EPA Superfund Record of Decision Amendment: Haviland Complex EPA ID: NYD980785661 OU 01 Town of Hyde Park NY 08/01/1997


EPA/AMD/R02-97/167
1997

EPA Superfund

Record of Decision Amendment:

HAVILAND COMPLEX
EPA ID: NYD980785661
OUOl

TOWN OF HYDE PARK, NY
08/01/1997

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EPA/541/R-97/167

RECORD OF DECISION AMENDMENT
Haviland Complex
Hyde Park, NEW YORK

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK, NEW YORK

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DECLARATION STATEMENT
RECORD OF DECISION AMENDMENT

SITE NAME AND LOCATION

Haviland Complex
Hyde Park, New York

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected modification to the original remedial action for
the Haviland Complex site (the Site), located in Hyde Park, New York. The original remedial
action was selected in the Record of Decision (ROD) issued by the United States Environmental
Protection Agency (EPA) on September 28, 1987.

The modification to the original remedy was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) , as
amended by the Superfund Amendments and Reauthorization Act of 198 6 (SARA), and the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). This decision document explains the
fundamental changes to the remedy previously selected for the Site.

The New York State Department of Environmental Conservation (NYSDEC) concurs with the
modification to the selected remedy. A letter of concurrence from the NYSDEC is attached to this
document (Appendix 1).

The information supporting this remedial action decision is contained in the administrative
record for the Site. The index for the administrative record is attached to this document
(Appendix 2).

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the Site, if not addressed by
implementing the response actions selected in the September 28, 1987 ROD, as revised by this
Record of Decision Amendment, may present an imminent and substantial threat to the public
health, welfare or the environment.

DESCRIPTION OF MODIFICATION TO THE SELECTED REMEDY

The modification to the selected remedy addresses the provision of a public water supply to site
residents and the extraction and treatment of contaminated groundwater within the study area.

The major components of the modification to the selected remedy include:

• Continued use of existing whole-house groundwater treatment systems on affected
residences to prevent exposure to low level groundwater contamination.

• Maintenance of filters and semi-annual monitoring of homes affected by low level
contamination present in the aquifer until three consecutive years of sampling
indicate that the well water meets Federal and State drinking water standards.

• Elimination of the public water supply system portion of the 1987 selected remedy.

• Natural attenuation of contaminants in the aquifer to below Federal and State
drinking water standards.

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Elimination of the groundwater extraction and treatment system portion of the 1987
selected remedy.

• Implementation of a groundwater monitoring program.

The remaining component of the original remedy as selected in the September 1987 ROD is not
affected by this modification. This component is:

• Removal and disposal of the contents of four septic tanks in the study area which
represent the source control portion of the remedy. This action was completed in
1990.

EXPLANATION OF FUNDAMENTAL CHANGE

This ROD Amendment describes the fundamental changes to the September 1987 ROD issued by EPA for
the Haviland Complex Superfund Site and concurred on by NYSDEC.

The remedy specified in the 1987 ROD included: the removal of the source of contamination,
i.e., contaminated septic systems (completed in 1990), the remediation of the aguifer through
extraction and treatment of contaminated groundwater and discharge to surface water, and the
provision of public water to the study area. The aguifer was to be remediated to Federal and
state drinking water standards.

The levels of contamination observed in the aguifer in 1987 have now diminished to levels near
or below Federal and State drinking water standards in both monitoring wells and affected
residential wells. As a result, the extraction and treatment of groundwater and the provision of
a public water supply system, do not need to be implemented to ensure the protection of human
health and the environment.

The modified remedy will rely on natural attenuation to reduce contaminant levels in the
groundwater to Federal and State drinking water standards; modeling indicates these standards
will be achieved in one to six years. The presently installed whole-house potable water
filtration systems will be maintained until three consecutive years of semi-annual sampling
demonstrates that the influent (untreated) water is below drinking water standards. The aguifer
will also be monitored to ensure that no other homes become impacted by site-related
contamination.

DECLARATION STATEMENT

This modification to the selected remedy is protective of human health and the environment,
complies with Federal and State reguirements that are legally applicable, or relevant and
appropriate to the remedial action, and is cost-effective. This water standards in both
monitoring wells and affected residential wells. As a result, the extraction and treatment of
groundwater and the provision of a public water supply system, do not need to be implemented to
ensure the protection of human health and the environment.

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DECLARATION STATEMENT

This modification to the selected remedy is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable, or relevant and
appropriate to the remedial action, and is cost-effective. This modified remedy utilizes
permanent solutions and alternative treatment technologies to the maximum extent practicable for
the Site.

Because the selected remedy will result in hazardous substances remaining on the Site above
health-based levels, a review will be conducted within five years after commencement of the
remedial action to ensure that the selected remedy continues to provide adequate protection of
human health and the environment.

EPA has determined that its future response at this Site does not require additional physical
construction. Therefore, the site now qualifies for inclusion on the Construction Completion
List.

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TABLE OF CONTENTS

Page

DECISION SUMMARY

I.	INTRODUCTION 	1

II.	HIGHLIGHTS OF COMMUNITY PARTICIPATION 	3

III.	REASONS FOR ISSUING THE RECORD OF DECISION AMENDMENT .4

IV.	SUMMARY OF SITE RISKS 	6

V.	DESCRIPTION OF REMEDIAL ALTERNATIVES 	9

VI.	SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 	13

VII.	SELECTED REMEDY 	20

VIII.	STATUTORY DETERMINATIONS 	20

ATTACHMENTS

APPENDIX I.	STATE LETTER OF CONCURRENCE

APPENDIX II.	ADMINISTRATIVE RECORD INDEX

APPENDIX III.	RESPONSIVENESS SUMMARY

APPENDIX IV.	1987 RECORD OF DECISION

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RECORD OF DECISION AMENDMENT SUMMARY
Haviland Complex Site
Hyde Park, New York

I. INTRODUCTION

The 275-acre Haviland Complex site consists of the Haviland Complex Apartments, the Hyde Park
Middle School, the Smith School, the Haviland Shopping Center, and approximately 35 residences
and small businesses located east of Route 9G in Hyde Park, New York. Hyde Park has an estimated
population of 21,000 people. Approximately 20% of the population are connected to a public sewer
system, and over 50% are served by a public or private water supply system. The remaining
population, including the 35 residences and small businesses previously mentioned, obtain water
from residential wells. Groundwater in the study area flows southeasterly and discharges into
Fall Kill Creek.

The Dutchess County Health Department (DCHD) began to receive complaints concerning the
groundwater quality in the site area in October 1981. A sampling program and septic system
survey of the Haviland Complex area was initiated by DCHD in December 1981, which indicated that
the Haviland Laundromat and Dry Cleaner and the Haviland Car Wash septic systems were failing.
Subsequently, the car wash installed a new septic tank and the laundromat installed a
pre-treatment system and a new tile field to handle its waste-water.

In December 1982, the New York State Department of Health (NYSDOH) began sampling the Haviland
area groundwater. The sampling data indicated that levels of tetrachloroethylene (PCE) and
dichloroethene (DCE) in the septic discharge from the laundromat exceeded New York State
Department of Environmental Conservation (NYSDEC) discharge standards. As a result, in 1983, the
laundromat was ordered to disconnect the dry cleaning operation from the septic system and to
dispose of all spent dry cleaning fluids at a permitted disposal facility. All residents in the
area were advised to use bottled water. Water treatment units were installed on the well
servicing the Haviland Complex Apartments and the laundromat in 1984 and 1985, respectively, to
remove organic contaminants. In February 1989, NYSDEC installed water treatment systems on homes
with well water which exceeded State or Federal Maximum Contaminant Levels (MCLs), i.e. safe
drinking water standards.

The site was proposed for inclusion on the National Priorities List (NPL) in October 1984, and
placed on the NPL in June 1986. NYSDEC was designated as the lead agency for the Remedial
Investigation and Feasibility Study (RI/FS).

Based on the results of the RI/FS, a Record of Decision (ROD) was signed on September 30, 1987,
identifying the following: 1) clean the contaminated septic systems identified as the source of
contamination; 2) extend public water from the nearby Harbourd Hills Water District (HHWD) to
ensure a potable supply of water to the residents on private wells (EPA would enter into an
agreement with the Town of Hyde Park to upgrade this system to meet New York State drinking
water standards); and 3) extract and treat contaminated groundwater.

The cleaning of the septic systems, which represented the source control portion of the selected
remedy, was completed by EPA on November 4, 1990. A sampling survey of the septic systems in the
study area had identified four septic tanks at the Haviland Complex and the Hyde Park Middle
School which were contaminated. These tanks were cleaned out and the sludges were sent off-site
for treatment and disposal.

Since the signing of the ROD, there has been difficulty in agreeing on the source of the
alternate water supply. On numerous occasions, Town of Hyde Park officials have requested that
EPA evaluate sources of water other than the HHWD. In its latest request, the Town proposed that

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water from the Hyde Park Fire and Water District (HPFW) be utilized. It is also noted that since
the signing of the ROD, the levels of groundwater contamination as measured in the monitoring
wells have decreased significantly. Residential well sampling data also indicate that levels of
contaminants entering impacted residential wells are decreasing. Conseguently, EPA and NYSDEC
decided to reevaluate the need for an alternate supply of public water in the Site study area
and the need for an active groundwater extraction and treatment system.

II. HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Post-Decision Proposed Plan (PDPP) for the Site was released to the public on August 26,
1996. The PDPP, along with all other Site-related documents, is available to the public at both
the administrative record and the information repository locations. A notice to announce the
public comment period on the PDPP, the public meeting to present the PDPP and the availability
of the technical documents at the repositories was published in the Poughkeepsie Journal on
August 24, 1996.

The public comment period began on August 24, 1996, and was scheduled to end on September 23,
1996. However, EPA granted a reguest to extend the comment period; the comment period closed on
October 23, 1996. A public meeting was held on September 4, 1996 at the Haviland Middle School
located in Hyde Park, New York. The purpose of the public meeting was to discuss the proposed
amendment to the September 1987 ROD.

The responses to the comments received during the public comment period as well as those
expressed verbally at the public meeting, are summarized in the Responsiveness Summary, which is
an attachment to this Record of Decision Amendment.

This Record of Decision Amendment, presents the selected remedial action for the contaminated
aguifer and contaminated residential wells at the Site, chosen in accordance with CERCLA as
amended by SARA, and, to the extent practicable, the NCP, 40 CFR Part 300. The decisions made
for the Site, is based upon the administrative record. An index for the administrative record is
included as an attachment to this document. This Record of Decision Amendment will become a part
of the administrative record file.

The administrative record file, containing the information upon which the modification to the
original remedy is based, is available at the following locations:

Hyde Park Free Library
2 Main Street
Hyde Park, NY 12538
914-229-7791

U.S. Environmental Protection Agency
290 Broadway - Records Center
New York, New York 10007-1866
212-637-4308
Hours: Monday - Friday: 9:00 a.m. to 4:30 p.m.

III. REASONS FOR ISSUING THE RECORD OF DECISION AMENDMENT

Site conditions have changed significantly since the issuance of the 1987 ROD; the sources of
contamination have been remediated, the contaminant levels in the aguifer and at the impacted
residential wells have decreased dramatically as have the risks associated with the site
contamination. The following summary explains the changed contaminant levels and site risks.

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Improvement in groundwater quality

Based on sampling data obtained from 18 monitoring wells, the RI report documented the presence
of a low-level groundwater contamination plume, consisting of numerous volatile organic
compounds (VOCs) (e.g., PCE concentration sparging from 2.0 to 42.0 parts per billion (ppb)) and
metals (e.g., lead and chromium at concentrations above drinking water standards). The
contaminants were believed to be emanating from septic systems connected to the Haviland
Shopping Center (Laundromat), Haviland Complex Apartments, and Haviland Middle School. It was
determined that the plume generally migrated from the sources in a south-southeasterly direction
and discharged into Fall Kill Creek. The RI also documented that several residential wells in
this area were contaminated with VOCs.

Since the RI report was issued, residential and monitoring wells in the study area have been
sampled on numerous occasions, and computer modeling of the groundwater regime has also been
conducted. These efforts were conducted to better define the nature and extent of groundwater
contamination, and to quantify the benefits the groundwater treatment system would provide that
would not be realized if this portion of the remedy were not implemented.

Additional sampling of the RI monitoring wells was conducted by EPA's contractor, Ebasco
Services, in October 1988 and July 1990. These sampling results were summarized in a March 1991
report entitled the "Summary of Groundwater Investigations." The report documented the presence
of a low-level volatile plume underlying the Site, flowing toward the Fall Kill Creek to the
southeast. Localized PCE, PCE-breakdown products, and chlorobenzene plumes were documented in
the southeastern portion of the main plume.

In June and November 1992, EPA's Environmental Response Team sampled the study area monitoring
wells to provide a baseline of the levels of contamination in the aquifer at that time.

Low-level VOCs above MCLs were only observed in MW-24 (8.1 ppb PCE, 6.8 ppb dichloroethene
(DCE)) and MW-27B (7.8 ppb DCE), which are located immediately upgradient and downgradient of
the affected homes. The drinking water standard for each of these contaminants is 5.0 ppb.
Although, chromium was detected above standards in two wells during the June 1992 sampling
event; the November 1992 sampling and additional results described below indicated that the
inorganic contamination was a natural artifact of the aquifer itself.

Also, in June 1994, a confirmatory round of groundwater sampling data was collected by Ebasco
which confirmed the continued presence of very low-level VOC concentrations in the shallow
aquifer underlying the Site. All volatile concentrations were close to or below the New York
State MCLs of 5 ppb for PCE, DCE, and chlorobenzene. These data indicated that the VOCs were
still present but occurred at lower concentrations than what were observed previously. Levels of
all inorganic compounds were either not detectable or were well below safe drinking water
levels. The spreading of the plume described in the RI/FS and ROD had not occurred and the plume
appears to be naturally attenuating. This information was documented by Ebasco in its September
1994 report entitled "Summary of Groundwater Investigations."

In order to monitor and maintain the effectiveness of the individual home water treatment units,
NYSDEC has contracted for the sampling of the private potable wells for organic contaminants
semiannually since 1989. NYSDOH reviews and tabulates the data, and then sends the results to
the residents. Analyses of the well samples have demonstrated the trend of diminishing organic
contamination in the aquifer. While maximum concentrations of 79 ppb of PCE, 190 ppb of
chlorobenzene, and 27 ppb of DCE, were measured in some residential wells in 1985, 1983, and
1988, respectively, the contaminant concentrations observed in all of the private wells have
diminished to levels near or below MCLs. At the September, 1996 PDPP public meeting, some
residents raised concerns that although residential wells with home water treatment units had

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been sampled frequently, other residences in the vicinity of the site had not been sampled
recently. As a result, in October 1996 NYSDOH sampled selected residential potable wells which
had not been sampled in over five years. The results of this sampling event, which were provided
to the residents in November 1996, revealed that none of their homes had been impacted by
contamination from the Site. Additional sampling of the homes with water treatment units in
January and June of 1997 further supported the trend of diminishing contaminant levels in the
aquifer. Maximum concentrations from the January 1997 sampling event of untreated water were 15
ppb of PCE and 12 ppb of chlorobenzene with no detectable concentrations of DCE or TCE. Results
from the June 1997 sampling event showed maximum concentrations of 14 ppb of PCE, 9 ppb of
chlorobenzene, 8 ppb of TCE, and 7 ppb DCE. In addition, Site-related metals contamination has
not been observed in any of the potable wells in the study area.

IV. SUMMARY OF SITE RISKS

During the conduct of the RI/FS, a baseline risk assessment was conducted to estimate the risks
associated with current and future site conditions. The baseline risk assessment, which was
based on data obtained during the RI, estimated the human health risk which could result from
the contamination at the Site, if no remedial action were taken. A summary of the baseline risk
assessment and a recalculation of the risk using current data is presented below.

Human Health Risk Assessment

The baseline risk assessment evaluated the health effects which could result from exposure to
contamination as a result of ingestion. An apartment complex, a middle school, a shopping
center, and approximately 35 private homes are contained within the site boundaries. All are
occupied and use private wells for provision of potable water.

EPA's acceptable cancer risk range is 10 -4 to 10 -6, which can be interpreted to mean that an
individual may have one in ten thousand to one in a million increased chance of developing
cancer as result of site-related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions at the Site.

The results of the baseline risk assessment conducted as part of the 1987 RI/FS indicated that,
if used as a supply of household water, the groundwater at the Site posed unacceptable risks to
human health and the environment. The risk assessment was indicative of a worst case total
lifetime exposure to maximum organic concentrations at an assumed constant rate (drinking 2
liters of water daily for 30 years in an adult living to the age of 70 years). It was determined
that the total cancer risk exceeded 1X10 -3, or 1 case in 1000. Most of this risk was due to the
presence of vinyl chloride which has not been detected since 1987. Eliminating vinyl chloride
from the risk assessment results in a calculated carcinogenic risk that is within EPA's
acceptable risk range. Using current data, and applying these data to present standards, (which
are more stringent than those of 1987), the carcinogenic risk is calculated to be 1.1 x 10 -5 ,
which is within EPA's acceptable range.

