RECORD OF DECISION
SYW-12 Site
Operable Unit of the Wastebed B/Harbor Brook Subsite of the Onondaga
Lake Superfund Site
Syracuse, Onondaga County, New York
New York State Department of Environmental Conservation
and
United States Environmental Protection Agency
Region II
March 2023
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
SYW-12 Site, an Operable Unit of the Wastebed B/Harbor Brook Subsite of the
Onondaga Lake Superfund Site
Syracuse, Onondaga County, New York
Superfund Site Identification Number: NYD986913580
Operable Unit: 28 (Operable Unit 2 of the Wastebed B/Harbor Brook Subsite)
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the New York State Department of
Environmental Conservation (NYSDEC) and U.S. Environmental Protection Agency's
(EPA's) selection of a remedy for the SYW-12 Site (Site), an Operable Unit of the
Wastebed B/Harbor Brook subsite of the Onondaga Lake Superfund site, chosen in
accordance with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. § 9601 -9675,
and the National Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300 (NCP). This decision document explains the factual and legal basis for selecting a
remedy to address the contaminated soil/fill materials and groundwater associated with
this Site. The attached index (Appendix III) identifies the items that comprise the
Administrative Record upon which the selected remedy is based.
The New York State Department of Health (NYSDOH) was consulted on the proposed
remedy in accordance with CERCLA Section 121(f), 42 U.S.C. § 9621(f), and concurs
with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances at this Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy includes the following components:
• Placement of a two-foot-thick soil cover where accessible and not detrimental to
the environment (i.e., avoiding mature tree removal, disturbance of bald eagles,
etc.), and restoring wetlands in select non-forested wetland and upland areas of
the Site. To restore the wetland areas, contaminated soil may be removed, and
either reused on-Site or disposed off-Site, prior to cover placement to a depth
necessary to preserve wetland conditions and functions. Reuse of material in
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accordance with NYSDEC DER-10 (Table 5.4(e)4), which could include use of soil
for future trail construction, will need to be compatible with wetland regulations and
will be evaluated during design. Where cover material is placed, a demarcation
layer will be evaluated during the remedial design to delineate the boundary
between the contaminated soil/fill material and the soil cover. If a demarcation
layer is necessary, it will be compatible with the wetland or tree growth, as
appropriate. The targeted remedial footprint focuses on reducing ecological
exposure while still retaining forested SYW-12 habitat to preserve areas currently
used by bald eagles for winter roosting.
• Fill material brought to this Site will need to meet the requirements for the identified
Site use as set forth in New York State regulations (6 NYCRR Part 375-6.7(d)).
Native species will be used for the vegetative component of covers.
• A tree survey and surface soil pre-design investigation will be performed to
evaluate whether additional areas should be included in the remediation footprint.
Should surface soil sampling and the tree survey indicate that elevated surface
soil/fill contaminant concentrations could be addressed without impacting large
trees (e.g., large trees and/or soils within their drip-zone would not need to be
removed or disturbed), soil excavation and/or backfilling of these areas with clean
material would be considered.
• Biota monitoring will be performed to evaluate remedy effectiveness and assess
protectiveness for ecological receptors. A baseline sampling program consisting
of two sampling events will be implemented, with subsequent sampling events
following remedy implementation using an adaptive, data-driven approach (e.g.,
years 3 and 5). A field assessment of Site vegetative community composition (e.g.,
diversity, richness, invasive species evaluation) and qualitative wildlife community
observations will be performed to support the biota monitoring program. The field
assessment will also include an evaluation of Site trees, specifically trees that
serve as roosts for bald eagles, for overall health and preservation. Specific
sample locations, species, sampling and analytical methods, and sampling
frequencies will be assessed and established during the remedial design. It is
assumed that the monitoring program will consist of analysis of soil invertebrate
and small mammal tissues, with collection of co-located surface soil/fill samples
for laboratory analysis of chemical constituents. The details related to the scope of
biota sampling will be developed during the remedial design phase.
• Periodic sampling and analysis of groundwater will be included as a means of
monitoring changes in groundwater concentrations and natural attenuation of
naphthalene. Natural attenuation of other groundwater contaminants may be
evaluated, if necessary.
• Institutional controls (ICs) in the form of environmental easements and/or
restrictive covenants will be used to limit land use to commercial (including passive
recreational), as appropriate, prevent the use of groundwater without approved
treatment, and require that any intrusive activities on the Site will be conducted in
accordance with a NYSDEC-approved Site Management Plan, which will include
the following:
¦ Institutional and Engineering Control Plan that identifies all use restrictions and
engineering controls (ECs) for the Site and documents the steps and media-
specific requirements necessary to ensure the following ECs and ICs remain in
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place and effective:
o environmental easements and/or restrictive covenants described above
o Site cover described above
o future remediation/management in areas where no cover is present at
the Site (e.g., due to erosion or changes in vegetation)
o excavation plan that details the provisions for management of future
excavations on the Site
o descriptions of provisions of the ICs, including any land use or
groundwater use restrictions
o soil vapor intrusion evaluation to be completed, and appropriate
actions implemented for any on-Site buildings (if they were to be
constructed)
o provisions for management and inspection of the identified ECs
o protection measures to be implemented while conducting any needed
subsurface soil disturbance activities, to prevent exposure to sheens or
blebs (droplets) of nonaqueous phase liquids
o maintenance of Site access controls and NYSDEC notification (e.g.,
change in Site use)
o steps necessary for periodic review and certification of the ECs and/or
ICs.
¦ Monitoring Plan to assess performance and effectiveness of the remedy.
Elements of the monitoring plan will include groundwater and biota monitoring,
assessing restoration success (e.g., wetland delineation, invasive species
management), and repair of habitat and wetlands. The final monitoring
program will be established during the design.
The cover system will require routine maintenance and inspections to maintain its
integrity. Maintenance of the cover systems may consist of cover repair in areas of
disturbance or reapplication of vegetation in areas of non-survival, as necessary.
Based on the investigations, geochemical conditions at the Site are favorable for natural
attenuation of polycyclic aromatic hydrocarbons (PAHs), including naphthalene, to occur.
The determination that natural attenuation is occurring is, in part, based upon detected
concentrations of ferrous iron, sulfide, and methane in groundwater and oxidation-
reduction potential data that suggests the presence of iron- and sulfate-reducing
conditions in groundwater. Biodegradation of naphthalene can occur under anaerobic
conditions, particularly under iron- or sulfate-reducing conditions. Further, the presence
of methane and observed decreases in groundwater concentrations of PAHs over time
(such as acenaphthene and naphthalene) indicate that natural attenuation is likely
occurring.
Environmental benefits of the selected remedy may be enhanced by utilization of
technologies and practices that are considered sustainable in accordance with EPA
Region 2's Clean and Green Energy Policy and NYSDEC's Green Remediation Policy.1
1 See http://epa.aov/reaion2/superfund/areeri remediation/ and http://www.dec.nv.aov/docs/re-
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This includes consideration of green remediation technologies and practices.
DECLARATION OF STATUTORY DETERMINATIONS
Part 1- Statutory Requirements
The selected remedy meets the requirements for remedial actions set forth in CERCLA
in Section 121, 42 U.S.C. § 9621, because, as implemented, it (1) is protective of human
health and the environment; (2) meets a level of standard of control of the hazardous
substances, pollutants, and contaminants which at least attains the legally applicable or
relevant and appropriate requirements under the federal and State laws; (3) is cost-
effective, and (4) utilizes permanent solutions and alternative treatment technologies to
the maximum extent practicable.
Part 2- Statutory Preference for Treatment
CERCLA includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous substances as a
principal element (or provide a justification for not satisfying the preference). Based on a
review of data collected at the Site and the evaluation of various remedial technologies
and alternatives, combined with the presence of a mature forested area that supports the
roosting of bald eagles at the Site, NYSDEC and EPA have determined that treatment of
contaminated soil at the Site is not practicable or cost effective.
Part 3- Five-Year Review Requirements
Because this remedy is anticipated to result in hazardous substances, pollutants, or
contaminants remaining on-Site above levels that allow for unlimited use and unrestricted
exposure, a statutory review will be conducted within five years after initiation of the
remedial action and at five-year intervals thereafter to ensure that the remedy is, or will
be, protective of human health and the environment.
ROD DATA CERTIFICATION CHECKLIST
This ROD contains the remedy selection information noted below. More details may be
found in the Administrative Record file for the selection of this remedy.
• Contaminants of concern and their respective concentrations (see ROD, pages 5-
9 and Appendix II, Tables 1-3);
• Potential land and groundwater use that will be available at this Site as a result of
the selected remedy (see ROD, page 11);
• Baseline risk represented by the contaminants of concern (see ROD, pages 11-
mediation hudsori pdfZder31.pdf
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18);
• Cleanup levels established for contaminants of concern, and the basis for these
levels (see ROD, pages 18-19 and Appendix II, Tables 1-3);
• Key factors used in selecting the remedy {i.e., how the selected remedy provides
the best balance of tradeoffs with respect to the balancing and modifying criteria,
highlighting criteria key to the decision) (see ROD, pages 40-41);
• Estimated capital, annual operation and maintenance, and present-worth costs;
discount rate, and the number of years over which the remedy cost estimates are
projected (see ROD, page 45 and Appendix II, Table 5); and
• Manner of addressing source materials constituting principal threats (see ROD,
page 46).
AUTHORIZING SIGNATURES
March 30, 2023
Andrew 0. Guglielmi, Director
Division of Environmental Remediation
NYSDEC
Date
Evangelista
Pat
Digitally signed by Pat
Evangelista
Date: 2023.03.31 13:50:11
-04'00'
Pat Evangelista, Director
Superfund and Emergency Management Division
EPA, Region 2
Date
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DECISION SUMMARY
SYW-12 Site
Operable Unit of the Wastebed B/Harbor Brook Subsite
of the Onondaga Lake Superfund Site
Syracuse, Onondaga County, New York
New York State Department of Environmental Conservation
and
United States Environmental Protection Agency
Region II
March 2023
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Table of Contents
SITE NAME, LOCATION, AND DESCRIPTION 1
SITE HISTORY 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT 4
SUMMARY OF SITE CHARACTERISTICS 5
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 11
SUMMARY OF SITE RISKS 11
REMEDIAL ACTION OBJECTIVES 18
SUMMARY OF REMEDIAL ALTERNATIVES 19
COMPARATIVE ANALYSIS OF ALTERNATIVES 27
SELECTED REMEDY 40
STATUTORY DETERMINATIONS 44
ATTACHMENTS
APPENDIX I FIGURES
APPENDIX II TABLES
APPENDIX III ADMINISTRATIVE RECORD INDEX
APPENDIX IV NYSDOH LETTER OF CONCURRENCE
APPENDIX V RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION, AND DESCRIPTION
The SYW-12 site (Site), an Operable Unit (OU)1 of the Wastebed B/Harbor Brook Subsite
of the Onondaga Lake Superfund site, is located east of Onondaga Lake in Syracuse,
New York (see Appendix I, Figure 1). The Site property is owned by Onondaga County
and includes undeveloped land and a portion of Wetland SYW-12, a 45.5-acre Class I
wetland. Portions of Wetland SYW-12 are located around the mouth of Ley Creek along
the southeastern shoreline of Onondaga Lake in Syracuse, New York (see Appendix I,
Figure 2, Site Location).
The Site is bounded by CSX railroad tracks to the north and east, Onondaga Creek to
the south, and Onondaga Lake to the west. The Lower Ley Creek subsite of the
Onondaga Lake site is also situated to the north but is being addressed as part of a
separate remedy. A figure showing the Site layout is included as Appendix I, Figure 3.
The Site encompasses approximately 23.5 acres, with 10.4 acres of upland {i.e., non-
wetland areas) and 13.1 acres of delineated wetland between Onondaga Lake and the
CSX railroad tracks (based on a 2018 wetland delineation). Mature trees typical of
floodplain forests occupy the central portion of the Site, which also serve as a roost site
for wintering bald eagles (Haliaeetus leucocephalus).
SITE HISTORY
On June 23, 1989, the Onondaga Lake site was added to the New York State Registry
of Inactive Hazardous Waste Disposal Sites. On December 16, 1994, Onondaga Lake,
its tributaries, and the upland hazardous waste sites that have contributed or are
contributing contamination to the lake (subsites) were added to the U.S. Environmental
Protection Agency's (EPA's) National Priorities List (NPL). This NPL listing means that
the lake system is among the nation's highest priorities for remedial evaluation and
response under the federal Superfund law for sites where there has been a release of
hazardous substances, pollutants, or contaminants as defined under the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or
Superfund), as amended.
1 Because many Superfund sites are complex and have multiple contamination impacts and/or
geographic areas, they are often divided into OUs for managing the site-wide response actions.
In the National Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300
(NCP), an OU is defined as "a discrete action that comprises an incremental step toward
comprehensively addressing site problems. This discrete portion of a remedial response
manages migration, or eliminates or mitigates a release, threat of a release, or pathway of
exposure. The cleanup of a site may be divided into OUs, depending on the complexity of the
problems associated with the site. OUs address geographical portions of a site, specific site
problems, initial phases of an action, or consist of any set of actions performed over time or any
actions that are concurrent but located in different parts of a site."
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The New York State Department of Environmental Conservation (NYSDEC) and EPA
have organized the work for the Onondaga Lake NPL site2 into discrete subsites, which
are considered by EPA to be OUs of the Onondaga Lake NPL site. Many of the
Onondaga Lake NPL subsites are further subdivided into OUs to address specific
geographical portions of a site or specific site problems. One of the subsites is the
Wastebed B/Harbor Brook (WBB/HB) subsite. In 2000, Honeywell and NYSDEC entered
into an administrative consent order to conduct a remedial investigation/feasibility study
(RI/FS)3 for this subsite. As documented in a July 2005 Record of Decision (ROD) issued
by EPA and NYSDEC for the Onondaga Lake Bottom subsite, the SYW-12 Site, also
known as Murphy's Island, was administratively included in the investigation of the
WBB/HB subsite. The SYW-12 Site was investigated by Honeywell as reported in the
2015 WBB/HB Revised Rl Report, 2009 Revised Human Health Risk Assessment
(HHRA) Report and hazard calculation updates (Appendix 1 of the SYW-12 Site FS
Report), 2011 Revised Baseline Ecological Risk Assessment (BERA) Report, 2014
SYW-12 Sources of Contamination Investigation Report, and 2020 Revised SYW-12
Groundwater Investigation Report.
Following NYSDEC's approval of the Rl and risk assessments for the WBB/HB subsite,
it was separated into two OUs. OU-1 includes the Lakeshore Area, the Penn-Can
Property, the Railroad Area, and two "Areas of Study," AOS#1 and AOS#2 (see
Appendix I, Figure 1). Following the issuance of an OU-1 FS Report in July 2018, a ROD
was signed in October 2018. The SYW-12 Site (which is OU-2 of WBB/HB) was
subsequently designated as New York State Inactive Hazardous Waste Site No.
734075A. The FS for the for the SYW-12 Site was completed in September 2022.
Prior to the early 1800s, the location of the future SYW-12 Site was partially under water,
with the remaining portion being wetlands containing cedar and ash trees. Both Mud
Creek (later renamed Ley Creek) and Onondaga Creek meandered across the northern
portion of the Site before flowing into Onondaga Lake. In 1822, New York State lowered
the level of Onondaga Lake by approximately 2 ft, resulting in the draining of wetlands
along the lakeshore, including a portion of the Site. The newly created land was filled in
and partitioned as building lots.
In 1873, the lower 0.75 mile of Onondaga Creek was rerouted and channelized slightly
south of the present-day Barge Canal. A channel and harbor basin were also dredged at
the mouth of Onondaga Creek as part of the construction of a large amusement complex
known as the Iron Pier Resort (see Appendix I, Figure 4). The complex included a 600-
ft pavilion that was built adjacent to the harbor. The pavilion contained venues for dining,
2 The Onondaga Lake Superfund Site's Superfund Site Identification Number is NYD986913580.
NYSDEC is the lead agency; EPA is the support agency.
3 The purpose of an Rl is to determine the nature and extent of the contamination at a site and
evaluates the associated human health and ecological risks. An FS identifies and evaluates
remedial alternatives to address the contamination at a site.
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bowling, billiards, concerts, and a carousel. Steamboats from the harbor provided
service to other resorts on the lake. The Iron Pier Resort was closed in 1906 and the
pavilion was demolished by 1908.
Following closure and demolition of the pavilion, historical maps indicate that portions of
the Site, the Iron Pier channel, and harbor basin may have been filled with refuse
materials {e.g., soda ash, waste fill) from various sources. Dredged materials were also
potentially placed on the Site because of additional changes to the Onondaga Creek
location and configuration, including dredging of the Barge Canal and harbor terminal in
1915, which relocated the channel between the pre-1873 Onondaga Creek channel and
the 1873 relocated Onondaga Creek channel. The Barge Canal was reportedly dredged
on several occasions between 1941 and 1954. The potential sources of contamination
at the Site include dredge spoils from Onondaga Creek, historic dredge material from
the southern portion of Onondaga Lake and possibly the former Marley property, the Oil
City properties, the Niagara Mohawk Hiawatha Boulevard - Syracuse Former
Manufactured Gas Plant (MGP) subsite, the Erie Boulevard former MGP site, and Ley
Creek.
Based on a review of historic aerial maps, the Site has changed in shape and size over
time as a result of dredge deposition and natural erosion but has remained undeveloped
and vegetated with low-lying vegetation, brush, and trees since the early 1900s.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS reports and a Proposed Plan detailing a proposed remedy were released to
the public for comment on January 19, 2023. These documents were made available to
the public via NYSDEC's website and at information repositories maintained at the
Atlantic States Legal Foundation and the NYSDEC Region 7 office, all located in
Syracuse, New York; and the NYSDEC Division of Environmental Remediation office,
located in Albany, New York. A NYSDEC listserv bulletin notifying the public of the
availability for the above-referenced documents, the comment period commencement
and completion dates, and the date of the public meeting was issued on January 18,
2023. A public notice providing the same information was published in the Syracuse
Post-Standard on January 19, 2023. The public comment period ran from January 19,
2023 to February 18, 2023.
