
16
-
-
-
-
-
-
102
7439-92-1
Lead
284
31
-
-
-
-
-
-
87.8
7439-97-6
Mercury
1.3
0.15
-
-
-
-
-
-
0.29
7440-02-0
Nickel
447
16
-
-
-
-
-
-
34.4
7440-22-4
Silver
18
1
-
-
-
-
-
-
2.1
7440-66-6
Zinc
1640
120
-
-
229
26
-
-
342
22967-92-6
Methylmercury
0.3481
—
-
-
0.12
0.012
0.11
0.01 1
-
1746-01-6
Dioxins/Furans, as TEQ
0.00561
—
-
-
0.0018
0.00018
0.00029
0.0000:9
-
11097-69-1
Aroclor 1254
0.024
-
19.3
1.4
-
-
0.01
0.001 1
-
11096-82-5
Aroclor 1260
1.093
-
19.3
1.4
-
-
0.009
0.0009
-
-
Total PCBs
4.645
-
19.3
1.4
-
-
0.12
O.Oi:
-
-
Total PAHs
164a, 451.9", 249.2°
-
73f
-
314
31
-
-
45.19
Notes:
All values in mg/kg.
EPC = Exposure Point Concentration.
PRG = Preliminary Remdiation Goal.
" = Sediment EPC used in upper level receptor food web.
" = Maximum sediment concentration of high molecular weight PAHs used in benthic invertebrate and plant benchmark screening.
^ = Maximum sediment concentration of low molecular weight PAHs used in benthic invertebrate and plant benchmark screening.
u = Metals sediment screening values are the "Lowest Effect Levels" obtained from Table 2: Sediment Criteria for Metals in "Technical Guidance for Screening Contaminated Sediments, New York State Department of Environmental Conservation, January 1999."
c = Organic sediment screening values obtained from Table 1: Sediment Criteria for Non-polar Organic Compounds in "Technical Guidance for Screening Contaminated Sediments, New York State Department of Environmental Conservation, January 1999."
1 = listed value is the lowest sediment screening value associated with PAHs (fluorene).
= lowest proposed PRG.
Page 1 of 1
-------
Table 2.A
Ecological Risk-based Cleanup Values - Ley Creek Sediment
Mink
C\s NiiiiiIh'I
< Hllslllllilll
1 i-v < "i wk
Sin l.m W.iU i
i r< i nii/td
III III l< \
VtllllHUl
1-1'<' 1 lill/rd
in III l<\
'MIL1 kli'
Proposed
K>MI /An.-#/
Cleanup Value
(tf/lf A'.lf)
Proposed
\o\ii
Cleanup Value
(tug-kg)
Sill I'iiri-
W.ilu
1 hisc
VtllllHUl
sili-S|H-i-iru-
1 pl.lki- I'.lilHl
I'l i-v
< Ulll l llll illlull-
1 isll
'l-slllll.lU'd'
I'l i-v
1 iii.il D.ul.v
1 nl.iki—
1 <>\l 1.
li.iMtl NIC
|h|.|| D.lll.V
1 lllilki—
\<>\l 1
ii.imcI n«;
ll<\
¦ M.uiiiii.ili.iu-
1 <>\H •
1<>\l 1
li.lMtl IK.)
ll<\
¦ M.innibili.iii
i\|-1 .
\<>\l 1
llsisrtl 1U.>
COCs
22967-92-6
Methylmercury
0.0001
0.3481
0.67
0.067
0.0000104
0.00050
0.115
0.076989371
0.02414
0.025
0.002
0.025
0.986
0.0025
0.990
1746-01-6
Dioxins/Furans, as TEQ
NV
0.00561
0.0029
0.00029
NV
0.0000022
0.009
2.48128E-05
0.00001
0.000010
0.000
0.00001
0.995
0.000001
0.995
11097-69-1
Aroclor 1254
NV
0.024
0.026
0.0031
NV
0.00002
10.192
0.264983333
0.08307
0.083
0.010
0.1
0.831
0.01
0.991
11096-82-5
Aroclor 1260
NV
1.093
1.1
0.11
NV
0.00083
0.093
0.101948765
0.03196
0.033
0.003
0.034
0.964
0.0034
0.964
Total PCBs
NV
4.645
1.5
0.15
NV
0.00113
0.067
0.101
0.03164
0.033
0.003
0.034
0.964
0.0034
0.964
llrllrtl kiiiL'Tislii-i
C\s NiiiiiIh'I
< Hllslllllilll
1 i-v < "i u-k
sin r.ii-i- w.iu-i
i r< i nii/rd
Ml Itl u \
VtllllH'lll
1-1'<' 1 lill/rd
in Itl \<\
'MIL1 l\L"
Proposed
Id Ml /An.-#/
Cleanup Value
(/Mlf A'.lf)
Proposed
\o\ii n.^.d
Cleanup Value
(tug'kg)
sin r.ii-i-
Wjli-i
DhM
VtllllH'lll
sili-S|u-i-irii-
1 plilki- l iK lui
¦ |-|s||i
I'l i-v
( ulU i llll .lliull-
lisll
¦ I'slini.ili'tl'
I'l i>
|)ust
1 iil.il D.ul.v
1 lll.lki—
1 <>\| |
ItiiMtl I'UC
|h|.|| D.llK
1 lll.lki—
M>\|-|
it.iMti n«;
ll<\
¦ \v 1,111-
m\i i •
1<>\l 1
|{.IMtl ll(.)
ll<\
¦ M.iiiiiieiIi.iii
N«)\| | .
M>\|-|
Kisi'i\ I in
COCs
22967-92-6
Methylmercury
0.0001
0.3481
1.1
0.11
0.000011
0.00128
0.11
0.13
0.05904
0.06
0.01
0.064
0.943
0.0064
0.944
1746-01-6
Dioxins/Furans, as TEQ
NV
0.00561
0.027
0.0027
NV
0.0000315
0.01
0.00
0.00011
0.00014
0.000014
0.00014
0.996
0.000014
0.996
Total PAHs
NV
164.314
1220
122
NV
1.42
NV
NV
NV
1.42
0.14
1.43
0.996
0.143
0.996
7440-66-6
Zinc
NV
181.055
1550
171
NV
1.81
0.18
276.52
129.15214
130.96
14.45
131
1.000
14.5
0.996
1 .ill- 1 hsloi V r.ll illlH'U l s .IS I'l i'Si'llU'tl III ISI K\
1 ill- lllslul V D.ll.l
1 nils
Mink
ISilUtl
Muslela vixon
Cervle alcxon
Body Weight
kg
0.600
0.136
Food Ingestion Rate
(dry weight basis)
kg DW/kg BW-day
0.08
0.12
Percent Dry Matter in
Diet
%
24
25
Food Ingestion Rate
(wet weight basis)
kg WW/kg BW-day
0.313
0.467
Water Ingestion Rate
kg/kg BW-day
0.10
0.11
Time & Area Use
Factor
unitless
1.0
1.0
Territory size
km or ha
1 - 5 (km)
0.39-2.19 (
1 *•'¦ t.->-|| 1 Dl' l ( m||||I|illlll|,lll lll^'">llM|| |\,||>- llllul lll.lllull
Fraction of diet that is
soil/sediment
% (DWbasis)
1.0
1.0
Soil/Sediment
ingestion rate
kg DW/kg BW-day
0.00075
0.00117
I'l i'.V < 'lilHrllll.llhHI - I'lsll
¦ Miiisiiii-tli ¦ in** ki."
Methylmercury
0.04
Dioxins/Furans, as TEQ
0.000048
Aroclor 1254
0.2446
Aroclor 1260
0.1013
Total PCBs
0.3125
PAHs
NV
Zinc
32.3
Notes:
All values in mg/kg
NA = Compound did not result in HQ > 1 for this receptor in corresponding risk assessment.
NV = Not a COC for this media.
* Value represents sediment EPC corresponding to a HQ less than one, given risk assessment model parameters and assumptions. HQ determined via use of NOAEL.
Cleanup value determined assuming body burden from surface water remains identical to that presented in BERA (i.e. surface water not remediated).
Page 1 of 1
-------
Table 2.B
Ecological Risk-based Cleanup Values
Lower Ley Creek Sediment
Benthic Invertebrates
Sediment l*R(«s - lien 1 hie Invertebrates
CAS Number
Constituent
Concentriition I sed in
lienchniiirk Screening lor
Kent hie Invertebrates
(Maximum Concentration)
(m»/k»)
Proposed l*R<«
(Miiximum No KITect
Concentriition viii
Toxicity Testing)
(m»/k»)
COCs
7440-38-2
Arsenic
19
5.6
7440-43-9
Cadmium
107
6.4
7440-47-3
Chromium
1090
94.2
7440-50-8
Copper
433
102
7439-92-1
Lead
284
87.8
7439-97-6
Mercury
1.3
0.29
7440-02-0
Nickel
447
34.4
7440-22-4
Silver
18
2.1
7440-66-6
Zinc
1640
342
-
Total PAHs
451.9a, 249.2"
45.19
Notes:
a = High molecular weight PAHS
b = Low molecular weight PAHs
Page 1 of 1
-------
Table 2.C
Ecological Risk Benchmark Screening
Lower Ley Creek Soil
Benthic Invertebrates
\iiiil\le
i:i»\ iao-ssi.