To assess the overall potential for noncarcinogenic effects posed more than one contaminant, EPA
has developed a hazard index (HI). This index measures the assumed exposures to several
chemicals simultaneously at low concentrations which could result in an adverse health effect.
When the HI exceeds one, there may be concern for potential noncarcinogenic effects.

In 1987, the concentrations all noncarcinogenic contaminants were compared with their respective
subchronic and chronic intake levels, and were found to be within acceptable intake levels.

Using current data, and applying these data to present toxicological standards (which are more
stringent than those of 1987), results in a noncarcinogenic risk Hazard Index of 1.

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It is noted that the only exposure routes to humans at the Site are through ingestion and
inhalation of VOCs via the contaminated groundwater. However, those residential wells which did
exceed MCLs have been supplied with whole-house water treatment units. Furthermore, the levels
of contamination observed in 1987 have now diminished to levels near or below MCLs in both
monitoring wells and residential Wells.

On three successive occasions, computer modeling was used to better understand the transport
fate of the groundwater contamination in the study area. The first effort, conducted as part of
the RI, concluded that groundwater flowed from the identified sources through the area of
contaminated residential wells to the Fall Kill. The second modeling event, which was conducted
by Ebasco in 1989 to determine the optimum groundwater extraction rate for implementation of the
remedy, identified declining levels of contamination in the aguifer.

The third modeling event was performed by EPA's Robert S. Kerr Environmental Research Laboratory
in 1992. This effort, which focused on determining the fate and transport of the aguifer
contamination, was documented in a report entitled "Groundwater Modeling Report for the Haviland
Complex Superfund Site." Using 1987 and 1990 data, the report concluded that site contamination
would be below MCLs within 5 to 10 years without pumping and treating the contaminated
groundwater. The modeling also predicted, however, that, if implemented, extraction and
treatment of the groundwater would result in the contamination declining to concentrations below
State and Federal drinking water standards within about the same time frame of about 5 to 10
years. Since the modeling was done in 1992, the expected range of aguifer cleanup would be
within about 1 to 6 years from today.

As a result of the significantly diminished groundwater contamination and site risks, as well as
the computer modeling effort which indicates that the active groundwater extraction and
treatment remedy called for in the 1987 ROD would not remediate the aguifer significantly more
guickly than naturally occurring processes, EPA determined that the active groundwater treatment
system was not cost-effective nor necessary to protect human health and the environment.
Similarly, due to these changing conditions it was determined that the provision of a permanent
alternate water supply was not cost-effective and that the maintenance of the existing
whole-house treatment units would provide similar levels of protection at less cost.

V. DESCRIPTION OF REMEDIAL ALTERNATIVES

CERCLA reguires that each selected site remedy be protective of human health and the
environment, be cost-effective, comply with other statutory laws, and utilize permanent
solutions and alternative treatment technologies and resource recovery alternatives to the
maximum extent practicable. In addition, the statute includes a preference for the use of
treatment as a principal element for the reduction of toxicity, mobility, or volume, of the
hazardous substances.

This ROD Amendment evaluates two alternatives for addressing groundwater contamination, namely,
Alternatives GW-1 and GW-2, and two alternatives addressing the alternate water supply
identified as AW-1 and AW-2. Consistent with ROD amendment guidance, the components of the
original remedy to be amended (Alternatives GW-2 and AW-2) have been updated and are being
compared to new preferred alternatives (Alternatives GW-1 and AW-1) which were developed based
upon existing site circumstances, including the groundwater monitoring and modeling data
presented above. It should be noted that the time to implement reflects only the time reguired
to construct, or implement the remedy and does not include the time reguired to design the
remedy, negotiate with the potentially responsible parties or procure contracts for design and
construction.

The remedial action objectives for addressing groundwater contamination are to (1) protect human

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health by ensuring residents are not exposed to contaminated groundwater, and (2), reduce
groundwater contamination levels to drinking water standards. The remedial action objective for
the alternate water provision portion of the remedy is to protect human health by ensuring
residents are not exposed to contaminated residential well water.

The alternatives for addressing the site groundwater contamination are:

Alternative GW-1 No Further Action/Natural Attenuation

Capital Cost: $0

0 & M Cost: $5000/year (for 7 years)

Present Worth Cost: $24,873
Time to Implement: 0

This alternative does not include active treatment of the aguifer; it relies upon natural
attenuation to reduce the contamination below State and Federal drinking water standards. Based
on groundwater modeling, it is estimated that natural attenuation processes would reduce levels
of contamination in the aguifer to State and Federal drinking water standards within 1 to 6
years.

This alternative would include an annual groundwater monitoring program. Five monitoring wells
located in the area would be utilized to monitor the aguifer upgradient and downgradient of the
affected homes. Analytical data obtained from these wells would serve to demonstrate the
progress of the aguifer remediation. Groundwater samples would be analyzed for inorganic and
volatile organic parameters.

Alternative GW-2 (Existing Remedy) Groundwater Extraction, Treatment, and Discharge to Surface
Waters

Capital Cost: $626,500
0 & M Cost: $116,375/year (for 7 years)

Present Worth Cost: $1,205,439
Time to Implement: One year

This alternative includes aguifer restoration through hydraulic containment and interception of
the identified contaminant plume. Interception of contaminated groundwater would be accomplished
using four stainless steel extraction wells, screened in the surficial aguifer, each pumping
continuously at 20 gpm. Proper sizing and location of these wells would result in containment of
the plume through modification of the groundwater gradient caused by the cones of depression
around each well. Small areas of the plume which are already near the Fall Kill would continue
to migrate until they enter the creek.

This alternative assumes that the extracted groundwater would reguire some treatment prior to
discharge. Treatment technology for metals removal would consist of pH adjustment and precipi-
tation. After metals treatment, the groundwater would be treated through an air stripper and
then would be discharged to the Fall Kill. Worst-case emissions from the stripper were
calculated to be insignificant in comparison to New York State standards. The design of the
groundwater treatment system would be based on the reguirements which would be the more
stringent of the effluent limitations for a class C water body or the water guality limitation
for the Fall Kill.

Groundwater extraction and treatment offers long-range public health protection against
consumption of contaminated groundwater. Based on site hydrogeologic conditions, the time
reguired to rehabilitate the aguifer to acceptable State and Federal drinking water standards is

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estimated to be within 1 to 6 years.

Aquifer rehabilitation would be accompanied by an annual groundwater monitoring program. The
sampling and analysis would utilize selected monitoring wells located in the study area.
Analytical data obtained from these wells would serve to demonstrate the progress of the aquifer
remediation. Groundwater samples would be analyzed for inorganic and volatile organic
parameters.

The alternatives identified for an alternative water supply are:

Alternative AW-1 - No Further Action/Continue to Maintain Whole-House Water Treatment Units

Capital Cost: $0
0 & M Cost: $27,053/year (for 10 years)

Present Worth Cost: $166,082
Time to Implement: 0

This alternative would continue to address the low-level contamination present in the seven
affected homes by maintaining the existing whole-house filters presently installed in these
homes. The units consist of a sediment filter, an ultra-violet treatment unit and twin
activated-carbon filtration cylinders. These homes have been sampled semi-annually by the
NYSDEC; the sampling results indicate that the units are working quite effectively and have
provided a safe reliable source of water for residential use while requiring minimal
maintenance.

Water in these seven homes would continue to be monitored on a semi-annual basis. The units
would be maintained by NYSDEC until three years of consecutive semi-annual rounds of sampling
demonstrate that the well water meets Federal and State drinking water standards indicating that
treatment will no longer be necessary.

Alternative AW-2 (Existing Remedy) - Provision of Public Water to Study Area

Capital Cost: $3,147,969
0 & M Cost: $0
Present Worth Cost: $3,147,969
Time to Implement: 18 months

This alternative provides for the extension of a local public water system into the study area.
The ROD originally envisioned that EPA would enter into an agreement with the Town of Hyde Park
to share in the costs to upgrade the Harbourd Hills Water District Well water treatment system
to meet NYSDOH standards. It is noted, however, because of residents concerns about incurring
costs associated with upgrading the HHWD treatment facilities, the Town passed a resolution
stating that the HHWD facilities not be upgraded. Furthermore, the Town of Hyde Park has
requested that the HPFW be utilized as the water source. The water distribution network would be
the same as that described in the ROD. The distribution system would be installed along the
Haviland Road and Wright Avenue, and connections would be made by EPA from this distribution
system to residences in the study area. This network would be connected to HPFW at a point
approximately one-half mile away.

VI. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

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permanence, reduction of toxicity, mobility, or volume through treatment short-term
effectiveness, Implementability, cost, and state and community acceptance.

The evaluation criteria are described below.

• Overall protection of human health and the environment addresses whether or not a
remedy provides adequate protection and describes how risks posed through each
pathway are eliminated, reduced, or controlled through treatment, engineering
controls, or institutional controls.

• Compliance with applicable or relevant and appropriate requirements (ARARs)
addresses whether or not a remedy will meet all of the applicable or relevant and
appropriate requirements of other Federal and State environmental statutes and
requirements or provide grounds for invoking a waiver.

• Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup
goals have been met.

• Reduction of toxicity, mobility, or volume through treatment is the anticipated
performance of the treatment technologies a remedy may employ.

• Short-term effectiveness addresses the period of time needed to achieve protection
and any adverse impacts on human health and the environment that may be posed during
the construction and implementation period until cleanup goals are achieved.

• Implementability is the technical and administrative feasibility of a remedy,
including the availability of materials and services needed to implement a
particular option.

• Cost includes estimated capital and operation and maintenance costs, and net present
worth costs.

• State acceptance indicates whether, based on its review of the RI/FS reports and
Post-Decision Proposed Plan, the State concurs, opposes, or has no comment on the
preferred alternative at the present time.

• Community Acceptance is assessed by reviewing the public comments received on the
RI/FS reports, during the public meetings and the Post-Decision Proposed Plan.

A comparative analysis of these alternatives based upon the evaluation criteria noted above
follows.

Groundwater Contamination

• Overall Protection of Human Health and the Environment

Both Alternatives GW-1 and GW-2 would provide full protection to human health and the
environment. Modeling predicts that the active extraction and treatment of the Site groundwater
would result in contaminant levels being reduced to State and Federal groundwater and drinking
water in 1 to 6 years. Modeling of the natural attenuation alternative also predicts that the
ARARs would be achieved in 1 to 6 years. Nonetheless, the extraction and treatment of the
groundwater under Alternative GW-2 may provide a slightly more rapid removal of contamination
from the aquifer than the natural attenuation process of Alternative GW-1. The exposure route to

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the people at the Site is through ingestion of groundwater or the inhalation of volatile
contaminants from the groundwater. Private wells which contain levels of contaminants above
drinking water standards have been fitted with individual water-treatment units, thereby
ensuring a safe supply of potable water. The levels of contaminants entering these wells has
been decreasing, and sampling of the water prior to and after treatment from these units
indicates that the units are working effectively.

• Compliance with ARARs

Both alternatives would comply with ARARs in approximately the same time frame. Modeling
predicts that the no further action/natural attenuation Alternative GW-1 and the active
groundwater extraction and treatment Alternative GW-2 would result in contaminant levels being
reduced to State and Federal groundwater and drinking water standards in 1 to 6 years.

• Long-Term Effectiveness and Permanence

Alternatives GW-1 and GW-2 would be egual in providing long-term effectiveness and permanence in
that the groundwater contamination would be reduced below State and Federal drinking water
standards within 1 to 6 years.

Alternative GW-2 would potentially result in greater long-term exposure to contaminants by
workers who could come into direct contact with the concentrated sludges from the treatment
system. However, proper health and safety precautions would be implemented to minimize exposure
to the sludges.

• Reduction in Toxicity, Mobility, or Volume Through Treatment

Under both alternatives, the volume and toxicity of the groundwater contaminants above ARARs
would be reduced at approximately the same rate and would ultimately be eliminated in
approximately the same time frame.

The mobility of the contamination plume would be reduced by actively extracting the groundwater
under Alternative GW-2. It is assumed that even with the active groundwater extraction, some
contamination would migrate into the Fall Kill, but a lesser amount than under the natural
flushing conditions of Alternative GW-1. It is noted that sampling of the Fall Kill indicates
that levels of the contaminants reaching the creek do not pose a threat to human health and the
environment.

• Short-Term Effectiveness

There would be virtually no short-term impacts on human health and the environment by continuing
to maintain the residential water treatment units under Alternative GW-1. Also, because the
residential water treatment units are already installed, no time would be required to implement
this alternative. However, construction activities associated with Alternative GW-2 (e.g.,
installation of extraction wells and underground piping, and construction of the treatment unit)
would have potentially negative impacts on residents in the study area. While efforts would be
made to minimize these impacts, some disturbances to residents would result from disruption of
traffic, excavation activities on public and private land, noise, and fugitive dust emissions.
It is estimated that the construction activities for Alternative GW-2 would take approximately
one year to complete.

• Implementability

The technologies proposed for extracting and treating contaminated groundwater in Alternative

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GW-2 are proven and reliable in achieving the specified cleanup goals, however, Alternative GW-2
would be much more complex than Alternative GW-1 to implement. The design and construction of
the groundwater extraction system would take approximately 2 years to complete. Alternative GW-2
would reguire that property be acguired/leased for the treatment unit and that access/easements
be obtained from private and public property owners for the installation of piping and
extraction wells. The operation and maintenance of the system would include the monitoring of
the aguifer for system effectiveness, monitoring of the system emissions to determine compliance
with permit eguivalencies, and the handling and disposal of the concentrated contaminated
treatment residuals.

Alternative GW-1 would be more easily implemented, as it would only reguire the sampling of
selected monitoring wells already in place once a year.

•	Cost

Alternative GW-1 has no direct costs associated with its implementation. The present worth of
this alternative of $24,873 is for implementation of an annual groundwater monitoring program.
The capital and present worth costs of Alternative GW-2 are estimated to be approximately
$625,500 and $1,205,439, respectively.

Both alternatives would provide a similar level of protection in a similar time frame however,
Alternative GW-1 would do so at a much lower cost.

•	State Acceptance

The State of New York concurs on the modified selected remedy.

•	Community Acceptance

The community generally seemed to be in favor of the modified selected remedy.

Alternate Water Supply

•	Overall Protection of Human Health and the Environment

Both Alternatives AW-1 and AW-2 would provide full protection of human health. Both alternatives
would prevent the potential exposure of residents at the Site through ingestion or inhalation of
contaminants present in selected residential wells. Data from the sampling of the impacted
residential wells has shown that the whole-house treatment units installed at these residences
are fully effective and provide sustained protection with minimal maintenance.

The provision of public water to the site area described in Alternative AW-2 would not be more
protective to the residents than what presently exists, but, would preclude the need for future
sampling of the impacted wells and maintenance of the whole-house treatment units.

•	Compliance with ARARs

Alternatives AW-1, and AW-2 would both comply with ARARs, the primary ARARs of concern being
State and Federal drinking water standards. Neither Alternative AW-1 nor AW-2 would provide a
significant advantage over the other with respect to ARARs.

Compliance with ARARs under Alternative AW-1 would be demonstrated via the home sampling and
filter maintenance program. Compliance with ARARs under Alternative AW-2 would be demonstrated

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by the water supplier via regular sampling of the water distribution system as reguired by the
State of New York.

• Long-Term Effectiveness and Permanence

Because groundwater contamination is estimated to be completely attenuated within 1 to 6 years,
Site-related contaminants would not be expected to impact the residential wells over the long
term. Therefore, both alternatives would provide long-term protectiveness and permanence.

• Reduction in Toxicity, Mobility, or Volume Through Treatment

A comparison of the two alternatives abilities to satisfy this criterion is not necessarily
applicable since the goal of the alternate water supply is to provide a potable supply of water
and does not reguire that the toxicity, mobility or volume of contaminants be reduced to do so.
Nonetheless, Alternative AW-1 would reduce the toxicity, mobility and volume of contaminants in
the residential well water, and to a limited extent the aguifer. Alternative AW-2 would not
provide any reduction of contaminants.

• Short-Term Effectiveness

There would be virtually no short-term impacts to human health and the environment by continuing
to maintain the residential water treatment units under Alternative AW-1. Also, because the
residential water treatment units are already installed, no time would be reguired to implement
this alternative. However, construction activities associated with Alternative AW-2 (e.g.,
installation of in underground water distribution system) would have potentially negative
impacts on residents in the study area. While efforts would be made to minimize these impacts,
some disturbances to residents would result from disruption of traffic, excavation activities on
public and private land, noise, and fugitive dust emissions. It is estimated that the
construction activities for Alternative AW-2 would take approximately 18 months to complete.