On January 31, 2023, NYSDEC and EPA conducted a public meeting at the Salina Town
Hall in Salina, New York to inform local officials and interested citizens about the
Superfund process, to present the Proposed Plan for this Site, including the preferred
remedy, to respond to questions, and accept comments. There were approximately 12
people, including residents and local government employees, in attendance. Responses
to the questions and comments received at the public meeting and to comments
submitted in writing during the public comment period are included in the
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Responsiveness Summary (see Appendix V).
The Onondaga Nation reviewed the draft Rl and FS reports and draft Proposed Plan,
and NYSDEC and EPA communicated with representatives of the Onondaga Nation
about these documents. NYSDEC and EPA will continue consultation with the Onondaga
Nation and provide documents for their review throughout the design, construction and
long-term management phases of the remedy.
SCOPE AND ROLE OF OPERABLE UNIT
As was noted above, Superfund sites are often divided into OUs for managing the site-
wide response actions. NYSDEC and EPA have, to date, organized the work for the
Onondaga Lake NPL site into 11 subsites. These subsites are also considered by EPA
to be OUs of the Onondaga Lake NPL site. The following are the eleven subsites that
are being addressed:
1. Onondaga Lake Bottom (which includes Geddes Brook/Ninemile Creek as an
OU);
2. LCP Bridge Street;
3. Semet Residue Ponds;
4. Willis Avenue;
5. WBB/HB;
6. Solvay Wastebeds 1-8;
7. General Motors - Inland Fisher Guide;
8. Town of Salina Landfill;
9. Ley Creek PCB Dredgings;
10. Lower Ley Creek; and
11. Niagara Mohawk Hiawatha Boulevard - Syracuse Former MGP.
For the Onondaga Lake Bottom subsite, dredging activities and capping activities were
performed from 2012 to 2014 and in 2016, respectively. Habitat restoration activities
associated with the remedy were completed in 2017. The dredged material is being
managed at a sediment consolidation area constructed on former Solvay Wastebed 13.
Construction activities at the consolidation area, which included the placement of an
engineered cap, were completed in 2017. Remedial construction has also been fully
implemented at the Semet Residue Ponds, Wastebeds 1-8 OU-1, WBB/HB OU-1, LCP
Bridge Street, Geddes Brook/Ninemile Creek, Niagara Mohawk Hiawatha Boulevard -
Syracuse Former MGP, Salina Landfill, and the Ley Creek PCB Dredgings subsites. All
the above-noted subsites/OUs are undergoing long-term maintenance and monitoring.
Remedial actions at portions of, or environmental media {e.g., soil, groundwater) at
Wastebeds 1-8 OU-2, Willis Avenue, and General Motors - Inland Fisher Guide (OU-1
and OU-2) subsites have been completed or are in progress. Other portions of, or
media at, these subsites are in the remedial design (RD) or RI/FS phase. The Lower
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Ley Creek subsite is in the RD phase.
The response action documented in this ROD addresses the contaminated soil/fill
material and groundwater at the SYW-12 Site. NYSDEC and EPA expect this remedy
to be a final, comprehensive remedy. Because of the presence of forested areas on the
Site that are winter roosting habitat for bald eagles, some of the alternatives evaluated
in this ROD only include remediation in 8.2 to 10 acres of the 23.5-acre Site that are
accessible and/or non-forested so that the mature trees used for roosting are not
impacted. Additional discussion is provided in the alternatives described below.
SUMMARY OF SITE CHARACTERISTICS
The Rl activities that were conducted at this Site included geological and hydrogeological
investigations, a human health risk assessment, an ecological risk assessment, and the
collection of samples from the shallow soil (top two ft of soil), subsurface soil (below two
ft), and groundwater.
Based upon the results of the Rl, the primary contaminants of concern (COCs) in soil
were determined to be assorted polycyclic aromatic hydrocarbons (PAHs) {e.g.,
benzo(a)pyrene), pesticides {e.g., 4,4'-DDT), polychlorinated biphenyls (PCBs), and
metals {e.g., cadmium, chromium, mercury). Naphthalene was the only COC determined
to be applicable for groundwater.
To delineate the nature and extent of the contamination, the analytical results from the
Rl sampling were compared to the respective New York State Soil Cleanup Objectives
(SCOs) set forth at 6 NYCRR Part 375 Environmental Remediation Programs for each
land use type, including Commercial-Use SCOs (which includes passive recreational
uses, such as walking trails), Protection of Ecological Resources SCOs, and
Unrestricted-Use SCOs. The Unrestricted-Use SCOs represent the concentrations of
constituents in soil that, when achieved at a site, are sufficiently low that New York State
imposes no use restrictions on the site for the protection of public health, groundwater,
and ecological resources. Additional information can be found in the Rl and FS reports.
In Appendix II, Tables 1 and 2, there is a summary of the Unrestricted, Commercial- and
Protection of Ecological Resource SCOs exceedances in shallow and subsurface soil/fill
material for the Site. Groundwater was compared to the New York State Class GA
Standards and Guidance Values (SGVs) and is included in Appendix II, Table 3. The
results of the Rl are summarized below.
Site Geology and Hydrogeology
The local geology for the Site consists of the following:
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• unconsolidated deposits which consist of 2 to 15 feet (ft) of reworked fill consisting
of sand, silt, gravel, shell material, and concretions below a thin layer of recently
deposited wetland sediments;
• 15 to 25 ft of marl, which is a carbonate-rich sediment containing a significant
amount of shells with variable amounts of clays and silt. The 15 to 25 ft marl unit
becomes gradually finer grained with depth from a sandy, shell rich marl at the
top of the unit to clayey silt marl with a trace of shell material at the bottom of the
unit; and
• the geological units underlying the marl unit include silt and clay, silt and fine-
grained sand/basal sand and gravel, till, and bedrock, based on regional geologic
information and data collected from nearby locations.
The depth to groundwater beneath the Site ranges from approximately 3.3 to 9.2 ft below
ground surface (bgs). The groundwater occurs in the unconsolidated unit and flows
westward toward Onondaga Lake from the central and southern portions of the Site.
Groundwater on the northern portion of the Site flows north toward Ley Creek.
Shallow Soil/Fill Materials (0- to 2-feet bgs)
Volatile organic compounds (VOCs), SVOCs, pesticides, PCBs, polychlorinated
dibenzo-p-dioxins/polychlorinated dibenzofurans (PCDD/Fs), and metals were detected
in shallow soil/fill material on the Site as described below. The data were compared to
the SCOs for Commercial Use, Protection of Ecological Resources, and Unrestricted
Use (see Appendix II, Table 1).
VOCs, including chlorinated benzenes and benzene, toluene, ethylbenzene, and xylene
(BTEX) compounds, were detected in the shallow soil/fill material, but they did not
exceed the SCOs. The constituents that exceeded the SCOs for Unrestricted Use
predominantly included seven SVOCs (assorted PAHs), five pesticides (4,4'-DDT, 4,4'-
DDD, dieldrin, 4,4'-DDE, and endrin), PCBs (Aroclor 1254 and Aroclor 1260), and
inorganic compounds/metals (mercury, zinc, lead, chromium, cadmium, copper, silver,
and nickel).
Several of the above-mentioned constituents exceeded the following SCOs: (a)
Commercial Use SCOs, for four SVOCs (assorted PAHs), including benzo(a)anthracene
(maximum concentration of 7,300 micrograms per liter (|jg/kg) [Commercial Use SCO of
1,000 |jg/kg]), benzo(a)pyrene (maximum concentration of 9,100 |jg/kg [Commercial Use
SCO of 1,000 |jg/kg]), benzo(b)fluoranthene (maximum concentration of 12,000 |jg/kg
[Commercial Use SCO of 5,600 |jg/kg]), and dibenzo(a,h)anthracene (maximum
concentration of 1,100 |jg/kg [Commercial Use SCO of 560 MQ/kg]); PCBs (Aroclor 1254
and Aroclor 1260) with the highest concentration at 3,470 |jg/kg (Commercial Use SCO
of 1,000 MQ/kg); and three inorganics including mercury (maximum concentration of 8.6
mg/kg [Commercial Use SCO of 2.8 mg/kg]), copper (maximum concentration of 330
mg/kg [Commercial Use SCO of 270 mg/kg]), and cadmium (maximum concentration of
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52 mg/kg [Commercial Use SCO of 9.3 mg/kg]); and (b) Protection of Ecological
Resources SCOs were exceeded for one SVOC (benzo(a)pyrene at a maximum
concentration of 9,100 |jg/kg [Ecological Resource SCO of 2,600 |jg/kg]); five pesticides
including 4,4'-DDT (maximum concentration of 100 |jg/kg [Ecological Resource SCO of
3.3 Mg/kg]), 4,4'-DDD (maximum concentration of 73 |jg/kg [Ecological Resource SCO
of 3.3 Mg/kg]), 4,4'-DDE (maximum concentration of 3.6 Mg/kg [Ecological Resource SCO
of 3.3 Mg/kg]), dieldrin (maximum concentration of 30 Mg/kg [Ecological Resource SCO
of 6 MQ/kg]), and endrin (maximum concentration of 26 Mg/kg [Ecological Resource SCO
of 14 Mg/kg]); PCBs (Aroclor 1254 and Aroclor 1260) with the highest concentration at
3,470 Mg/kg (Ecological Resource SCO of 1,000 Mg/kg); and eight inorganic compounds
including mercury (maximum concentration of 8.6 mg/kg [Ecological Resource SCO of
0.18 mg/kg]), zinc (maximum concentration of 780 mg/kg [Ecological Resource SCO of
109 mg/kg]), lead (maximum concentration of 390 mg/kg [Ecological Resource SCO of
63 mg/kg]), chromium (maximum concentration of 410 mg/kg [Ecological Resource SCO
of 41 mg/kg]), cadmium (maximum concentration of 52 mg/kg [Ecological Resource SCO
of 4 mg/kg]), copper (maximum concentration of 330 mg/kg [Ecological Resource SCO
of 50 mg/kg]), silver (maximum concentration of 13 mg/kg [Ecological Resource SCO of
2 mg/kg]), and nickel (maximum concentration of 87 mg/kg [Ecological Resource SCO
of 30 mg/kg]).
Subsurface Soil/Fill Material (at depths greater than 2-feet bgs)
VOCs, SVOCs, pesticides, PCBs, PCDD/Fs, and inorganic compounds were detected
in subsurface soil/fill material on the Site as described below. The data were compared
to the SCOs for Commercial Use, Protection of Ecological Resources, and Unrestricted
Use (see Appendix II, Table 2).
SVOCs were detected throughout shallower subsurface soils (2 to 16 ft bgs) but were
not detected in the deeper subsurface samples. PAHs were the most commonly detected
SVOCs in the subsurface soil/fill material and accounted for most of the exceedances
observed above the Commercial Use SCOs. Limited exceedances of pesticides and
PCBs were observed with detections only between 2 and 10 ft bgs with two Commercial
Use SCO exceedances. Inorganic compounds were detected throughout the subsurface,
with Commercial Use SCO exceedances for arsenic, mercury, copper, and cadmium.
Coal tar/petroleum-like impacted soils, including blebs (droplets) of nonaqueous phase
liquids (NAPLs),4 were also identified in the location of the former Onondaga Creek
channel. Stained soil and black stained sludge were found in subsurface soil in the
central part of the Site. An evaluation of data and field observations determined that the
presence of stained soils and NAPL does not necessarily correlate with elevated
organics concentrations in soil and groundwater at proximate locations. This evaluation
4 NAPLs are persistent organic liquid contaminants that do not dissolve in, or easily mix with,
water (hydrophobic).
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included a comparison of subsurface soil data exceeding SCOs for the Protection of
Groundwater, exceedances of Class GA SGVs, and field observations of stained soils
and NAPL.
Groundwater
The groundwater analytical data were compared to the New York State Class GA
groundwater SGVs (see Appendix II, Table 3). As detailed in Appendix II, Table 3, there
were a few VOC (ethylbenzene, isopropylbenzene and xylenes) and SVOC
exceedances (4-methylphenol, 4-nitrophenol, acenaphthene, and naphthalene) of Class
GA SGVs identified during the Rl from data collected before 2015. A supplemental
groundwater investigation conducted in 2019 indicated that naphthalene, at a
concentration of 23 |jg/L in one well, was the only organic compound that marginally
exceeded the Class GA SGV (guidance value of 10 |jg/L), with slightly lower
concentrations than in historical detections (36 |jg/L in 2012). Inorganic
compounds/metals detected in Site groundwater include barium, iron, magnesium,
manganese, sodium, and chloride, with Class GA SGV exceedances primarily observed
for iron, manganese, sodium, and chloride, which may be ubiquitous in the area and/or
naturally occurring as described in the Revised SYW-12 2019 Groundwater Investigation
Report.
Polytetrafluoroethylene Sheen Net Samples
Polytetrafluoroethylene sheen net samples were collected as part of the sources of
contamination investigation. Visual observations during the test trenching within or in the
vicinity of the former Onondaga Creek channel footprint indicated that when soils were
disturbed, a sheen formed on the groundwater within the excavated trench. Results of
the sheen net sampling and PAH and petroleum biomarker analysis verified that the
sheen had been mobilized from Site soils when disturbed. Results of the sheen net
sampling and the corresponding groundwater sampling further indicate that the organic
compounds remain bound to the soils when undisturbed.
Conclusions
Based on the results of the Rl and supplemental groundwater investigation, the following
conclusions have been drawn:
• The primary Site contaminants include assorted PAHs {e.g., benzo(a)pyrene),
PCBs, and metals;
• As shown on Appendix I, Figures 5 to 10, Site contaminants in soil/fill material are
randomly distributed and are likely related to several sources, including historical
placement of fill material in the former Onondaga Creek channel/Iron Pier area,
dredge spoils from Onondaga Creek, historic dredge material from the southern
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portion of Onondaga Lake, and other potential historical sources (i.e., the former
Marley property, the Oil City properties, the Niagara Mohawk Hiawatha Boulevard
- Syracuse Former MGP subsite, the Erie Boulevard Former MGP site, and Ley
Creek). The Marley and Oil City properties are believed to have impacted the
Barge Canal sediment that was then dredged and placed on the Site during
historical dredging operations. Contamination at these properties is currently
being addressed by the potentially responsible parties for these sites under
NYSDEC and EPA oversight; and
• There are few exceedances of the Class GA SGVs for organic constituents in Rl
groundwater samples, suggesting that organic constituents in shallow and
subsurface soils are generally not mobilizing to groundwater; however,
naphthalene concentrations in subsurface soil may be contributing to localized
naphthalene being detected in groundwater in one monitoring well (HB-MW-29).
The 2019 groundwater samples indicated that naphthalene was the only organic
compound that marginally exceeded the Class GA SGV, with an overall decrease
in organic constituent concentrations over time. Geochemical conditions at the
Site are favorable for natural attenuation of naphthalene to occur.
The Site contaminants in surface soil identified during the Rl were further evaluated
during the FS to identify a targeted list of compounds (i.e., benzo(a)pyrene, 4,4'-DDT,
total PCBs, mercury, chromium and cadmium) that can serve as surrogates for other
contaminants that are most likely to drive risk and remediation, and, therefore, will be
representative chemicals for optimizing remedy protectiveness.
Contamination Fate and Transport
Natural attenuation is a variety of physical, chemical, or biological processes that, under
favorable conditions, act without human intervention to reduce the mass, toxicity,
mobility, volume, or concentration of contaminants in soil or groundwater. These in-situ
processes include biodegradation, dispersion, dilution, sorption, volatilization,
radioactive decay, and chemical or biological stabilization, transformation, or destruction
of contaminants. As a remedial strategy, these conditions are monitored to ensure that
natural attenuation is occurring. This strategy is known as monitored natural attenuation
(MNA).
Natural attenuation of organic constituents in groundwater at the Site is discussed in the
Revised SYW-12 2019 Groundwater Investigation Report. As summarized in that report,
geochemical conditions at the Site are favorable for natural attenuation of PAHs,
including naphthalene, to occur. The determination that natural attenuation is occurring
is, in part, based upon detected concentrations of ferrous iron, sulfide, and methane in
groundwater and oxidation-reduction potential data that suggest the presence of iron-
and sulfate-reducing conditions in groundwater. Biodegradation of naphthalene can
occur under anaerobic conditions, particularly under iron- or sulfate-reducing conditions.
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Further, the presence of methane and observed decreases in groundwater
concentrations of PAHs over time (such as acenaphthene and naphthalene) indicate that
natural attenuation is likely occurring.
Bald Eagles
Over the past decade, occupation of the Site by bald eagles has increased significantly,
particularly exhibited by winter roosting behavior of a large number of individuals. The
Site is recognized as a winter roosting area for bald eagles by the United States Fish
and Wildlife Service (USFWS) and NYSDEC. Bald eagles likely gather at the Site
because of the warm water outflow from the nearby Metropolitan Syracuse Wastewater
Treatment Plant which provides ice-free open water and the opportunity for eagles to
forage during winter months. The large trees at the Site serve as roosts for wintering
bald eagles. Location-specific applicable or relevant and appropriate requirements
(ARARs) related to habitat protection, including the Federal Bald and Golden Eagle
Protection Act (16 U.S.C. 668 et seq), USFWS National Bald Eagle Management
Guidelines, Conservation Plan for Bald Eagles in New York State, and 6 NYCRR 182,
provide requirements and guidance regarding the protection of bald eagle habitat,
including the "take and disturbance" of bald eagles, and limiting activities that may alter
communal roost sites and foraging areas.