New York Soil
('lc;inii|> Ohjeclhes-
1 Voice lion ol' Keoloniciil
Resources
KI'A Region 5
Kcoloyiciil Soil
Screening l.eu'ls
\hi\imiim
Delected \ nliie''
(miikii)
I'hmls
Terrestrhil
Imerlehmles
Birds
Miinmiiils
2-MethylnaphthaIene
Based on sum of low molecular weight PAHs
-
-
2.51
Acenaphthene
-
-
2.25
Acenaphthylene
-
-
7.84
Anthracene
-
-
14.9
Fluoranthene
-
-
61.4
Fluorene
-
-
3.76
Naphthalene
-
-
3.68
Phenanthrene
-
-
28.2
Sum Low Molecular
Weight PAHs
NSV
NSV
100
--
--
124.54
Benzo(a)anthracene
Based on sum of high molecular weight PAHs
-
-
36.2
Benzo(a)pyrene
-
-
27.4
Benzo(b)fluoranthene
-
-
29.1
Benzo(g,h,i)perylene
-
-
16
Benzo(k)fluoranthene
-
-
20.9
Chrysene
-
-
36.7
Dibenzo(a,h)anthracene
-
-
6.4
Indeno(l ,2,3-cd)pyrene
-
-
14.3
Pyrene
-
-
62.2
Sum High Molecular
Weight PAHs
NSV
18
NSV
1.1
--
--
249.2
1,4-Dichlorobenzene
-
-
-
-
20
-
0.14
2-Butanone
-
-
-
-
100
-
0.38
4-Methylphenol
-
-
-
-
-
163
0.05
4-Nitroaniline
-
-
-
-
-
21.9
0.06
Acetone
-
-
-
-
2.2
2.5
2.03
Alpha-Chlordane
-
-
-
-
1.3
0.224
0.0493
Aluminum
-
-
-
-
-
-
15300
Antimony
NSV
78
NSV
u 2~
-
-
19.6
Arsenic
18
NSV
43
46
-
-
17.4
Barium
NSV
33n
NSV
2000
-
-
431
Benzene
-
-
-
-
70
0.255
0.06
Beryllium
NSV
40
NSV
21
-
-
3.61
Bis-(2-ethyhexyl)phthalate
-
-
-
-
-
0.925
0.71
Bromomethane
-
-
-
-
-
0.235
0.002
Butylbenzylphthalate
-
-
-
-
-
i) 23lJ
1.1
Cadmium
140
0.77
(I
-
-
337
Carbazole
-
-
-
-
-
-
3.23
Carbon Disulfide
-
-
-
-
-
0.0941
0.05
Chromium
NSV
NSV
2(>
34
-
-
1320
cis-1,2-Dichloroethene
-
-
-
-
-
-
0.003
Cobalt
13
NSV
120
230
-
-
12.2
Copper
~i)
80
28
-W
-
-
731
Cyanide
-
-
-
-
-
1.33
0.6
Dibenzofuran
-
-
-
-
-
-
2.24
Di-n-butylphthalate
-
-
-
-
-
0.15
0.157
Endrin
-
-
-
-
0.014
0.01
0.084
Gamma-Chlordane
-
-
-
-
-
0.224
0.035
Iron
-
-
-
-
-
-
31100
Isophorone
-
-
-
-
-
139
0.05
Lead
120
1700
11
5(>
-
-
575
Manganese
22u
450
4300
4000
-
-
554
Mercury
-
-
-
-
-
0.1
4.11
Methoxychlor
-
-
-
-
-
0.0199
0.0085
Methylene chloride
-
-
-
-
12
-
0.004
Nickel
38
280
210
130
-
-
434
p,m Xylene
-
-
-
-
0.26
-
0.003
p,p'-DDD
DDT and metabolites
-
-
0.008
p,p'-DDE
-
-
0.492
p,p'-DDT
-
-
0.216
DDT and metabolites
NSV
NSV
U.1W3
0.021
-
-
0.716
PCB-1248
-
-
-
-
1
-
86.1
PCB-1260
-
-
-
-
1
-
2.94
Phenol
-
-
-
-
30
-
0.0476
Selenium
ii 52
4.1
1.2
(I
-------
Table 2.D
Biota-Sediment Accumulation Factors
Mosm I'isli Tissuo
Mosul Sodimoiil
USA l;
coc
C'onconlrsilion
C'onconlrsilion
(k» sodimoiil/k$>
(m»/k» wol \\1)
(m»/k»)
llsli lissuo wol wl)
Methylmercury*
0.04
0.034
1.2
Dioxins/Furans as TEQ**
0.000033
0.0002
0.17
Aroclor 1254**
0.2446
0.0051
48
Aroclor 1260**
0.1013
0.0051
20
Total PCBs*
0.1475
0.102
1.4
PAHs
NA
NA
0
Zinc*
32.3
25.75
1.3
* Results for downstream reach.
** Results for upstream reach.
NA = Not applicable; no tissue concentrations listed in the BERA
Table 2.E
Mink
cot
Surl'sico Wsilor
t one (m»/L)
Surl'sico Wsilor
ln»eslion Ksilo
(L/k» IJW-dsn)
Surl'sico Wsilor Doso
(m»/k» BW-dsi\)
TRY - IOAIX
(m»/k» liW-dsi\)
TRY - noai:l
(m»/k}> liW -dsi\)
lsir»ol LOAI-L HQ
Tsirj-ol NOAIX HQ
loai:l i»r(;
(m»/k» sodimoiil)
\oai:l i»r<;
(m«/k« sodimoiil)
Methylmercury
0.0001
0.104
0.0000104
0.025
0.0025
0.99
1
0.11
0.011
Dioxins/Furans, as TEQ
NA
0.104
NA
1.00E-05
0.000001
0.99
1
0.00029
2.9E-05
Aroclor 1254
NA
0.104
NA
0.1
0.01
0.99
1
0.010
0.0011
Aroclor 1260
NA
0.104
NA
0.034
0.0034
0.99
1
0.009
0.0009
Total PCBs
NA
0.104
NA
0.034
0.0034
0.99
1
0.12
0.012
Surface water concentration obtained from BERA. No remediation of surface water assumed.
NA = Not available; concentrations not provided in BERA.
Sediment Ingestion Rate (kg sed/kg BW-day)
Fish Tissue Ingestion Rate (kg tissue ww/kg BW-day)
Table 2.F
Belted Kingfisher
cot
Surl'sico Wsilor
Cone (my/L)
Surl'sico Wsilor
ln»eslion Ksilo
(L/k» liW -dsi>)
Surl'sico Wsilor Doso
(my/k" HW-dsi>)
TRY - IOAIX
(my/k" liW-dsi>)
TRY - noai:l
(my/kfi liW -dsi\)
l sir»ol loai:l HQ
Tsirj-ol N()AI:L HQ
ioai:l i»r<;
(my/kii sodimoiil)
NOAM. PRC
(iny/k" sodimoiil)
Methylmercury
0.0001
0.114
0.0000114
0.064
0.0064
0.99
1
0.12
0.012
Dioxins/Furans, as TEQ
NA
0.114
NA
0.00014
0.000014
0.99
1
0.0018
0.00018
Total PAHs
0.0127
0.114
0.0014478
1.43
0.143
0.99
1
314
31
Zinc
0.0134
0.114
0.0015276
131
14.5
0.99
1
229
26
Surface water concentration obtained from BERA. No remediation of surface water assumed.
NA = Not available; concentrations not provided in BERA.
Sediment Ingestion Rate (kg sed/kg BW-day)
Fish Tissue Ingestion Rate (kg tissue ww/kg BW-day)
Page 1 of 1
-------
APPENDIX C
Remedial Alternative Cost Estimates
-------
Table C-l
Lower Ley Creek
Soil Remedial Alternative Cost Estimates (On-site Disposal)
lh'N(Ti|)iioii
Mu-rimiiu-Siiil-I
No Ulimi
MU'i'imliM' Snil-2
l\\l ;l\iiliim ol' Soil In \K-i-l ( U-;illll|i (iuiilo
MU'riuiliM' Soil-.?
l \i:i\iiliim nl' Siiiillirrii S\\ ;ilr Soil- In \kvl
( lr:iiui|i (hhiIn mill Snil ( up I'm' Nui lliwr«l Soils
Mli-niiiliu- S..il-4
Soil ( :i|i(>M-r \ll < (>iil;imiii;ilreiier«il Silt' Mohili/.iiion
1 S
s 40.000
0
$
1
$
40,000
1
$ 40,000
1
$ 40,000
1- \c;imiIc Soils
i\
n 15
0
$
75,239
$
1,128,585
73,997
$ 1,109,955
63,865
$
957,975
1 r.msporl .iihI Dispose ol" M.ileri.il < >nsiie | \oii 1 S<'V)
loll
s 5
0
$
85,772
$
428,862
84,357
$ 421,783
72,806
$ 364,031
1 iMiispori .iimI Dispose ol' M.ileri.il
< Mi'siie [II 511 ddiii)
loll
\ "5
0
$
0
$
0
$
0
$
1 r.msporl *)
0
903
$ 333,158
888
$ 327,659
766
$
282,794
( iillin-iil Siiid\
hour
S 100.00
0
$
500
$
50,000
500
$ 50,000
500
$
50,000
ell.iikI ll.ihihil Kesior.ilion
SI
N 0„*5
0
$
892,071
$
312.225
892,071
$ 312,225
892,071
$
312,225
1 l-ool Soil < 'iip|>ini!
SI
N 1.00
0
$
66,034
$
66,034
72,736
$ 72,736
134,576
$
134,576
It.uUIIII Soil ll.ihihil 1 .i\er
i\
s .{0.00
0
$
75,239
$
2,257,170
73,749
$ 2,212,470
61,326
$
1,839,780
Suh 1 ol.il ( oiisiriielion < osis
$
$ 5,428,616
$ 5,345,995
$ 4,671,123
( oiilin<>ciie\
15"..
$
$
814,292
$ 801,899
$
700,668
-'rvvvrrvvrr'^:rvvvvvvvvvvvv';tW^l Cousti'uetion Cost
$
$ 6,242,908
$ 6,147,894
$ 5,371,791
rrnri ssiiHi.il .mil 1
rrllllir.il *srr\ ii rs
1- ii<*iiieei*iii<*
nr..
$
$ 624,291
$ 614,789
$ 537,179
( oiisiriielion M.in.i^cnicnl
2ir..
$
$ 1,248,582
$ 1,229,579
$
1,074,358
I'rojeel M.iihi^cnicnl
nr..