• Implementability

Alternative AW-2 would reguire the design and construction of a public potable water
distribution system and its connection to HPFW. The system would take approximately 18 months to
construct. The technologies necessary for implementing this alternative are proven and reliable.

The implementation of Alternative AW-1 would reguire the continued monitoring and maintenance of
the home filtration units.

• Cost

Alternative AW-1 provides a similar level of protection as Alternative AW-2 but at a much lower
cost. AW-1 has no direct capital costs associated with its implementation. The present worth
cost of AW-1 is $166,082 is based on annual costs of $27,053 per year for the semi-annual
sampling and maintenance of the whole-house treatment systems.

The total cost of Alternative AW-2 is estimated to be approximately $3,147,969. The capital cost
is based on the cost of connecting to HPFW which is estimated to be $848,969 and construction of
the distribution system which is estimated to be $2,299,000. While EPA and the NYSDEC would not
incur any operating or maintenance expenditures under Alternative AW-2, residents connected to
the system would have to pay for the water received, which is estimated to be approximately $200
to $400 per year.

State Acceptance

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The State of New York concurs on the modified selected remedy.

•	Community Acceptance

While local officials clearly favored the original remedy, Alternative AW-2 (Provision of Public
Water to the study area), residents in the area seemed to be divided in their preferences.

VII.	SEIiECTED REMEDY

Based upon an evaluation of the various alternatives, EPA and NYSDEC have determined that
Alternative GW-1, No Further Action/Natural Attenuation, and Alternative AW-1, No-Further
Action/Continue to Maintain Whole-House Filter Systems are the appropriate modified remedies for
the Site.

These alternatives provide the best balance of trade-offs among alternatives with respect to the
evaluating criteria in that they are protective of human health and the environment, comply with
ARARs, are cost-effective, and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.

VIII.	STATUTORY DETERMINATIONS

Under its legal authorities, the EPA's primary responsibility at Superfund sites is to undertake
remedial actions that achieve adeguate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other statutory reguirements and preferences
that the selected remedy must meet. Section 121 of CERCLA specifies that when complete, the
selected remedial action for the Site must comply with ARARs established under Federal and State
environmental laws unless a statutory waiver is justified. The selected remedy also must be
cost-effective and utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable. Finally, the statute includes
a preference for remedies that employ treatment that permanently and significantly reduce the
volume, toxicity, or mobility of hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory reguirements.

Protection of Human Health and the Environment:

The modified selected remedy ensures that affected residences are protected from contaminants in
the aguifer through the maintenance and monitoring of the whole house treated systems and is
fully protective of human health and the environment.

Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs):

Groundwater modeling predicts that the modified selected remedy for groundwater contamination
will achieve ARARs, specifically the Safe Drinking Water Act (SDWA) Maximum Contaminant Levels
(40CFR 141.11-141.16), 6NYCRP Groundwater Quality Regulation (Parts 703.5, 703.6, 703.7) and NYS
Sanitary Code 10 NYCR Part 5 for contaminants in drinking water within six years.

Cost-Effectiveness

The modified selected remedy is cost-effective and provides the greatest overall protectiveness
proportionate to costs.

Utilization of Permanent Solutions and Alternative Treatment Technologies (or Resource Recovery
Technologies) to the Maximum Extent Practicable:

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The modified selected remedy represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effective manner at the Site.

Preference for Treatment as a Principal Element:

The modified selected remedy utilizes point-of-use treatment of the Site groundwater. Treatment
of the aguifer-at-large is determined to not be cost-effective at this Site.

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APPENDIX 1



Concurrence Letter from the NYSDEC

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APPENDIX 2

Index for the Administrative Record

HAVILAND COMPLEX SITE
ADMINISTRATIVE RECORD FILE AMENDMENT
INDEX OF DOCUMENTS

4.0 FEASIBILITY STUDY

4.3 Proposed Plan

P. 005 0051- Plan: Superfund Post-Decision Proposed Plan,

005 0058 Haviland Complex, Hyde Park, Dutchess County, New

York, prepared by U.S. EPA, Region II, August 1996.

5.0 REMEDIAL DESIGN/REMEDIAL ACTION

5.7 Reports

P. 005 0059- Report: Haviland wells Site, Hyde Park, New York,
005 0368 Groundwater Flow and Transport Modeling Final

Report, prepared for U.S. EPA, Region II, prepared
by Ebasco Services Incorporated, September 13, 1989.

P. 005 0369- Report: Haviland Complex Wells Site, Summary

005 0400 Report of Groundwater Investigations, prepared by
Ebasco Services Incorporated, March 1991.,

P. 005 0401- Letter to Mr. Kevin Willis, Remedial Project

005 0444 Manager, U.S. EPA, Region II, from Mr. Frank A.

Cavacini, Site Manager, Ebasco Constructors Inc.,
re: ARCS II Program - EPA Contract No. 68-W8-0110,
Work Assignment No. 033-2RE5, Haviland Wells
Complex-Hyde Park, New York, Final Report,

September 23, 1991. (Attachments: Attachments 1-3)

P. 005 0445- Report: Haviland Complex Site Hyde Park, New
005 0478 York, Groundwater and Water Level Data Report,
prepared for U.S. EPA, Region II, prepared by
Environmental Response Team, Environmental
Response Branch, U.S. EPA, June 1992.

P. 005 0479- Report: Groundwater Modeling at the Haviland
005 0541 Complex Site, Hyde Park, New York, prepared by

Milovan S. Beljin, Ph.D., HydroLink, and Randall
R. Ross, EPA Robert S. Kerr Research Laboratory,
December 1992.

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P. 005 0542- Memorandum to Mr. Kevin Willis, Remedial Project
005 0649 Manager, U.S. EPA, Region II, from Royal J.

Nadeau, Ph.D., Environmental Response Team,
Environmental Response Branch, U.S. EPA, Region
II, re: Report on Groundwater Chemistry and Water
Level Determinations at Haviland Complex NPL Site
- Hyde Park, New Yotk - November Sampling, January
19, 1993.

P. 005 0650- Letter to Mr. Kevin Willis, U.S. EPA, Region II,
005 0681 from Mr. Richard Rienzo, Site Manager, Ebasco

Environmental, re: Haviland Complex Site Remedial
Design, Summary Report of Groundwater Investi-
gation, September 28, 1994. (Attachment: Haviland
Complex Wells Site,. Hyde Park, New York, Summary
Report of Groundwater Investigation, prepared by
Ebasco Services Incorporated).

10.0 PUBLIC PARTICIPATION
10.4 Public Meeting Transcripts

P. 005 0682- Public Meeting Transcript: U.S. EPA, Public

005 0796 Meeting, Haviland Complex Superfund Site, Haviland
Middle School, Hyde Park, New York, Wednesday,
September 4, 1996.

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APPENDIX 3

RESPONSIVENESS SUMMARY
HAVILAND COMPIiEX SUPERFUND SITE

INTRODUCTION

A responsiveness summary is required by Superfund regulation. It provides a summary of citizens,
comments and concerns received during the public comment period, and the United States
Environmental Protection Agency's (EPA's) and the New York State Department of Environmental
Conservation's (NYSDEC's) responses to those comments and concerns. All comments summarized in
this document have been considered in EPA's and NYSDEC's final decision for the selected remedy
for the Haviland Complex site (Site) .

SUMMARY OF COMMUNITY RELATIONS ACTIVITIES

Community involvement at the Site has been strong. EPA has served as the lead Agency for
community relations and remedial activities at the Site.

The Post-Decision Proposed Plan (PDPP) for the Site was released to the public for comment on
August 24, 1996. This document, together with the Remedial investigation/Feasibility Study
reports, two reports entitled "Summary of Groundwater Investigations," "Groundwater Modeling
Report for the Haviland Complex Site," and others were made available to the public in the
Administrative Record file at the EPA File Room in Region II, New York, in the information
repository at the Hyde Park Town Hall, Route 9, Hyde Park, New York and in the Hyde Park Free
Library, Hyde Park, New York. The notice of availability for the above-referenced documents was
published in the Poughkeepsie Journal on August 24, 1996. The public comment period,on these
documents was open from August 24, 1996 to September 23, 1996. At the public meeting, Paul
Prentice, a citizen, requested a thirty (30) day extension to the public comment period. This
extended the comment period until October 23, 1996.

EPA conducted a public meeting on September 4, 1996 at the Haviland Middle School, Hyde Park,
New York to discuss the Post-Decision Proposed Plan for the site and to provide an opportunity
for the interested parties to present oral comments and questions to EPA.

Attached to the Responsiveness Summary are the following Appendices:

Appendix A - Post-Decision Proposed Plan

Appendix B - Public Notices

Appendix C - September 4, 1996 Public Meeting Attendance Sheets
Appendix D - September 4, 1996 Public Meeting Transcript
Appendix E - Letters Submitted During the Public Comment Period
SUMMARY OF COMMENTS AND RESPONSES

Comments expressed at the September 4, 1996 public meeting and written comments received during
the public comment period have been organized as follows:

Post-Decision Proposed Plan

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Hydrogeology/Computer Model

Residential Well Sampling Data
Monitoring Well Sampling Data

Future Aguifer and Residential Well Monitoring Program
Miscellaneous

A summary of the comments and EPA's responses to the comments is provided below:
I. Post-Decision Proposed Plan

A.	Groundwater Remedy

The community generally accepted the proposed No Further Action Remedy for the Site groundwater.
For the most part, the comments raised with respect to this portion of the PDPP did not focus on
the remedy itself, but rather on the analytical results and computer modeling activities which
supported the proposed remedy; these comments are addressed in Sections II and IV below.

B.	Alternate Water Supply Remedy

Comment #1: Many commenters, particularly representatives from the Town of Hyde Park and the
local water providers/districts, expressed concern that the preferred remedy of No Further
Action did not provide a permanent solution to the problem. They expressed a preference for a
connection to a public water supply (i.e., Alternative AW-2) and indicated that it would be more
protective and would eliminate the need for groundwater monitoring.

EPA's Response: Since the issuance of the ROD, EPA has conducted several widespread groundwater
investigations of the study area to reestablish a baseline of groundwater guality data.
Monitoring data showed that the levels of contamination in the aguifer have exhibited a dramatic
decrease to the present levels near or below State and Federal drinking water standards. In
addition to groundwater monitoring of the affected homes and approximately 15 other wells in the
Site area, three successive groundwater computer modeling efforts have been conducted to predict
the future concentrations of contaminants in the aguifer. The groundwater monitoring data
support the computer modeling predictions which estimate that the contamination in the aguifer
will decrease to levels below standards in 1 to 6 years; as the sources of these contaminants
have been remediated, this decrease in contaminant concentrations will represent a permanent
reduction in contaminant levels.

Given the fact that the existing activated carbon filters reliably protect the seven serviced
residences from the Site contamination, and the fact that modeling predicts that contaminant
levels will reach drinking water standards within a few years, EPA and New York State believe
that the levels of contamination observed in the aguifer no longer warrant the implementation of
the public water supply and groundwater extraction portions of the 1987 ROD. Therefore, EPA has
decided to amend the ROD and rely on the activated carbon filters, until it is confirmed that
the levels of contaminants in the groundwater have permanently declined to levels below drinking
water standards. This approach will provide an eguivalent level of protection to the residents
at far less cost than the remedy specified in the ROD.

It should be noted that although the officials from the Town and various water districts which
serve the Town were in favor of the installation of a public water supply, it was apparent at
the public meeting that there is a difference of opinion among the local residents in their

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desire to have a public water system. EPA received only two letters, both form letters, from
residents which indicated a preference for public water. Some residents, at the meeting
indicated that they were not in favor of the public water, citing increased, costs to them and
possible elevation of the water table which could impact their residences. EPA's own
door-to-door survey of residents whose homes are supplied with carbon filters also indicated
that they were split on their desire for an alternate water supply.

Comment 2: The consulting engineer for the Harbourd Hills Water District stated that the
emphasis of the 9/6/96 presentation was centered on seven homes along Haviland Road and wanted
to know what assurances would be made to ensure the protection of other entities in the study
area, including the Haviland Middle School, and the Haviland Shopping Center and Haviland
Complex Apartments.

EPA's Response: Alternative AW-1 is considered to be fully protective of all entities currently
impacted or potentially impacted by the limited contamination present at the Site. The levels of
contamination in the plume have naturally attenuated to the present levels which are near or
below drinking water standards. Monitoring of the plume for the past 10 years has shown little
deviation from the originally determined pathway. It should be noted that any further migration
of the plume would result in further dilution of the contaminant levels in the plume.

Systems are or will be in place to ensure that each of the entities continue to have a potable
water supply. Site-related contamination has never been observed in the Haviland Middle School
water supply and none is expected to be observed in the future as the school's supply well is
located in a separate and distinct aquifer than the aquifer which supplies the affected
residents. Also, the school is required to perform annual sampling of its water supply. The
Haviland Complex has been providing potable water to its residents and businesses since 1985,
via its own water supply and its own water treatment facility, which is required to be sampled
on a quarterly basis. The sampling of both facilities is required under New York State Sanitary
Code Subpart 5-1, Public Water Systems, Public Health Law Sec. 225. The more frequent monitoring
of the Haviland Complex Supply is due to the continued presence of trace organic contamination.

Finally, the modified selected remedies require the implementation of a routine monitoring
program; homes along Haviland Road and Wright Avenue will be monitored as part of this
aquifer monitoring.

Comment 3: Numerous commmenters stated that they felt that the decision to not install the
public water system was purely economically based. One commenter acknowledged that EPA has
spent approximately $1.3 billion on environmental cleanups in New York State, but wanted to know
why such a relatively small sum as the approximately $3 million could not be spent putting in
the public water system.

EPA's Response: EPA utilizes nine criteria, one of which is cost to evaluate remedial
alternatives. Two of the nine criteria, overall protection of human health and the environment,
and compliance with applicable or relevant and appropriate requirements, must-be satisfied
before an alternative can be given further consideration; these two criteria are called the
threshold criteria. Alternatives AW-1 and AW-2 both satisfy the threshold criteria and provide
an equivalent level of protection of human health and the environment. The comparison of the two
alternatives provided in the PDPP and the Decision Summary of this ROD Amendment indicates that
they are also similar with respect to most of the other criteria, however, Alternative AW-1 is
much less expensive to implement than Alternative AW-2 and was therefore identified as EPA's
preferred alternative. Furthermore, as stated previously, EPA did try to implement Alternative
AW-2 for many years without success.

Comment 4: The Dutchess County Water and Wastewater Authority expressed their preference for the

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installation of the public water system, stating that the water pressure would be better, there
would be no need for monitoring, and that a clean water supply would be available for all.

EPA's Response: Under the Superfund program, EPA must evaluate risks posed by a site and
determine the best means of protecting human health and the environment from any risks deemed to
be unacceptable. As noted above, EPA uses nine criteria to evaluate various options for
remediating sites; in this case, the evaluation indicated that Alternative AW-1 is fully
protective of human health and the environment and provides the best balance of trade-offs with
respect to the evaluation criteria.

Comment 5: The Dutchess County Water and Wastewater Authority stated that the Hyde Park Fire and
Water System has a significant excess of capacity which is creating a financial hardship to its
district residents which would be somewhat relieved by expanding its district into the Haviland
Complex area.

EPA's Response: As mentioned previously, EPA is reguired under the Superfund statute and the NCP
to utilize nine specific criteria in evaluating remedial alternatives. As such, EPA is precluded
from considering the Dutchess County Water and Wastewater Authority's development of excess
capacity in its evaluation.

Comment 6: Two commenters stated that they were distressed as to the length of time it has taken
to come to this decision.

EPA's Response: Since the ROD was issued, efforts to implement the design of the alternate water
supply have been interrupted or delayed for a number of reasons, including some internal EPA
contractual issues. The primary reasons for delays, however, were a result of the changes in the
Town's desire as to the source of public water for the affected area. Since the ROD was signed,
different administrations have indicated a desire to use water supply sources other than the
HHWD supply wells, as well as recurring reguests to reconsider FHWD. In fact, EPA has received
eight written reguests to change the source of water since the preparation of the 1987 ROD.

These other sources included the Hyde Park Fire and Water District and the City of Poughkeepsie.

As explained in the response to comment #1, during the 10 years since the ROD has been signed,
EPA has continued to monitor groundwater guality. Because contaminant levels have decreased to
near or below drinking water standards, EPA has determined that no further remedial action is
necessary at the Site to protect human health and the environment.

Comment 7: One commenter expressed that in October 1995, the Town of Hyde Park had held a public
meeting and said that there was a firm plan to install the public water system into the study
area and was wondering why this plan was not being carried out.