As part of the FS development, USFWS provided location-specific recommendations
related to soil/fill material to be addressed, that would also preserve trees that serve as
roosts for bald eagles. The following measures were also recommended by USFWS to
provide for the continued integrity of this roost site and enable bald eagles to feed and
shelter during winter:
• Minimize tree clearing as part of remediation.
• Perform remedial activities outside the December 15 to March 15 winter roosting
season to avoid disturbance to roosting bald eagles.
NYSDEC's March 2016 Conservation Plan for Bald Eagles in New York State cited
above provides further guidelines and actions recommended for the conservation of New
York's bald eagle population and recommends that work and activities disturbing trees
be performed outside the December 1 to March 31 winter roosting season. These
measures were considered as part of the development and evaluation of remedial
alternatives, in particular when balancing potential risks with remedy elements potentially
detrimental to valuable habitat.
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CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
Land Use
The Site property is owned by Onondaga County and is zoned as parkland within the
City of Syracuse. The surrounding area is commercial. As was noted above, CSX
Railroad tracks are located immediately to the north and east of the Site. The land is
currently undeveloped and, given the prevalent wetlands throughout the Site and
proximity to the CSX Railroad tracks, future development for residential or industrial use
is unlikely. Based on the land use evaluation, the reasonably anticipated current and
future use of the Site is passive recreation as part of the Onondaga County's Loop the
Lake Trail - Southeast Extension. Ecological receptors currently use the undeveloped
areas of the Site and it is anticipated that they will continue to do so. An extension of the
Onondaga County Loop the Lake Trail, a multi-use recreational trail, was constructed on
the Site. In February 2019, NYSDEC issued a Freshwater Wetlands Permit and Section
401 Water Quality Certification for the project following an extended public comment
period and a public hearing. In January 2021, Onondaga County requested a
modification to a 2019 permit to replace a proposed steel pile boardwalk over Onondaga
Lake with a 330 linear-foot berm trail from the City of Syracuse Lake Lounge to the
wetland boundary. The multi-use recreational trail construction includes a wooden
boardwalk within wetland areas and a minimum 1 ft of cover for passive recreational use
within the trail footprint in non-boardwalk areas in addition to ICs and signage to keep
trail users on the established trail.
SUMMARY OF SITE RISKS
As part of the Rl, baseline quantitative risk assessments were conducted for this Site to
estimate the risks to human health and the environment (under current and anticipated
future land uses). A baseline human health risk assessment (BHHRA) evaluates
potential risks to people, and a baseline ecological risk assessment (BERA) evaluates
potential risks to the environment; both analyze the potential for adverse effects caused
by hazardous substance releases from a site assuming no further action to control or
mitigate exposure to these hazardous substances are taken.
Human Health Risk Assessment
A BHHRA was conducted to estimate current and future effects of contaminants on
human health. A BHHRA is an analysis of the potential adverse human health effects
caused by hazardous substance exposure in the absence of any actions to control or
mitigate these exposures under current and future site uses. If it is determined that an
unacceptable risk exists, the BHHRA provides the basis for taking an action and
identifies the contaminants and exposure pathways that need to be addressed through
implementation of a remedial action. This section of the ROD summarizes the results of
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the BHHRA for this site.
A four-step process is utilized for assessing site-related human health risks for
reasonable maximum exposure scenarios, as follows:
Hazard Identification - uses the analytical data collected to identify the
contaminants of potential concern (COPCs) for each medium, with consideration of a
number of factors explained below.
Exposure Assessment - estimates the magnitude of actual and/or potential
human exposures, the frequency and duration of these exposures, and the pathways
(e.g., ingesting contaminated soil) by which humans are potentially exposed.
Toxicity Assessment - determines the types of adverse health effects
associated with chemical exposures, and the relationship between magnitude of
exposure (dose) and severity of effect (response).
Risk Characterization - summarizes and combines outputs of the exposure and
toxicity assessments to provide a quantitative assessment of site-related risks. The risk
characterization also identifies contamination with concentrations that exceed
acceptable levels, defined in the NCP as an excess lifetime cancer risk greater than 1 x
10_6to 1 x 10"4 or a Hazard Index greater than 1.0 (discussed in more detail, below);
contaminants at these concentrations are considered COCs and are typically those that
will require remediation at a site. Also included in this section is a discussion of the
uncertainties associated with these risks.
Hazard Identification
In this step, analytical data collected during the Rl was used to identify COPCs in site
media based on factors such as toxicity, frequency of detection, fate and transport of the
contaminants in the environment, concentrations of the contaminants, as well as their
mobility and persistence. The HHRA characterized the risk to human health from
exposure to soil and groundwater at the Site. COPCs were determined for each exposure
area and medium by comparing the maximum detected concentrations of each chemical
identified with state and federal risk-based screening values.
Exposure Assessment
In this step, the different exposure scenarios and pathways through which people might
be exposed to the contaminants identified in the previous step are evaluated. Consistent
with Superfund policy and guidance, the BHHRA is a baseline assessment and therefore
assumes a scenario where no remediation or institutional controls (ICs) to mitigate or
remove hazardous substance releases occurs. Cancer risks and noncancer hazard
indices are calculated based on an estimate of the reasonable maximum exposure
(RME) expected to occur under current and potential future conditions at a site. The
RME is defined as the highest exposure that is reasonably expected to occur at a site.
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The exposure assessment identified potential human receptors based on a review of
current and reasonably foreseeable future land use at this Site. Exposure scenarios
were developed taking into account how receptors currently and potentially in the future
might access these areas through reasonable activities. Receptors evaluated in the
BHHRA include current and future child and adult recreational visitors, railroad workers,
and utility workers, as well as future construction workers, commercial/industrial workers,
and child and adult residents.
Recreational and railroad worker receptors were assumed to be exposed to surface soil
via ingestion, dermal contact, and inhalation of fugitive dust or volatile emissions. Utility
and construction worker exposure to surface and subsurface soil to a depth of less than
or equal to 10 ft {i.e., surface and subsurface soil) was based on ingestion, dermal
contact, fugitive dust or volatile emissions, and groundwater present during excavations
necessary for work. The resident and the commercial/industrial worker receptors were
assumed to be exposed to surface soil via incidental ingestion, dermal contact, and
inhalation of particulate dust or volatile emissions. Inhalation of vapors in the
occupational workspace or residence from vapor intrusion was also evaluated as a viable
exposure pathway. Exposure to groundwater in the future for residents via ingestion,
dermal contact, and inhalation of vapors while showering was evaluated, as well. The
specific exposure scenarios are presented in Appendix II, Table 4.
Toxicity Assessment
In this step, the types of adverse health effects associated with contaminant exposures
and the relationship between the magnitude of exposure and the severity of adverse
health effects were determined. Potential health effects are contaminant-specific and
may include the risk of developing cancer over a lifetime or other noncancer health
effects, such as changes in the normal functions of organs within the body {e.g., changes
in the effectiveness of the immune system). Some contaminants are capable of causing
both cancer and noncancer health effects.
Under current EPA guidelines, the likelihood of carcinogenic risks and noncancer
hazards that are due to exposure to site chemicals are considered separately.
Consistent with current EPA policy, it was assumed that the toxic effects of any site-
related chemicals would be additive. Thus, cancer and noncancer risks associated with
exposures to individual COPCs were summed to indicate the potential risks and hazards
associated with mixtures of potential carcinogens and noncarcinogens, respectively.
Toxicity data for the HHRA were taken from the Integrated Risk Information System
database, the Provisional Peer Reviewed Toxicity Database, or another source that is
identified as an appropriate reference for toxicity values consistent with EPA's directive
on toxicity values.
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Risk Characterization
This step summarizes and combines outputs of the exposure and toxicity assessments
to provide a quantitative assessment of Site risks. Exposures were evaluated based on
the potential risk of developing cancer and the potential for noncancer health hazards.
For carcinogens, risks are generally expressed as the incremental probability of an
individual developing cancer over a lifetime as a result of exposure to a carcinogen, using
the cancer slope factor (SF) for oral and dermal exposures and the inhalation unit risk
(IUR) for inhalation exposures. Excess lifetime cancer risk for oral and dermal exposures
is calculated from the following equation, while the equation for inhalation exposures
uses the IUR, rather than the SF:
Risk = LADD x SF
where: Risk = a unitless probability (1 x 10~6) of an individual developing cancer
LADD = lifetime average daily dose averaged over 70 years (milligrams
per kilogram [mg/kg]-day)
SF = cancer slope factor, expressed as 1/(mg/kg-day)
The likelihood of an individual developing cancer is expressed as a probability that is
usually expressed in scientific notation (such as 1 x 10"4). For example, a 1 x 10~4 cancer
risk means a "one-in-ten-thousand excess cancer risk"; or one additional cancer may be
seen in a population of 10,000 people as a result of exposure to site contaminants under
the conditions described in the exposure assessment. Current Superfund guidelines for
acceptable exposures are an individual lifetime excess cancer risk in the range of 10"4 to
10~6 (corresponding to a one-in-ten-thousand to a one-in-a-million excess cancer risk).
For noncancer health effects, a hazard index (HI) is calculated. The HI is determined
based on a comparison of expected contaminant intakes and benchmark comparison
levels of intake (reference doses, reference concentrations). Reference doses (RfDs)
and reference concentrations (RfCs) are estimates of daily exposure levels for humans
(including sensitive individuals) that are thought to be safe over a lifetime of exposure.
The estimated intake of chemicals identified in environmental media (e.g., the amount of
a chemical ingested from contaminated drinking water) is compared to the RfD or the
RfC to derive the hazard quotient (HQ) for the contaminant in the particular medium. The
HI is determined by adding the hazard quotients for all compounds within a particular
medium that impacts a particular receptor population.
The HQ for oral and dermal exposures is calculated as shown below.
HQ = Intake/RfD
where: HQ = hazard quotient
Intake = estimated intake for a chemical (mg/kg-day)
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RfD = reference dose (mg/kg-day)
The intake and the RfD will represent the same exposure period (i.e., chronic,
subchronic, or acute).
The HQ for inhalation exposures is calculated using a similar model that incorporates
the RfC, rather than the RfD.
The principal concept for a noncancer HI is that a "threshold level" (measured as an HI
of less than 1.0) exists below which noncancer health effects are not expected to occur.
The HI is calculated by summing the HQs for all chemicals for likely exposure scenarios
for a specific population. An HI greater than 1 indicates that the potential exists for non-
carcinogenic health effects to occur as a result of site-related exposures, with the
potential for health effects increasing as the HI increases. When the HI calculated for all
chemicals for a specific population exceeds 1, separate HI values are then calculated for
those chemicals which are known to act on the same target organ. These discrete HI
values are then compared to the acceptable limit of 1 to evaluate the potential for
noncancer health effects on a specific target organ. The HI provides a useful reference
point for gauging the potential significance of multiple contaminant exposures within a
single medium or across media.
Results
At this Site, the cancer risks and noncancer hazards were estimated for each of the
exposure areas/media and the risk was evaluated for the specific populations identified
in each unit under current and reasonably anticipated future use. The initial risk
assessment for the Site was completed in 2009. Since that time, EPA reevaluated and
updated toxicity information for PAHs and issued new guidance on the methodology for
assessing risks associated with the inhalation pathway of exposure. To incorporate these
updates, risk calculations for soil exposures were revised in 2018 and 2022. The
conclusions of these evaluations indicate that the lifetime excess cancer risks and
noncancer hazards for current/future utility workers, passive recreational users, and
railroad workers, as well as future commercial/industrial workers and adult residents, are
below the regulatory risk thresholds. Cancer risks are also within the target risk range for
future construction workers and child residents. Elevated hazard was identified for future
child residents exposed to highly chlorinated PCBs in surface soil and for construction
workers by exposure to chromium and benzo(a)pyrene in groundwater. However, the
anticipated future land use of the Site does not include residential use and the
unacceptable hazard posed by chromium and benzo(a)pyrene to construction workers
was based on the results obtained during the Rl; sampling subsequent to the Rl indicates
the absence of chromium and benzo(a)pyrene in groundwater underlying the Site. A
summary of the cancer risks and noncancer hazards above threshold levels for each
population, along with the chemicals that contribute the most to the risk or hazard, or
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COCs, can be found in Appendix II, Table 4.
The vapor intrusion screening in the BHHRA identified chemicals with a potential to
migrate to indoor air, based on factors such as the chemical-specific vapor pressure.
Because these factors apply to chemicals present in media, such as soil, fill material,
and groundwater, all media with these chemicals have the potential for future vapor
intrusion concerns. Naphthalene was identified and retained as a vapor intrusion COPC
because of its maximum detected concentration in Site groundwater exceeded its
groundwater vapor intrusion screening level. Based on the vapor intrusion screening,
measures may be included in the design and construction of buildings at this Site to
mitigate the potential for exposure to constituents that may be present in soil vapor. Such
measures may include an active sub-slab depressurization system, use of a vapor barrier
or the installation of a venting system. It should be noted that the anticipated future use
does not include buildings in the predominantly wetland area.
Uncertainty in the Risk Assessment
The process of evaluating human health cancer risks and noncancer health hazards
involves multiple steps. Inherent in each step of the process are uncertainties that
ultimately affect the final risks and hazards. Important site-specific sources of uncertainty
are identified for each of the steps in the four-step risk process below.
Uncertainties in Hazard Identification
Uncertainty is always involved in the estimation of chemical concentrations. Errors in
the analytical data may stem from errors inherent in sampling and/or laboratory
procedures. While the datasets for this Site are robust, because environmental samples
are variable, the potential exists that these datasets might not accurately represent
reasonable maximum concentrations. There is a low potential that the risks may be
overestimated or underestimated.
Uncertainties in Exposure Assessment
There are two major areas of uncertainty associated with exposure parameter
estimation. The first relates to the estimation of exposure point concentrations (EPCs).
The second relates to parameter values used to estimate chemical intake {e.g., ingestion
rate, exposure frequency). The estimates of the EPCs are influenced on how likely the
dataset fully characterizes the contamination at the Site. These datasets are robust, so
the potential for overestimating or underestimating risk is low. Many of the exposure
parameters used in the BHHRA are based on best professional judgement, but are
meant to be health protective. Therefore, there is a low potential that the risks may be
underestimated.
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Uncertainties in Toxicity Assessment
A potentially large source of uncertainty is inherent in the derivation of the EPA toxicity
criteria {i.e., RfDs, RfCs, SFs, lURs) through extrapolating data from animals to humans
and from high to low doses of exposure. Although these criteria have been extensively
reviewed and peer-reviewed, there is a medium potential that uncertainty factors applied
during their derivation may result in overestimation or underestimation of toxicity.
Nevertheless, these uncertainties are addressed by making conservative assumptions
concerning risk and exposure parameters throughout the risk assessment. As a result,
the risk assessment provides upper-bound estimates of risk and is unlikely to
underestimate actual risks related to the Site. However, there are many contaminants
for which no toxicity values are available and therefore they are not quantitatively
evaluated in the BHHRA. For these chemicals, there is potential for underestimation
because of this lack of toxicity information.
Uncertainties in Risk Characterization
When all of the uncertainties from each of the previous three steps are added,
uncertainties are compounded. Because it is unknown whether many of the uncertainties
result in an overestimation or underestimation of risk, the overall impact of these
uncertainties is unquantifiable. However, some of the uncertainties, such as the lack of
toxicity information, will likely result in an overall underestimation of risk.
Ecological Risk Assessment
The BERA for the Site identified current and future habitat use and potential ecological
receptors. Based on the ecological receptors identified, potentially unacceptable risk was
driven by the following constituents by receptor for the Site Exposure Area:
• Potential risk to terrestrial plants is driven by 11 metals via exposure to surface
soil based on average concentrations throughout the exposure area exceeding
screening criteria for the protection of plants.
• Potential risk to soil invertebrates is driven by five metals via exposure to surface
soil based on exceedances of screening criteria for the protection of soil
invertebrates and microfauna.
• Potential food chain bioaccumulation risks for insectivorous birds, as represented
by the American robin (Turdus migratorius), exceeded the risk threshold {i.e.,
hazard quotient [HQ] > 1.0) for lowest effect dose levels for six metals and four
organic compounds in surface soil.
• Risks to insectivorous mammals from food chain exposure, as represented by the
short-tailed shrew {Blarina brevicauda), exceeded 1.0 based on lowest effect level
doses for five metals and five organic compounds in surface soil.
• Potential food chain risks to carnivorous mammals, as represented by the red fox
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(Vulpes vulpes), are considered nominal for each constituent with the exception
of chromium.
• Risks to carnivorous mammals from food chain exposure, as represented by the
red-tailed hawk (Buteo jamaicensis), did not exceed 1.0 for any constituent based
on lowest effect level doses.
• Potential risks to predatory mammals that may forage on terrestrial mammals and
fish in the lake area abutting the Site, as represented by the mink (Neovison
vison), are considered nominal given that no HQs based on lowest effect level
doses exceeded 1.0.
In summary, the conclustions in the BERA indicate that select metals and organic
compounds, namely chromium, cadmium and PCBs, pose a potential risk to communities
or organisms and to bird and mammal populations with relatively restrictive home ranges
{e.g., American robin and short-tailed shrew). A full discussion of these evaluations and
conclusions is presented in the BERA report.
Summary of Human Health and Ecological Risks
The results of the HHRA and post-HHRA evaluations indicate that exposure to
contaminated soil, indoor air, and groundwater present current and/or potential future
unacceptable risks, and the ecological risk assessment indicates that the contaminated
soils pose an unacceptable risk.