$
$
811,578
$ 799,226
$ 698,333
Suh loi.il I'rol'ession.il .md 1 cclinic.il Sen ices
$
$ 2,684,450
$ 2,643,595
$ 2,309,870
ViiiiimI < >per;ilion .ind M.iiiilcii.inec
Soil < '.ip M.iinleii.inee .ind ll.ihii.il Kesior.ilion Monitoring
\r
s 5.000
0
$
-
1
$
5.000
1
$ 5,000
1
$
5,000
(•enei'iil Keimiiiii^^ M.m.ii>enienl
\r
s 10.000
0
$
1
$
10.000
1
$ 10,000
1
$
10,000
Sill) lohil \iiiiii.iI < >peiMlion ;ilid M.iinleiMiiee
s
\
15.000
s 15.000
\
15.000
I'eriodie ( osis
5 \e.ir l\c\ iew
5 \r
s 20.000
1
$
20,000
0
$
1
$ 20,000
1
$ 20,000
Suh loi.il I'eriodie < osis
$ 20,000
$
$ 20,000
$ 20,000
lol.il <'.ipil.il Cosis (('oiisiriielion. I'rol'ession.il .ind leelinie.il Seniees)
$
$
8,927,358
$ 8,791,489
$
7,681,661
lol.il Vllllll.il ( Os|
l(>\M .ind I'eriodie Cosisi
$
4,000
$
15,000
$ 19,000
$
19,000
1-slim.tied ^ M Dur.ilion
\r
30
30
30
30
Diseounl K.ile
I'resenl N.iluelol' ViiiiiliI < osis)
$49,636
$186,136
$235,772
$235,772
1 ol.il I'rojeel Nel I'resenl N ;ilue
$49,636
$9,113,494
$9,027,261
$7,917,433
Notes:
LS- Lump Sum
ft - feet
CY - cubic yard
LT2005
Table C-1
Soil Remedial Alternative Cost Estimates
1 of 1
-------
Table C-2
Lower Ley Creek
Sediment Remedial Alternative Cost Estimates (On-site Disposal)
Description
Allorn;ili\o Sodinu'iil-I
No Action
\llcriiiili\c Sc(limcn(-2
Kcmo\;il ol'SodiiiK'iil lo ( Iciiniip
(>Oills
\llcrn:ili\c Scdimcnl-J
(iriiniihir Miilcriiil Scdimcnl ( ;i|)
\lliTiiiili\c Scdimcnl-J
l-'.n^inccrcd licnlonilc Scdimcnl ( ;ip
\llcriiiili\c Scdimcnl-5
Monitored \;i(ur;il Kcco\cn
Cost 1(0111
I nils
1 nil ( osl
Units
Cost
Units
Cost
Units
Cost
Units
Cost
Units
Cost
('unsirikiiun Aili\ilk-s
(ii'iuTiil Siii- Miihili/iiiiiui
LS
S 40.000
()
$
1
$ 40,000
1
$ 40,000
1
$ 40,000
0
Si-dimi-iil ('iindiiinniii^ An-a (unsirikiiun
LS
S 6(1,(1(1(1
()
$
1
$ 60,000
1
$ 60,000
1
$ 60,000
0
$
r.\i;i\;ili')
()
873
$ 322,022
680
$ 250,842
475
$ 175,251
0
$
WallT I'lVill 1111-111 ClISlS
gal
S 1
()
$
363,620
$ 363,620
283,245
$ 283,245
197,890
$ 197,890
0
$
Granular Mali-rial Cap
CY
S 30.00
()
$
0
$
12,463
$ 373,890
0
$
0
$
3-in lii-iiiiinik- Cap (I'n-slmali-r l'i iriiinhil ii in) ;iml 3-
in s;iihI la\i-r
SF
S J.X')
()
$
0
$
0
$
443,956
$ 1,726,989
0
$
Armiir SIiiik-, l.ar»i- Kiprap Kink Cim-r
CY
S 53.7'>
()
$
0
$
8,851
$ 476,095
0
$
0
$
Armiir SIiiik-, M id in m Ri|>r;i|> kink CiiM-r
CY
S 53.11
()
$
0
$
903
$ 47,958
0
$
0
$
Suh-Tiikil ( iinslriii'liiin Cusis
$
$ 4,055,828
$ 4,733,219
$ 4,748,737
$
Coniinm.'iu\
15%
$
$ 608,374
$ 709,983
$ 712,311
$
Tiil;il ( iiiislriii'liiin ( iisl
$
$ 4,664,202
$ 5,443,202
$ 5,461,048
$
Prut
.¦ssiunal and Ti-i'linkal Si-niivs
I'li^iiuviinu
io"
$
$ 466,420
$ 544,320
$ 546,105
$
( iiiislriii'liiin M;iii:iui-iik-iiI
20%
$
$ 932,840
$ 1,088,640
$ 1,092,210
$
Priiji-il Miiii;i<:i-iiK-iil
I0"i.
$
$ 606,346
$ 707,616
$ 709,936
$
Sul>-1'iiliil I'l'iili-ssiiinid ;ind l icliniiiil Si-r\iii-s
$
$ 2,005,607
$ 2,340,577
$ 2,348,251
$
LT2005
Table C-2
Sediment Remedial Alternative Cost Estimates
1 of 2
-------
Table C-2 Continued
Lower Ley Creek
Sediment Remedial Alternative Cost Estimates (On-site Disposal)
Description
\llcrn;ili\c SodiiiH'iK-l
\llcniiili\c Sc(limcnl-2
KciiiomiI ol'Sediment lo Clciinnp
(>Oills
\llcrn:ili\c Sc(limcnl-3
\llcriiiili\c Sci'iiniiliir Miilcriiil Sediment Cap
l-.iiiiinccrcd licnlonilc Sediment Cap
Monitored N;ilnr;il Rcco\cr\
Cos! hem
1 nils
l nil ( osl
I nils
Cost
I nils
Cost
Units
Cost
Units
Cost
Units
Cost
Amiiiiil ()|K'nilion ;ind \l;iillk'ii;iHU-
M'S K Siimplinu
vr
S 100.000
$
o
$
1
$ 100,000
1
$ 100,000
1
$ 100,000
\1\K Ki-porlinu
vr
S 30.000
()
$
1
$ 30,000
1
$ 30,000
1
$ 30,000
Si-dimi-nt ( ;i|> M;iink-n;iiui-
vr
S 30.000
o
$
1
$ 30,000
1
$ 30,000
0
$
Gi-iut;iI Reporting - l iihil Annii.il Opi-r.ition iiiul M;iiiik-ii;iiui-
$
$ 10,000
$ 170,000
$ 170,000
$ 140,000
Periodic Cusis
5 \ i ;ir \ ii-«
5 vr
S 20.000
1
i) 2() ()()()
()
$
1
$ 20,000
1
$ 20,000
1
$ 20,000
5 M-iir I'ish S;iiii|)linu
5 vr
S 75,000
()
$
1
$ 75,000
1
$ 75,000
1
$ 75,000
1
$ 75,000
Suh- l oliil Periodic Costs
S 211,000
$ 75,000
$ 95,000
$ 95,000
$ 95,000
l oliil C iipiliil Cusis (Construction, ProIVssii>11 :i 1
;iihI Technic.il Sen iii's)
$
$ 6,669,809
$ 7,783,778
$ 7,809,298
$
l oliil Annii.il Cost
(OWl ;ill(l Periodic Cusis)
T) 4 ()()()
$ 25,000
$ 189,000
$ 189,000
$ 159,000
r.siim;ik-d ()\ M Dunilion
vr
M)
30
30
30
30
Discount K;iu-
TO/
/ /o
Present Value (ol' Annii.il Costs)
$49,636
$310,226
$2,345,309
$2,345,309
$1,973,038
loliil Project Net Present Value
$49,636
$6,980,035
$10,129,087
$10,154,607
$1,973,038
Notes:
LS- Lump Sum
ft - feet
CY - cubic yard
LT2005
Table C-2
Sediment Remedial Alternative Cost Estimates
2 of 2
-------
Table C-3
Lower Ley Creek
Soil Remedial Alternative Cost Estimates (Off-site Disposal)
lh'N(Ti|)iioii
Mli-niiiiiu- S.,il-I
No Ulimi
MU'i'imliM' Snil-2
l\\l ;l\iiliim ol' Soil In \K-i-l ( U-;illll|i (iuiilo
MUTiuiliM' Soil-.?
l \i:i\iiliim nl' Suiillirrii Sw :ilr Soil- in \K-rl
( lr:mii|i (hhiIn mill Snil ( up I'ur \oilhwrsl Soils
Mu-niiiliu- S..il-4
Soil ( :i|i(>mt \ll < oiil;imiii;ilr(l Soils
( mn| lU'in
1 IlilN
1 nil < eiier«il Silt' Mohili/.iiion
1 S
s 40.000
0
$
1
$
40,000
1
$
40,000
1
$ 40,000
1- UMMilr Soils
i\
n 15
0
$
75,239
$
1,128,585
73,997
$
1,109,955
63,865
$
957,975
1 r.msporl .iimI Dispose ol" M.iieri.il < >nsiie I \oii 1 S<'\)
lOII
s 5
0
$
0
$
0
$
0
$
1 iMiispori .iimI Dispose ol' M.iieri.il
< Mi'siie [II 511 ddiii)
loll
\ "5
0
$
85,772
$
6,432,935
84,357
$
6,326,744
72,806
$
5,460,458
1 iMiispoii iind Dispose ol' M.iieri.il
< Mi'siie (511 500 itmin
loll
n 225
0
$
3,611
$
812,581
3,552
$
799,168
3,066
$
689,742
1 r.msporl .ind Dispose ol' M.iieri.il
< )ITsiie (500 pdiii )
loll
N .*<>*)
0
$
903
$ 333,158
888
$
327,659
766
$
282,794
( ulliinil Slud\
liour
S 100.00
0
$
500
$
50,000
500
$ 50,000
500
$
50,000
elLintl ILihihil Kesior.ilion
Sl
N o..<5
0
$
892,071
$
312.225
892,071
$ 312,225
892,071
$
312,225
1 l-ool Soil < ii|)|>iii2
SI
N 1.00
0
$
66,034
$
66,034
72,736
$
72,736
134,576
$
134,576
ItiirUIIII Soil ll.ihihil 1 .i\er
i\
s .to.oo
0
$
75,239
$
2,257,170
73,749
$
2,212,470
61,326
$
1,839,780
Sill) 1 ol.il ( oiisiriielion < osis
$
$ 11,432,688
$ 11,250,956
$ 9,767,550
( 'onlin<>eiie\
15"..