EPA's Response: At that time, EPA was still intending to implement the public water supply
portion of the 1987 Record of Decision. EPA attempted for many years to implement the
installation of the public water supply, but was unable to do so for many reasons, the most
important being the freguent reguests by the Town of Hyde Park to consider various and changing
sources for the potable water. Also see EPA's response to Comment 1 for an explanation of EPA's
decision not to install the public water system.

Comment 8: One commenter was concerned with the situation where his home at 16 Haviland Road was
located between homes with State-maintained filters but his well was not augmented. He wanted to
know how his well was to be protected.

EPA's Response: All homes with potable wells where VOC contamination was detected above drinking
water standards were fitted with activated carbon filters. The well at 16 Haviland Road is

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unique relative to the other wells in that it has never been contaminated. This well is deeper
than the wells at neighboring homes and is not drawing water from the contaminant plume.

Additionally, occasional sampling of this well will continue in the future as part of the
monitoring program conducted by NYSDEC.

Comment 9: One commenter inquired as to what guarantee will be provided to the residents that
their government-installed home filters be maintained in the future.

EPA's Response: The ROD Amendment requires that EPA and NYSDEC maintain the filters until three
years of consecutive semi-annual sampling shows that contaminant levels in the affected wells
are below drinking water standards. EPA and NYSDEC could only be relieved of this obligation
through a subsequent amendment to the ROD; such an amendment would require notification of
homeowners and other parties in the area, as well as a public meeting for citizens to comment on
the proposed amendment.

Comment 10: The Harbourd Hills Water District Engineer inquired if there would be an impact to
the selected remedy if the community insisted on being connected to the Hyde Park Fire and
Water District.

EPA's Response: As noted above, EPA utilizes nine criteria to evaluate remedial alternatives,
one of which is community acceptance. EPA fully considers community opinions and concerns before
selecting or modifying a remedial action. Community acceptance was given full consideration
during this process.

II. Hydrogeology/Computer Model

Comment 11: One commenter inquired as to the accuracy of the pathways of contaminant migration
depicted as output from the computer modeling of the study area.

EPA's Response: The flow-migration pathways shown during the public meeting were produced as
part of the last computer modeling effort done by EPA in 1993. The flow lines drawn on the map
were computer-generated and were calculated utilizing water-level measurements taken on one day.
Together, they depict the general flow patterns within the aquifer.

The pathways shown approximate the path a molecule of water would likely follow in a system with
invariable conditions. The pathway would fluctuate slightly in response to changing conditions
within the aquifer (seasonal, precipitation, etc.), but would generally follow the projected
path. EPA believes that the model's projected path is reasonably reliable and accurate because
the model has been verified by comparing actual site conditions to what was generated by the
computer.

Comment 12: One commenter expressed the opinion that the number of samples collected within the
contamination plume needs to be increased to more accurately define the leading edge of the
plume.

EPA's Response: EPA believes that the number of monitoring locations is more than adequate. The
number of monitoring locations for this plume is actually greater than is typically the case for
a plume of this size and levels of contaminants.

Comment 13: A commenter expressed concern that there could be a change in the direction of
groundwater flow in the future, thus redirecting the flow of contamination into areas which
were previously uncontaminated and opening up liabilities for entities performing development.

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EPA's Response: EPA does not expect any significant change in the direction of groundwater flow.
The direction of flow has not changed significantly in the 10 years during which EPA has been
observing the groundwater contamination at the Site. In the unlikely event that the direction of
flow does change, EPA will be able to observe this change through its monitoring program and
could take appropriate action, if any were reguired.

Comment 14: One commenter wanted to know how close the modeled degradation of the contaminant
plume compared to the actual degradation of the plume.

EPA's Response: A computer model is verified by comparing the calculated results to data from
the Site. If the anticipated computer-generated numbers correspond with actual field conditions,
the model is considered to be accurate.

The results of the computer modeling were compared to the data gathered from potable and
monitoring wells. The contamination in the aguifer appears to be attenuating at a more rapid
rate than was anticipated by the computer model. EPA has continued to use the time frames
described by the computer model, as a conservative means of predicting the attenuation of the
plume.

Comment 15: One commenter referred to Figure 20 in the December 1992 report "Groundwater
Modeling at the Haviland Complex Site, Hyde Park, NY" noting the following statement, "Figure 20
indicates that even after 10 years, concentration levels of Tetrachloroethene will not decrease
below 10 ppb level" and asked if EPA believed in this computer prediction.

EPA's Response: As is often the case in modeling efforts, several retardation factors were
evaluated. The retardation factor used in Figure 20 was more conservative than others used in
the same modeling effort. Conseguently, this retardation factor predicted higher levels of
residual contamination than were predicted when using the other less conservative retardation
factors. The text from which the commenter extracted the guote continues on to describe the
relation of the retardation factors used in the modeling effort: "If the value of the
retardation factor was reduced to a more reasonable factor of 6, after 10 years the
concentration of Tetrachloroethene would significantly decrease (figures 24 through 26)". The
data gathered since the modeling effort indicates that the contamination in the aguifer is
attenuating at an even more rapid rate than was projected by the model and that retardation
factors utilized to generate figures 24 through 2 6 are more representative of actual conditions
than the retardation factors used to generate figure 20. Data collected from the potable well
water also supports and confirms the model's accuracy.

III. Residential Well Sampling Data

Comment 16: One commenter inguired if the data used in determining the trends of contaminant
concentrations in the residential well samples were from filtered or unfiltered samples.

EPA's Response: All of the residential well data used in determining the trends were of water
collected prior to, or upstream of, home filtration units.

Comment 17: Numerous commenters expressed concern with the fluctuations of contaminant
concentrations in the raw (pre-filtered) potable water samples.

EPA's Response: Fluctuations of the magnitude observed in the semi-annual residential well
sampling data are not unusual. This variation is due to the dynamic conditions which occur in an
aguifer, such as seasonal changes or annual rainfall differences.

Although minor fluctuations have occurred, the sampling results from 1987 to date indicate that

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the concentrations of contaminants in the study-area aquifer have dropped by an order-of-
magnitude to concentrations near or below drinking water standards. Given this significant
decrease in contaminant concentrations, and the fact that the sources of contamination have been
addressed, EPA feels confident that this trend will continue, and that a significant increase in
contaminant levels will not be observed in the future.

Comment 18: A commenter raised concern that the homes along the western end of Haviland Road
weren't tested between 1990 and 1992.

EPA's Response: NYSDOH sampled potable wells along the western end of Haviland Road in October
1996 and confirmed that there is no Site-related contamination in this area. This study
confirmed the results of the last comprehensive study in the Site area conducted by NYSDOH in
1993. The outcome of that effort showed no Site-related contamination. Additional sampling of
these wells will be performed by NYSDOH in mid-1997.

Comment 19: Three commenters raised the concern that the Haviland Middle School water supply
well may be contaminated by Site-related contamination.

EPA's Response: The Haviland Middle School maintains its own potable water supply well and
samples this well on an annual basis in accordance with New York State requirements. This well
has never shown any indication of Site-related contamination. It is important to note that
unlike the shallow wells in homes along Haviland Road which have been impacted by contamination
in the shallow aquifer, the Middle School well is a very deep bedrock well which draws water
from a different aquifer than the aquifer utilized by the homes along Haviland Road.

Comment 20: The Dutchess County Water and Wastewater Authority expressed concern that the
fluctuations in the potable well sampling results may have impacted the reliability of the
computer modeling effort.

EPA's Response: The fluctuations in semi-annual sampling data for the residential wells are not
unusual. The general trend of the contaminant levels in the aquifer is a more accurate indicator
of the fate of contaminants in the aquifer. Computer modeling is used to predict a future trend
given an initial set of conditions. Field data are collected and compared to the predicted
trends in order to verify the model. The minor fluctuations in the home sampling data have no
impact on the reliability of the computer model.

Comment 21: One commenter inquired as to why the graphs of residential well data presented at
the meeting on September 4, 1996 were more recent than those published in the August 1996
report.

EPA's Response: The graphs presented at the public meeting did contain some new information. New
York State monitors the affected residential wells on a semi-annual basis, typically every
January and July. The week before the September 1996 public meeting, EPA received data from the
July 1996 sampling of the residential wells. In order to make the latest information available
to the public, EPA incorporated these data into its presentation that evening. These latest data
represent a small addition to the previously existing data compiled from twelve rounds of
sampling over six years, and are important in that they confirm the continuing decline of
volatile organic contaminants in the groundwater underlying the Site.

IV. Groundwater Monitoring Well Data

Comment 22: A commenter expressed concern that EPA has apparently discontinued the sampling of
some of the monitoring wells in the study area.

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EPA's Response: EPA has only discontinued sampling of those monitoring wells which are no longer
suitable for sampling; most of these wells were damaged by vehicles. During the development of
the monitoring plan for the Site, EPA will assure that the aquifer is sampled in appropriate
locations. If the integrity of a well has been compromised at any of these locations, or if a
well was never present in one of these locations, new monitoring wells will be constructed in
these locations. Any compromised wells will be appropriately decommissioned at that time.

Comment 23: The Harbourd Hills Water District Engineer inquired as to the status of VOC
contamination in the remainder of the study area aquifer outside of the plume.

EPA's Response: Only one well outside of the defined plume has shown groundwater VOC
contamination above drinking water standards; this well is located immediately north of the
affected homes (MW-24). MW-24 showed contamination decreasing to near or below drinking water
standards up until the time the well was destroyed in the winter of 1992-1993. A replacement
well will be installed at an appropriate location immediately upgradient of the effected homes
as part of the future monitoring program.

Comment 24: Three commenters expressed concern that levels of chromium and nickel detected in
1992 were in excess of NYSDEC standards and wanted to know how EPA had addressed this
contamination.

EPA's Response: In an effort to reestablish a baseline of groundwater Vality data at the Site,
EPA sampled existing monitoring wells in June 1992 and observed elevated levels of inorganic
constituents in two wells in the aquifer immediately south of the Middle School. EPA had
requested that the New York State Department of Health (NYSDOH) sample local residential wells
to assure that there was no human exposure to these metals. NYSDOH sampling of the residential
wells showed that there were no Site-related elevated levels of inorganic contamination in these
residential wells. EPA resampled the monitoring wells in November 1992 and the results indicated
that the inorganic contamination was a natural artifact of the aquifer itself. In June 1994, a
comprehensive sampling of monitoring wells was conducted by EPA's contractor Ebasco, Inc.
utilizing state-of-the-art sampling techniques (low-flow environmental sampling pumps to
minimize induced turbidity). The results from this investigation were documented in the
September 1994 "Summary Report of Groundwater Investigations," and indicated that the levels of
all inorganic compounds in the groundwater were either not detectable or were below safe
drinking water levels. This study again determined that the metals previously detected in the
1992 study were related to naturally occurring substances which were mobilized into the
groundwater by the agitation from the sampling method. This report is available in the Site
repository established at the local library.

V. Future Aquifer and Residential Monitoring Program

Comment 25: Commenters inquired about the scope of the monitoring program; one commenter wanted
to know if all the homes in the study area would be sampled prior to the delisting of the Site
in the future.

EPA's Response: NYSDOH has agreed to conduct a comprehensive sampling of homes throughout the
study area in the near future. In addition, EPA and the State have already initiated discussions
regarding the scope of the monitoring program and expect that this plan will be completed in the
next few months. As indicated in the PDPP, the seven residences which have whole-house treatment
units will be sampled on a semi-annual basis, until each round of sampling results over the
course of three years indicates that all Site-related contaminants are below federal and State
drinking water standards. Additional residential wells in the area will be monitored on a less
frequent basis. A series of monitoring wells, some of which are existing and some which may be
added as necessary to provide adequate information on the fate of contaminants in the aquifer,
will also be sampled on an annual basis.

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Comment 26: Two commenters inquired as to what would happen if contamination was released into
the aquifer in the future. They insisted that the residential wells are vulnerable to
contamination from future releases.

EPA's Response: As a result the elimination of the oriqinal discharqes of hazardous substances
to the aquifer, as well as EPA's 1990 remediation of the septic systems (these septic systems
served'as a continuinq source of contamination of the aquifer) the levels of contamination in
the aquifer have declined to close to drinkinq water standards. EPA has no reason to believe
that the Site-related contaminant levels will increase in the future; however, if additional
Site-related contamination were observed, EPA could install additional whole-house treatment
units or move forward with additional investiqation of the contamination, or if necessary, amend
the ROD to allow for alternative remedial measures.

If non-Site related contamination were observed, for example oriqinatinq from a residential
septic system, EPA would work with the other appropriate qovernment aqencies such as the NYSDOH,
NYSDEC or the County Health Department to determine the most appropriate course of action.

VI. Miscellaneous

Comment 27; One commenter wanted to know if the "Haviland Complex Site" will be reduced in size
considerinq that the contamination appears to be isolated to the southeastern quadrant of the
study area.

EPA's Response: Althouqh EPA is capable of deletinq portions of sites, EPA has no current plans
to do so at this site. Due to the characteristics of this site, it is likely that the Site would
be deleted in its entirety, rather than in a piecemeal fashion.

Comment 28: A commenter inquired if EPA was tryinq to recover its expenditures from the
Potentially Responsible Parties (PRPs) and whether a settlement was beinq souqht with the school
district and its qoverninq State aqencies.

EPA's Response: EPA is attemptinq to recover its expenditures at the Site from the PRPs who own
the Haviland Complex. EPA had issued notice letters to the PRPs at the Site offerinq them the
opportunity to implement the remedies specified in the 1987 ROD; the PRPs declined this offer.
As is the case on most sites where PRPs decline to implement remedial activities, EPA is
attemptinq to reach a settlement with the PRPs for recovery of the Aqency's past costs by
enqaqinq in settlement discussions whereby the PRPs would voluntarily offer to reimburse EPA. It
is anticipated that these neqotiations will come to closure in the near future. If the
settlement neqotiations fail, EPA is prepared to refer the case to the U.S. Department of
Justice for litiqation.

EPA is not currently seekinq a settlement with the school district.

Comment 29: One commenter stated that the Harbourd Hills Water District has spent in excess of
$29,000 because of EPA involvement at the Haviland Site which would not have otherwise been
spent and inquired about reimbursement.

EPA's Response: EPA acknowledqes that HHWD may have expended as much as $29,000 durinq the last
few years of this project. Because of the difficulty in selectinq the water source, EPA has also
utilized considerable resources in an attempt to implement the public water supply portion of
the ROD. As discussed previously, however, we believe that siqnificant additional funds will not
be required to ensure that the residents have a potable supply of water.

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EPA cannot reimburse Harbourd Hills for its past expenditures because such costs are not
reimbursable under the Superfund statute.

Comment 30: The Harbourd Hills Water District Engineer asked for an accounting for the funding
spent at the Haviland Site.

EPA's Response: Approximately $2.1 million has been expended at the Site. Over $1.4 million was
expended for the following contracted services: the RI/FS; the design and implementation of the
septic tank cleanout and associated site restoration; the preliminary design for the provision
of a public water supply; and groundwater sampling, analysis, and modeling, and associated
reports. In addition, over $600,000 was expended for EPA services including payroll, groundwater
sampling, analysis, and modeling, NYSDEC oversight, and indirect costs.

Comment 31: One commenter expressed concern that the public comment period started on August 24,
1996 for a report that was not available until two days later on August 26, 1996.

EPA's Response: EPA had expected to have the PDPP available to the public on August 24. During
the public meeting, EPA acknowledged that the PDPP was not available in the Town Hall until
Monday, August 26. EPA considered this in the Agency's decision to extend the public comment
period an additional 30 days, allowing sixty days in all for public comment.

Comment 32: A commenter wanted to know why all of the appropriate documents were not available
at the designated repository (Hyde Park Free Library).

EPA's Response: Following the public meeting, EPA contacted the library and was informed that
most of the information was in the repository with the exception of a few documents; EPA
forwarded the additional documents and confirmed that they were received by September 20, 1996.
The fact that these documents were not available at an earlier date was considered by EPA in its
decision to extend the public comment period an additional 30 days to October 23, 1996.

Comment 33: One commenter was-concerned with the fact that the notice of the 9/4/96 public
meeting which was published in the Poughkeepsie Journal was placed in the middle of the sports
section.

EPA's Response: EPA cannot always control the location of its newspaper notices. EPA had, in
fact, reguested that the Public Notice be put in the front section of the newspaper.
Unfortunately, the notice did not appear in EPA's preferred location, and there was insufficient
time to meet the newspaper's deadline for republication prior to the public meeting. It should
be noted that EPA used other mechanisms to make the community aware of the comment period and
meeting date including a press release, and mailing notices to each addressee on EPA's extensive
mailing list for the Site.

Comment 34: A commenter wanted to know if a ROD expires.