Based upon the results of the Rl and the risk assessments, EPA and NYSDEC have
determined that actual or threatened releases of hazardous substances from the Site, if
not addressed by the preferred remedy or one of the other active measures considered,
may present a current or potential threat to human health and the environment.
Basis for Action
The selected remedy described in this ROD is necessary to protect public health and the
environment from actual or threatened releases of hazardous substances.
REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are specific goals to protect human health and the
environment based on conditions at a site. These objectives are based on available
information and standards, such as ARARs, to-be-considered guidance, and site-specific
risk-based levels established using the risk assessments. Based on consideration of
potential chemical-specific ARARs, nature and extent of contamination, potentially
unacceptable risks, the current, intended and reasonably anticipated future use of the
Site and its surroundings, and the recognized value of and use of the forested areas of
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the Site by the bald eagle, the following RAOs have been established for the Site:
Groundwater
RAO for Public Health Protection
• Prevent ingestion of groundwater with contaminant levels exceeding drinking
water standards and/or guidance values.
Soil
RAOs for Public Health Protection
• Prevent ingestion/direct contact with contaminated soil above remedial goals
and/or that result in unacceptable risk.
• Prevent inhalation of or exposure from contaminants volatilizing from
contaminants in soil.
RAOs for Environmental Protection
• Prevent impacts to biota from ingestion/direct contact with soil causing toxicity or
impacts from bioaccumulation through the terrestrial food chain.
• Prevent or reduce the migration of contaminants that would result in sediment or
surface water contamination.
Vapor Intrusion
RAO for Public Health Protection
• Mitigate impacts to public health resulting from existing, or the potential for, vapor
intrusion.
NYSDEC's SCOs for Commercial Use and the Protection of Ecological Resources have
been identified as remediation goals for soil to attain these RAOs. SCOs are risk-based
criteria that have been developed by the State following methods consistent with EPA's
methods/protocols/guidance, and they are set at levels consistent with EPA's acceptable
levels of risk that are protective of human health and ecological exposure depending
upon the existing and anticipated future use of the Site. While the land use of the Site
has historically been vacant, current and anticipated future uses of some areas could
include commercial use (including passive recreational use such as a trail). Groundwater
remedial goals are the New York State Ambient Water Quality Standards.
COCs identified for the Site include benzo(a)pyrene and other PAHs; 4,4'-DDT and other
pesticides; PCBs; and cadmium, chromium, mercury and other metals.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA Section 121(b)(1), 42 U.S.C. § 9621(b)(1), mandates that remedial actions
must be protective of human health and the environment, cost-effective, and utilize
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permanent solutions and alternative treatment technologies and resource recovery
alternatives to the maximum extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions that employ, as a principal element, treatment to
permanently and significantly reduce the volume, toxicity, or mobility of the hazardous
substances, pollutants and contaminants at a site. CERCLA Section 121(d), 42 U.S.C.
§ 9621(d), further specifies that a remedial action must attain a level or standard of
control of the hazardous substances, pollutants, and contaminants, which at least attains
ARARs under federal and state laws, unless a waiver can be justified pursuant to
CERCLA Section 121(d)(4), 42 U.S.C. § 9621(d)(4).
Based on the anticipated future development of this Site, expectations of the reasonably-
anticipated future land use, as described above, were considered in the FS to facilitate
the development of remedial alternatives. The reasonably-anticipated land use includes
commercial use (e.g., passive recreational use) and ecological use.
For all the alternatives other than the no action alternative, all of the RAOs, except
restoring the groundwater to levels that meet state and federal standards, would be met
following construction and implementation of appropriate ICs {e.g., estimated one to
seven years). The estimated time to restore the groundwater to the New York State Class
GA guidance value of 10 |jg/L for naphthalene for all the alternatives, other than the no
-action alternative, is approximately seven years. These estimates, which are discussed
above, used available data for groundwater collected from the Site and were based on
conservative assumptions. Additional data {e.g., groundwater) would be collected to
refine the estimated timeframe for restoration and long-term monitoring will be
performed.
As presented in the FS Report, an evaluation of surface soil Area-Weighted Average
Concentrations (AWACs) was conducted to further understand and evaluate surface soil
concentrations pre- and post-remedy implementation relative to NYSDEC's SCOs.
AWACs are calculated concentrations of select constituents representative of site-wide
conditions that facilitate comparisons between existing conditions and future conditions
following implementation of potential remedial alternatives. To develop AWACs,
computer software is used to interpolate concentrations between sample locations from
known sample data based on the premise that closer values are more similar than values
farther away and therefore the closer values should have greater influence, or weight, in
the averaging process. The result is a grid or an array of cells (2 ft x 2 ft) encompassing
the entire site with each cell assigned a sample concentration. The calculated AWAC for
a given constituent is equal to the average concentration of the interpolated grid and
represents the pre-remediation AWAC for that constituent. Where remedial activities are
proposed, the exercise is repeated using representative topsoil concentrations within the
remedial footprint and the remaining surface soil concentration in undisturbed areas. The
existing AWAC concentrations are then compared to the post-remediation AWAC results
to assess improvement and protectiveness of remedial alternatives relative to existing
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conditions. Appendix 8 of the FS Report presents additional details on the site-specific
approach to calculating AWACs. Discussion of this evaluation is presented below under
the Comparative Analysis of Alternatives heading.
The remedial alternatives are as follows:
Alternative 1 - No Action
The Superfund program requires that the "no action" alternative be considered as a
baseline for comparison with the other alternatives. The no action remedial alternative
would be that no measures would be taken to address the soil/fill material and
groundwater contamination at this Site.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Capital Cost: $0
Annual O&M Cost: $0
Present-Worth Cost: $0
Alternative 2 - Soil Cover in Select Areas, Wetland Restoration, Biota Monitoring,
and Monitored Natural Attenuation
This alternative includes the placement of a soil cover where accessible and not
detrimental to the environment {i.e., avoiding mature tree removal, disturbance of bald
eagles, etc.) and restoring wetlands in select non-forested wetland and upland areas of
the Site. The 2-ft-thick soil cover would be placed on an approximately 8.2-acre area,
which includes 7.5 acres of non-forested wetland (perched wetland cover areas shown
on Appendix I, Figure 11) and 0.7 acres of non-forested upland. The soil cover would
control potential erosion of, and direct contact with, contaminated soil/fill material, as well
as control the potential inhalation of dust in these areas. To restore wetland areas,
contaminated soil may be removed, and either reused on-Site or disposed of off-Site,
prior to cover placement with clean fill to a depth necessary to preserve wetland
conditions and functions. Reuse of excavated material in accordance with NYSDEC
DER-10 (Table 5.4(e)4), which could include use of soil for future trail construction, would
need to be compatible with wetland regulations and would be evaluated during design.
It is estimated that clean backfill would be transported to the Site, resulting in
approximately 2,450 dump truck trips {i.e., round-trip with a 10-yard dump truck). The
remedial footprint is targeted to reduce ecological exposure while still retaining forested
SYW-12 habitat to preserve areas currently used by bald eagles for roosting. Specifically,
damage to root zones through the placement of soil cover material which would limit
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oxygen supply to the tree roots and/or removal of mature trees used for eagle roosting
would be avoided under this alternative. The remediated areas would be restored and
biota monitoring would be performed. As described in the "Bald Eagles" section above,
because of special considerations being given to the forested area that provides bald
eagle habitat, surface soil in non-remediated areas may exceed Commercial Use and
the Protection of Ecological Resources SCOs where cover would not be placed.
A surface soil pre-design investigation and tree survey would be performed to evaluate
adding additional areas to the remediation footprint. The areas for consideration include
two areas within the forested wetland characterized by scrub vegetation on the northern
portion of the Site, four areas within the non-forested wetland on the western portion of
the Site, and one upland forested area on the southern portion of the Site (purple outlined
areas on Appendix I, Figure 11), although other areas could also be considered. Should
surface soil sampling and the tree survey indicate that elevated surface soil/fill material
contaminant concentrations could be addressed without impacting large trees {i.e., large
trees and/or soils within their drip-zone would not need to be removed or disturbed), soil
excavation and/or backfilling of these areas with clean material would be considered.
To minimize loss of wetland acreage or function, wetland conditions and functions would
be integrated into the areas where the cover would be placed within the current wetland
footprint. To improve the success of the restored wetlands, the remedial design would
consider excavation and/or grading to allow wetland functions and values. An evaluation
would be conducted as part of the cover design to promote sufficient flooding and
saturation to facilitate the development of wetland soils and hydrology appropriate for
native plants and other habitat in conjunction with grading/soil profile design such that
wetland conditions and functions are replaced. Where the water budget and/or grading
cannot replace wetland conditions or functions, additional mitigation measures would be
included during the design.
The soil covers would also be installed to support and preserve existing mature trees
present proximate to the proposed cover to allow for future tree succession. Additional
tree-planting may be performed as part of restoration. Where cover material is placed,
a demarcation layer would be evaluated during the remedial design to delineate the
boundary between the contaminated soil/fill material. If a demarcation layer is
necessary, the soil cover would be compatible with the wetland or tree growth, as
appropriate. The demarcation layer would provide evidence of cap erosion and provide
a warning that contaminated material may exist below.
Excavated soil reuse options and limitations {e.g., within wetland areas), impacts to the
bald eagle habitat, and the final wetland restoration approach, including opportunities to
improve wetland functions and values, planting of trees, and sustainable remediation
principles would be further evaluated during the pre-design and design phases. Should
reuse of excavated/graded/handled materials not be possible at the Site following
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remedial design evaluations, the material would need to be managed off-Site.
Because of the Onondaga County trail construction, geotechnical concerns, and
discussion and coordination with railroad operations, the boundaries of the remedy
illustrated in Appendix I, Figure 11 are conceptual. It is anticipated that there would be
no excavation in wetland areas adjacent to the railroad tracks based on stability
concerns. Mitigation would be necessary where construction results in a loss of wetland
acreage or function, and wetland conditions cannot be returned. The extent of the cover
would be revisited during the design phase based on pre-design sampling and other
activities and in consideration of the trail alignment. Onondaga County has included
signage requiring recreational users to remain on the trail. The potential need for
additional measures {e.g., fencing/railing, maintaining dense vegetation along the trail,
additional/improved signage, and/or sampling) would be reviewed during the design
phase and based on management of the trail.
Biota monitoring would be performed to evaluate remedy effectiveness and assess
protectiveness of ecological receptors. A baseline sampling program, consisting of two
sampling events, would be implemented with subsequent sampling events following
remedy implementation using an adaptive, data-driven approach {e.g., years 3 and 5). A
field assessment of Site vegetative community composition {e.g., diversity, richness,
invasive species evaluation) and qualitative wildlife community observations would be
performed to support the biota monitoring program. The field assessment would also
include an evaluation of Site trees, specifically trees that serve as roosts for bald eagles,
for overall health and preservation. Specific sample locations, species, sample and
analytical methods, and frequencies would be assessed and established during the
remedial design. It is assumed that the monitoring program would consist of analysis of
soil invertebrate and small mammal tissue, with collection of co-located surface soil/fill
material samples for laboratory analysis of chemical constituents. The details related to
the scope of biota sampling would be developed during the remedial design phase.
Periodic sampling and analysis of groundwater would be included as a means of
detecting changes in groundwater concentrations and monitoring of the natural
attenuation of naphthalene in groundwater. Natural attenuation of other contaminants
may be evaluated, if necessary. Specific monitoring locations, parameters, and
frequencies would be established during remedial design. For cost estimation purposes,
it was assumed that the monitoring program would consist of semi-annual sampling of
ten monitoring wells with analyses for VOCs, SVOCs (including PAHs), metals, mercury,
cyanide, and cations/anions. However, the specific number of wells and analyses will
be determined during remedial design or site management.
Fill material brought to this Site will need to meet the requirements for the identified Site
use as set forth in New York State regulations (6 NYCRR Part 375-6.7(d)). Native
species will be used for the vegetative component of covers.
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The cover system would require routine maintenance and inspections to maintain its
integrity. Maintenance of the cover systems may consist of cover repair in areas of
disturbance or reapplication of vegetation in areas of non-survival, as necessary.
ICs in the form of environmental easements and/or restrictive covenants would be used
to limit land use to commercial (including passive recreational), as appropriate, prevent
the use of groundwater without approved treatment and require that any intrusive
activities on the Site would be conducted in accordance with a NYSDEC-approved Site
Management Plan (SMP), which would include the following:
• Institutional and Engineering Control Plan that identifies all use restrictions and
engineering controls (ECs) for the Site and documents the steps and media-specific
requirements necessary to ensure the following ECs and ICs remain in place and
effective:
o environmental easements and/or restrictive covenants described above
o Site cover described above
o future remediation/management in areas where no cover is present at the
Site {e.g., due to erosion or changes in vegetation)
o excavation plan that details the provisions for management of future
excavations on the Site
o descriptions of the provisions of the ICs, including any land use or
groundwater use restrictions
o soil vapor intrusion evaluation to be completed, and appropriate actions
implemented for any on-Site buildings (if they were to be constructed)
o provisions for the management and inspection of the identified ECs
o protection measures to be implemented while conducting any needed
subsurface soil disturbance activities, to prevent exposure to sheens or
blebs of NAPL
o maintenance of Site access controls and NYSDEC notification {e.g.,
change in Site use)
o steps necessary for periodic reviews and certification of the ECs and/or
ICs.
• Monitoring Plan to assess the performance and effectiveness of the remedy.
Elements of the monitoring plan will include groundwater and biota monitoring,
assessing restoration success {e.g., wetland delineation, invasive species
management) and repair of habitat and wetlands. The final monitoring program
would be established during the design.
Because this alternative would result in contaminants remaining above levels that allow
for unrestricted use and unlimited exposure, CERCLA requires that the remedy for the
Site be reviewed at least once every five years.
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The estimated construction time of this alternative is one construction season.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Alternatives 3A/3B - Surface Excavation with On-Site Reuse or Off-Site Disposal
and Soil Cover/Wetland Restoration on Perimeter and Interior Areas, Biota
Monitoring, and Monitored Natural Attenuation, with Limited Tree Removal
This alternative is similar to Alternative 2, except that it includes remediation in an
additional 1.8 acres in not readily accessible non-forested wetland areas (perimeter and
interior wetlands). Excavation of approximately 21,000 cubic yards (cy) of surface soil/fill
material (up to 2 ft bgs) over 7 acres would be performed prior to placement of the soil
cover. In addition to the 8.2 acres of perimeter wetlands addressed under Alternative 2
with a cover, this alternative also includes an additional 1.3 acres of cover to address
interior wetland areas as indicated on Appendix I, Figure 12. Disturbance of
approximately 0.5 acres of forested upland/wetlands, which would result in the removal
of trees, would be needed to construct a road to access the 1.3 acres of non-forested
wetlands, and the soil cover would be extended over these 0.5 acres. The total
anticipated acreage of the soil cover is approximately 10 acres. Pre-design surface soil
sampling and a tree survey would be performed to evaluate the potential need to address
contaminated surface soil/fill material in approximately 1 acre of additional wetland and
upland areas based on surface soil SCOs, including one upland forested area on the
southern portion of the Site and two areas of forested wetland on the northern portion of
the Site. However, because of the special considerations being given to the forested
area that provides bald eagle habitat, surface soil in non-remediated areas may exceed
Commercial Use and the Protection of Ecological Resources SCOs in areas where a soil
cover is not being placed.
Excavated contaminated soil/fill material management options are included as variations
of Alternative 3. Specifically, on-Site reuse and off-Site disposal options to a permitted
facility are presented as Alternatives 3A and 3B, respectively. Alternative 3A is
anticipated to result in approximately 2,650 dump truck trips, while Alternative 3B is
anticipated to result in 4,200 dump truck trips because of the off-Site disposal of
excavated soil/fill material. Because of the Onondaga County trail construction,
geotechnical concerns, and discussion and coordination with railroad operations, the
boundaries of the remedy illustrated in Appendix I, Figure 12 are conceptual.
Annual O&M Costs:
Capital Cost:
Present-Worth Cost:
$7,530,000
$181,000
$8,300,000
Because this alternative would result in contaminants remaining above levels that allow
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for unrestricted use and unlimited exposure, CERCLA requires that the remedy for the
Site be reviewed at least once every five years.
The estimated construction time of this alternative is one to two construction seasons.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Alternative 4 - Full Removal and Off-Site Disposal with Wetland Restoration and
Monitored Natural Attenuation
Alternative 4 includes the mechanical excavation of soil/fill material within the forested
and non-forested areas of the Site exhibiting concentrations above 6 NYCRR Part 375
Unrestricted Use SCOs (Appendix I, Figure 13). This is anticipated to require the removal
of material as deep as 16 ft bgs. Approximately 400,000 cy of contaminated soil/fill
material would be excavated and disposed off-Site under this alternative. The excavated
areas would be backfilled with clean fill. Excavated wetland areas would be backfilled to
existing grade using materials appropriate for wetland establishment. Appropriate
wetland species would be planted to reestablish both forested and non-forested wetlands
to include wetland vegetation, shrubs and trees.
Given the number of trees and larger organic debris {e.g., chipped mature trees and
brush) that would be generated from clearing, it is estimated that 900 tons of organic
debris would also require off-Site transport and management. In addition, this alternative
would include monitoring the natural attenuation of naphthalene in the groundwater. The
timeframe for the naphthalene to achieve groundwater standards would be the same as
for Alternative 2. Groundwater monitoring would be performed as part of site
management.
It is estimated that 600,000 tons of excavated soil/fill material would be transported and
disposed off-Site to a permitted facility. It is estimated that the soil/fill and organic debris
would be transported off-Site over the course of four construction seasons, resulting in
approximately 56,000 truck trips. Because of the required 30-ft setback from the adjacent
CSX Railroad tracks, impacted material may need to remain on-Site. Therefore, ICs, a
SMP, and periodic reviews, as described under Alternative 2, may be necessary.