$
$
1,714,903
$
1,687,643
$
1,465,132
-'rvvvrrvvrr'^:rvvvvvvvvvvvv';tW^l Cousti'uetion Cost
$
$ 13,147,591
$ 12,938,599
$ 11,232,682
rrnri ssiiHi.il .mil 1
rrllllir.il *srr\ ii rs
1- ii<*iiieei*iii<*
nr..
$
$ 1,314,759
$ 1,293,860
$ 1,12.3,268
( oiisiriielion M.in.i^einenl
:ir..
$
$ 2,629,518
$ 2,587,720
$
2,246,536
I'rojeel M.iihi^einenl
nr..
$
$
1,709,187
$
1,682,018
$ 1,460,249
Suh 1 ol.il I'rol'ession.d «md 1 eeluiie.il Sen iees
$
$ 5,653,464
$ 5,563,598
$ 4,830,053
\nnii;il < >per;ilion .md M.iinlen.uiee
Soil < '.ip M.iinleii.mee .md ll.ihii.il Kesior.ilion Monitoring
\r
s 5.000
0
$
-
1
$
5.000
1
$ 5,000
1
$
5,000
(•euei'iil Ke|)oiiiii2\ M.in.ii>emenl
\r
s 10.000
0
$
1
$
10.000
1
$ 10,000
1
$
10,000
Suh lohil \nnu.il < >peiMlion ;ind M.iinleiMiiee
s
\
15.000
\
15.000
\
15.000
I'eriodie ( osis
5 \e.ir l\c\ iew
5 \r
s 20.000
1
$
20,000
0
$
1
$
20,000
1
$ 20,000
Suh 1 oi.il I'eriodie ( osis
$ 20,000
$
$ 20,000
$ 20,000
loi.il <'.ipii.il < os|s (('oiisiriielion. I'rol'ession.il .iimI leelinie.il Seniees)
$
$
18,801,055
$ 18,502,197
$
16,062,735
lol.il Kllllll.ll ( Os|
l(>\M .iimI I'eriodie ( osis i
$
4,000
$
15,000
$
19,000
$
19,000
1-slim.tied ^ M Dur.ilion
\r
30
30
30
30
Diseouni K.iie
I'resenl N.due(ol' \iiiiiliI ( osis)
$49,636
$186,136
$235,772
$235,772
1 ol.il I'rojeel Nel I'resenl N nine
$49,636
$18,987,191
$18,737,968
$16,298,507
Notes:
LS- Lump Sum
ft - feet
CY - cubic yard
LT2005
Table C-3
Soil Remedial Alternative Cost Estimates
1 of 1
-------
Table C-4
Lower Ley Creek
Sediment Remedial Alternative Cost Estimates (Off-site Disposal)
Description
AlKTiiiiliM* Si'diiiK'iil-l
No Aclion
AlkTiiiiliM- Srdiim'iil-2
UcnioMil of SnliiiK'iil lo ( Iciinup
(>o;ils
AlKTii;ili\c ScdiiiK'iil-3
(•ninuhir M;ikri;il Scdinicnl C;i|>
AlkTiiiiliM' SnliiiK'iil-4
Kn»iiKTiT(l licnlonilc SnliiiKMil ( ;i|>
AlkTiiiiliM' ScdiiiK'iil-5
Monitored Niilunil Ri'co\cr\
Cos! llciii
I nils
1 nil ( osl
I nils
Cost
I nils
Cost
I nils
(osl
I nils
Cost
I nils
(osl
Ciiiisiriii'iiiui Aili\ ilii-s
(ii'iu'i'iil Siii- Miil)ili/;iiiiui
LS
s
40.000
0
$
1
$ 40,000
1
$ 40,000
1
$ 40,000
0
$
Si-dimi-nl C'ondiliiuiiii^ Aivii Ciiiisiriii'iiiui
LS
s
f.0,000
0
$
1
$ 60,000
1
$ 60,000
1
$ 60,000
0
$
F.\i;i\ ;ilinn r.(|iii|)iiH'iil Miil>ili/;iiiiin
LS
s
40.000
0
$
1
$ 40,000
1
$ 40,000
1
$ 40,000
0
$
SIkiIIhw l.\i;n uliiiii In mi Shun-
CY
s
15
0
$
72,724
$ 1,090,860
56,649
$ 849,735
39,578
$ 593,670
0
$
I5;uklill Si-dillli-llls/l l;il)il;il l.;i\iT
CY
s
30
0
$
19,192
$ 575,760
36,450
$ 1,093,500
35,467
$ 1,064,010
0
$
l)i-x\;ili-r/ ('iindilinn Si-dimi-nls
CY
s
5
0
$
72,724
$ 363,620
56,649
$ 283,245
39,578
$ 197,890
0
$
Tmnspiirl ;ind Dispose hI' M;iU-ri;il Onsile
lllll
s
5
$
0
$
0
$
0
$
0
$
Transport ;iikI Dispose nl' M;iU'i'i;il
OITsile (0-50 111>m)
lllll
s
75
0
$
82,905
$ 6,217,902
64,580
$ 4,843,490
45,119
$ 3,383,919
0
$
Tl'iinspiirl ;illd Dispose (if M;iU'l'i;il
OITsiU- (50-500 |)|)in)
lllll
s
225
0
$
3,491
$ 785,419
2,719
$ 611,809
1,900
$ 427,442
0
$
Tmnspurl ;iikI Dispose ul' \l;ileri;il
OITsiU- (500 ppm +)
lllll
s
3fi'>
0
873
$ 322,022
680
$ 250,842
475
$ 175,251
0
$
\\ :iler Tre:ilmenl Ciisls
«a 1
S 1
0
$
363,620
$ 363,620
283,245
$ 283,245
197,890
$ 197,890
0
$
(Jninuhir \1;ileri;il (:ip
CY
s
30.00
0
$
0
$
12,463
$ 373,890
0
$
0
$
3-in lieiilmiile C;ip (freshw :iler I'iinilnhi 1 iiill) ;ind 3
in s;ilid l;i\er
SF
s
3.S')
0
$
0
$
0
$
443,956
$ 1,726,989
0
$
Annul- SI ii ik', l.;ir;>e Kipiup Kmk (mcr
CY
s
53.7')
0
$
0
$
8,851
$ 476,095
0
$
0
$
Arnnir Siiiiu-, Medium Ripmp Kmk ( hut
CY
s
53.11
0
$
0
$
903
$ 47,958
0
$
0
$
SuI)-T'hI;iI Ciiiisiriii'iiiui Ciisls
$
$ 9,859,203
$ 9,253,809
$ 7,907,062
$
(iiiilinmiHN
15%
$
$ 1,478,880
$ 1,388,071
$ 1,186,059
$
T'uUil C'liiislriii'liiin ( us!
$
S ll.33S.0S4
S lO.MI.SSO
S '),0')3,I2I
s
Profession;!! ;ind rii liniiul Si i v iii-s
r.nuiiu-iTiiiLi
10
$
$ 1,133,808
$ 1,064,188
$ 909,312
$
CiinslriKliiiii M;iii;iui'iiH'iil
20%
$
$ 2,267,617
$ 2,128,376
$ 1,818,624
$
Pniji'il M;in;i^i'iiH'iil
10",.
$
$ 1,473,951
$ 1,383,444
$ 1,182,106
$
Sul)-T'iil;il I'liil'i'ssiuiKil ;iikI l i'iliiiiiul Si-in ins
$
$ 4,875,376
$ 4,576,009
$ 3,910,042
$
LT2005
Table C-4
Sediment Remedial Alternative Cost Estimates
1 of 2
-------
Table C-4 Continued
Lower Ley Creek
Sediment Remedial Alternative Cost Estimates (Off-site Disposal)
Description
AlKTiiiiliM- SnlinuMil-l
No Aclion
AlkTiiiiliM- Srdiim'iil-2
UcnioMil ol'SnliiiKMil lo ( kiinup
(>o;ils
AlKTii;ili\c ScdiiiK'iil-3
(•ninuhir \l;ikri;il Scdinicnl C;i|>
AlliTii;iliM' SnliiiK'iil-4
Kiiginmrd licnlonik* Si-dimi-nl ( ;i|>
AlkTiiiiliM' ScdiiiK'iil-5
Monitored Nnliinil Ri'co\cr\
Cos! llciii
( nils
I nil Cos!
Units
Cost
Units
Cost
Units
Cost
Units
Cost
Units
Cost
A111111 :i 1 ()|K'l';ilinn ;in(1 \l;iillli-ll;illl'i-
MNK Siimplinu
vr
S 100.0(10
$
()
$
1
$ 100,000
1
$ 100,000
1
$ 100,000
M\K Ki'|nirliiit>
vr
S 30.000
()
$
1
$ 30,000
1
$ 30,000
1
$ 30,000
Si-dillli-lll C ;i|> \l;iiiili-ll;ini'i-
yr
S 30.000
()
$
1
$ 30,000
1
$ 30,000
0
$
(ii'lU'l'ill Kipoi lii^ \ .\l;ill;i;>i-llli-lll
vr
S 10.000
$
1
l ()()()()
1
$ 10,000
1
$ 10,000
1
$ 10,000
Snl>-'Tnl:il Aiiiin;i 1 Opiiiilinn ;iikI \l;iinli-ii;ini'i-
$
S HMHHI
$ 170,000
$ 170,000
$ 140,000
IVriudii' Cnsls
5 \i-iir Ki-\ ii-H
5 vr
S 20.000
1
S ^0 000
()
$
1
$ 20,000
1
$ 20,000
1
$ 20,000
5 \i-;ir I 'isli S;i in pi i ni>
5 vr
S 75,000
()
$
1
S 7*5 ()()()
1
$ 75,000
1
$ 75,000
1
$ 75,000
Suh-Toliil IVriudii' Costs
S 20.000
S 75,000
$ 95,000
$ 95,000
$ 95,000
Tuliil C ;i|)il;il C osls (C onslriiilioii, Proli-ssion;il
:ilid Ti-ihiiii;il Si-i n iii's)
$
$ 16,213,459
$ 15,217,889
$ 13,003,163
$
Tohil Alllllliil C'hsI
(O&M ;inil IVriudii- ( osls)
$ 4,000
$ 25,000
$ 189,000
$ 189,000
$ 159,000
r.sliniiili'd () M l)iir;iliiui
vr
30
30
30
30
30
Discount Kiill"
7%
Pri'si-nl Y;ilin- (ill' Annii;i 1 ( osls)
$49,636
$310,226
$2,345,309
$2,345,309
$1,973,038
l
-------
APPENDIX D
Site Photographs
-------
107 22V20TZ
Photograph 1 - Capping of former Town of Salina Landfill (looking west from Route 11)
Photograph 2 - Lower Ley Creek at about 1500 feet downstream of Route 11 (looking west)
1
-------
Photograph 3 - View of Lower Ley Creek looking south from 71" North St.