EPA's Response: A ROD does not expire. A ROD describes the remedial activities reguired to be
performed at a Site in order to protect human health and the environment. These activities must
be implemented unless it is documented through a ROD amendment that the actions are no longer
necessary to protect human health and the environment, or that other measures are more
appropriate to achieving protection of human health and the environment.

Comment 35: A commenter inguired as to the source of the information stated on page 5 of the
PDPP - "...the Town recently passed a resolution stating that the Harbourd Hills Water District
facilities not be upgraded."

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EPA's Response: Although the October 13, 1995 Town Resolution (10:13-1) did not specifically
state that HHWD facilities should not be upgraded, it is implied as the following excerpt from
the resolution indicates:

"...Whereas, the upgrade to the Harbourd Hills Water
District needed to supply potable water to the Haviland
Complex will result in an undue financial burden on the
residents of the Harbourd Hills Water District" and,

"Therefore, be it resolved, that this Board urgently
reguests that the United States Environmental Protection
Agency immediately proceed with the design and construction
of the water mains and appurtenances needed to provide a
reliable, potable water supply to the Haviland Complex a
connection to the Hyde Park Fire and Water District."

Comment 36: A commenter inguired if the NYSDOH and NYSDEC both concurred with the PDPP.

EPA's Response: NYSDEC and NYSDOH had reviewed and concurred with the PDPP prior to its,release
to the public. The first paragraph of the PDPP indicates that NYSDEC concurred on the PDPP; the
last page of the PDPP indicates that the State of New York concurs on the proposed modified
remedy. During the public meeting Geoff Lacetti, a representative from NYSDOH, reiterated
NYSDOH's concurrence with the PDPP.

Comment 37: The Harbourd Hills Water District Engineer inguired as to what economic impact the
"site" designation has upon properties within the study area.

EPA's Response: While EPA does not have information as to the specific impact the designation of
a Superfund site has had on the community, in general, the value of property in the vicinity of
many Superfund sites depreciates prior to site remediation. Fortunately, the elimination and
remediation of the sources of contamination at the Haviland Complex Site has resulted in levels
of contaminants declining to levels which approach drinking water standards; modeling predicts
that all contaminant levels will meet drinking water standards within 1 to 6 years. As a result,
EPA will also be able to move forward with the deletion of the Site from the NPL in the next few
years. The fact that EPA and NYSDEC are specifying in this ROD amendment that no further
remedial action is warranted at the Site, and that the Site should be deleted in the next few
years should have a positive impact in restoring property values, assuming they had been
affected.

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PURPOSE OF POST-DECISION PROPOSED PLAN

This Post-Decision Proposed Plan describes proposed fundamental changes to the September 1987
Record of Decision (ROD) issued by the United States Environmental Protection Agency (EPA) with
respect to the Haviland Complex Superfund Site and concurred and by the New York State
Department of Environmental Conservation (NYSDEC).

The remedy specified in the 1987 ROD included the removal of the source of contamination, i.e.,
contaminated septic systems, extraction and treatment of contaminated groundwater and the
provision of public water to the study area. The source control portion of the remedy was
completed in 1990.

As described in this Post-Decision Proposed Plan, EPA is proposing that the extraction and
treatment of groundwater, and the provision of a public water system do not need to be
implemented to ensure the protection of human health and the environment

COMMUNITY ROLE IN SELECTION PROCESS

EPA and NYSDEC rely on public input to ensure that the concerns of the community are considered
in selecting an effective remedy for each Superfund site. Similarly, EPA and NYSDEC also rely on
public input when proposing fundamental changes to a remedy previously selected. To this end,
this Post-Decision Proposed Plan, the EPA Groundwater Modeling Report for the Haviland Complex
Superfund Site, and the May 1995 Summary of Groundwater Investigations Report have been made
available to the public for a public comment period which begins on August 16, 1996 and
concludes on September 16, 1996.

A public meeting will be held during the public comment period at the Haviland Middle School on
August 28, 1996 at 7:00 PM to present the basis for the proposed amendment to the ROD and to
receive public comments.



Comments received at the public meeting, as well as written comments, will be documented and
addressed in the Responsiveness Summary Section of the ROD amendment

All written comments should be addressed to:

Kevin Willis

U.S. Environmental Protection Agency
290 Broadway 20th Floor
New York, NY 10007-1866

Dates to remember:

MARK YOUR CALENDAR

August 24, 1996 - September 23, 1996

Public comment period on this Post-Decision Proposed
Plan, and remedies considered

September 4,1996

Public meeting at the Haviland Middle School at 7:00 PM

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SITE BACKGROUND

The 275-acre Haviland Complex site (see Figure 1) consists of the Haviland Complex Apartments,
the Hyde Park Junior High School, the Smith School, the Haviland Shopping Center, and
approximately 35 residences and small businesses located east of Route 9G in Hyde Park, New
York. Hyde Park has an estimated population of 21,000 people. Approximately 20% of the
population are connected to a public sewer system, and over 50% are served by a public or
private water supply system. The remaining population, including the 35 residences and small
businesses previously mentioned, obtain water from residential wells. Groundwater in the study
area flows southeasterly and discharges into Fall Kill Creek.

The Dutchess County Health Department (DCHD) began to receive complaints concerning the
groundwater quality in the site area in October 1981. A sampling program and septic system
survey of the Haviland Complex area was initiated by DCHD in December 1981, which indicated that
the Haviland Laundromat and Dry Cleaner and the Haviland Car Wash septic systems were failing.
Subsequently, the car wash installed a new septic tank and the laundromat installed a pre-
treatment system and a new tile field to handle its waste-water.

In December 1982, New York State Department of Health (NYSDOH) began sampling the Haviland area
groundwater. The sampling data indicated that levels of tetrachloroethylene (PCE) and
dichloroethene (DCE) in the septic discharge from the laundromat exceeded NYSDEC discharge
standards. As a result in 1983, the laundromat was ordered to disconnect the dry cleaning
operation from the septic system end to dispose of all spent dry cleaning fluids at a permitted
disposal facility. All residents in the area were advised to use bottled water. Water treatment
units were installed on the wells servicing the Haviland Apartments and the laundromat in 1984
and 1985, respectively, to remove organic contaminants. In February 1989, NYSDEC installed
water treatment systems off homes with wall water which exceeded State or Federal Maximum
Contaminant Levels (MCLs), i.e., safe drinking water standards.

The site was proposed for inclusion on the National Priorities List (NPL) in October 1984, and
placed on the NPL in June 1986. NYSDEC was designated as the lead agency for the Remedial
Investigation and Feasibility Study (RI/FS).

Based on the results of the RI/FS, a ROD was signed on September 30, 1987, identifying the
following: 1) clean the contaminated septic systems identified as the source of contamination 2)
extend public water from the nearby Harbourd Hills Water District (HHWD) to ensure a potable
supply of water to the residents on private wells (EPA would enter into an agreement with the
Town of Hyde Park to upgrade this system to meet New York State drinking water standards) and 3)
extract and treat contaminated ground water.

The septic systems' cleaning, which represented the source control portion of the selected
remedy, was completed by EPA on November 4, 1990. A sampling survey of the septic systems in the
study area had identified six septic tanks at the Haviland Complex and the Hyde Park Junior High
School which were contaminated. These tanks were cleaned out and the sludges were sent off-site
for treatment and disposal.

Since the signing of the ROD, there has been difficulty in agreeing on the source of the
alternate water supply. On numerous occasions, Town of Hyde Park officials have requested that
EPA evaluate sources of water other than the HHWD. Most recently, the Town requested that water
from the Hyde Park Fire and Water water district (HPFW) be utilized. It is also noted that since
the signing of the ROD, the levels of groundwater contamination as measured in the monitoring
wells have decreased significantly. Residential well sampling date also indicates that levels of
contaminants entering impacted residential wells are decreasing. It was determined that
additional sampling and modeling of the groundwater regime was warranted. Consequently, EPA and

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NYSDEC decided to reevaluate the need for an alternate supply of public water in the site study
area and the need for an active groundwater extraction and treatment system.

SUMMARY OF SITE INVESTIGATIONS

Based an sampling data obtained from 18 monitoring wells the RI report documented the presence
of a low-level groundwater contamination plume, consisting of numerous volatile organic
compounds (VOCs) (e.g., PCE concentrations ranging from 2.0 to 42.0 parts per billion (ppb)) and
metals (e.g., at concentrations above drinking water standards). The contaminants were believed
to be emanating from septic system connected to the Haviland Shopping Center (Laundromat),
Haviland Complex Apartments, and Haviland Junior High School. It was determined that the plume
generally migrated from the sources in a south-southeasterly direction and discharged into Fall
Kill Creek. The RI also documented that several residential wells in this area were contaminated
with VOCs.

Since the RI report was issued, residential and monitoring wells in the study area have been
sampled on numerous occasions, and computer modeling of the groundwater regime has also been
conducted. These efforts were conducted to better define the nature and extent of groundwater
contamination, and to guantify the benefits the groundwater treatment system would provide that
would not be realized, if this portion of the remedy were not implemented.

Additional sampling of the RI monitoring wells was conducted by EPA's contractor, Ebasco
Services, in October 1988 and July 1990. These sampling results were summarized in a March 1991
report entitled the "Summary of Groundwater Investigations". The report documented the presence
of a low-level volatile plume underlying the site, flowing toward the Fall Kill Creek to the
southeast. Localized PCE, PCE-breakdown products, and chlorobenzene plumes were documented in
the southeastern portion of the main plume.

In 1992, EPA's Environmental Response Team sampled the study area monitoring wells on two
additional occasions to provide a baseline of the levels of contamination in the aguifer at that
time. Low-level VOCs above MCLs were only observed in MW-24 (8.1 ppb PCE, 6.8 ppb dichloroethene
(DCE))and MW-27B (7.8 ppb DCE). The drinking water standard for each of these contaminants is
5.0 ppb. Also, in June 1994, a confirmatory round of groundwater sampling data was collected by
Ebasco which confirmed the continued presence of very low level VOC concentrations in the
shallow aguifer underlying the site. All volatile concentrations were close to or below the New
York State MCLs of 5 ppb for PCE, DCE, and chlorobenzene. These data indicated that the VOCs
were still present but occurred at lower concentrations than what were observed previously. The
occurrence of the spreading of the plume described in the RI/FS and ROD had not occurred and the
plume appears to be naturally attenuating. This information was documented by Ebasco in its
September 1994 report entitled "Summary of Groundwater Investigations."

On three successive occasions, computer modeling was used to better understand the transport and
fate of the groundwater contamination in the study area. The first effort, conducted as part of
the RI, concluded that groundwater flowed from the identified sources through the area of
contaminated residential wells to the Fall Kill. The second modeling event which was conducted
by Ebasco in 1989 to determine the optimum groundwater extraction rate for implementation of the
remedy, identified declining levels of contamination in the aguifer.

The third modeling event was performed by EPA's Robert S. Kerr Environmental Research Laboratory
in 1992. This effort, which focused an determining the fate and transport of the aguifer
contamination, was documented in a report entitled "Groundwater Modeling Report for the Haviland
Complex Superfund Site." Using 1987 and 1990 data, the report concluded that site contamination
would be below MCLs within 5 to 10 years without pumping and treating the contaminated
groundwater. The modeling also predicted, however, that if implemented, extraction and treatment

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of the groundwater would result in the contamination declining to concentrations below State and
Federal drinking water standards within the same time frame of about 5 to 10 years. Since the
modeling was done in 1992, the expected range of aguifer cleanup would be within about 2 to 7
years from today.

In order to monitor and maintain the effectiveness of the individual home water treatment units,
NYSDEC has contracted the sampling of the private potable wells for organic contaminants
semiannually since 1989. NYSDOH reviews and tabulates the data, and then sends the results
to the residents. Analyses of the well samples have demonstrated the trend of diminishing
organic contamination in the aguifer. While maximum concentrations of 79 ppb of PCE, 190 ppb of
chlorobenzene, and 27 ppb of DCE, were measured in some residential wells in 1985, 1983, and
1988, respectively, the contaminant concentrations observed in all of the private wells have
diminished to levels near or below MCLs. The residential well data from 1990 to the present are
summarized in Figure 2. Maximum concentrations from the January 1996 sampling event were 15 ppb
of PCE and 12 ppb of chlorobenzene with no detectable concentrations of DCE. In addition,
site-related metals contamination has not been observed in any of the potable wells in the study
area.

SUMMARY OF SITE RISK

During the conduct of the RI/FS, a baseline risk assessment was conducted to estimate the risks
associated with current and future site conditions. The baseline risk assessment which was based
on data obtained during the RI, estimated the human health risk which could result from the
contamination at the site if no remedial action were taken. A summary of the baseline risk
assessment and a recalculation of the risk using current data is presented below.

Human Health Risk Assessment

The baseline risk assessment evaluated the health effects which could result from exposure to
contamination as a result of ingestion. An apartment complex, a junior high school, a shopping
center, and approximately 35 private homes are contained within the site boundaries. All are
occupied and use private wells for provision of potable water.

EPA's acceptable cancer risk range is 10 -4 to 10 -6, which can be interpreted to mean that an
individual may have one in ten thousand to one in a million increased chance of developing
cancer as result of site-related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions at the site.

The results of the baseline risk assessment conducted as part of the 1987 RI/FS indicated that,
if used as a supply of household water, the groundwater at the site posed unacceptable risks to
human health and the environment. The risk assessment was indicative of a worst case total
lifetime exposure to maximum organic concentrations at an assumed constant rate (drinking 2
liters of water daily for 30 years in an adult living to the age of 70 years). It was determined
that the total cancer risk exceeded 1x10 -3, or 1 case in 1000. Most of this risk was due to the
presence of vinyl chloride which has not been detected since 1987. Eliminating vinyl chloride
from the risk assessment results in a calculated carcinogenic risk that is within EPA's
acceptable risk range. Using current data, and applying these data to present standards (which
are more stringent than those of 1987), the carcinogenic risk is calculated to be 1.1X10 -5,
which is within EPA's acceptable range.

To assess the overall potential for noncarcinogenic effects posed by more than one contaminant,
EPA has developed a hazard index (HI). This index measures the assumed exposures to several
chemicals simultaneously at low concentrations which could result in an adverse health effect.
When the HI exceeds one, there may be concern for potential noncarcinogenic effects.

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All noncarcinogenic contaminants were within acceptable intake levels in 1987, based on their
respective subchronic and chronic intakes. Using current data, and applying these data to
present standards (which are more stringent than those of 1987), results in a noncarcinogenic
risk Hazard Index of 1.

It is noted that the only exposure routes to humans at the site are through ingestion and
inhalation of VOCs via the contaminated groundwater. However, those residences which did exceed
MCLs have been supplied with wholehouse water treatment units. Furthermore, the levels of
contamination observed in 1987 have now diminished to levels near or below MCLs in both
monitoring wells and residential wells.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment. These
objectives are based on available information and standards such as applicable or relevant and
appropriate reguirements (ARARs) and risk-based levels established in the risk assessment.

The objective of the feasibility study was to identify and evaluate a cost-effective remedial
action alternative which would minimize the risk to public health and the environment resulting
from groundwater contamination at the site. The FS report had evaluated in detail 5 remedial
alternatives for addressing the contamination associated with the site. The remedy which EPA
selected included contaminant source control, provision of public water to the site area, and
extraction and treatment of contaminated groundwater. As noted above, the source control portion
of the remedy was completed in January 1990.

Given the decrease in site-related groundwater contaminant levels, EPA has decided to reevaluate
components of the remedy specified in the 1987 ROD. This Post-Decision Proposed Plan addresses
the groundwater extraction and treatment and the provision of an alternate water supply portions
of the remedy. The remedial action objectives for the groundwater remedy are to (1) protect
human health by ensuring residents are not exposed to contaminated groundwater, and (2) reduce
groundwater contamination levels to drinking water standards. The remedial action objective for
the alternate water provision portion of the remedy is to protect human health by ensuring
residents are not exposed to contaminated residential well water.

SUMMARY OF REMEDIAL ALTERNATIVES

CERCLA reguires that each selected site remedy be protective of human health and the
environment, be cost-effective, comply with other statutory laws, and utilize permanent
solutions and alternative treatment technologies and resource recovery alternatives to the
maximum extent practicable. In addition, the statute includes a preference for the use of
treatment as a principal element for the reduction of toxicity, mobility, or volume of the
hazardous substances.

The alternatives for addressing groundwater contamination are provided below and are identified
as GW-1 and GW-2. These alternatives are followed by the alternate water supply alternatives
which are identified as AW-1 and AW-2. Consistent with ROD amendment guidance, the components
of the original remedy proposed for amendment (alternatives GW-2 and AW-2) have been updated and
are being compared to new preferred alternatives (alternatives GW-1 and AW-1) which were
developed based upon existing site circumstances, including the groundwater monitoring and
modeling data presented above. It should be noted that the time to implement reflects only the
time reguired to construct, or implement the remedy and does not include the time reguired to
design the remedy, negotiate with the responsible parties, or procure contracts for design and
construction.