Capital Cost:
Annual O&M Costs:
Present-Worth Cost:
Alternative 3A
(On-Site Reuse)
$21,110,000
$185,000
$21,900,000
Alternative 3B
(Off-Site Disposal)
$26,150,000
$185,000
$27,000,000
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ECs (i.e., sheet piling and bulkhead) would be necessary along the perimeter of the Site
to maintain stability of the excavation walls, prevent potential impacts to the railroad
tracks, and to prevent inundation from Onondaga Lake, Onondaga Creek and Ley Creek.
Further geotechnical evaluations would be necessary to evaluate sheet pile installation
in the vicinity of the railroad.
It is assumed that the soil/fill material excavated below the groundwater table would need
to be dewatered prior to off-Site transportation and disposal. Treatment of this
construction water is anticipated to be necessary; a temporary water treatment facility
would be utilized to treat this construction water. Treated construction water would be
managed in a manner and in accordance with discharge requirements to be determined
by NYSDEC during the remedial design phase.
Because additional geotechnical evaluations and discussion and coordination with
Onondaga County and railroad operations would need to be conducted, the remedy
depiction illustrated in Appendix I, Figure 13 is conceptual.
Because this alternative would result in contaminants remaining above levels that allow
for unrestricted use and unlimited exposure, CERCLA requires that the remedy for the
Site be reviewed at least once every five years.
The estimated construction time of this alternative is five to seven construction seasons.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
COMPARATIVE ANALYSIS OF ALTERNATIVES
The detailed analysis required under the NCP consists of an assessment of the individual
alternatives against each of the nine evaluation criteria (see below) and a comparative
analysis focusing upon the relative performance of each alternative against those
criteria.
The first two criteria are known as "threshold criteria" because they are the minimum
requirements that an alternative must meet to be eligible for selection as a remedy. The
next five criteria, criteria 3 through 7, are known as "primary balancing criteria." These
criteria are applied as factors between response measures so that the best option will
be chosen given site-specific data and conditions. The final two criteria, criteria 8 and 9,
Capital Cost:
Annual O&M Costs:
Present-Worth Cost:
$281,150,000
$57,000
$281,300,000
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are known as "modifying criteria." Community and support agency acceptance are
factors that are assessed by reviewing comments received during the public comment
period, including any new information that might be made available after publication of
the proposed plan that significantly changes basic features of the remedy with respect
to scope, performance, or cost.
The nine evaluation criteria are:
1. Overall protection of human health and the environment in which it is determined
whether an alternative eliminates, reduces, or controls threats to public health and
the environment through the implementation of remedial measures such as ICs,
ECs, or treatment.
2. Compliance with ARARs in which it is evaluated whether the alternative would
meet all of the applicable or relevant and appropriate requirements of federal and
state environmental statutes and other requirements that pertain to this Site or
provide grounds for invoking a waiver.
3. Long-term effectiveness and permanence is considered in the context of the
ability of an alternative to maintain protection of human health and the
environment over time.
4. Reduction of toxicity, mobility, or volume through treatment is the criterion by
which an alternative's anticipated performance related to treatment technologies
that an alternative may employ is gauged.
5. Short-term effectiveness is considered in the context of the duration needed to
implement an alternative and the risks that the alternative may pose to workers,
residents, and the environment during implementation.
6. Implementabilitv is the technical and administrative feasibility of implementing the
alternative, including the availability of materials and services.
7. Cost includes estimated capital and annual operation and maintenance costs, as
well as present-worth costs. Present-worth cost is the total cost of an alternative
over time in terms of today's dollar value. Cost estimates are expected to be
accurate within a range of +50 to -30 percent.
8. State acceptance indicates if the State concurs with the selected remedy.
9. Community acceptance refers to the public's general response to the alternatives
described in the Proposed Plan and the RI/FS reports.
A comparative analysis of these alternatives based upon the evaluation criteria noted
above follows.
Overall Protection of Human Health and the Environment
Based on the reasonably anticipated future Site use, including a recreational trail, current
human health hazards and risks associated with recreational use for all receptors are
acceptable based on post-HHRA re-evaluations of hazard and risk (see Appendix II,
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Table 4). Alternative 1, no action, would not be protective of human health and the
environment because it would not actively address the contaminated soil/fill or
groundwater, which pose unacceptable human health and ecological risks. Alternatives
2 through 4 would provide for human health protection relative to potential exposure to
soil/fill material through ECs and ICs. ICs, a SMP, and monitoring the natural attenuation
of naphthalene in groundwater included in Alternatives 2 through 4 would provide
protection of human health relative to potential exposure to surface and subsurface
soil/fill material, sheens that may develop during soil excavations, and groundwater for
receptors such as construction or utility workers. The SMP would require special
measures to address water during excavation activities. Alternative 2 would provide
protectiveness through placement of clean cover material in 8.2 acres of non-forested
wetland and non-forested upland areas, in addition to ICs and MNAforthe groundwater.
Alternative 3 would provide protectiveness over 10 acres through removal of surface
soil/fill material within non-forested wetlands, restoration of non-forested wetlands,
placement of a soil cover within non-forested upland areas, ICs, and MNA for the
groundwater. Alternative 3 is anticipated to result in some disturbance to the eagle
habitat, because it requires removal of an approximate half-acre area that includes
mature trees. Alternatives 2 and 3 would also include the flexibility to provide added
protection (as determined by pre-design soil sampling) through grading/handling of
surface soil/fill material to address additional wetland and/or upland areas, provided that
eagle habitat {e.g., mature trees) is not significantly impacted. Alternative 4 would be the
most protective but would also result in the greatest impact to forested habitat, including
the eagle roosting areas, through Site-wide removal of trees.
The soil cover and/or targeted excavation of surface soil as presented in Alternatives 2
and 3 would address SCOs for Commercial Use and Protection of Ecological Resources
where the cover is placed within the non-forested wetland and upland areas, while
preserving as much of the forested bald eagle roosting habitat as possible. In order to
consider contaminant concentrations on a Site-wide basis (including contamination that
would remain in the undisturbed forested areas), an evaluation of Site-wide surface soil
AWACs was performed to demonstrate the level of protectiveness that would be
achieved for remedial alternatives relative to one another and to current conditions.
Exceedances of Commercial Use SCOs in surface soil may be present in the forested
areas where a soil cover is not being placed, although the AWACs calculated for the
existing conditions and conditions following implementation of Alternatives 2 and 3
illustrate improvement in average surface soil concentrations as a result of these
remedies. With respect to human health, based on this analysis the surface soil AWACs
are below SCOs for Commercial Use for chromium, mercury, 4,4-DDT and total PCBs
with no further remedy implementation {i.e., under Alternative 1). Implementation of
Alternatives 2 or 3 would further reduce AWACs for these representative risk and remedy
drivers and reduce AWAC values for cadmium to below the corresponding Commercial
Use SCO. Implementation of Alternatives 2 and 3 would also reduce AWAC values for
benzo(a)pyrene to concentrations marginally exceeding the corresponding Commercial
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Use SCO. Potential exposure risks for human receptors to residual contamination would
be addressed through ECs {e.g., soil cover, fencing/railing) and ICs {e.g., signage,
environmental easements).
In developing ecological remediation goals in sensitive habitats, consideration must be
given to the intrusive nature of some remedial activities and the potential negative
impacts resulting from implementation of such remedial activities, particularly in
consideration of the forested habitat and the extensive utilization of the Site by bald
eagles. Exceedances for Protection of Ecological Resources SCOs may be present in
the forested areas where a soil cover is not being placed, although Alternatives 2 and 3
are expected to reduce average surface soil concentrations below the SCOs for
benzo(a)pyrene. Average levels of total PCBs pre-remediation are below the Protection
of Ecological Resources SCO for PCBs and would be further reduced after
implementation of Alternatives 2 or 3. Post-remediation AWACs for cadmium, chromium,
mercury, and 4,4-DDT would potentially exceed SCOs for the Protection of Ecological
Resources within the top two ft of soil, though significant reductions are anticipated under
Alternatives 2 and 3. More information on the AWACs are included in the FS.
Under Alternatives 2 and 3, a significant portion of the elevated concentrations of
contaminants at the Site would be addressed, remaining concentrations would be
expected to be protective of community impacts to ecological receptors when the Site is
considered in its entirety, and significant habitat alteration and bald eagle disturbance
would be avoided. As a result, Alternatives 2 and 3 are considered to improve protection
of ecological exposures. Specifically, further examination of post-remedy exposure to
constituents that would potentially exceed the SCOs for the Protection of Ecological
Resources, indicates that Alternatives 2 and 3 would reduce lowest observed adverse
effect level (LOAEL)-based HQs to below 1, or marginally above 1, for the most sensitive
receptor (short-tailed shrew) evaluated in the BERA. Thus, Alternatives 2 and 3 address
protectiveness of anticipated future use and ecological receptors while observing primary
tenets of Ecological Risk Assessment Guidance for Superfund (ERAGS). Biota
monitoring would also be performed under Alternatives 2 and 3 to monitor protectiveness
of ecological resources and remedy effectiveness and to determine if additional remedial
actions are necessary.
Consistent with 6 NYCRR-1.8(f) and DER-10.4.2(i), the current, intended, and
reasonably anticipated future use of the Site was considered when selecting SCOs.
Alternative 1 would not be consistent with current, intended, and reasonably anticipated
future use of the Site. The soil cover in Alternative 2 would address at least 8.2 acres of
non-forested wetland and upland area surface soil/fill material exceeding SCOs
consistent with current, intended, and reasonable anticipated future use of the Site, while
15.3 acres would not be addressed. The soil cover with added removal of surface soil/fill
material in Alternative 3 would support the current, intended, and reasonably anticipated
future land use, and address at least 9.5 acres of non-forested wetland and upland areas
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along with 0.5 acres of forested upland, while 13.5 acres would not be addressed.
However, Alternative 3 would impact 0.5 acres of forested area that is important bald
eagle habitat. Removal of soil/fill material in Alternative 4 would support the current,
intended, and reasonably anticipated future land use and address 23.5 acres of Site area
exceeding SCOs; however, it would remove and/or prevent use of the recreational trail
at the Site during the 5-to-7-year construction period and would result in Site-wide
clearing of valuable forested habitat and likely adversely affect the bald eagles that use
the Site for winter roosting.
Alternative 1 would not address RAOs related to potential erosion and direct contact with
soil/fill material. RAOs for protection of ecological receptors would be improved via
AWACs for Alternatives 2 and 3, although SCOs at certain locations may still be
exceeded. Alternatives 2 and 3 would improve protectiveness of the environment and
would provide for additional protection of human health within non-forested wetland and
upland areas and would meet RAOs through the use of soil covers, which would control
potential erosion of, and direct contact with, soil/fill material as well as control the
potential inhalation of dust in these areas. Alternative 3 would provide added protection
of human health and the environment within non-forested wetland areas as compared to
Alternative 2 and would meet RAOs through soil covers and the removal of surface
soil/fill material for portions of the Site. ICs, a SMP, and monitoring would provide for
continued protection of the environment and provide a means to evaluate continued
protectiveness in Alternatives 2 through 4. Alternatives 2 and 3 also include biota
monitoring for the purpose of assessing ecological protectiveness. Alternative 4 would
be protective of human health and the environment within forested and non-forested
wetland and upland areas through removal of accessible surface and subsurface soil/fill
material and would allow for unrestricted use of the majority of the Site by addressing
soil/fill material exceeding SCOs for Unrestricted Use. With the exception of Alternative
4, each of the alternatives would provide preservation of trees utilized seasonally by bald
eagles for roosting.
In summary, because Alternative 1 does not provide protection of human health and the
environment, this alternative does not satisfy this threshold criterion. Alternatives 2
through 4 would satisfy this threshold criterion by providing protection of human health
and the environment. Alternatives 2 through 4 would provide varying degrees for
protection of human health and the environment through ECs and ICs. Alternative 3 is
anticipated to directly address more of the Site as compared to Alternative 2, however,
this is at the expense of eliminating 0.5 acres of valuable forested habitat. Alternative 4
would provide the greatest protectiveness but would result in the most significant impact
to forested habitat, including eagle roosting, through Site-wide removal of trees.
Alternatives 2 and 3 are considered reasonably protective of human and ecological
receptors by addressing elevated soil concentrations while preserving the forested
habitat, critical to overall Site ecology and utilization by bald eagles.
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Compliance with ARARS
SCOs are identified in 6 NYCRR Part 375, Environmental Remediation Programs,
Subpart 375-6, effective December 14, 2006. New York State's Commercial Use and
Protection of Ecological Resources SCOs at 6 NYCRR Section 375-6.3(b) have been
identified as an ARAR, TBC, or other guideline to address contaminated surface and
subsurface soil.5 While surface soil at the Site contains contaminants at concentrations
exceeding Commercial Use SCOs, potential exposure risks for human receptors to
residual contamination would be addressed through ECs {e.g., soil removal/cover,
fencing/railing, etc.) and ICs {e.g., signage, environmental easements). As discussed
above under the HHRA and Overall Protection of Human Health and the Environment
sections, the Revised HHRA and subsequent re-evaluation identified acceptable risks
for the anticipated public use of the Site {i.e., recreational trail).
Because the contaminated soil/fill material would not be actively addressed under
Alternative 1, it would not achieve the SCOs. Under Alternative 2, soil/fill material
exceeding SCOs would be addressed within a portion of the non-forested wetland and
upland areas (8.2 of the 23.5-acres) through the installation of a soil cover, where
accessible and not detrimental to the environment {e.g., tree removal, disturbance of
bald eagles, etc.). In Alternative 3, as compared to Alternative 2, the installation of a soil
cover with the additional removal of surface soil/fill material within the western portion of
the non-forested wetland areas and restoration with clean material would address soil
exceeding SCOs within the additional non-forested wetland (10 of the 23.5-acres)
although this would require the removal of some forested habitat. While some areas
exhibiting soil concentrations greater than the Protection of Ecological Use SCOs may
remain under Alternatives 2 and 3 they are expected to be protective of community
impacts to ecological receptors throughout the Site, based on AWAC calculations,
coupled with the avoidance of significant habitat alteration and bald eagle disturbance.
For Alternatives 2 and 3A, should reuse of material be incorporated into the remedy,
consideration for re-exposure and long-term management would be addressed in the
remedial design and O&M requirements. Alternative 4 would address surface and
subsurface soil exceeding Unrestricted Use SCOs within the footprint of the Site,
including the forested and non-forested areas. Alternatives 2, 3 and 4 would address
exceedances of New York State Class GA guidance value for naphthalene in
groundwater through natural attenuation.
No location- or action-specific ARARs were identified for Alternative 1 (No-Action
alternative). Construction methods and safety procedures would be implemented to
adhere to the location- and action-specific ARARs, guidances, and To-Be-Considereds
(TBCs) that are pertinent to Alternatives 2 through 4. Specifically, ICs would be
5 Protection of Groundwater SCOs are not considered in this action because of provisions within
NYCRR Part 375 {e.g., an environmental easement would be utilized to restrict groundwater
usage; contaminated groundwater at the Site is not migrating nor likely to migrate off-Site).
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implemented in Alternatives 2 through 4 in general conformance with NYSDEC's
guidance DER-33 (see
https://www.dec.nv.gov/docs/remediation hudson pdfZder33.pdf) and EPA guidance
(see https://www.epa.gov/superfund/superfund-institutional-controls-guidance-and-
policv). Additionally, Alternatives 2 and 3 would mitigate potential erosion and exposure
to soil/fill material where soil covers are installed and would be implemented in general
conformance with NYSDEC's DER-10 (see
https://www.dec.nv.gov/regulations/67386.html). Procedures would be implemented to
adhere to the location-specific ARARs related to federal and state requirements, such
as for the portion of the Site that is a designated wetland for cultural, archeological, and
historical resources. Additionally, proposed actions would be conducted in a manner
consistent with Fish and Wildlife Coordination Act requirements for the protection of
Onondaga Lake and for areas proximate to Onondaga Lake. As necessary, actions
under Alternatives 2 through 4 would be implemented in general conformance with state
and federal wetland and floodplain assessment requirements in addition to navigable
waterway and New York State Railroad Law. Specifically, wetland permitting and
mitigation requirements, such as those in 6 NYCRR Part 663, Article 15 and 6 NYCRR
Part 608 would be considered during the remedial design phase. With respect to action-
specific ARARs, the soil cover, wetland restoration, and excavation related activities
would be conducted consistent with applicable standards including RCRA Subtitle D, 40
CFR Part 358.60 - Closure Criteria, 40 CFR Part 257 - Criteria for Classification of Solid
Waste Disposal Facilities and Practices, and 40 CFR Parts 264 and 265, Subpart N -
Landfills and 6 NYCRR 360 - Solid Waste Management Facilities; earth
moving/excavation activities would be conducted consistent with air quality standards
including 6 NYCRR 200-203, 211-212 - Prevention and Control of Air Contamination
and Air Pollution, and 40 CFR Part 50.1 - 50.12 - National Ambient Air Quality
Standards; and transportation and disposal activities would be conducted in accordance
with applicable state and federal requirements including 6 NYCRR 364 - Waste
Transporter Permits and 49 CFR 107, 171-174 and 177-179 - Department of
Transportation Regulations, by licensed and permitted haulers, with disposal at
permitted facilities. Under Alternative 4, construction water would be managed in a
manner and in accordance with discharge requirements to be determined by NYSDEC
during the remedial design phase.