Photograph 4 - View of Lower Ley Creek looking north from Park Street (1-81 crossing above)
-------
APPENDIX E
Sand and Armor Sediment Capping Details
-------
APPENDIX E
SAND AND ARMOR SEDIMENT CAPPING DETAILS
LOWER LEY CREEK SUBSITE OF THE
ONONDAGA LAKE SUPERFUND SITE, SYRACUSE, NY
1.0 SUMMARY OF CAP DESIGN
The composition and dimensions of the components of a sediment cap can be referred to as the
cap design. This design must physically isolate the contaminated sediment from the benthic
environment and achieve the intended cap functions. The design must also include a
habitat/bioturbation layer to provide a clean substrate for recolonization by bottom-dwelling
organisms.
This appendix presents the basis of design for the granular material sediment cap (Alternative
Sediment-3). In areas of the Site with low erosion potential (i.e., Old Ley Creek), the granular
material sediment cap includes the following design layer:
• Isolation/Habitat Layer (2 feet [ft] thick).
In areas of the site with high erosion potential (i.e., Lower Ley Creek), the granular material
cap includes the following design layers, from top to bottom:
• Habitat Layer (2 ft thick);
• Armor Layer (0.375 - 2.04 ft thick); and
• Isolation Layer (2 ft thick).
The following sections discuss the sediment transport characterization of each section of
Lower Ley Creek and the design of each of these granular material caps.
LT2005
U.S. EPA Region 2
E-l-1
HGL 1/17/2014
-------
This page intentionally left blank.
-------
HGL—Appendix E—Lower Ley Creek Subsite of the Onondaga Lake Superfund Site, Syracuse, NY
2.0 SEDIMENT TRANSPORT CHARACTERIZATION OF LOWER
LEY CREEK
As stated in Section 4 of the Final Feasibility Study (FS) that incorporates this appendix, most
of the Lower Ley Creek channel is considered to be neither erosional nor depositional on the
basis of field evidence (i.e., suspended sediment flux from the bed is likely to be balanced
evenly between erosion and deposition, and material entering the section of the creek as
suspended load can be transported through the section). However, for sediment cap design, a
more conservative evaluation of erosional potential is required. This is due to the potential of
extreme hydrodynamic conditions (i.e., floods, ice scouring) causing permanent damage to the
sediment cap and creating contaminate releases.
2.1 Streamflow Characteristics
One U.S. Geological Survey (USGS) stream gauge (USGS 04240120) is operated in the
Lower Ley Creek Subsite. Monthly mean streamflows for Lower Ley Creek from 2000-2010
are exhibited in Figure 4.1 and peak flow events from 1974-2010 in Lower Ley Creek are
shown in Figure 4.2 of this document.
Based on available information, the following general comments about Lower Ley Creek
streamflow can be made:
• Runoff is typically low during the summer and early fall months, except during
occasional frontal storms, and during midwinter when ice-cover forms or a snowpack
is present in the watershed.
• Flood flows are most common during spring snowmelt, primarily early-March to
mid-April.
• Based on monthly mean streamflows between 2000-2010, the average streamflow can
be estimated at about 45 cubic feet per second (cfs).
• The maximum peak streamflow exhibited at Lower Ley Creek between 1974-2010 was
approximately 1400 cfs.
• The U.S. Army Corps of Engineers (USACE) prepared a 100-year storm hydrograph
in June 1971 which estimated peak flow in Lower Ley Creek to be 2000 cfs.
2.2 Determination of the Erosional Potential of Lower Ley Creek
The LATA Team calculated the erosional potential of Lower Ley Creek using three different
procedures:
• The standard Hjulstrom Curve (Figure E-2) that is widely cited and used in literature
and applications (Fryirs and Brierley, 2012).
• The alternative Hjulstrom Curve (Marshak, 2007) that directly relates river bed
materials to river bed status under different river velocities (Figure E-3).
• Guidance provided in Chapter 3 of the EM 1110-2-1601 entitled Hydraulic Design of
Flood Control Channels (USACE, 1994).
LT2005
U.S. EPA Region 2
E-2-1
HGL 1/17/2014
-------
HGL—Appendix E—Lower Ley Creek Subsite of the Onondaga Lake Superfund Site, Syracuse, NY
2.2.1 Hjulstrom Curves
Because this is a natural main stream with significant vegetation and relatively slow water
movement, we assume Manning's coefficient (n) to be 0.05 (Chow, 1959). The energy slope
(S) was estimated to be 0.0003 (ft/ft) using Google Maps, however, this value may subject to
significant variation. Therefore, we altered it from original estimate of 0.0003 to 0.0001
(ft/ft). The cross-section is assumed to be rectangular, or trapezoidal with zero side slope (z)
(Figure E-l). Because the river width (B) is much larger than its depth (Y), this assumption is
acceptable.
Figure E-l
Trapezoidal Cross-Section
The average depth of water may subject to the most variation and we assume it is unknown.
We adjust the depth to obtain desired flow rate (Q) of 45 cfs. The final adjusted depths are
I.6, 1.3, and 2 ft deep for the upstream, middle and downstream sections, respectively (Table
E-l). They appear to be within the reasonable range. Under this flow rate of 45 cfs, velocity is
calculated by dividing the flow rate by the cross-section area (A). The final velocities are 12,
II, and 14 cm/s for the upstream, middle and downstream sections, respectively (we change
to SI unit to use the Hjulstrom curve, see Figure E-2 and Figure E-3).
Using the set of parameters estimated from the observation data, we assume the same energy
slope and river width, then adjust the depth to obtain the desired maximum flow rate of 2000
cfs (100-year flood). Using the final set of depths of 18.4, 13.8, and 25 ft for the upstream,
middle and downstream sections, respectively (Table E-2), we calculated the velocities to be
47, 44 and 49 cm/s for the upstream, middle and downstream sections, respectively.
Based on these maximum velocities, we reviewed Hjulstrom Curve and determined the
corresponding status of river bed materials. Note that two versions of Hjulstrom Curves are
used. One is the standard Hjulstrom Curve (Figure E-2) that is widely cited and used in
literature and applications (Fryirs and Brierley, 2012). This curve relates river bed material to
the material particle status under different river velocities. The second version is an alternative
Hjulstrom Curve (Marshak, 2007) that directly relates river bed materials to river bed status
under different river velocities (Figure E-3).
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HGL—Appendix E—Lower Ley Creek Subsite of the Onondaga Lake Superfimd Site, Syracuse, NY
Using the Hjulstrom Curve in the most common form (Figure E-2), we conclude that at flow
rate of 45 cfs, all sections of the creek are in transition mode (i.e., the bed material is under
both erosion and deposition). At flow rate of 2000 cfs, the upstream section of Lower Ley
Creek will be in erosion mode, while the middle and downstream sections will be in transition
mode.
Using the Alternative Hjulstrom Curve (Figure E-3), we conclude that at flow rate of 45 cfs,
all sections of Lower Ley Creek are in sedimentation mode. At flow rate of 2000 cfs, the
middle and downstream sections of Lower Ley Creek will be in transition mode, but upstream
section is in danger of erosion.
Although these two curves are slightly different, they both indicate the potential for erosion
and transport of particles during 100-year flood conditions in the upstream section of Lower
Ley Creek.
Figure E-2
Standard Hjulstrom Curve
The HiUlstrom curve
SAVDS
0001 001 0.1 1 10 100 1000
Sediment size (mm)
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Figure E-3
Alternative Hjulstrom Curve
Cobbles and
boulders
1000'
800 i,.
soof-
200
^ 100
M I
I —scl]
Sand
Clay
Silt
Fine
Medium
to coarse
Granules
Pebbles
"OA
°s,
\ °f= p^^
-
o **
A.\
o
1 *
•? Noncohesive clay and silt m
i _!oj rrrr
'Of sedimentation
><0
X
X
2 ^
I I '
0001 | 0005 | 002 00S 0.1 0.2 OS I 2
0002 0 01
Grain size (mm)
2000 cfs
45 cfs
S 10 20 SO 100
2.2.2 Modified USACE Equation
Because Lower Ley Creek does not experience significant navigation, it mainly requires
protection for the maximum flood flows, storm velocities, and ice scouring. At sites without
navigation having flow velocities typically found in flood control channels, the maximum grain
size required to resist erosion should follow the guidance provided in Chapter 3 of the EM
1110-2-1601 entitled Hydraulic Design of Flood Control Channels (USACE, 1994).
Velocity and flow depth are the two basic factors used to determine grain size requirements.