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The alternatives developed for the site groundwater (GW) are:

Alternative GW-1 - No further action/natural attenuation
Capital Cost: $0

0 & M Cost: $5000/year (for 7 years)

Present Worth Cost: $24,873
Time to Implement: immediate

This alternative does not include active treatment of the aquifer, it relies upon natural
attenuation to reduce the contamination below State and Federal drinking water standards. Based
on groundwater modeling it is estimated that natural attenuation processes would reduce levels
of contamination in the aquifer to State and Federal drinking water standards within 2 to 7
years.

This alternative would include an annual groundwater monitoring program. Five monitoring wells
located in the area would be utilized to monitor the aquifer upgradient and downgradient of the
affected homes. Analytical data obtained from these wells would serve to demonstrate the
progress of the aquifer remediation. Groundwater samples would be analyzed for inorganic and
volatile organic parameters.

Alternative GW-2 - Groundwater extraction, treatment, and discharge to surface waters
Capital Cost: $626,500

0 & M Cost: $116,375/year (for 7 years)

Present Worth Cost: $1,205,489
Time to Implement: One year

This alternative includes aquifer restoration through containment and interception of the
identified contaminant plume. Interception of contaminated groundwater would be accomplished
using four stainless steel extraction wells, screened in the surficial aquifer, each pumping
continuously at 20 gpm. Proper sizing and location of these wells wouid result in containment of
the plume through modification of the groundwater gradient caused by the cones of depression
around each well. Small areas of the plume which are already near the Fall Kill would continue
to migrate until they enter the creek.

This alternative assumes that the extracted groundwater would require some treatment prior to
discharge. Treatment technology for metals removal would consist of pH adjustment and
precipitation. After metals treatment, the groundwater would be treated through an air stripper
and then would be discharged to the Fall Kill. Worst-case emissions from the stripper were
calculated to be insignificant in comparison to New York State standards. The design of the
groundwater treatment system would be based on SPDES requirements which would be the more
stringent of the effluent limitation for a class C water body or the water quality limitation
for the Fall Kill.

Groundwater extraction and treatment offers long-range public health protection against
consumption of contaminated groundwater. Based on site hydrogeologic conditions, the time
required to rehabilitate the aquifer to acceptable State and Federal drinking water standards is
estimated to be within 2 to 7 years.

Aquifer rehabilitation would be accompanied by an annual groundwater monitoring program. The
sampling and analysis would utilize selected monitoring wells located in the study area.
Analytical data obtained from these wells would serve to demonstrate the progres of the aquifer
remediation. Groundwater samples would be analyzed for inorganic and volatile organic

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parameters.

The alternatives developed for an alternative water supply (AW) are:

Alternative AW-1 - No Further Action/Continue to Maintain Whole-House Water Treatment Units
Capital Cost: $0

0 & M Cost: $27,053/year (for 10 years)

Present Worth Cost: $166,082
Time to Implement: immediate

This alternative would continue to address the low level contamination present in the seven
affected homes by maintaining the existing whole-house filters presently installed in these
homes. The units consist of a sediment filter, an ultra-violet treatment unit and twin
activated-carbon filtration cylinders. These homes have been sampled semi-annually by the
NYSDEC; the sampling results indicate that the units are working guite effectively and have
provided a safe reliable source of water for residential use. These units have operated
effectively while reguiring minimal maintenance.

Alternative AW-2 - Provision of Public Water to Study Area

Capital Cost: $3,147,969
0 & M Cost: $0

Present Worth Cost: $3,147,969
Time to implement: 18 months

This alternative provides for the extension of a local public water system into the study area.
The ROD originally envisioned that EPA would enter into an agreement with the Town of Hyde Park
(THP) to share in the costs to upgrade the Harbourd Hills Water District Well water treatment
system to meet NYSDOH standards. It is noted, however, because of residents' concerns about
incurring costs associated with upgrading the Harbourd Hills Water District (HHWD) treatment
facilities, the Town recently passed a resolution stating that the HHWD facilities not be
upgraded. Furthermore, the Town of Hyde Park has reguested that the Hyde Park Fire and Water
district (HPFW) be utilized as the water source. The water distribution network would be the
same as that described in the ROD. The distribution system would be installed along the Haviland
Road and Wright Avenue, and connections would be made by EPA from this distribution system to
residences in the study area. This network would be connected to HPFW at a point approximately
one-half mile away.

EVALUATION OF ALTERNATIVES

During the detailed evaluation of remedial alternatives, each alternative is assessed against
nine evaluation criteria, namely, overall protection of human health and the environment,
compliance with applicable or relevant and appropriate reguirements, long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume, short-term effectiveness,
implementability, cost, and state and community acceptance.

The evaluation criteria are described below.

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• Overall protection of human health and the environment addresses whether or not a remedy
provides adequate protection and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engineering controls, or
institutional controls.

• Compliance with applicable or relevant and appropriate requirements (ARARs) addresses
whether or not a remedy will meet all of the applicable or relevant and appropriate
requirements of other federal and state environmental statutes and requirements or provide
grounds for invoking a waiver.

• Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup goals have
been met

• Reduction of toxicity, mobility, or volume through treatment is the anticipated
performance of the treatment technologies a remedy may employ.

• Short-term effectiveness addresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the
construction and implementation period until cleanup goals are achieved.

• Implementability is the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement a particular option.

• Cost includes estimated capital and operation and maintenance costs, and net present worth
costs.

• State acceptance indicates whether, based on its review of the RI/FS reports and
Post-Decision Proposed Plan, the state concurs, opposes, or has no comment on the
preferred alternative at the present time.

• Community acceptance will be assessed in the Record of Decision (ROD) following a review
of the public comments received on the RI/FS reports and the Post-Decision Proposed Plan.

A comparative analysis of these alternatives based upon the evaluation criteria noted above
follows.

Groundwater

• Overall Protection of Human Health and the Environment

Both Alternatives GW-1 and GW-2 would provide full protection to human health and the
environment. Modeling predicts that the active extraction and treatment of the site groundwater
would result in contaminant levels being reduced to State and Federal groundwater and drinking
water in 2 to 7 years. Modeling of the natural attenuation alternative also predicts that the
ARARs would be achieved in 2 to 7 years. Nonetheless, the extraction and treatment of the
groundwater under Alternative GW-2 may provide a slightly more rapid removal of contamination
from the aquifer than the natural attenuation process of Alternative GW-1. The exposure route to
the people at the site is through ingestion of groundwater or the inhalation of volatile
contaminants from the groundwater. Private wells which contain levels of contaminants above
drinking water standards have been fitted with individual water-treatment units, thereby
ensuring a safe supply of potable water. The levels of contaminants entering these wells has
been decreasing, and sampling of the water prior to and after treatment from these units
indicates that the units are working effectively.

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Compliance with ARARs

Both alternatives would comply with ARARs in approximately the same time frame. Modeling
predicts that the no further action/natural attenuation Alternative GW-1 and the active
groundwater extraction and treatment Alternative GW-2 would result in contaminant levels being
reduced to State and Federal groundwater and drinking water standards in 2 to 7 years.

•	Long-Term Effectiveness and Permanence

Alternatives GW-1 and GW-2 would be egual in providing long-term effectiveness and permanence in
that the groundwater contamination would be reduced below State and Federal drinking water
standards within 2 to 7 years.

Alternative GW-2 would potentially result in greater long-term exposure to contaminants by
workers who could come into direct contact with the concentrated sludges from the treatment
system. However, proper health and safety precautions would be implemented to minimize exposure
to the sludges.

•	Reduction in Toxicity, Mobility, or Volume

Under both alternatives, the volume and toxicity of the groundwater contaminants above ARARs
would be reduced at approximately the same rate and would ultimately be eliminated in
approximately the same time frame.

The mobility of the contamination plume would be reduced by actively extracting the groundwater
under alternative GW-2. It is assumed that even with the active groundwater extraction, some
contamination would migrate into the Fall Kill, but a lesser amount than under the natural
flushing conditions of Alternative GW-1. It is noted that sampling of the Fall Kill indicates
that levels of the contaminants reaching the creek do not pose a threat to human health and
the environment.

•	Short-Term Effectiveness

There would be virtually no short-term impacts on human health and the environment by continuing
to maintain the residential water treatment units under Alternative GW-1. Also, because the
residential water treatment units are already installed, no time would be required to implement
this alternative. However, construction activities associated with Alternative GW-2 (e.g.,
installation of extraction wells and underground piping, and construction of the treatment unit)
would have potentially negative impacts on residents in the study area. While efforts would be
made to minimize these impacts, some disturbances to residents would result from disruption of
traffic, excavation activities on public and private land, noise, and fugitive dust emissions.
It is estimated that the construction activities for Alternative GW-2 would take approximately
one year to complete.

•	Implementability

The technologies proposed for extracting and treating contaminated groundwater in Alternative
GW-2 are proven and reliable in achieving the specified cleanup goals, however, Alternative GW-2
would be much more complex than Alternative GW-1 to implement. The design and construction of
the groundwater extraction system would take approximately 2 years to complete. Alternative GW-2
would require that property be acquired/leased for the treatment unit and that access/easements
be obtained from private and public property owners for the installation of piping and
extraction wells. The operation and maintenance of the system would include the monitoring of
the aquifer for system effectiveness, monitoring of the system emissions to determine compliance

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with permit equivalencies, and the handling and disposal of the concentrated contaminated
treatment residuals.

Alternative GW-1 would be more easily implemented, as it would only require the sampling of
selected monitoring wells once a year.

• Cost

Alternative GW-1 has no direct costs associated with its implementation. The present worth of
this alternative of $24,873 is for implementation of an annual groundwater monitoring program.
The capital and present worth costs of Alternative GW-2 are estimated to be approximately
$625,500 and $1,205,439 respectively.

Both alternatives would provide a similar level of protection in a similar time frame, however,
Alternative GW-1 would do so at a much lower cost.

• State Acceptance

The State of New York concurs on the proposed modified remedy.

• Community Acceptance

Community acceptance of the preferred alternative will be assessed in the ROD amendment
following review of the public comments received on this Post-Decision Proposed Plan.

Alternate Water Supply

• Overall Protection of Human Health and The Environment

Both Alternatives AW-1 and AW-2 would provide full protection of human health. Both alternatives
would prevent the potential exposure of residents at the site through ingestion or inhalation of
contaminants present in selected residential wells. Data from the sampling of the impacted
residential wells has shown that the whole-house treatment units installed at these residences
are fully effective and provide sustained protection with minimal maintenance.

The provision of public water to the site area described in Alternative AW-2 would not be more
protective to the residents than what presently exists, but would preclude the need for future
sampling and maintenance of the impacted wells.

• Compliance with ARARS

Alternatives AW-1 and AW-2 would both comply with ARARs, the primary ARARs of concern being
State and Federal drinking water standards. Neither Alternative AW-1 nor AW-2 would provide a
significant advantage over the other with respect to ARARs.

Compliance with ARARs under Alternative AW-1 would be demonstrated via the home sampling and
filter maintenance program. Compliance with ARARs under Alternative AW-2 would be demonstrated
by the water supplier via regular sampling of the water distribution system as required by the
State of New York.

• Long-Term-Effectiveness and Permanence

Because groundwater contamination is estimated to be completely attenuated within 2 to 7 years,
site-related contaminants would not be expected to impact the residential wells over the long

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term. Therefore, both alternatives would provide long-term protectiveness and permanence.

• Reduction in Toxicity, Mobility, or Volume

A comparison of the two alternatives' abilities to satisfy this criterion is not necessarily
applicable since the goal of the alternate water supply is to provide a potable supply of water
and does not reguire that the toxicity, mobility or volume of contaminants be reduced to do so.
Nonetheless, Alternative AW-1 would reduce the toxicity, mobility and volume of contaminants in
the residential well water, and to a limited extent the aguifer. Alternative AW-2 would not
provide any reduction of contaminants.

• Short-Term Effectiveness

There would be virtually no short-term impacts to human health and the environment by continuing
to maintain the residential water treatment units under Alternative AW-1. Also, because the
residential water treatment units are already installed, no time would be reguired to implement
this afternative. However, construction activities associated with Alternative AW-2 (eg.,
installation of underground piping) would have potentially negative impacts an residents in the
study area. While efforts would be made to minimize these impacts, some disturbances to
residents would result from disruption of traffic, excavation activities on public and private
land, noise, and fugitive dust emissions. It is estimated that the construction activities for
Alternative AW-2 would take approximately one year to complete.

• Implementability

The implementation of Alternative AW-1 would reguire the continued monitoring and maintenance of
the home filtration units.

• Cost

The total cost of Alternative AW-2 is estimated to be approximately $3,147,969. The capital cost
is based on the cost of connecting to HPFW which is estimated to be $848,969 and construction of
the distribution system is estimated to be $2,299,000. While EPA and the NYSDEC would not incur
any operating or maintenance expenditures under Alternative AW-2, residents connected to the
system would have to pay for the water received, which is estimated to be approximately $200 to
$400 per year.

• State Acceptance

The State of New York concurs an the proposed modified remedy.

• Community Acceptance

Community acceptance of the preferred alternative will be assessed in the ROD amendment
following review of the public comments received on this Post-Decision Proposed Plan.

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PREFERRED ALTERNATIVE

Based upon an evaluation of the various alternatives, EPA and NYSDEC recommend Alternative GW-1,
No Further Action/Natural Attenuation, and AW-1, No-Further Action/Continue to Maintain
Whole-House Filter Systems.

The Post-Decision preferred alternative provides the best balance of trade-offs among
alternatives with respect to the evaluating criteria. EPA and the NYSDEC believe that the
preferred alternative will be protective of human health and the environment, will comply with
ARARs, will be cost-effective, and will utilize permanent solutions and alternatives treatment
technologies or resource recovery technologies to the maximum extent practicable.

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From: P. N. Prentice To: EPA in NYC

Date: 8/30/96 Time: 10:48:12

Page 1 of 1

P.N. Prentice
29 Lawrence Rd.

Hyde Park, NY 12538-2429

August 30, 1996

Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866

Dear Sir:

The Harbourd Hills Water Advisory Committee is composed of 8 members who live in the district
and are appointed to the committee by the Hyde Park Town Board. The members monitor the affairs
of the district and advise the Town Board on matters related to the operation of the district
when the occasion demands that.

The notice for the 9/4 [Haviland Area in Hyde Park] meeting appeared in the Poughkeepsie Journal
on 8/26 in the middle of the sports section. The committee feels that this was a poor choice of
location [some people don't read the sports section] and asks that the notice be repeated before
the 9/4 meeting to insure that residents and other interested parties are properly notified.

The committee also noted that there has been previously published data on heavy metals in the
water samples, but no information appeared in your report at a detail level given to VOC's. We
ask that a graphical representation of heavy metals over time be given the same presentation as
VOC's were given.

It was also interesting to note that your report appeared in the Hyde Park Town Clerk's office
late in the day on 8/2 6 and announced that the comment period started on 8/24.

Sincerely yours,

P. N. Prentice

Executive Secretary to the Committee

914-229-2995 Fax by prior arrangement [I have to turn the computer on]
cc/ Hyde Park Town Board..

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P.N. Prentice
29 Lawrence Rd.

Hyde Park, NY 12538-2429

September 5, 1996

Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866

Dear Sir:

Following the advice you gave last night I went to the Hyde Park Free Library to search out he
documents you said were deposited there. With the help of the Librarian we found the large
report dated 1987 (I think July) and the report which was a copy of that given to the Hyde Park
Town Clerk on 9/2 6/96.

Where is the information for the period between 1987 and 1996? Please advise soonest as the
comment period ends 9/23.

Sincerely yours,



P. N. Prentice

Executive Secretary to the Committee

cc/ Hyde Park Town Board..

Mr. Soya
Mr. Cain
HPF&W

Hyde Park School District Buildings and Grounds

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P.N. Prentice
29 Lawrence Rd.

Hyde Park, NY 12538-2429

September 7, 1996

Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866

Dear Sir:

Please include this letter and my letter of 9/5/96 in the matter of record on the Haviland site
Hyde Park NY.

When your 8 page report became available at the Hyde Park Town Clerk's office I obtained a copy
and noted what I then believed to be an inaccurate statement on page 5 [copy enclosed] which I
guote in part... "... the Town recently passed a resolution stating that the HHWD facilities not
be upgraded."

I faxed a request to the Hyde Park Town Hall on 8/29/8 6 [copy enclosed] and received pages from
the official minutes of the meetings on 10/13/96 [page 245 - note resolution 10:13-1 of 1995]
and meeting 2/2 6/96 [page 63 - note resolution 2:26-14 of 1996]. These resolution do not support
your statement.