Location-specific ARARs related to habitat protection, including the Federal Bald and
Golden Eagle Protection Act (16 U.S.C. 668 et seq), USFWS National Bald Eagle
Management Guidelines, Conservation Plan for Bald Eagles in New York State, and 6
NYCRR 182, provide requirements and guidance regarding the protection of bald eagle
habitat, including the "take and disturbance" of bald eagles, and limiting activities that
may alter communal roost sites and foraging areas. Alternatives 2 and 3 can be
implemented while preserving the valuable tree habitat, with minimal removal of low- to
mid-story vegetation and retaining larger-scale vegetation at the Site, whereas
Alternative 4 would require the Site-wide removal of trees providing valuable forested
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habitat used by bald eagles for winter roosting.
Long-Term Effectiveness and Permanence
Alternative 1 would involve no active remedial measures and, therefore, would not be
effective in eliminating the potential exposure to contaminants in the soil/fill material and
groundwater. Unlike Alternative 1, Alternatives 2 through 4 would provide varying levels
of long-term effectiveness and permanence. Alternative 4 provides the most reduction in
residual risk, however, it requires removal of trees that enhance the overall value of Site
habitat and provide eagle roosting habitat. Alternatives 2 and 3 would support the
anticipated future use of the Site for a multi-use recreational trail while preserving trees
utilized seasonally by bald eagles for foraging and roosting. Alternative 3 would provide
some additional level of long-term effectiveness and permanence relative to Alternative
2 as it would result in a greater acreage of remediation although limited tree removal
would be required. Potential human health risks associated with Alternatives 2 through
4 would be reliably addressed through ECs {e.g., soil removal/cover, fencing/railing)
and/or ICs {e.g., signage, environmental easements). Each alternative would result in
minimal long-term fuel/energy consumption, greenhouse gas emissions, and impacts to
water, ecology, workers, or the community associated with long-term maintenance of the
remedies.
The long-term performance of Alternatives 2, 3 and 4 could potentially be impacted as a
result of erosion of the soil covers during severe storms/weather events and associated
flooding that may be more frequent or severe as a result of climate change. These effects
would be noted and documented as a result of inspections which would be conducted in
accordance with the SMP, particularly after flood events, and mitigated as may be
necessary and appropriate.
Reduction in Toxicity. Mobility, or Volume Through Treatment
Because none of the alternatives involve active treatment, there would be no reduction
in toxicity, mobility, or volume in soil/fill material through treatment provided under
Alternatives 1 through 4. Treatment technologies were evaluated and screened out in
the FS because of implementability and/or compatibility limitations, heterogeneous
conditions and proximity to the lake, and the variety of contaminant types could limit
effectiveness. In addition, the presence of a mature forested area that supports the
roosting of bald eagles at the Site makes the treatment of all the contaminated soil at the
Site impracticable.
Short-Term Effectiveness
Alternative 1, the no-action alternative, does not include active remedial components,
and, therefore, would not present any potential adverse impacts to workers and the
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community. Alternatives 2 through 4 would be implemented and constructed using
proper protective equipment to manage potential risks to on-Site workers, and proper
precautions and monitoring to be protective of the general public and the environment.
Because no action would be performed under Alternative 1, there would be no
implementation time. Alternative 2 is anticipated to be completed within one construction
season, while Alternative 3 is anticipated to be completed within one to two construction
seasons. Because of the volume of surface and subsurface soil/fill material exceeding
Unrestricted Use SCOs, Alternative 4 would require a longer timeframe to attain RAOs
in the forested and non-forested wetland, as excavation is estimated to take place over
five to seven construction seasons.
Impacts to the community resulting from the implementation of Alternatives 2 and 3
would primarily be as a result of increased truck traffic and increased noise for the
duration of construction of the soil cover under Alternative 2, and contaminated surface
soil/fill material excavation and soil cover construction under Alternative 3. Additional
truck traffic and noise is anticipated for the duration of Alternative 3B because of off-Site
transport of excavated surface soil/fill material. Alternative 4 would have significantly
increased truck traffic, noise, dust and emissions compared to Alternatives 2 and 3
because of the need to clear the Site of trees prior to surface and subsurface soil/fill
material excavation for the five- to seven-year duration of construction. The
implementation of the clearing, surface and subsurface soil/fill material excavation and
off-Site disposal included in Alternative 4 would result in far greater impacts to the
community, including substantially increased truck traffic, dust and emissions as well as
increased noise, although mitigative measures would be implemented to the extent
practicable to limit the impacts of noise, dust and traffic. Additionally, Alternative 4 would
involve the addition of sheeting or other stabilization measures along the railroad tracks
and bulkhead installation along the shoreline during construction.
As it relates to traffic, transportation of cover material to the Site is anticipated to result
in approximately 2,450 truck trips under Alternative 2, while transport of cover material,
excavation of surface soil/fill material, on-Site consolidation and wetland restoration
under Alternative 3A (on-Site reuse of excavated material) is anticipated to result in
approximately 2,650 truck trips. Alternative 3B (off-Site disposal of excavated material)
is anticipated to result in an additional 1,550 truck trips for off-Site disposal of excavated
soil/fill material when compared to Alternative 3A. Excavation of contaminated surface
and subsurface soil/fill material, off-Site transportation and disposal and wetland
restoration included in Alternative 4 would require approximately 56,000 truck trips over
four years, resulting in the greatest impact on traffic and potentially adverse effects on
local air quality. The increased traffic associated with construction of Alternatives 3 and
4 would result in a potential increase in safety-related risks and impacts to CSX Railroad
operations that would be due to off-Site transport of excavated soil/fill material requiring
additional crossing and coordination with railroad traffic proximate to the Site.
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With respect to sustainability, there is an environmental footprint inherent in
implementation of each alternative as it relates to construction and operation, as well as
impacts to the community (as described above). The implementation of the excavation
and off-Site disposal included under Alternative 4 would result in far greater direct
emissions and fuel consumption, as compared to importing construction materials and
construction of the soil cover included in Alternative 2 and soil cover, surface soil/fill
material excavation and management of excavated material included in Alternative 3.
Construction of Alternatives 2 and 3 would result in greater greenhouse gas impacts than
Alternative 1 and construction of Alternative 4 would result in substantially greater
greenhouse gas impacts than the other alternatives. Consistent with NYSDEC and EPA
policies on green remediation, sustainability considerations will not be used to justify
implementation of the no-action alternative or a less comprehensive alternative when a
more comprehensive remedy is called for, appropriate, and feasible.
Worker and community risks during remedy implementation are significantly greater for
Alternative 4 compared to Alternatives 2 and 3. Specifically, the added risks to workers
and the community, the added duration to achieve RAOs, the significant truck traffic
impacts to the community, and the significantly greater environmental footprint
associated with Alternative 4 would present greater risk in the short-term relative to
Alternatives 2 and 3.
Implementabilitv
Alternative 1 would be the easiest alternative to implement, as there are no activities to
undertake.
Alternatives 2 through 4 would employ technologies (soil covers and excavation) known
to be reliable and that can be readily implemented. Equipment, services and materials
needed for these alternatives are readily available. Monitoring the effectiveness of the
soil covers under Alternatives 2 and 3 would be accomplished through inspections and
maintenance to verify continued cover integrity, visual inspections for signs of erosion,
and visual inspection of the soil cover condition. Areas of wetland restoration/mitigation
under Alternatives 2 and 3 would be monitored for signs of erosion, condition of
vegetation, and presence of invasive species. A SMP and periodic reviews would also
be implemented under Alternatives 2 and 3 for the purpose of monitoring and
documenting remedy effectiveness, managing remaining contamination, and
implementing measures as needed to prevent human exposures, in addition to
groundwater monitoring as a means to assess potential changes in groundwater
concentrations.
The actions under Alternatives 2 through 4 would be administratively feasible. They
would require access across the CSX Railroad tracks and work in proximity to the
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railroad, Onondaga Lake, Onondaga Creek, and Ley Creek. Alternatives 2 through 4
would also require coordination with other agencies, including NYSDEC, New York
State Department of Transportation, NYSDOH, EPA, USFWS, City of Syracuse, and
CSX Railroad. Coordination with Onondaga County would also be necessary since it is
the property owner and for maintenance of the multi-use recreational trail.
Alternative 3, which includes Alternatives 3A (on-Site reuse of excavated material) and
3B (off-Site disposal of excavated material), would be more difficult to implement than
Alternative 2. Specifically, a geotechnical evaluation concluded that global stability
associated with excavation in the vicinity of the railroad tracks under Alternative 3 is
anticipated to limit implementability of this alternative. CSX Railroad concurrence with
remedial design of the cover and excavation elements included in this alternative would
be required. Thus, stability concerns may affect the implementability of this alternative.
Additionally, Alternative 3A is less implementable than Alternative 2, because it is
necessary to evaluate and identify on-Site reuses to manage the additional spoils
anticipated during implementation of Alternative 3A. Alternative 3B is less implementable
than Alternative 2 because off-Site transport and disposal included under Alternative 3B
would result in impacts to CSX Railroad operations requiring additional crossing and
coordination with railroad traffic proximate to the Site. In addition, landfill disposal
capacity would require confirmation prior to implementation of Alternative 3B.
Alternative 4 would be the most difficult to implement in comparison to Alternatives 2 and
3 for the following reasons:
• There are significant implementability limitations associated with the excavation,
transportation, and disposal (capacity) for approximately 400,000 cy of soil/fill
material.
• There are challenging construction water management and greater slope stability
concerns relative to the active CSX Railroad lines when compared to the shallow
excavations included under Alternative 3, which would require CSX concurrence.
Construction water management using a temporary treatment system is
anticipated to be significant during the excavation, as large water volumes are
anticipated as a result of the presence of heterogenous and permeable fill and
excavations in proximity of the on-Site wetlands, Onondaga Lake, Onondaga
Creek, and Ley Creek. Excavations in the vicinity of active railroads, subsurface
utilities, and surface water bodies are anticipated to limit the implementability of
excavations in certain areas and require the costly design, procurement, and
installation of shoring. As part of the supporting geotechnical evaluations,
installation of sheet piling would be evaluated and installed, if required, to support
excavations in these areas.
• There are also significant transportation concerns related to Alternative 4. The
estimated volume requiring disposal is 400,000 cy (estimated to be approximately
615,000 tons). Based on a daily production rate of 500 cy per day for 10 months
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of the year, it is estimated that up to approximately 100,000 cy of material could
be shipped off-Site each year in 7,000 truckloads (up to 35 truckloads per day)
with an approximately equivalent number of trips being required for restoration,
over a duration of 5 to 7 years. During a 10-hour workday, this would equate to
approximately one truck entering or leaving the Site every 10 minutes. In addition
to the potentially significant adverse effects on local air quality and community
traffic patterns, traffic of this magnitude is anticipated to result in significant
adverse effects on conditions of roadways.
• Ecological considerations limit the implementability of Alternative 4, including the
removal of trees providing valuable forested habitat and that are utilized by bald
eagles. The Site serves as a winter roost site and concentration area for a large
number of bald eagles; a State-listed threatened species. Alternative 4 would
require the disturbance of 23.5 acres, including 13.1 acres of wetland areas and
15.3 acres of forested areas, and the Site-wide removal of trees that serve as an
important habitat, and it is anticipated it would take several decades to restore.
Cost
The estimated present-worth costs were calculated using a discount rate of seven
percent and a thirty-year time interval for the post-construction monitoring and
maintenance period (although O&M would likely need to continue beyond the 30-year
period, this is the typical period used when estimating costs for a comparative analysis).
The estimated capital, annual O&M, and present-worth costs using a 7% discount factor
for each of the alternatives are presented in the table below.
Alternatives
Capital Cost
Annual O&M
Cost
Total Present
Worth Cost
1 - No Action
$0
$0
$0
2 - Soil Cover in Select
Areas, Wetland Restoration,
Biota Monitoring, and MNA
$7.5 million
$181,000
$8.3 million
3A - Surface Excavation
with On-Site Reuse and Soil
Cover/Wetland Restoration
on Perimeter and Interior
Areas, Biota Monitoring,
MNA, with Limited Tree
Removal
$21.1 million
$185,000
$21.9 million
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3B - Surface Excavation
with Off-Site Disposal and
Soil Cover/Wetland
Restoration on Perimeter
and Interior Areas, Biota
Monitoring, MNA, with
Limited Tree Removal
$26.2 million
$185,000
$27.0 million
4 - Full Removal and Off-
Site Disposal with Wetland
Restoration and MNA
$281.2 million
$57,000
$281.3 million
State Acceptance
NYSDEC is the lead agency for the Site. EPA has determined that the selected remedy
meets the requirements for a remedial action as set forth in CERCLA Section 121, 42
USC § 9621. As such, for the purpose of satisfying this remedy selection criterion of the
NCP, NYSDEC, on behalf of New York State, supports the selected remedy. NYSDOH
also supports the selection of this remedy; its letter of concurrence is attached (see
Appendix IV).
Community Acceptance
Questions and feedback were received from the community during the public comment
period. These included concerns regarding potential health risks, evaluation of other
alternatives, requests for additional signage related to contamination that may be present
off the trail, concerns with using the AWACs to evaluate alternatives, emerging
contaminants and contaminant sources. Comments received during the public comment
period are summarized and addressed in the Responsiveness Summary, which is
attached as Appendix V to this document.
PRINCIPAL THREAT WASTE
The NCP establishes an expectation that the EPA will use treatment to address the
principal threats posed by a site, wherever practicable (NCP Section 300.430
(a)(1)(iii)(A)). The principal threat concept is applied to the characterization of source
materials at a Superfund site. A source material is material that includes or contains
hazardous substances, pollutants, or contaminants that act as a reservoir for the
migration of contamination to groundwater, surface water, or air, or act as a source for
direct exposure. Principal threat wastes are those source materials considered to be
highly toxic or highly mobile that generally cannot be reliably contained or will present a
significant risk to human health or the environment should exposure occur. The decision
to treat these wastes is made on a site-specific basis through a detailed analysis of
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alternatives, using those remedy-selection criteria that are described above. This
analysis provides a basis for making a statutory finding that the remedy employs
treatment as a principal element.
While stained soils and blebs of NAPL are present at the Site, they do not necessarily
correlate with elevated organic contaminant concentrations in the soil and groundwater
at proximate locations. NYSDEC and EPA have not identified material at the Site as
principal threat wastes.
SELECTED REMEDY
Summary of the Rationale for the Selected Remedy
Based upon consideration of the requirements of CERCLA, the detailed analysis of the
alternatives, and public comments, NYSDEC and EPA select Alternative 2, which
includes a Soil Cover in Select Areas, Wetland Restoration, Biota Monitoring, and MNA,
because it best satisfies the requirements of CERCLA Section 121, 42 U.S.C. § 9621,
and provides the best balance of tradeoffs among the remedial alternatives with respect
to the NCP's nine evaluation criteria, set forth at 40 CFR § 300.430(e)(9).
Alternative 1 does not meet the RAOs for the Site. Alternative 2 would better meet the
primary balancing criteria for implementability, short-term effectiveness, and cost, as
Alternative 3 would potentially present geotechnical stability issues for the nearby
railroad tracks that would limit its implementability and may require an additional
construction season to implement, resulting in more potential community impacts. In
addition to significantly impacting the bald eagle habitat at the Site, Alternative 4 would
be extremely difficult to implement, presents significant short-term impacts, would take
longer to implement compared to other alternatives, and is the least cost-effective means
of achieving the objectives.
Based on information currently available, NYSDEC and EPA believe that the selected
remedy, Alternative 2, best meets the threshold criteria and provides the best balance of
tradeoffs among the other alternatives with respect to the balancing and modifying
criteria. NYSDEC and EPA expect the selected remedy to satisfy the following statutory
requirements of CERCLA Sectionl 21 (b): (1) it will be protective of human health and the
environment; (2) it will comply with ARARs; (3) it will be cost-effective; (4) it will utilize
permanent solutions and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and (5) it will satisfy the preference for
treatment as a principal element (or justify not meeting the preference).
NYSDEC and EPA agree that the selected remedy is protective of human health and the
environment, can be readily constructed and operated, presents minimal potential short-
term impacts to workers and the community, and is cost-effective. The selected remedy
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utilizes permanent solutions, alternative treatment technologies, and resource-recovery
technologies to the maximum extent practicable.
Description of the Selected Remedy
The selected remedy, Alternative 2, is described in more detail, above, in the "Description
of the Remedial Alternatives" section and includes the following components:
• Placement of a two-foot-thick soil cover where accessible and not detrimental to
the environment {i.e., avoiding mature tree removal, disturbance of bald eagles,
etc.), and restoring wetlands in select non-forested wetland and upland areas of
the Site. To restore the wetland areas, contaminated soil may be removed, and
either reused on-Site or disposed off-Site, prior to cover placement to a depth
necessary to preserve wetland conditions and functions. Reuse of material in
accordance with NYSDEC DER-10 (Table 5.4(e)4), which could include use of
soil for future trail construction, will need to be compatible with wetland regulations
and will be evaluated during design. Where cover material is placed, a
demarcation layer will be evaluated during the remedial design to delineate the
boundary between the contaminated soil/fill material and the soil cover. If a
demarcation layer is necessary, it will be compatible with the wetland or tree
growth, as appropriate. The targeted remedial footprint focuses on reducing
ecological exposure while still retaining forested SYW-12 habitat to preserve
areas currently used by bald eagles for winter roosting.
• Fill material brought to this Site will need to meet the requirements for the
identified Site use as set forth in New York State regulations (6 NYCRR Part 375-
6.7(d)). Native species will be used for the vegetative component of covers.
• A tree survey and surface soil pre-design investigation will be performed to
evaluate whether additional areas should be included in the remediation footprint.
Should surface soil sampling and the tree survey indicate that elevated surface
soil/fill contaminant concentrations could be addressed without impacting large
trees {e.g., large trees and/or soils within their drip-zone would not need to be
removed or disturbed), soil excavation and/or backfilling of these areas with clean
material would be considered.