The following equation, modified from EM 1110-2-1601, relates velocity to grain size and is
applicable to any location in the channel:
D50 = Sf*Cs*Cv*Ct*Cg*d*[{(aw/(as-aw)}1/2*{V/(V(Ki*g*d))}]2'5
Where:
D?o = characteristic grain size of which 50 percent (%) is finer by weight
Sf = safety factor (minimum 1.1)
Cs = stability coefficient for incipient failure (0.30 for angular rock, 0.375 for rounded rock)
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Cv = Velocity distribution coefficient (1.0 for straight channels and inside of bends, 1.25
downstream of concrete channels and end of dykes)
Ct = blanket thickness coefficient (typically 1.0 for flood flows)
Cg = gradation uniformity coefficient (typical range = 1.8 to 3.5)
d = local water depth
a® = unit weight of water
as = unit weight of stone (typical value of 165 pounds [lb]/ft3)
V = local depth average water velocity
Ki = side slope correction factor (0.88 for 2H:1V)
g = gravitational constant
Grain size calculations for Lower Ley Creek are shown in Table E-3.
2.2.3 Upstream Section of Lower Ley Creek
The upstream section of Lower Ley Creek extends from just upstream of the Route 11 Bridge
to the intersection with the 7th North Street Bridge. Substrate in this section ranges from sand
to clay with some small (1-4 centimeter) stones. Old Ley Creek enters Lower Ley Creek near
the middle of the section and Beartrap Creek enters Lower Ley Creek at the downstream end
of the section. There are multiple bends and bridge crossings in this section of Lower Ley
Creek.
Water depth is variable, but is typically between 2 to 4 ft deep. The average width of the
upstream Section of Lower Ley Creek is about 70 ft. Based on an average streamflow of 45
cfs; a peak streamflow of 2000 cfs; an average water depth of 3 ft; and an average width of 70
ft; the approximate water velocities for this section of Lower Ley Creek are calculated as:
• Average = 0.21 ft/s; and
• Maximum = 9.5 ft/s.
As shown in Table E-3, a maximum water velocity of 9.5 ft/s in 3 ft deep water require a
median grain size that exceeds those typically found in a granular sand cap (0.0002 ft diameter
for fine sand). Therefore, based on the maximum water velocity and average depth of the
creek, an armor layer should be included in any sediment cap design in the upstream section of
Lower Ley Creek.
2.2.4 Middle Section of Lower Ley Creek
As stated in Section 4, the middle section of Lower Ley Creek extends from the intersection
with 7th North Street Bridge to approximately 2,000 ft southwest of the intersection (near the
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Alliance Bank Stadium). This section consists of a generally straight, uniform, low gradient
stream. Substrate in this section mostly consists of silt and clays. There is only one bridge
crossing in this section of Lower Creek.
Water depth in this section is approximately 4 ft deep. The average width of the middle section
of Lower Ley Creek is about 100 ft. Based on an average streamflow of 45 cfs; a peak
streamflow of 2000 cfs; an average water depth of 4 ft; and an average width of 100 ft; the
approximate water velocities for this section of Lower Ley Creek are calculated as:
• Average = 0.11 ft/s; and
• Maximum = 5 ft/s.
As shown in Table E-3, a maximum water velocity of 5 ft/s in 4 ft deep water requires a
median grain size that exceeds those typically found in a granular sand cap (0.0002 ft diameter
for fine sand). Therefore, based on the maximum water velocity and average depth of the
creek, an armor layer should be included in any sediment cap design in the middle section of
Lower Ley Creek.
2.2.5 Downstream Section of Lower Ley Creek
As stated in Section 4, the downstream section of Lower Ley Creek extends from
approximately 2,000 ft southwest of the 7th North Street Bridge intersection to the intersection
with Onondaga Lake. This section has a low gradient and substrate in this section mostly
consists of silt and clay. There are multiple bends and bridge crossings in this section of
Lower Ley Creek.
Water depth is variable, but is typically between 8 to 12 ft deep. The average width of the
downstream section of Lower Ley Creek is about 50 ft. Based on an average streamflow of 45
cfs; a peak streamflow of 2000 cfs; an average water depth of 10 ft; and an average width of
50 ft; the approximate water velocities for this section of Lower Ley Creek are calculated as:
• Average = 0.09 ft/s; and
• Maximum = 4 ft/s.
As shown in Table E-3, a maximum water velocity of 4 ft/s in 10 ft deep water requires a
median grain size that exceeds those typically found in a granular sand cap (0.0002 ft diameter
for fine sand). Therefore based on the maximum water velocity and average depth of the
creek, an armor layer should be included in any sediment cap design in the downstream
section of Lower Ley Creek. However, the downstream section of Lower Ley Creek will not
be capped under the granular material sediment cap alternative (Alternative Sediment-3).
2.3 Conclusion
While the Hjustrom Curves only indicate that the upstream section of Lower Ley Creek may
require an armor layer, the modified US ACE equation indicates that the middle section of
Lower Ley Creek may also require an armor layer. Although these equations account for a
100-year flood event, they do not account for ice scouring events, which may temporarily
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erode portions of the granular sediment cap in all sections of Lower Ley Creek. Therefore,
based on the potential of ice scouring events, an armor layer will be included in the granular
sediment cap design for the upstream and middle sections of Lower Ley Creek.
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HGL—Appendix E—Lower Ley Creek Subsite of the Onondaga Lake Superfund Site, Syracuse, NY
3.0 GRANULAR SEDIMENT CAP DESIGN FOR LOW EROSIONAL
AREAS
As discussed above, the sediments in Old Ley Creek exhibit low erosional potential so an
armor layer is not required for the granular sediment cap in this location.
Therefore, the preliminary cap design for the granular sediment cap in this was determined
through an evaluation of site-specific information so that the cap would meet the following
objectives:
• Physical isolation of COPCs in the sediment from the benthic environment;
• Chemical isolation (i.e., reduce the flux of dissolved COPCs to the water column);
• Erosion protection (i.e., to mitigate resuspension and transport of sediments to
downstream areas) to maintain cap stability against forces resulting from open water
river flows and ice jam-related flows; and
• Provide a clean substrate for recolonization by bottom-dwelling organisms.
In accordance with EPA (Palermo et al., 1998) and USACE (USACE, 1998) design guidance,
the total thickness of a protective cap was specified as the sum of the thicknesses required to
achieve each of the design objectives listed above. An additional factor of safety beyond the
EPA and USACE design requirements was also incorporated into the preliminary cap design
to ensure its protectiveness.
Therefore, a 2-ft thick granular sand cap was designed for Old Ley Creek. This is
conservative design in a simple hydrologic system exhibiting low hydraulic gradients and weak
erosional and depositional environments. In addition, a 2-ft thick granular sand cap will
physically and chemically isolate the COPCs in the sediment below and provide a clean
substrate for recolonization by bottom-dwelling organisms.
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HGL—Appendix E—Lower Ley Creek Subsite of the Onondaga Lake Superfund Site, Syracuse, NY
4.0 GRANULAR SEDIMENT CAP DESIGN FOR HIGH EROSIONAL
AREAS
As discussed above, all sections of Lower Ley Creek exhibit a potentially high erosional
potential, so an armor layer is required for the granular sediment cap for upstream and middle
sections of Lower Ley Creek.
The preliminary cap design for the armored sediment cap was determined through an
evaluation of site-specific information so that the cap would meet the following objectives:
• Physical isolation of COPCs in the sediment from the benthic environment;
• Chemical isolation (i.e., reduce the flux of dissolved COPCs to the water column);
• Erosion protection (i.e., to mitigate resuspension and transport of sediments to
downstream areas) to maintain cap stability against forces resulting from open water
river flows and ice jam-related flows; and
• Provide a clean substrate for recolonization by bottom-dwelling organisms.
In accordance with EPA (Palermo et al., 1998) and USACE (USACE, 1998) design guidance,
the total thickness of a protective cap was specified as the sum of the thicknesses required to
achieve each of the design objectives listed above. An additional factor of safety beyond the
EPA and USACE design requirements was also incorporated into the preliminary cap designs
to ensure their protectiveness.
4.1 Design of Isolation Layer
The objective of this study was to evaluate the thickness of the chemical isolation layer so that
the chemical isolation layer is able to contain the chemicals in the river sediments.
The point of compliance was assumed to be at the bottom of the habitat layer, which
corresponds with the top of the chemical isolation layer. The source concentration in the
sediments is assumed to be the pore water concentration that is in equilibrium with the soil
concentration. The relationship between the soil concentration and pore water concentration
can be described by a sorption linear isotherm (See Equation 1.0). The soil organic
carbon-water partitioning coefficient of polychlorinated biphenyls (PCBs) is assumed to be
1,380,384 liters per kilogram (L/kg). The organic fraction of the river sediment was measured
at 3.7 %.
The transport process within the chemical isolation layer is described by a one dimensional
advection-diffusion model with Retardation effects (Equation 2.0). Because the point of
compliance was assumed to be at the bottom of the habitat layer, the traveling distance equals
to the thickness of the chemical isolation layer. The traveling time is assumed to be 1000
years, which is equivalent to a very long time period.
The other assumption of model input parameters include:
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• the porosity of the capping material is assumed to be 0.4;
• the bulk density of the chemical isolation layer is assumed to be 1.59 grams per cubic
centimeter (g/cm3);
• the dispersivity of the chemical isolation layer is assumed to be 0.0125 cm; and
• the molecular diffusion coefficient of PCB at 45 degrees Fahrenheit is assumed to be
3.42E-06 square centimeters per second (cm2/sec).
The flow velocity within the chemical isolation layer is assumed to be the base flow upwelling
velocity through the river sediments (Equation 3.0). It was reported that the base flow is
approximately 56% at an average flow rate of 45 cfs, which resulted in a 25 cfs baseflow.
This value is close to the minimum flow observed from the USGS stream gauge (USGS
04240120) at the Site.
The model parameters and final results are listed in Table E-4. At the maximum levels of
PCBs detected below a depth of 2 ft in the upstream section of Lower Ley Creek (69
milligrams per kilogram [mg/kg]), a 60 cm (~2 ft) thick isolation layer is required to meet the
0.09 parts per billion (ppb) PCB water quality standard for use as a human water source. All
sediment between 0-2 ft will be excavated before a sediment cap is put in place. Therefore, a
2-ft thick granular sand cap was designed as the isolation layer for high erosional potential
areas in the upstream section of Lower Ley Creek. A 2-ft thick granular sand cap will
physically and chemically isolate the COPCs in the sediment below and provide a supportive
base for the overlying armor layer.