This is all of the record I am aware of which would have any relevance to your statement quoted
above. I continue to believe your statement is inaccurate. Can you support your statement "...
the Town recently passed a resolution stating that the HHWD facilities not be upgraded?"

Sincerely yours,



P. N. Prentice

Executive Secretary to the Committee

cc/ Hyde Park Town Board..

Mr. Soya.

Mr. Cain
HPF&W

Hyde Park School District Buildings and Grounds
HH Advisory Committee

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From: P. N. Prentice To: EPA in NYC

Date: 9/15/98 time:

P.N. Prentice
29 Lawrence Rd.

Hyde Park, NY 12538-2429

September 15, 1996

Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866

Dear Sir:

of the

Free Library

so tnat l will not nave to Jootner tne liiorary every day to una out wnen tnese "new" materials
are available?

914-229-2995

Thank you.

Sincerely yours,

P. N. Prentice

Executive Secretary to the Committee

cc/ Hyde Park Town Board..

Mr. Soya
Mr. Cain
HPF&W

Hyde Park School District Buildings and Grounds

Got your notice about comment period being extended until Oct. 23rd in the matter
Haviland Area of Hyde Park, NY. Thank you.

Would you please advise when you will place additional materials in the Hyde Park

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P.N. Prentice
29 Lawrence Rd.

Hyde Park, NY 12538-242

added September 24, 1996

Note my letter of Sept. 15, 1996 following.

I visited the library today and was told no information has been added to the 1987 material
discovered before.

What are your intention and when are your intentions. I note the comment period ends 10/23/96
Please add all of this to the record as a comment.



September 15, 1996

Mr. Kevin Willis
US-EPA 20th Floor
290 Broadway
New York, NY 1007-1866

Dear Sir:

Got your notice about comment period being extended until Oct. 23rd in the matter of the
Haviland Area of Hyde Park, NY. Thank you.

Would you please advise when you will place additional materials in the Hyde Park Free Library
so that I will not have to bother the library every day to find out when these "new" materials
are available?

914-229-2995

Thank you.

Sincerely yours,



P. N. Prentice

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Harbourd Hills Water Advisory Committee
Hyde Park, NY 12538-2429

October 9, 1996

Mr. Kevin Willis
US-ERA 20th Floor
290 Broadway
New York, NY 1007-1866

Dear Sir:

RE: Your report titled "Superfund Post-Decision Proposed Plan Haviland
Complex Hyde Park Dutchess County, NY" dated "August 1996."

The Harbourd Hills Water Advisory Committee is composed of 8 members who live in the district
and are appointed to the committee by the Hyde Park Town Board. The members monitor the affairs
of the district and advise the Town Board on matters related to the operation of the district
when the occasion demands that.

When the Harbourd Hills Water District was formed [and the Harbourd Hills Water Advisory
Committee established] it did not include the Haviland Road and Haviland Shopping center. A
short time later, the discovery of pollution in that area caused the Town of Hyde Park to expand
the Harbourd Hills Water District to include these two areas in anticipation of providing water
to these residents.

The ROD [Record of Decision] when published established the EPA as a source of help and funding
to expand water system distribution and refurbish the water plant to accommodate the new area.
The committee hired [[with the approval of the Town of Hyde Park] an engineer to work with the
district and the EPA on the best method to accomplish this task. Since the existing well/plant
site was too small to accommodate the needed water treatment facility other alternatives were
investigated and this finally culminated in the concept of an association [a tenant would be
accurate] with Hyde Park Fire and Water (HPF&W) as a source of supply. This was also the least
expensive.

Part of this decision was predicated on the late understanding of the restrictions on the EPA
funding which would have placed a considerable burden on the existing 250 families in our
district who would have to sustain the bond debt of the expansion while exempting the Haviland
Road expansion. The most reasonable course of action to our district would have been to take
advantage of the connection to Hyde Park Fire and Water at the Haviland Road area and build
supporting facilities in our district such as a storage tank. Haviland Road would also benefit
from this improvement as it would level the demand for water which would also make the water
less costly to our district as well as the Haviland Road area.

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Harbourd Hills Water Advisory Committee
Hyde Park NY 12538-2429

A water supply from Hyde Park Fire and Water would also enable the Haviland Middle School to
purchase water rather than sustain a significant capital expense to replace and refurbish
equipment in the school which is at or near the end of life. Further a public supply would
enable the school district to avoid the expense of maintenance and testing of its supply. The
existing school well furnished not only Haviland Middle School, but also Ralph R. Smith
Elementary School [near by] and the bus garage complex [also near by]. It should be noted that
the well used by the school is deep, and while historically isolated from the pollution above,
the school officials still worry about possible future contamination. (The undersigned is an ex-
member of the Hyde Park School Board whose three year term expired last July 1st and thus has
knowledge of this subject.)

The committee has noted that if the present Harbourd Hills water district is required to service
our existing service area as well as the Haviland Road, possibly some Wright Ave., Haviland
Apartments and shopping center, and the Haviland school complex then our well yield capacity
would be strained. An alternate source would be much preferred. The yield test for Harbourd
Hills Wells has not been recently done to establish safe yield plus reserve. The wells are close
together with one shallow and one deep. There has been observed interaction between them in that
pumping one causes the cone of depression on the other to draw down. No tests have been done to
establish the safe yield when both are pumping at maximum capacity.

The committee notes there has been a long history of reports, letters, meetings, which have all
been supportive in a general way of EPA funding for this area. Our district has formulated our
plans and done our engineering work with the underlying assumption of EPA funding and
involvement. Our Engineer estimates our district has spent something in excess of $29,000
because of EPA involvement that would have otherwise not been spent or spent for other work. Can
we be reimbursed? It was noted at the meeting on Sept. 4th that the $2.1 million dollars you
claim to have spent would have been sufficient to connect to HPF&W and thus end the matter.

The committee has several questions:

•	The graphs [pollution levels at various Haviland Road houses] presented at the meeting on
9/4 were more recent than those published in the August 1996 report. Why were these not
made available to our committee and the public?

•	The heavy metals report circa 1992 had elevated levels of Cr. and Ni. in excess of NYS DOH
standards. At the meeting you claimed to have done later analysis. Where are those
reports? If heavy metals are in the background soil why not sample the soil to determine
if this is so and clear up the matter regarding heavy metals?

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Harbourd Hills Water Advisory Committee
Hyde Park, NY 12538-2429

Why did the comment period start on 8/24 for a report that was not available until two
days later on 8/26?

The Hyde Park Free Library was announced at the 9/24 meeting as being a source of
information. When we visited the library the most recent information was 1987 and the
report caption above. Where is the rest of the data?

The statement on page 5 of the above captioned report which I guote in part the Town

recently passed a resolution stating that the Harbourd Hills Water District facilities not
be upgraded." The official minutes of the meetings on 10/13/96 [page 245 - note resolution
10:13-1 of 1995] and meeting 2/26/96 [page 63 - note resolution 2:26-14 of 1996] do not
support your statement. Where did you get your information from?

Why was the EPA notice of the 9/4 meeting published in the Poughkeepsie Journal placed in
the middle of the sports section [not read by all] and why did you not publish a second
notice when this was brought to your attention? The announcement should have been placed
in the legal notices.

When the Town councilman for our district and the secretary to the committee visited all
the homes on Haviland Road and Wright Ave. we were informed that some of the houses had
not been tested in years. This is curious because your foil of the computer model showed
the pollution plume extending to Wright and yet there were no plans to test again. What
plans do you have for a comprehensive test before electing to abandon support for the
area? Further, we obtained selected pages from a report titled "Groundwater Modeling at
the Haviland Complex site, Hyde Park, NY" prepared by Milovan S. Beljin, Ph.D. and dated
Dec. 1992. The Hyde Park Free Library was not the source of this report access. Page 14 of
this memo states, "Figure 20 indicates that even after 10 years, concentration levels of
tetrachloroethene will not decrease below 10 ppb level." [this was for one set of
assumptions] Figure 20-31 show projections of various other organic compounds at contour
levels of 5 and 10 ppb after 2, 5, and 10 year intervals. All tend to show concentrations
near or at the east end of Haviland and Wright Ave. [just before Bill Reynolds Blvd.]
Do you believe this computer similation and if so why have you not tested in this area?

The NYS DOH and the DEC all signed the ROD. The committee has not seen any documentation
from those parties relative to your information that they support the EPA position. Can
you supply this?

At the 9/4/96 EPA meeting in response to the guestion about the ROD, EPA claimed that it
did not expire. The ROD itself has language suggesting it expires in 1997. Please explain
this apparent discrepancy?

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Harbourd Hills Water Advisory Committee
Hyde Park, NY 12538-2429

•	Why did you fail to respond to the secretary's letters of 8/25/96 [[newspaper notice],
8/30/96 [request for recent analysis data], 9/5/96 [Hyde Park Free Library not a source],
and 9/7/96 [inaccurate statement in above captioned matter]?

•	It would be reasonable to provide interested parties with up-to-date documentation and
hold another information meeting before a final decision is made.

You must have learned from the meeting on 9/4/96 that the residents of Haviland Road and Wright

Ave. are still concerned about their water. Their concern could be closed by a connection to

HPF&W with your support. The remaining part of the district would also benefit.

Please reconsider your pending action.

Sincerely yours,



P. N. Prentice

Executive Secretary to the Committee

cc/ Hyde Park Town Board..

Mr. Soyka District Engineer

Mr. Cain System Operator

Hyde Park Fire and Water District

Hyde Park School District Buildings and Grounds

Scott Chase Dutchess County Water and Waste Water

NYS DEC

NYS DOH

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September 19, 1996

Kevin Willis
US-EPA

290 Broadway, 20th Floor
New York, NY 10007-1866

RE: Haviland Superfund Site
96-200.3

Dear Mr. Willis:

This office in its capacity as a Town Engineer for several municipalities and as a former Town
Engineer for the Town of Hyde Park, has some viable experience with this site. There are,
however, several issues that in our opinion remain open. They are:

• The heavy metal guestion. This area was a very significant guestion from The
inception of the project inception, through the ROD development, and up until
several months ago. This office would recommend split-spoon soil sampling to
determine the accuracy of the statement of the pre-existence of heavy metals. A
soil analysis would be reguired in our opinion to eliminate any doubt about the
existence of the heavy metals.

• Small statistical sampling population. The sample population for the pollution plume
needs to be expanded to find the real edge of the pollution plume. It is our opinion
that the sample size needs to be substantially increased.

• The guestion of the contribution of the Haviland Road School to the pollution. It is
our understanding that the School District has been formally notified that it is a
PRP. Has the EPA changed it's view of the responsibility of the School District.

Finally, while there has been a certain amount of avoidance of responsibility on all sides of
this issue, we believe it would be fair to say that the Town of Hyde Park in the past several
years has taken the lead in addressing and attacking

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D.F. WHEELER ENGINEERS, P.C.

Haviland Superfund Site

this problem. Also, we feel that while nature has remediated some of the materials (i.e. VOC
the heavy metals remain a serious and enduring health concern. We also feel that a cursory
review of the metals question does not support the contention that they are pre-existing.

It is our position that the situation has not changed substantially at the Haviland complex
that the obligation to the residents remains. Therefore, the ROD should be executed.

Should you have any questions, please do not hesitate to contact this office.



DFW\cb

cc: Supervisor Spence and Town Board

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effectiveness of whole house treatment units. Once again, the evaluation appears to not address
the residences with out treatment systems.

The exclusion of the additional residences within the Haviland complex site seems to be based on
an assumption that, since these residential wells did not show contamination in the past, they
will not do so in the future. The validity of this assumption seems open to question for the
following reasons; lack of current sampling data, variability of the sampling data, accuracy of
modeling and the lack of future monitoring.

Lack of monitoring data for additional residences: If a low level volatile plume is in
factmoving south easterly from the Haviland Shopping Center and Haviland Complex Apartments
area, it seems possible that additional homes on Haviland Avenue and homes on Wright Avenue may
be at risk of contamination. It is unclear when the last time residential wells of homes without
treatment units were sampled, but it appears that many have not been sampled in over three
years.

Variability in sampling data: The concern regarding the lack of recent sampling data for
residential wells without treatment units is heightened by the high variability in sampling
results for the residential wells on Haviland Road, which have been sampled semi-annually since
1989. Specifically:

•	At 10 Haviland Road PCE levels went from 3 ppb to 11 ppb in 4 months (1990),

•	At 14 Haviland Road CBZ levels went from 0 to 21 ppb in 6 months (1995),

•	At 20 Haviland Road PCE level went from 10 to 41 ppb in 9 months (1991), and CEZ
levels went from 8 to 35 ppb in 9 months (1991) and from 0 to 13 ppb in 4 months
(94-95),

•	At 22 Haviland Road DCE levels went from 0 to 5.6 ppb in 4 months (93-94), and CBZ
levels went from 0 to 11 ppb in 4 months (93-94),

•	At 24 Haviland Road PCE levels went from 0 to 27 ppb in 4 months (93-94), and CBZ
levels from 0 to 10 ppb in 6 months (1995) .

It appears from this data that distribution of contamination levels within the plume are far
from uniform, and that levels of contamination at any particular point can easily vary from non-
detectable to above MCLs in a relatively short time period. This raises questions as to whether
the limited testing done on additional residential wells is adequate to support an assumption
that they are not currently, and will not in the future, be impacted by contamination.

In contrast to the amount of sampling data upon which EPA is basing a decision to take no
further action on homes without treatment units, Alternative AW-1 anticipates maintenance of the
treatment units until 3 years of consecutive semi-annual rounds of sampling (i.e. 6 samples over
3 year) meet MCLs.

Accuracy of modeling: Modeling based on 1987 and 1990 data predicts that the contamination plume
will not impact additional residential wells. However, modeling is not an exact science; it
predicts a range of future outcomes based on current conditions. But conditions can change; for
example, changes in water table conditions or water withdrawals could change the direction of
groundwater flow. As stated above, there is a great deal of variability in the sampling results;
how might this impact the reliability of the modeling?

For these reasons, it would seem prudent for EPA to conduct at least one more round of testing
of all of the residential wells with in the Haviland Complex site and downgradient of the
source prior to making a final decision regarding appropriate remedies.

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In the event that EPA determines to select remedies GW-1 and AW-1, we recommend ongoing
monitoring, at least annually, of residential wells which do not have home treatment units as
part of the monitoring plan. Currently, Alternative AW-1 anticipates semi-annual monitoring of
all homes with treatment units, and maintenance of units, until 3 years of consecutive
semi-annual rounds of sampling meet MCLs. No additional monitoring is recommended for the
"non-treatment" homes.

In addition, monitoring wells should be sited both upgradient and down gradient of homes on
Haviland Avenue and Wright Avenue to insure the detection of any contaminant plume that may
impact the non-treatment homes. Alternative GW-1 calls for 5 monitoring wells upgradient and
downgradient of "affected" homes - it is not clear whether "affected" homes includes all 35
homes in site area, or just the homes with treatment units. If the latter, EPA should evaluate
whether 5 monitoring wells is adeguate to cover the entire area.

Benefits of providing public water supply: There are overall benefits to the community of
providing public water to the Haviland Area (Alternative AW-2). These issues are relevant to the
issue of "Community Acceptance":

•	a greater guarantee of clean water for all businesses and residents in the Haviland
Complex,

•	the elimination of the need for ongoing monitoring of all water supply wells in the
impacted area,

•	the elimination of the inconveniences and impacts on water pressure currently being
experienced by those residents with whole home treatment systems,

•	the resolution of the area residents' concerns that the water contamination problems
(real and perceived) are negatively impacting their property values, and

•	the ability of the Haviland Middle School and Ralph R. Smith Elementary School to
purchase water rather than continue to bear the ongoing operation, maintenance and
monitoring expenses, and future capital improvement expenses for their on site
supply system.

There are additional benefits to the community at large of providing public water. A connection
to the Hyde Park Fire and Water District would also benefit the other residents of the Harbourd
Hills water District who are outside of the Haviland Complex Area. The Hyde Park Fire and Water
District currently has significant excess capacity compared to its service population. This has
created a financial hardship on district residents (regarding both operation and capital costs)
that can only be resolved by expanding the service area.