• Biota monitoring will be performed to evaluate remedy effectiveness and assess
protectiveness for ecological receptors. A baseline sampling program consisting
of two sampling events will be implemented, with subsequent sampling events
following remedy implementation using an adaptive, data-driven approach {e.g.,
years 3 and 5). A field assessment of Site vegetative community composition
{e.g., diversity, richness, invasive species evaluation) and qualitative wildlife
community observations will be performed to support the biota monitoring
program. The field assessment will also include an evaluation of Site trees,
specifically trees that serve as roosts for bald eagles, for overall health and
preservation. Specific sample locations, species, sampling and analytical
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methods, and sampling frequencies will be assessed and established during the
remedial design. It is assumed that the monitoring program will consist of analysis
of soil invertebrate and small mammal tissues, with collection of co-located
surface soil/fill samples for laboratory analysis of chemical constituents. The
details related to the scope of biota sampling will be developed during the
remedial design phase.
• Periodic sampling and analysis of groundwater will be included as a means of
monitoring changes in groundwater concentrations and natural attenuation of
naphthalene. Natural attenuation of other groundwater contaminants may be
evaluated, if necessary.
• Institutional controls (ICs) in the form of environmental easements and/or
restrictive covenants will be used to limit land use to commercial (including
passive recreational), as appropriate, prevent the use of groundwater without
approved treatment, and require that any intrusive activities on the Site will be
conducted in accordance with a NYSDEC-approved Site Management Plan,
which will include the following:
¦ Institutional and Engineering Control Plan that identifies all use restrictions and
engineering controls (ECs) for the Site and documents the steps and media-
specific requirements necessary to ensure the following ECs and ICs remain
in place and effective:
o environmental easements and/or restrictive covenants described
above
o Site cover described above
o future remediation/management in areas where no cover is present at
the Site {e.g., due to erosion or changes in vegetation)
o excavation plan that details the provisions for management of future
excavations on the Site
o descriptions of provisions of the ICs, including any land use or
groundwater use restrictions
o soil vapor intrusion evaluation to be completed, and appropriate actions
implemented for any on-Site buildings (if they were to be constructed)
o provisions for management and inspection of the identified ECs
o protection measures to be implemented while conducting any needed
subsurface soil disturbance activities, to prevent exposure to sheens or
blebs of NAPL
o maintenance of Site access controls and NYSDEC notification {e.g.,
change in Site use)
o steps necessary for periodic review and certification of the ECs and/or
ICs.
¦ Monitoring Plan to assess performance and effectiveness of the remedy.
Elements of the monitoring plan will include groundwater and biota monitoring,
assessing restoration success {e.g., wetland delineation, invasive species
management), and repair of habitat and wetlands. The final monitoring
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program will be established during the design.
The cover system will require routine maintenance and inspections to maintain its
integrity. Maintenance of the cover systems may consist of cover repair in areas of
disturbance or reapplication of vegetation in areas of non-survival, as necessary.
Based on the investigations, geochemical conditions at the Site are favorable for natural
attenuation of PAHs, including naphthalene, to occur. The determination that natural
attenuation is occurring is, in part, based upon detected concentrations of ferrous iron,
sulfide, and methane in groundwater and oxidation-reduction potential data that
suggests the presence of iron- and sulfate-reducing conditions in groundwater.
Biodegradation of naphthalene can occur under anaerobic conditions, particularly under
iron- or sulfate-reducing conditions. Further, the presence of methane and observed
decreases in groundwater concentrations of PAHs over time (such as acenaphthene and
naphthalene) indicate that natural attenuation is likely occurring.
Green remediation techniques, as detailed in NYSDEC's Green Remediation Program
Policy-DER-31,6 and EPA Region 2's Clean and Green Policy,7 will be considered for
the selected remedy to reduce short-term environmental impacts. Green remediation
best practices such as the following may be considered such as:
• use of renewable energy and/or purchase of renewable energy credits to power
energy needs during construction and/or O&M of the remedy;
• reduction in vehicle idling, including both on and off-road vehicles and construction
equipment during construction and/or O&M of the remedy;
• design of the soil cover, to the extent possible, to be usable for alternate uses, require
minimal maintenance (e.g., less mowing), allow for infiltration of storm water and/or
be integrated with the planned use of the property;
• maximizing habitat value and creating habitat when possible;
• reuse of material that would otherwise be considered a waste; and
• use of Ultra Low Sulfur Diesel.
Because this alternative will result in contaminants remaining above levels that allow for
unrestricted use and unlimited exposure, CERCLA requires that this Site be reviewed at
least once every five years after initiation of the remedy.
Summary of the Estimated Remedy Costs
The estimated capital cost of the selected remedy is $7.5 million; the annual O&M is
$181,000; and the total present-worth cost (using a 7% discount rate) is $8.3 million.
6 See http://www.dec.ny.gov/docs/remediation hudson pdfZder31.pdf.
7 See http://epa.gov/region2/superfund/green remediation
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Appendix II, Table 5 provides the basis for the cost estimates for Alternative 2.
It should be noted that these cost estimates are expected to be within +50 to -30 percent
of the actual project cost. These cost estimates are based on the best available
information regarding the anticipated scope of the selected remedy. Changes to the cost
estimate can occur as a result of new information and data collected during the design
of the remedy.
Expected Outcomes of the Selected Remedy
The results of the HHRA indicate that the contaminated groundwater presents a
potentially unacceptable noncancer hazard for receptors that would be involved in
intrusive work, such as a utility or construction worker. The results of the BERA indicate
that the Site, if not remediated, poses an unacceptable ecological exposure risk.
The State of New York, Onondaga County, and the City of Syracuse have jointly
sponsored the preparation of a land-use master plan to guide future development of the
Onondaga Lake area (Syracuse-Onondaga County Planning Agency, 1998). The
primary objective of these land-use planning efforts is to enhance the quality of the
Onondaga Lake area for recreational and commercial uses. Implementation of the
remedy will aid this long-term planning effort by addressing concerns related to human
exposure to contaminated sediments, soils, and surface water.
Under the selected remedy, potential risks to human health and the environment will be
reduced to acceptable levels. Remediation goals for the COCs are presented in
Appendix II, Tables 1 through 3. Remediation goals for surface soil will be met following
construction and implementation of appropriate ICs {e.g., approximately one year
following the start of construction). The estimated time to attain remediation goals is
approximately 7 years. These estimates are based on available data for groundwater at
the Site and were based on conservative assumptions. Additional data {e.g.,
groundwater) will be collected to refine the estimated timeframe for restoration and long-
term monitoring will be performed.
STATUTORY DETERMINATIONS
Under CERCLA Section 121 and the NCP, the lead agency must select remedies that
are protective of human health and the environment, comply with ARARs (unless a
statutory waiver is justified), are cost-effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum
extent practicable. Section 121(b)(1) also establishes a preference for remedial actions
that employ treatment to permanently and significantly reduce the volume, toxicity, or
mobility of the hazardous substances, pollutants, or contaminants at a site.
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For the reasons discussed below, NYSDEC and EPA have determined that the selected
remedy meets these statutory requirements.
Protection of Human Health and the Environment
The results of the risk assessment indicate that, if no action is taken, this Site poses an
unacceptable ecological and human health risk.
The selected remedy will adequately protect human health and the environment.
Placement of soil covers combined with ICs and ECs will provide protectiveness of
human health while placement of soil covers combined with biota monitoring will be
performed to evaluate remedy effectiveness and assess protectiveness of ecological
receptors. Implementation of the Selected Remedy will not pose unacceptable short-
term risks or adverse cross-media impacts.
Compliance with ARARs and Other Environmental Criteria
The selected remedy will comply with the location-, chemical- and action-specific ARARs
identified. The ARARs, TBCs, and other guidelines for the selected remedy are provided
in Appendix II, Table 6.
Cost-Effectiveness
A cost-effective remedy is one whose costs are proportional to its overall effectiveness
(NCP Section 300.430(f)(1 )(ii)(D)). Overall effectiveness is based on the evaluations of
the following: long-term effectiveness and permanence; reduction in toxicity, mobility,
and volume through treatment; and short-term effectiveness. Based on the comparison
of overall effectiveness (discussed above) to cost, the selected remedy meets the
statutory requirement that Superfund remedies be cost-effective and will achieve the
cleanup levels in the same amount of time in comparison to the costlier alternatives.
Each of the alternatives underwent a detailed cost analysis. In that analysis, capital and
annual O&M costs were estimated and used to develop present-worth costs. In the
present-worth cost analysis, annual O&M costs were calculated for the estimated life of
the alternatives and related monitoring using a seven percent discount rate and a 30-
year interval. The estimated capital, annual O&M, and total present-worth costs for the
selected remedy are $7.5 million, $181,000; and $8.3 million, respectively. Alternatives
2 through 4 would effectively achieve the RAOs. Alternative 2 is less costly than
Alternatives 3 and 4 and best satisfies the threshold criteria. Alternative 2 also best
satisfies the primary balancing criteria, as it is more implementable than Alternatives 3
and 4 and can be constructed with less short-term impacts to the community and to the
CSX Railroad.
45
-------
Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected remedy provides the best balance of tradeoffs among the alternatives with
respect to the balancing criteria set forth in NCP Section 300.430(f)(1)(i)(B), such that it
represents the maximum extent to which permanent solutions and treatment
technologies can be utilized in a practicable manner at this Site.
The soil cover will control potential erosion of, and direct contact with, contaminated
soil/fill material, as well as control the potential inhalation of dust in areas where they are
installed while ICs and Site Management Plans will be used to provide protection of
human health.
Preference for Treatment as a Principal Element
CERCLA includes a preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity or mobility of hazardous substances as a
principal element (or justify not satisfying the preference). The selected remedy does not
include treatment. Treatment technologies were evaluated and screened out in the FS
because of implementability and/or compatibility limitations, heterogeneous conditions
and proximity to the lake, and the variety of contaminant types that could limit
effectiveness. In addition, the presence of a mature forested area that supports the
roosting of bald eagles at the Site, makes treatment of contaminated soil at the Site
impracticable.
Five-Year Review Requirements
The selected remedy, once fully implemented, will result in hazardous substances,
pollutants, or contaminants remaining on-site above levels that would otherwise allow for
unlimited use and unrestricted exposure. Consequently, a statutory review will be
conducted within five years after initiation of the remedial action and at five-year intervals
thereafter, to ensure that the remedy is, or will be, protective of human health and the
environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan, released for public comment on January 19, 2023, identified
Alternative 2, Soil Cover in Select Areas, Wetland Restoration, Biota Monitoring, and
MNA, as the preferred alternative for this Site. Based upon its review of the written and
verbal comments submitted during the public comment period, NYSDEC and EPA
determined that no significant changes to the remedy, as originally identified in the
Proposed Plan, were necessary or appropriate.
46
-------
SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX I
FIGURES
-------
FIGURE 1
MAP LOCATION
HONEYWELL INTERNATIONAL INC.
WASTEBED B / HARBOR BROOK
GEDDES AND SYRACUSE, NY
OU-1 LOCATION
SEPTEMBER 2018
1163.61858
1:24,000
[WASTEBEDS.1 -8
ON ON DAG All/A KE
SEMET
PONDS
LAKESHORE AREA
WILLIS
AVE
, r*— -.riir * V,', I '
iSPENN-CAN PROPERTY
, w
¦ AOS#1
RAILROAD AREA
AOS#2
O'BRIEN & GERE ENGINEERS, INC.
-------
¦A sadio Towers
"J (WHEN) 6
Fort Ste Mari^
Oe Gannentaha
Sewage
Disposal
MacArthur
Stadium,.
Lights
,/Co«w«yor
gf Sewage
(ty Disposal /
¦Kort h
Smith
Map Scale: 1:1:24,000;
Map Center: 76°10'33"W 43°4'17"N
SITE LOCATION
HONEYWELL INTERNATIONAL INC.
2 ooo SYW-12 PROPOSED REMEDIAL ACTION PLAN
_J Feet SYRACUSE, NEW YORK
FIGURE 2
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
WESTERN NON-FORESTED
WETLrA N DSjTOTA L»A R E A*=T1.3
EASTERN NON-FORESTED
lWETLfANDSjTOTAL5AREA = 5.2
CSX RAILROADTKACIg;
CSX RAILROAtfJR^21S
IrWihMW
NOTE:
THE WETLAND DELINEATION IS BASED ON A
2018 DELINEATION TO REEVALUATE WETLAND
BOUNDARIES BETWEEN CSX RAILROAD TRACKS
AND ONONDAGA CREEK (ANCHOR QEA 2018).
FIGURE 3
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
SITE PLAN
HONEYWELL INTERNATIONAL INC.
SYW-12 PROPOSED REMEDIAL ACTION PLAN
SYRACUSE, NEW YORK
0 125 250
1 I 1 Feet
IZ3 FORESTED UPLAND (7.4 AC) ¦ NONFORESTED WETLAND (6.5 AC)
1Z2NONFORESTED UPLAND (3.0 AC) QSITE BOUNDARY
~ FORESTED WETLAND (6.6 AC)
-------
1220 Meters
4000 Feet
IU>eka wav
Mail I tartan
; Beach
* Rtiiusaul
Bt-ar-K
Chestn
4se >.
Lake View
trtfjx IHt
Faii-iT;it>uucLs
CFfiinnonii
Figure 4. 1898 15-minute Syracuse East USGS quadrangle, with approximate area of the SYW-12 Site
highlighted.
-------
IS Program.Office,-Westchester Counfy'GI
0.01JNI
Mdra
irosfal
:hbIwsd-io
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-18
HB-WSD-12
NOTE:
COMMERCIAL SCO= 9.3 mg/kg
POGW SCO= 7.5 mg/kg
ECO SCO= 4.0 mg/kg
J = ESTIMATED VALUE
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS
HUMAN HEALTH RISKASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
ID FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < ECO SCO
| EXCEEDED ECO SCO
~ EXCEEDED ECO AND POGW SCO
~ EXCEEDED ECO, POGW AND COMMERCIAL SCO
DEPTH
0-6"
6"- 1'
V-2
CADMIUM
RESULT IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 5
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
wm
soy®®
i'QIS Program.Qffice^Westchester CounfyljIS
o noil
iOwSI
PSWSD-10
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
WMMMmSMMBMm
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-14
HB-WSD-18
HB-WSD-12
NOTE:
COMMERCIAL SCO= 1,500 mg/kg
POGW SCO= N/A
ECO SCO= 41 mg/kg
J = ESTIMATED VALUE
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS .
HUMAN HEALTH RISK ASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
r~t
LEGEND
ID FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < ECO SCO
¦ EXCEEDS ECO SCO
I I EXCEEDS BOTH ECO AND COMMERCIAL SCO
DEPTH
0-6"
6"-r
V - 2'
CHROMIUM
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 6
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
i'QIS Program.Office,BWestchester CounfyljIS
:hbIwsd-io
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
mmimmmmwiBmwm
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-18 a\
HB-WSD-14
HB-WSD-12
HB-WSD-04
NOTE:
COMMERCIAL SCO= 2.8 mg/kg
POGW SCO= 0.73 mg/kg
ECO SCO= 0.18 mg/kg
J = ESTIMATED VALUE
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS .
HUMAN HEALTH RISK ASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
150
I Feet
SOIL ANALYTICAL RESULTS
I FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
~ < ECO SCO
LI EXCEEDED ECO SCO
~ EXCEEDED ECO AND POGW SCO
~ EXCEEDED ECO, POGW AND COMMERCIAL SCO
DEPTH
0-6"
6" - V
1' - 2'
MERCURY
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 7
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
0.01JWI
Mdra
irosfal
:hbIwsd-io
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-18 a\
HB-WSD-14
HB1WSBI12
-HB-WSD-04
NOTE:
COMMERCIAL SCO= 1.0 mg/kg
ECO SCO= 2.6 mg/kg
POGW SCO= 22 mg/kg
J = ESTIMATED VALUE
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS
HUMAN HEALTH RISKASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
ID FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < COMMERCIAL SCO
¦ EXCEEDED COMMERCIAL SCO
[ ] EXCEEDED ECO AND COMMERCIAL SCO
~ EXCEEDED ECO, POGW AND COMMERCIAL SCO
DEPTH
0-6"
6" - 1'
V-2
BENZO(A)PYRENE
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 8
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
mmm
IS Program.Office,^Westchester Counfy'Gl
0.01JNI
Mdra
jpfehi
:hbIwsd-io
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
mmmimmmwmwm
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-18 ~
HB-WSD-12
NOTE:
COMMERCIAL SCO= 1.0 mg/kg
ECO SCO= 1,0 mg/kg
POGW SCO= 3.2 mg/kg
ND = NON-DETECT RESULT BELOW THE DETECTION LIMIT
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS .
HUMAN HEALTH RISK ASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
ID FORESTED UPLAND
~ DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < ECO SCO
1 j EXCEEDED ECO AND COMMERCIAL SCO
¦ EXCEEDED ECO, COMMERCIAL AND POGW SCO
DEPTH
0-6"
6" -1'
r -2'
TOTAL PCB
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 9
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
PSWSD-10
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-i 5
HB-WSD-23
;o o:4rJiaar.^^_k
°.°7j r^..