At the maximum levels of PCBs detected below a depth of 2 ft in the middle section of Lower
Ley Creek (5.5 mg/kg), a 45 cm (~ 1.5 ft) thick isolation layer is required to meet the 0.09
ppb PCB water quality standard for use as a human water source. All sediment between 0-2 ft
will be excavated before a sediment cap is put in place. Therefore, a 1.5-ft thick granular sand
cap was designed as the isolation layer for high erosional potential areas in the middle section
of Lower Ley Creek. A 1.5-ft thick granular sand cap will physically and chemically isolate
the COPCs in the sediment below and provide a supportive base for the overlying armor layer.
The downstream section of Lower Ley Creek will not be capped under the granular material
sediment cap alternative (Alternative Sediment-3).
The equations used in the calculations are listed below.
4.1.1 Equations
1. Initial Pore Water Concentration
The initial pore water concentration (C0) is a function of the concentration in the underlying
sediment. The sorption process is described by a linear isotherm (Fetter, 1993):
(Equation 1.0)
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Where:
€s is the concentration in the sediments (mg/kg);
if,! is the distribution coefficient (L/kg).
The distribution coefficient K£ of organic compound is primarily a function of the organic
carbon fraction of the soil matrix, for river sediments, it is the sediment organic carbon fraction.
For chemical isolation layer, it is the organic carbon fraction of the isolation layer.
JTtf = fe:sSme (Equation 1.1)
Where:
fjC is the organic carbon fraction (%);
Sm is the soil organic carbon-water partition coefficient (L/kg).
2. One dimensional Advection-Diffusion Model (Fetter, 1993) with Retardation Effect
A one dimensional advection-diffusion model was used to model the transport within the
chemical isolation layer. The model considers a transient transport of a fixed-step concentration
boundary within a single media, semi-infinite layer. The boundary and initial conditions are
given by:
Initial condition: eCM)=pr sag
Boundary conditions: C(Q. t) = fc P and C(cer£) = §,, £ > ®
The solution is (Ogata and Banks. 1961):
c¦<*'3 * 5 (Equa"on 2 0)
Where:
C(£,,t)is the concentration at location L, and time t;
L is the traveling distance (L);
t is the traveling time (T);
is the constant concentration at the boundary (M/L3);
vx is the linear velocity (L/T);
% is the longitudinal dispersion coefficient (L2/T); and
Bt is the retardation factor (dimensionless).
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The longitudinal dispersion coefficient DL is a function of longitudinal dispersivity (cet) and
linear velocity (itJ, and is calculated by:
D± = % • . + £?" (Equation 2.1)
Where:
aL is the longitudinal dispersivity (L);
is the molecular diffusion coefficient (L2/T).
The retardation efficient is applied in the form of a retardation factor (Rf), given by:
Bf = It (Equation 2.2)
Where:
** is the bulk density of the chemical isolation layer (M/L3);
Sis the porosity of the river sedimentation layer (Dimensionless).
3. Upwelling Velocity
The linear velocity is function of the river upwelling Darcy velocity (£?t) and is calculated
by:
_ y _ (Equation 3.0)
Where:
qx is the upwelling Darcy velocity (L/T);
%®3c is the average river base flow (L3/T);
A is the total river bottom area that contributes to the base flow (L2).
4.2 Design of Armor Layer
An armor layer will be incorporated into the granular sediment cap design in areas of high
erosional potential. The thickness of the armor will replace any sediment cap thickness
component for erosion. Both the size and thickness of the armor stones play a significant role
in defining the stability of the armor layer.
4.2.1 Armor Stone Sizing for Flood Flows
Because Lower Ley Creek does not experience significant navigation, it mainly requires
protection for the maximum flood flows, storm velocities, and ice scouring. At sites without
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navigation having flow velocities typically found in flood control channels, the armor
protection requirements should follow the guidance provided in Chapter 3 of the EM
1110-2-1601 entitled Hydraulic Design of Flood Control Channels (USACE, 1994).
Velocity and flow depth are the two basic factors used in armor protection. The following
equation, modified from EM 1110-2-1601, relates velocity to stone size and is applicable to
any location in the channel:
Dso = Sf*Cs*Cv*Ct*Cg*d*[{(aw/(as-aw)}1/2*{V/(V(Ki*g*d))}]2'5
Where:
D50 = characteristic riprap size of which 50 % is finer by weight
Sf = safety factor (minimum 1.1)
Cs = stability coefficient for incipient failure (0.30 for angular rock, 0.375 for rounded rock)
Cv = Velocity distribution coefficient (1.0 for straight channels and inside of bends, 1.25
downstream of concrete channels and end of dykes)
Ct = blanket thickness coefficient (typically 1.0 for flood flows)
Cg = gradation uniformity coefficient (typical range = 1.8 to 3.5)
d = local water depth
a® = unit weight of water
as = unit weight of stone (typical value of 165 lb/ft3)
V = local depth average water velocity
Ki = side slope correction factor (0.88 for 2H:1V)
g = gravitational constant
Armor stone size calculations for Lower Ley Creek are shown in Table E-5. Due to the
variation in water velocities and water depth across the creek, the medium grain size required
to withstand erosion varies per section of Lower Ley Creek.
The upstream section of Lower Ley Creek requires a median stone size of approximately 1.36
ft in diameter. The middle section of Lower Ley Creek requires a median stone size of
approximately 0.25 ft in diameter. Finally, the downstream section of Lower Ley Creek
requires a median stone size of approximately 0.12 ft in diameter. However, the downstream
section of Lower Ley Creek will not be capped under the granular material sediment cap
alternative (Alternative Sediment-3).
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4.2.2 Armor Stone Thickness for Flood Flows
Minimum layering thickness requirements for an armor stone layer vary depending on the type
of attack on the revetment. For flood flows, the minimum layer thickness is 1.5*Dso (max).
Using this calculation, the thickness of the armor layer in the upstream section of Lower Ley
Creek should be 1.5*1.36 ft = 2.04 ft thick. The thickness of the armor layer in the middle
section of Lower Ley Creek should be 1.5*0.25 ft = 0.375 ft thick.
4.2.3 Armor Stone Habitat Layer
In order to provide a clean substrate for recoIonization by bottom-dwelling organisms, a 2-ft
habitat/bioturbation layer will be placed above the armor stone layer in the Upstream and
Middle Sections of Lower Ley Creek. The habitat layer will be composed of fine sand,
although natural processes will eventually change the uppermost layer of the cap. It is likely
that portions of this habitat layer may fill the interstices of the armor stones. This is permitted
according to the EPA Contaminated Sediment Remediation Guidance for Hazardous Waste
Sites (EPA, 2007).
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5.0 REFERENCES
Chow, V.T., 1959. Open-Channel Hydraulics. McGraw-Hill.
Fetter, C. W., Jr., 1993. Contaminant Hydrogeology. Macmillan Publishing Company, New
York, 458 p.
Fryirs, K. A. and Brierley, G. J., 2012. References, in Geomorphic Analysis of River Systems:
An Approach to Reading the Landscape. John Wiley & Sons, Ltd, Chichester, UK.
doi: 10.1002/9781118305454.refs.
Marshak, S., 2007. Earth: Portrait of a Planet. W. W. Norton & Company (Third Edition),
New York. 880 pages.
Ogata, A., and Banks, R.B. 1961. A solution of the differential equation of longitudinal
dispersion in porous media. US Government Printing Office, Washington, DC.
Palermo, M., S. Maynard, J. Miller, and D. Reible, 1998. Guidance for In-Situ Subaqueous
Capping of Contaminated Sediments. USEPA 905-B96-004, Great Lakes National
Program Office, Chicago, Illinois. September.
U.S. Army Corps of Engineers (USACE), 1994. Hydraulic Design of Flood Control
Channels. EM 1110-2-1601, US Government Printing Office, Washington, D.C.
U.S. Army Corps of Engineers (USACE), 1998. Guidance for Subaqueous Dredged Material
Capping. Technical Report DOE-1, Washington, D.C. June.
U.S. Environmental Protection Agency (EPA), 2007. Contaminated Sediment Remediation
Guidance for Hazardous Waste Sites. EPA-540-R-0-/012. December.