Connection of the Haviland Complex area to the Hyde Park Fire and Water District would be an
effective alternative that would satisfy the criteria of; Overall Protection of Human Health
and the Environment, compliance with ARAR's, Long-Term Effectiveness and Permanence,
Implementability, and Community Acceptance. EPA should reconsider this alternative.



cc: Thomas Spence, Supervisor, Hyde Park

Paul Prentice, Harbourd Hills Water Advisory Board

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ROHDE, SOYKA
& ANDREWS

Consulting Engineers, P. C

Wilfred A. Rohde, P.E. * Michael W. Soyka, P.E
September 13, 1996
Kevin Willis

US Environmental Protection Agency
290 Broadway 20th Floor
New York, NY 10007-1866

Re: Superfund Post-Decision Proposed Plan
Haviland Complex

Dear Mr. Willis:

As you know, I am the Engineer who represents the Harbourd Hills Water District for the Town
of Hyde of Park. The Advisory Board to the District has reguested that I contact you about their
concerns regarding the subject matter. Therefore, I offer the following comments for your
consideration:

1. The emphasis of the presentation and the subject plan was placed on the seven homes
which have been identified in the past as having contaminated wells, and have
subseguently received treatment systems for their water supply. However, the Haviland
Complex also consists of a school campus with up to 1,300 students and staff; 86 homes
and apartments; and over 15 businesses. These entities represent a probable water
consumption of about 37,000 gallons per day. There was very little information
presented as to the size and potential consumption for this important part of the Haviland
Complex. What assurance is there that contamination of these remaining parcels is not

a problem? During my discussion with Mr. John Glass of the Dutchtss Count Health
Department on September 4, 1996, I was informed that the system supplying the 61
apartments is still using their air stripper to treat the water being provided to these
people. Please provide test data that shows the condition of the water guality for each
and every potential user within the Haviland Complex.

2. A graphical representation of the decrease in the VOC's was shown for selected
properties on Haviland Road. What is the data from all of the remaining monitoring
wells concerning the status of VOC's? Show this information in the same graphic
format.

3. The subject plan states on page 3: "In addition, site-related metals contamination
has not been observed in any of the potable wells in the study area." Does metals
contamination exist within any of the monitoring wells? If so, what is the potential for
migration to the potable wells? Please prepare a graphical presentation of the change in
metals contamination for all wells tested, similar to that for the eight wells on Haviland
Road.

. * John V. Andrews, Jr.,

40 Garden Street
Poughkeepsie, NY 12 601

(914) 452-7515
Fax: (914) 452-8335
P.E.

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Kevin Willis
September 13, 1996
Page 2 of 2

4.	The subject plan states that community acceptance of the preferred alternative will
be assessed in the ROD amendment. What is the impact if the community still insists on

a connection to the Hyde Park Fire and Water District?

5.	At the public meeting held on September 4, 1996, it was stated that the EPA has spent
$2.1 million on this project. Please provide an accounting of these expenditures.

6.	If the subject plan is accepted, will the Haviland Complex be reduced in size? If the
Haviland Complex is not reduced in size by an official declaration, what will the
economic impact be on properties that are deemed to be safe, yet are still located within
a declared Super Fund site?

I thank you for the time given to me during the public comment period at the September 4th
public meeting, and for your consideration of the above matters.

Very truly yours,

ROHDE, SOYKA & ANDREWS
CONSULTING ENGINEERS, P.C.



cc: Thomas Spence, Supervisor
Town Board Members
Town Clerk

Harbourd Hills Advisory Committee
96-069-06

ROHDE, SOYKA & ANDREWS CONSULTING ENGINEERS, P.C.

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HYDE PARK CENTRAL SCHOOL DISTRICT
Building and Grounds Department.
Haviland Road
Hyde Park, New York 12538

Douglas R. Mayen, C.D.F.

Director of Facilities & Operations

Tel. (914) 229-4064
Fax. (914) 229-4033

September 25, 1996

Mr. Kevin Willis, Project Manager
U.S. Environmental Protection Agency
Emergency & Remedial Response Division
290 Broadway 20th Floor
New York, New York 10007

Dear Mr. Willis:

I would like to reiterate, for the written record, the Hyde Park Central School District's
position as I stated in your meeting at the Haviland Middle School on September 04, 1996.

The School District takes exception to your "Superfund Post-Decision Proposed Plan" statement,
Page 2, Paragraph 1, under Summary of Site Investigations. The Haviland Junior High School never
emitted contaminants into the ground water, thereby, contributing to the contamination of the
shallow residential wells on Haviland Road.

As a matter of fact, the only contaminants found in our septic tanks were heavy metals which, by
your own admission on Page 3 of the Post-Decision Plan, you state that "site-related metals
contamination has not been observed." It has never been proven that the heavy metals have ever
left our septic tanks, contaminating any soil or water.

Furthermore, your Figure 33, dated September 1992, of Ebasco's Summary Report of Groundwater
Investigations is erroneous and misleading. This shows the "Path Lines from Potential Pollution
Sources" which, again, says the District is a potential source when the known pollutants of the
residential wells do not exist in our septic systems. Also, the third point from the left on
this figure is not a septic system but a rock ledge, and your sampling point there has always
been dry.

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To: Mr. Kevin Willis, Project Manager
Re: Superfund Post-Decision Proposed Plan

September 25, 1996

The District would also like to go on record as being in favor of alternate AW-2, the
installation of a Public Water System. The Haviland (Middle) Junior High School's deep well has
never been polluted and, hopefully, will not be anytime in the future. But, our fifty-year old
system is at the end of its useful life, and we would like to get out of the water supply
business. It seems inefficient and uneconomical for the School District to maintain a water
plant when the Hyde Park Fire and Water and Harbour Hills Water Systems could serve our needs,
as well as, the residents of the area.

Thank you again for taking these facts under consideration in your final analysis.

Yours truly,



DRM/Jam

cc: Mr. Paul F. Eckelman, Hyde Park Fire and Water

Mr. Clifford J. Ong, Support Services Administrator, HPCSD

Mr. Paul N. Prentice, Harbourd Hills Advisory Committee Secretary

Mr. Daniel W. Stone, Chazen Engineering

Dr. Stephen H. Urgenson, Superintendent of Schools, HPCSD

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September 16, 1996

Kevin Willis, Project Manager

US-EPA Emergency & Remedial Response Division
290 Broadway, 20th Floor
New York, NY 10007-1866

Re: Haviland Road Site

Dear Mr. Willis:

The town takes issue with the EPA's proposal which was presented in a public hearing in Hyde
Park on September 4, 1996.

The ROD had three signatories; the EPA should not unilaterally have the power to declare that
its provisions have been satisfied or to nullify it.

For at least nine years, heavy metal contamination was considered to be a serious problem. Now
it is decreed that this is no longer a problem. There should be extensive test boring of the
soil near to the existing wells to ensure that traces of heavy metals are not present. I saw no
evidence presented at the public hearing to indicate that such tests have been performed.

The amount of sampling is not sufficient to justify the abandonment of a plan to connect the
Haviland area to an assured water source. It appears that the only consistent ongoing sampling
has been at the faucets of seven afflicted homes. This modest list of points has been used to
drive a computer model, the results of which is used to project that all will be fine in a few
years. At a bare minimum EPA should sample all the houses on Haviland Road and Wright Avenue in
addition to sampling the schools and the shopping center.

Remarks from the floor indicated that the water in the schools may not be safe for drinking.
There should be no guestion about this before EPA decides to abandon the idea of connecting to a
good water source.

The previous town board passed a resolution in the fall of 1995 asking that the EPA adopt a
solution of connecting the Haviland Road site to the Hyde Park Fire & Water District. The
present town board passed a similar resolution in January of this year; the intent of this
second resolution was to demonstrate that the town's position on this guestion is grounded in
reason, not politics. I call to your attention Mr. Eckelman's letter to you of September 12,
1996.

-------
Kevin Willis

U.S. Environmental Protection Agency
290 Broadway 20th Floor
New York, NY 10007-1866

Dear Mr. Willis, September 22, 1996

At the September 5th Superfund Post-Decision Proposed Plan informational meeting on the Haviland
Complex, held at the Haviland Middle School, I and other concerned residents were informed that
the "Preferred Alternative" to the ongoing water problem was to continue with the plan already
in place. I strongly oppose this decision. I feel the testing has been insufficient, with the
test wells not being tested as freguently as needed or not at all. Our home was the first to
have pollution in the water supply. As a result we were left to ensure our own personal safety
by installing a water purifier filter at our own expense, and have been maintaining this system
throughout the years that this problem has been on the negotiating table. I feel the Preferred
Alternative Plan is inefficient, short and long term, and consider this problem to be a major
health concern for all the residents involved.

Furthermore on October 13, 1995 during the special meeting of the Hyde Park Town Board, the
Resolution 10:13-1 if 1995 was put forth and voted upon reguesting "The United States
Environmental Protection Agency immediately proceed with the design and construction of the
water mains and appurtenances needed to provide a reliable, potable water supply to the Haviland
Complex a connection to the Hyde Park Fire and Water District", with the role call vote
unanimously in favor. During the February 26, 1995 Public Hearing and Regular Meeting of the
Hyde Park Town Board another Resolution (2:26-1 of 1996) was carried unanimously and states as
follows: "BE IT RESOLVED, that the current Town Board does hereby reaffirm the Town's
commitment to cooperate and work with the United States Environmental Protection Agency toward
the goal set forth in the Hyde Park Resolution Number One of October 13, 1995."

In conclusion it is my belief that the EPA, NYSDEC, and the public officials that represent my
district need to be more conscious of the seriousness and urgency of this matter. There are also
two public schools involved, one of which the children are instructed NOT to drink the tap
water! I am outraged at the slow progress that has been taken to rectify this situation to
ensure all residents have clean healthy water. I appreciate your prompt attention to this
matter.

-------
Kevin Willis

U.S. Environmental Protection Agency.

290 Broadway 20th Floor
New York, NY 10007-1866

Dear Mr. Willis, September 12, 1996

At the September 5th Superfund Post-Decision Proposed Plan informational meeting on the Haviland
Complex, held at the Haviland Middle School, I and other concerned residents were informed that
the "Preferred Alternative" to the ongoing water problem was to continue with the plan already
in place. I strongly oppose this decision. I feel the testing has been insufficient, with the
test wells not being tested as freguently as needed or not at all. In the past six years my well
has not been tested by the County or State at all, leaving me no alternative but to personally
take on this responsibility. I feel the Preferred Alternative Plan is inefficient, short and
long term, and consider this problem to be a major health concern for all the residents
involved.

Furthermore on October 13, 1995 during the special meeting of the Hyde Park Town Board, the
Resolution 10:13-1 if 1995 was put forth and voted upon reguesting "The United States
Environmental, Protection Agency immediately proceed with the design and construction of the
water mains and appurtenances needed to provide a reliable, potable water supply to the Haviland
Complex a connection to the Hyde Park Fire and Water District", with the role call vote
unanimously in favor. During the February 26, 1995 Public Hearing and Regular Meeting of the
Hyde Park Town Board another Resolution (2.26-1 of 1996) was carried unanimously and states as
follows: "BE IT RESOLVED, that the current Town Board does hereby reaffirm the Town's commitment
to cooperate and work with the United States Environmental Protection Agency toward the goal set
forth in the Hyde Park Resolution Number One of October 13, 1995."

In conclusion it is my belief that the EPA, NYSDEC, and the public officials that represent my
district need to be more conscious of the seriousness and urgency of this matter. There are also
two public schools involved, one of which the children are instructed NOT to drink the tap
water! I am outraged at the slow progress that has been taken to rectify this situation to
ensure all residents have clean healthy water I appreciate your prompt attention to this matter.

Sincerely,

Mr. & Mrs. Horton Tucker

4 Haviland Road

Poughkeepsie, NY 12601

cc: Sen. Alfonse M. D'Amato

Sen. Daniel Patrick Moynihan

Rep. Gerald B. Solomon

Sen. Stephen Saland

Assemblyman Joel Miller

Thomas Spence, Hyde Park Supervisor

Geoffrey J. Tacietti & G. Anders Carlson, NYS EPI, NYSDOH

Douglas Gaborini, USEPA

Dutchess County Health Commissioner

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effectiveness of whole house treatment units. Once again, the evaluation appears to not address
the residences with out treatment systems.

The exclusion of the additional residences within the Haviland Complex site seems to be based on
an assumption that, since these residential wells did not show contamination in the past, they
will not do so in the future. The validity of this assumption seems open to question for the
following reasons; lack of current sampling data, variability of the sampling data, accuracy of
modeling and the lack of future monitoring.

Lack of monitoring data for additional residences: If a low level volatile plume is in fact
moving south easterly from the Haviland Shopping Center and Haviland Complex Apartments area, it
seems possible that additional homes on Haviland Avenue and homes on Wright Avenue may be at
risk of contamination. It is unclear when the last time residential wells of homes* without
treatment units were sampled, but it appears that many have not been sampled in over three
years.

Variability in sampling data: The concern regarding the lack of recent sampling data for
residential wells without treatment units is heightened by the high variability in sampling
results for the residential wells on Haviland Road, which have been sampled semi-annually since
1989. Specifically:

•	At 10 Haviland Road PCE levels went from 3 ppb to 11 ppb in 4 months (1990),

•	At 14 Haviland Road CBZ levels went from 0 to 21 ppb in 6 months (1995),

•	At 20 Haviland Road PCE level went from 10 to 41 ppb in 9 months (1991), and CBZ
levels went from 8 to 35 ppb in 9 months (1991) and from 0 to 13 ppb in 4 months
(94-95),

•	At 22 Haviland Road DCE levels went from, 0 to 5.6 ppb in 4 months (93-94), and CBZ
levels went from 0 to 11 ppb in 4 months (93-94),

•	At 24 Haviland Road PCE levels went from 0 to 27 ppb in 4 months (93-94), and CBZ
levels from 0 to 10 ppb in 6 months (1995).

It appears from this data that distribution of contamination levels within the plume are far
from uniform, and that levels of contamination at any particular point can easily vary from non-
detectable to above MCLs in a relatively short time period. This raises questions as to whether
the limited testing done on additional residential wells is adequate to support an assumption
that they are not currently, and will not in the future, be impacted by contamination.

In contrast to the amount of sampling data upon which EPA is basing a decision to take no
further action on homes without treatment units, Alternative AW-1 anticipates maintenance of the
treatment units until 3 years of consecutive semi-annual rounds of sampling (i.e. 6 samples over
3 years) meet MCLs.

Accuracy of modeling: Modeling based on 1987 and 1990 data predicts that the contamination plume
will not impact additional residential wells. However, modeling is not an exact science; it
predicts a range of future outcomes based on current conditions. But conditions can change; for
example, changes in water table conditions or water withdrawals could change the direction of
groundwater flow. As stated above, there is a great deal of variability in the sampling results;
how might this impact the reliability of the modeling?

For these reasons, it would seem prudent for EPA to conduct at least one more round of testing
of all of the residential wells with in the Haviland Complex site and downgradient of the
source prior to making a final decision regarding appropriate remedies.

-------
In the event that EPA determines to select remedies GW-1 and AW-1, we recommend
ongoing-monitoring, at least annually, of residential wells which do not have home treatment
units as part of the monitoring plan. Currently, Alternative AW-1 anticipates semi-annual
monitoring of all homes with treatment units, and maintenance of units, until 3 years of
consecutive semi-annual rounds of sampling meet MCLs. No additional monitoring is recommended
for the "non-treatment" homes.

In addition, monitoring wells should be sited both upgradient and down gradient of homes on
Haviland Avenue and Wright Avenue to insure the detection of any contaminant plume that may
impact the non-treatment homes. Alternative GW-1 calls for 5 monitoring wells upgradient and
downgradient of "affected" homes - it is not clear whether "affected" homes includes all 35
homes in site area, or just the homes with treatment units. If the latter, EPA should evaluate
whether 5 monitoring wells is adeguate to cover the entire area.

Benefits of providing public water supply: There are overall benefits to the community of
providing public water to the Haviland Area (Alternative AW-2). These issues are relevant to the
issue of "Community Acceptance":

•	a greater guarantee of clean water for all businesses and residents in the Haviland
Complex,

•	the elimination of the need for ongoing monitoring of all water supply wells in the
impacted area,

•	the elimination of the inconveniences and impacts on water pressure currently being
experienced by those residents with whole home treatment systems,

•	the resolution of the area residents, concerns that the water contamination problems
(real and perceived) are negatively impacting their property values, and

•	the ability of the Haviland Middle School and Ralph R. Smith Elementary School to
purchase water rather than continue to bear the ongoing operation, maintenance and
monitoring expenses, and future capital improvement expenses for their on site
supply system.

There are additional benefits to the community at large of providing public water. A connection
to the Hyde Park Fire and Water District would also benefit the other residents of the Harbourd
Hills Water District who are outside of the Haviland Complex Area. The Hyde Park Fire and Water
District currently has significant excess capacity compared to its service population. This has
created a financial hardship on district residents (regarding both operation and capital costs)
that can only be resolved by expanding the service area.

Connection of the Haviland Complex area to the Hyde Park Fire and Water District would be an
effective alternative that would satisfy the criteria of; overall Protection of Human Health
and the Environment, Compliance with ARAR's, Long-term Effectiveness and Permanence,
Implementability, and Community Acceptance. EPA should reconsider this alternative.



cc: Thomas Spence, Supervisor, Hyde Park

Paul Prentice, Harbourd Hills Water Advisory Board

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