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TABLES
-------
Table E-l
Using Manning's Equation to Estimate the most Plausible Set of River Parameters based on Observed Data
Observation
Assume Rectangle or Trapezoidal
Use Manning's Equation, adjust depth to fit Q
Hydrauli
Cross-
c
section
P wetted
Radius_(
Manning's
Energy
B_width
Side Slope
Area
Perimeter
R=A/P)_f
1.486/
A*RA2/3
Velocity_
Velocity_c
Material
n
Q_ave_cfs
Slope S
_Top_ft
Depth_Y_ft
Z
A ftA2
ft
t
n
RA(2/3)
SA(l/2)
*SAl/2
Q_try_cfs
ft/s
m/s
Upstream
Sand
0.05
45
0.0001
70
1.62
0
113.4
73.24
1.55
29.72
1.34
0.01
1.52
0.40
12
Silt and
Mid-stream
Clay
0.05
45
0.0001
100
1.30
0
130
102.6
1.27
29.72
1.17
0.01
1.52
45
0.35
11
Silt and
Downstream
Clay
0.05
45
0.0001
50
2.00
0
100
54
1.85
29.72
1.51
0.01
1.51
45
0.45
14
Table E-2
Estimate River Depth at Maximum Flow Rate (100-yr flood), and Corresponding Velocity
Maximum Flow Rate
Assume Rectangle or Trapezoidal
Use Manning's Equation, adjust depth to fit Q
Cross-
Hydraulic
section
P wetted
Radius_(
Manning's
Energy
B_width_T
Side Slope
Area
_Perimete
R=A/P)_f
1.486/
A*RA2/3
Velocity_
Velocity_c
Location
Material
n
CLcft
Slope S
op_ft
Depth_Y_ft
Z
A ftA2
r ft
t
n
RA(2/3)
SA(l/2)
*SAl/2
Q_try_cfs
ft/s
m/s
Upstream
Sand
0.05
2000
0.0001
70
18.40
0
1288
106.8
12.06
29.72
5.26
0.01
67.73
1.55
47
Silt and
Mid-stream
Clay
0.05
2000
0.0001
100
13.80
0
1380
127.6
10.82
29.72
4.89
0.01
67.49
2006
1.45
44
Silt and
Downstream
Clay
0.05
2000
0.0001
50
25.00
0
1250
100
12.50
29.72
5.39
0.01
67.33
2001
1.60
49
Tables E-l and E-2
Velocity Estimates
1 of 1
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Table E-3
Erosional Estimates Using Modified USACE Equation
S,
c\
K,
d
V
(I
Dsn
Sulci\ I'ador
Slahilil} Cocflicienl
Velocil\
Disirihulion
Coefficient
Blanket Thickness
Coefficient
(Gradation
Cocllicicnl
Side slope
Correction I'aclor
Waler Depth
(ID
Waler Velocih (li s)
I nil \\ eii»lil of
Slone (II) ll"')
I nil \Vei.!>hl of
Waler (II) ll ')
Consianl (ll s")
Median (irain Si/e
Ke(|iiired lo
Withstand ICrosion
(ll diameler)
Upstream Section of Lower Ley Creek
1.1
0.375
1.25
1
1.518
0.88
3
9.5
165
62.4
3.22E+01
1.36049
Middle Section of Lower Ley Creek
1.1
0.375
1.25
1
1.518
0.88
4
5
165
62.4
3.22E+01
0.25444
Downstream Section of Lower Ley Creek
1.1
0.375
1.25
1
1.518
0.88
10
4
165
62.4
3.22E+01
0.11583
Notes:
ft - feet
s - seconds
lb - pounds
Table E-3
Erosional Estimates Using Modified USACE Equation
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Table E-4
Isolation Layer Thickness Calculations
Calculation Sheet using One dimensional dispersion equation (Ogata and Banks, 1961)
C = CO/2 *[erfc(U) + exp(Pe)*erfc(V)]
Chemical
Cs
Toe
pb
8 or (n)
V
U
Co
a
Dw
D'
foe
Koc
Kd
z
Rr
t50
X
Transient
Model Time
C in
Porewater at
top of
isolation layer
C in sediment
at top of
isloation
layer
Vx/Rf
D/Rf
U in erfc(U) = (L-
Vx*t)/(2*(D*t)A0.5)
V in erfc(V) =
(L+Vx*t)/(2*(D*t)A0.5)
Pe =
Vx*L_/DL
[erfc(U) + exp(Pe) *
erfc(V)]/2
CPOI
(Concentrat
ion in
Underlying
Sediment)
Fraction of
organic
carbon in
sediment
material
Bulk
density of
cap
material
(1- s)*ps
Porosity
Porewater
Velocity, i.e.
Linear
Velocity (U/e)
Darcy Velocity
(or v*s)
Initial Porewater
concentration
Dispersivity
Molecular
diffusion
coefficient (at
45 F)
Diffusion/
dispersion
coefficient
Fraction of
organic carbon
in cap material
Organic
carbon
partition coeff
for organics
Observed partition
coefficient for CB
(organics=foc*
Koc,
metals=literature
value)
Chemical
Isolation Layer
Thickness
Retardation
Factor
Half
Life
Reaction Term
(=ln2/t5o)
mg/kg
g/cm3
cm/yr
cm/yr
ug/L (ppb)
cm
cm2/sec
cm2/yr
L/kg
L/kg
cm
day
yr-i
years
ppb
ug/kg
PCB
69
3.70%
1.59
0.4
250.0
100
1.350975428
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
30
5488
0
0.0
1000
1.34347
0.0456
0.0202
-1.7294
8.4007
67.5809
0.9944
69
3.70%
1.59
0.4
250.0
100
1.350975428
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
38.1
5488
0
0.0
1000
1.20856
0.0456
0.0202
-0.8288
9.3013
85.8277
0.8946
69
3.70%
1.59
0.4
250.0
100
1.350975428
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
45.72
5488
0
0.0
1000
0.69876
0.0456
0.0202
0.0185
10.1486
102.9933
0.5172
69
3.70%
1.59
0.4
250.0
100
1.350975428
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
53.34
5488
0
0.0
1000
0.16547
0.0456
0.0202
0.8657
10.9958
120.1588
0.1225
69
3.70%
1.59
0.4
250.0
100
1.350975428
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
60
5488
0
0.0
1000
0.01806
0.0456
0.0202
1.6063
11.7363
135.1618
0.0134
PCB
10
3.70%
1.59
0.4
250.0
100
0.19579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
30
5488
0
0.0
1000
0.19471
0.0456
0.0202
-1.7294
8.4007
67.5809
0.9944
10
3.70%
1.59
0.4
250.0
100
0.19579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
38.1
5488
0
0.0
1000
0.17515
0.0456
0.0202
-0.8288
9.3013
85.8277
0.8946
10
3.70%
1.59
0.4
250.0
100
0.19579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
45.72
5488
0
0.0
1000
0.10127
0.0456
0.0202
0.0185
10.1486
102.9933
0.5172
10
3.70%
1.59
0.4
250.0
100
0.19579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
53.34
5488
0
0.0
1000
0.02398
0.0456
0.0202
0.8657
10.9958
120.1588
0.1225
10
3.70%
1.59
0.4
250.0
100
0.19579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
60
5488
0
0.0
1000
0.00262
0.0456
0.0202
1.6063
11.7363
135.1618
0.0134
PCB
5.5
3.70%
1.59
0.4
250.0
100
0.107686447
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
30
5488
0
0.0
1000
0.10709
0.0456
0.0202
-1.7294
8.4007
67.5809
0.9944
5.5
3.70%
1.59
0.4
250.0
100
0.107686447
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
38.1
5488
0
0.0
1000
0.09633
0.0456
0.0202
-0.8288
9.3013
85.8277
0.8946
5.5
3.70%
1.59
0.4
250.0
100
0.107686447
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
45.72
5488
0
0.0
1000
0.05570
0.0456
0.0202
0.0185
10.1486
102.9933
0.5172
5.5
3.70%
1.59
0.4
250.0
100
0.107686447
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
53.34
5488
0
0.0
1000
0.01319
0.0456
0.0202
0.8657
10.9958
120.1588
0.1225
5.5
3.70%
1.59
0.4
250.0
100
0.107686447
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
60
5488
0
0.0
1000
0.00144
0.0456
0.0202
1.6063
11.7363
135.1618
0.0134
PCB
1
3.70%
1.59
0.4
250.0
100
0.019579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
30
5488
0
0.0
1000
0.01947
0.0456
0.0202
-1.7294
8.4007
67.5809
0.9944
1
3.70%
1.59
0.4
250.0
100
0.019579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
38.1
5488
0
0.0
1000
0.01752
0.0456
0.0202
-0.8288
9.3013
85.8277
0.8946
1
3.70%
1.59
0.4
250.0
100
0.019579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
45.72
5488
0
0.0
1000
0.01013
0.0456
0.0202
0.0185
10.1486
102.9933
0.5172
1
3.70%
1.59
0.4
250.0
100
0.019579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
53.34
5488
0
0.0
1000
0.00240
0.0456
0.0202
0.8657
10.9958
120.1588
0.1225
1
3.70%
1.59
0.4
250.0
100
0.019579354
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
60
5488
0
0.0
1000
0.00026
0.0456
0.0202
1.6063
11.7363
135.1618
0.0134
PCB
0.1
3.70%
1.59
0.4
250.0
100
0.001957935
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
30
5488
0
0.0
1000
0.00195
0.0456
0.0202
-1.7294
8.4007
67.5809
0.9944
0.1
3.70%
1.59
0.4
250.0
100
0.001957935
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
38.1
5488
0
0.0
1000
0.00175
0.0456
0.0202
-0.8288
9.3013
85.8277
0.8946
0.1
3.70%
1.59
0.4
250.0
100
0.001957935
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
45.72
5488
0
0.0
1000
0.00101
0.0456
0.0202
0.0185
10.1486
102.9933
0.5172
0.1
3.70%
1.59
0.4
250.0
100
0.001957935
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
53.34
5488
0
0.0
1000
0.00024
0.0456
0.0202
0.8657
10.9958
120.1588
0.1225
0.1
3.70%
1.59
0.4
250.0
100
0.001957935
0.0125
3.42E-06
111
0.10%
1,380,384
1,380
60
5488
0
0.0
1000
0.00003
0.0456
0.0202
1.6063
11.7363
135.1618
0.0134
Table E-4
Isolation Layer Thickness Calculations
1 of 1
-------
Table E-5
Armor Stone Size Calculations
S,
c\
c,
K,
d
V
(I
Dsn
Sulci\ Factor
Stahilil} Coefficient
Velocity
Disirihulion
Coefficient
Blanket Thickness
Coefficient
(Gradation
Cocllicicnl
Side slope
Correction Factor
Waler Depth
(ID
Waler Velocih (li s)
I nil \\ eii»lil of
Slone (II) ll"')
I nil \Vei.!>hl of
Waler (II) ll ')
Consianl (ll s")
Median Slone Size
Required lo
Withstand Krosion
(It diameter)
Upstream Section of Lower Ley Creek
1.1
0.375
1.25
1
1.518
0.88
3
9.5
165
62.4
3.22E+01
1.36049
Middle Section of Lower Ley Creek
1.1
0.375
1.25
1
1.518
0.88
4
5
165
62.4
3.22E+01
0.25444
Downstream Section of Lower Ley Creek
1.1
0.375
1.25
1
1.518
0.88
10
4
165
62.4
3.22E+01
0.11583
Notes:
ft - feet
s - seconds
lb - pounds
Table E-5
Armor Stone Size Calculations
1 of 1
------- |
|