0.02J I ""HB-WSD*09 a
HB-WSD-07
NOTE:
ECO SCO= 0.0033 mg/kg
COMMERCIAL SCO= 47.0 mg/kg
POGW SCO= 136 mg/kg
ND = NON-DETECT RESULT BELOW THE DETECTION LIMIT
J = ESTIMATED VALUE
JN = ESTIMATED, UNCONFIRMED VALUE
HB-WSD-13
HB-WSD-05
HB-WSD-08
HB-WSD-01
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS
HUMAN HEALTH RISK ASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
ID FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < ECO SCO
' EXCEEDED ECO SCO
EXCEEDED ECO AND COMMERCIAL SCO
~ EXCEEDED ECO, POGW AND COMMERCIAL SCO
DEPTH
0-6"
6" - 1'
1'-2'
4-4-DDT
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 10
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
CSX RAILROADin^gS
I ENGINEERED COVER IN NON-FORESTED AREA I
- PERCHED WETLAND COVER (7.5 ACRES)
. -
: j ENGINEERED SOIL COVER IN NON-FORESTED AREA
^ - UPLAND VEGETATED SOIL
COVER (0.7 ACRES)
UNDISTURBED EAGLE ROOSTING HABITAT
UNDISTURBED FORESTED HABITAT (15.3 ACRES)
¦SSra %\ M
• m
ALSO INCLUDES:
- WETLAND RESTORATION/MITIGATION
- GROUNDWATER MONITORING
- MONITORED NATURAL ATTENUATION
- ON-SITE REUSE AND/OR OFF-SITE DISPOSAL OF
EXCAVATED SOIL/FILL MATERIAL
- INSTITUTIONAL CONTROLS ^
- BIOTA MONITORING
- PRE-DESIGN SOIL SAMPLING AND TREE SURVEY
f j , w i iy«i
IrWihMW
FIGURE 11
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
PERCHED WETLAND COVER (7.5 AC)
l""isiTE BOUNDARY
POTENTIAL ADDITIONAL REMEDIAL
AREAS (E.G., BASED ON SOIL
SAMPLING, TREE SURVEY)
SYW-12 ALTERNATIVE 2
ENGINEERED COVER ON PERIMETER AREA (8.2 ACRES),
WETLAND RESTORATION I CREATION, BIOTA MONITORING, AND MNA
HONEYWELL INTERNATIONAL INC.
SYW-12 PROPOSED REMEDIAL ACTION PLAN
SYRACUSE, NEWYORK
POTENTIAL FUTURE TRAIL
EXTENSION
PLANNED RECREATIONAL TRAIL
ALIGNMENT
UPLAND VEGETATED SOIL COVER
(0.7 AC)
125 250
I 1 Feet
-------
I UNDISTURBED HABITAT
UNDISTURBED FORESTED HABITAT (13.5 ACRES) I
SURFACE EXCAVATION I WETLAND
l RESTORATION IN PERIMETER AND INTERIOR AREAS
RESTORED NON-FORESTED WETLAND (6.5 ACRES)
REQUIRES LIMITED DISTURBANCE / RESTORATION OF |
FORESTED HABITAT (0.5 ACRES)
I ENGINEERED SOIL COVER IN NON-FORESTED AREA
- UPLAND VEGETATED SOIL
COVER (3 ACRES)
jP|: ,
« * "Jm S3
Program Gf$c^Westcfyester County GlSafl
\
V
a- m'
W, *•
'
k\\
- e»
' i- *
^Mfnl
»^i
¦ml
/ ' Is
-}i"' ¦&!.« /"
':#fe «
'.I/ ' .• • • -.I.' J
v.k J
^ V"-.- f
'¦ r..- .r.-v
- " i. /
-, __ —
ALSO INCLUDES:
- WETLAND RESTORATION/MITIGATION
- GROUNDWATER MONITORING
- MONITORED NATURAL ATTENUATION
- ON-SITE REUSE OF EXCAVATED
SOIL/FILL MATERIAL (ALTERNATIVE 4A: TEMPORARY
ON-SITE CONSOLIDATION NOT SHOWN; LOCATION
TO BE DETERMINED)
- OFF-SITE DISPOSAL OF EXCAVATED SOIL/FILL MATERIAL
(ALTERNATIVE 4B)
- INSTITUTIONAL CONTROLS
- BIOTA MONITORING
- PRE-DESIGN SOIL SAMPLING AND TREE SURVEY
T7~~7
—I- T-r
POTENTIAL FUTURE TRAIL
EXTENSION
PLANNED RECREATIONAL TRAIL
ALIGNMENT
UPLAND VEGETATED SOIL COVER
(3 AC)
110 220
I I Feet
SURFACE EXCAVATION / WETLAND
RESTORATION (6.5 AC)
ON-SITE CONSOLIDATION AREA
(ALTERNATIVE 4A)
POTENTIAL ADDITIONAL REMEDIAL
AREAS (E.G., BASED ON SOIL
SAMPLING, TREE SURVEY)
SITE BOUNDARY
SYW-12 ALTERNATIVE 3A/B
SURFACE EXCAVATION AND ENGINEERED COVER I RESTORATION ON PERIMETER
AND INTERIOR AREAS (10 ACRES), BIOTA MONITORING, AND MNA, WITH LIMITED TREE
REMOVAL
HONEYWELL INTERNATIONAL INC.
SYW-12 PROPOSED REMEDIAL ACTION PLAN
SYRACUSE, NEW YORK
FIGURE 12
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
EXCAVATION
8-FT EXCAVATION
3.9 ACRES iL
12-FT EXCAVATION
16-FT EXCAVATION
I FULL EXCAVATION
- REMOVAL OF ALL TREES AND EXISTING HABITAT I
TO FACILITATE EXCAVATION (23.5 ACRES)
- EXCAVATION (23.5 ACRES)
r- - (i ;
MfT •
>?.'h
/r.:- -
kg i
" ^ *
NOTE:
THIS ALTERNATIVE WOULD BE EXTREMELY DIFFICULT
TO IMPLEMENT DUE TO STABILITY CONCERNS AND
PROXIMITY TO ACTIVE RAILROAD TRACKS
KStWK ¦NjCSSW " ta
'
¦¦
V :il
V 1
gate*m
(K 91 BHa*
S-UBfe :T""
*> *- m • v •
iv
HP
3 ALSO INCLUDES:
- RESTORATION
- FORESTED UPLAND (7.4 ACRES)
- NON-FORESTED UPLAND (3.0 ACRES)
- FORESTED WETLAND (6.6 ACRES)
- NON-FORESTED WETLAND (6.5 ACRES)
- MONITORED NATURAL ATTENUATION
- FULL EXCAVATION TO APPROXIMATELY
6 TO 16 FT BGS
- OFF-SITE DISPOSAL OF EXCAVATED SOIL/
FILL MATERIAL
- GROUNDWATER MONITORING
- INSTITUTIONAL CONTROLS
-------
SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX II
TABLES
-------
Table 1
SYW-12 Site
Surface Soils (0-2 ft bgs)
Summary of Detected Concentrations and Part 375 SCO
Exceedances
Minimum
Maximum
NYSDEC Part 375
Number of
NYSDEC Part 375
Number of
NYSDEC Part 375
Number of
Number of
Number of
Detected
Detected
Unrestricted Use
Unrestricted Use
Restricted Use -
Commercial SCO
Restricted Use -
Ecological SCO
Parameter
Samples
Detects
Cone.
Cone.
SCOS
SCO Exceedances
Commercial SCOs
Exceedances
Ecological SCOs
Exceedances
Semivolatile Organic Compounds (nq/kq)
BENZO(A)ANTHRACENE
63
63
140
7,300
1,000
48
5,600
6
NC
0
BENZO(A)PYRENE
63
63
130
9,100
1,000
49
1,000
49
2,600
20
BENZO(B)FLUORANTHENE
63
63
180
12,000
1,000
51
5,600
10
NC
0
BENZO(K)FLUORANTHENE
63
63
63
4,500
800
40
56,000
0
NC
0
CHRYSENE
63
63
140
9,200
1,000
49
56,000
0
NC
0
DIBENZO(A,H)ANTHRACENE
63
57
63
1,100
330
22
560
9
NC
0
INDENO(1,2,3-CD)PYRENE
63
62
52
2,800
500
35
5,600
0
NC
0
Pesticides (|jq/kq)
4,4'-DDD
63
9
6.5
73
3.3
9
92,000
0
3.3
9
4,4'-DDE
63
3
0.5
3.6
3.3
1
62,000
0
3.3
1
4,4'-DDT
63
21
2.5
100
3.3
20
47,000
0
3.3
20
DIELDRIN
63
10
4.9
30
5
9
1,400
0
6
9
ENDRIN
63
1
26
26
14
1
89,000
0
14
1
PCBs (uq/kq)
AROCLOR-1254
63
58
31
2,110
NC
0
NC
0
NC
0
AROCLOR-1260
63
58
29.6
1,360
NC
0
NC
0
NC
0
Total PCBs
63
58
65.3
3,470
100
50
1,000
8
1,000
8
Metals (mq/kq)
CADMIUM
63
63
1
52
2.5
55
9.3
34
4
53
CHROMIUM
63
63
7.3
410
30
55
1,500
0
41
49
COPPER
63
63
7.3
330
50
47
270
4
50
47
LEAD
63
63
9.1
390
63
51
1,000
0
63
51
MERCURY
63
63
0.07
8.6
0.18
60
2.8
13
0.18
60
NICKEL
63
63
3.4
87
30
28
310
0
30
28
SILVER
63
57
0.34
13
2
32
1,500
0
2
32
ZINC
63
63
37
780
109
56
10,000
0
109
56
NOTES
This table presents (1) Rl Report and SCI da
ta only, (2) the detected concentration data only and (3) only parameters that exceeded the Part 375 Unrestricted, Restricted-Commercial or Restricted-
Protection of Ecological SCOs.
NC = No criteria available.
SCO = Soil Cleanup Objectives;
NYSDEC =
New York State Department of Environmental Conservation.
-------
Table 2
SYW-12 Site
Subsurface Soils (>2 ft bgs)
Summary of Detected Concentrations and Part 375 SCO Exceedances
Minimum
Maximum
NYSDEC Part
Number of
NYSDEC Part 375
Number of
NYSDEC Part 375
Number of
Number of
Number of
Detected
Detected
375 Unrestricted
Unrestricted Use
Restricted Use -
Commercial SCO
Restricted Use -
Ecological SCO
Parameter
Samples
Detects
Cone.
Cone.
Use SCOS
SCO Exceedances
Commercial SCOs
Exceedances
Ecological SCOs
Exceedances
Volatile Orqanic Compounds (
ig/kg)
2-BUTANONE
40
22
3.1
220
120
1
500,000
0
100,000
0
ACETONE
40
15
14.2
730
50
9
500,000
0
2,200
0
ETHYLBENZENE
40
22
1.2
11,200
1,000
9
390,000
0
NC
0
METHYLENE CHLORIDE
40
2
5.3
80
50
1
500,000
0
12,000
0
XYLENES, TOTAL
40
24
0.96
15,300
260
9
500,000
0
260
9
Semivolatile Orqanic Compounds (nq/kq)
4-METHYLPHENOL
21
8
84
1,800
330
4
500,000
0
NC
0
ACENAPHTHENE
40
33
53
210,000
20,000
4
500,000
0
20,000
4
BENZO(A)ANTHRACENE
40
34
161
53,000
1,000
31
5,600
15
NC
0
BENZO(A)PYREN E
40
34
307
46,000
1,000
31
1,000
31
2,600
28
BENZO(B)FLUORANTHENE
40
34
236
45,000
1,000
32
5,600
12
NC
0
BENZO(K)FLUORANTHENE
40
34
97
9,500
800
28
56,000
0
NC
0
CHRYSENE
40
34
201
59,000
1,000
31
56,000
1
NC
0
DIBENZO(A,H)ANTHRACENE
40
32
66.9
4,220
330
27
560
20
NC
0
FLUORENE
40
33
48
86,000
30,000
3
500,000
0
30,000
3
INDENO(1,2,3-CD)PYRENE
40
34
160
8,350
500
31
5,600
5
NC
0
NAPHTHALENE
40
33
43.2
380,000
12,000
6
500,000
0
NC
0
PHENANTHRENE
40
34
65.1
280,000
100,000
3
500,000
0
NC
0
PYRENE
40
34
279
140,000
100,000
2
500,000
0
NC
0
Pesticides (nq/kq)
4,4'-DDD
21
1
4.4
4.4
3.3
1
92,000
0
3.3
1
4,4'-DDT
21
3
4.9
31
3.3
3
47,000
0
3.3
3
PCBs (nq/kq)
AROCLOR-1248
40
1
1,110
1,110
NC
1
NC
1
NC
1
AROCLOR-1254
40
6
7.88
1,530
NC
3
NC
2
NC
2
AROCLOR-1260
40
6
12.2
853
NC
2
NC
0
NC
0
Total PCBs
40
6
18.3
2640
100
3
1,000
2
1,000
2
Metals (mq/kq)
ARSENIC
40
37
1.5
19.7
13
3
16
2
13
3
CADMIUM
40
31
0.31
100
2.5
13
9.3
2
4
4
CHROMIUM
40
40
3
470
30
13
1,500
0
41
8
COPPER
40
40
2.8
450
50
27
270
1
50
27
LEAD
40
40
1.5
437
63
29
1,000
0
63
29
MERCURY
40
40
0.0069
6
0.18
29
2.8
4
0.18
29
NICKEL
40
40
3.6
116
30
21
310
0
30
21
SILVER
40
28
0.23
13
2
18
1,500
0
2
18
ZINC
40
40
11
1,200
109
27
10,000
0
109
27
NOTES
This table presents (1) Rl Report and SCI da
ta only, (2) the detected concentration data only and (3) only parameters that exceeded the Part 375 Unrestricted, Restricted-Commercial or Restricted-
Protection of Ecological SCOs.
NC = No criteria available.
SCO = Soil Cleanup Objectives;
NYSDEC =
New York State Department of Environmental Conservation.
-------
Table 3
SYW-12 Site
Shallow and Intermediate Groundwater
Summary of Detected Concentrations and Class GA SGV and EPA MCL Exceedances
Number of
Number of
Minimum
Maximum
NYSDEC Class
Number of Class
EPA National Primary
Number of MCL
Parameter
Samples
Detects
Detected Cone.
Detected Cone.
GA SGVs
GA Exceedances
Drinking Water MCLs
Exceedances
Volatile Organic Compounds (|ig/L)
ETHYLBENZENE
26
3
0.48
14.8
5(S)
2
700
0
ISOPROPYLBENZENE
26
5
0.23
5.25
5(G)
1
NC
0
O-XYLENE
3
2
2.1
7.3
5(S)
1
NC
0
XYLENES, TOTAL
26
5
0.45
15.2
5(S)
2
10,000
0
Semivolatile Organic Compounds (|ig/L)
4-METHYLPHENOL
23
3
0.36
2
1(S)
1
NC
0
4-NITROPHENOL
26
1
1.1
1.1
1(S)
1
NC
0
ACENAPHTHENE
26
13
0.53
41
20(G)
1
NC
0
NAPHTHALENE
26
5
1.6
170
10(G)
4
NC
0
Pesticides (uq/L)
Alpha-BHC
23
2
0.0087
0.027
0.01(S)
1
NC
o
Metals (mq/L)
BARIUM
26
18
0.12
2
1(S)
6
2
2
CHROMIUM
26
4
0.0093
0.16
0.05(S)
1
0.1
1
IRON
26
25
0.34
62.3
0.3(S)
25
NC
0
LEAD
26
4
0.005
0.041
0.025(S)
1
0.015
2
MAGNESIUM
26
20
23
176
35(G)
15
NC
0
MANGANESE
26
26
0.086
2.1
0.3(S)
23
NC
0
SODIUM
26
26
250
3,400
20(S)
26
NC
0
Inorganics (mq/L)
BROMIDE
17
11
1.6
16.6
2(G)
9
NC
0
CHLORIDE
26
26
380
9,940
250(S)
26
NC
0
NITROGEN, AMMONIA (AS N)
3
3
5.5
36
2(S)
3
NC
0
SULFIDE
14
4
2
17.6
0.05(G)
4
NC
0
NOTES
This table presents (1) Rl Report and 2019 follow up data only, (2) the detected concentration data only and (3) only parameters that exceeded the NYSDEC Class GA
SGVs or USEPA Drinking Water MCLs.
NC = No criteria available.
(S) = Standard; (G) = Guidance Value; MCL =
Maximum Contaminant Level; EPA = Environmental Protection Agency; NYSDEC =
New York State Department of
Environmental Conservation.
-------
Table 4 - Human Health Risk Re-Evaluation Summary
Timeframe
Receptor
Exposure Medium
Cancer Risk
Non-Cancer
Hazard
Hazard/Risk Driving COCs
Current/Future
Utility Worker
Surface/Subsurface Soil
3xl0"5
0.07
--
Outdoor Air
4xl0"7
0.006
--
Shallow Groundwater
6xl0"5
0.6
--
All Media
6xl0"5
0.6
--
Current/Future
Child Recreator
Surface Soil
6xl0"5
0.9
--
Outdoor Air
2xl0"7
0.006
--
All Media
6xl0"5
0.9
--
Current/Future
Adult Recreator
Surface Soil
3xl0"5
0.05
--
Outdoor Air
9xl0"7
0.006
--
All Media
4xl0"5
0.06
--
Current/Future
Railroad Worker
Surface Soil
lxlO"5
0.2
--
Outdoor Air
2xl0"5
0.01
--
All Media
lxlO"5
0.2
--
Future
Commercial/
Industrial Worker
Surface Soil
2xl0"5
0.3
--
Outdoor Air
9xl0"5
0.07
--
All Media
2xl0"5
0.3
--
Future
Construction
Worker
Surface/Subsurface Soil
lxlO"5
0.8
--
Outdoor Air
2xl0"7
0.07
--
Shallow Groundwater
3xl0"5
7.1
Benzo(a)pyrene, chromium1
All Media
3xl0"5
8.0
Benzo(a)pyrene, chromium1
Future
Child Resident2
Surface Soil
9xl0"5
7.6
Highly chlorinated PCBs
Outdoor Air
5xl0"5
0.4
--
All Media
lxlO"4
7.9
Highly chlorinated PCBs
Future
Adult Resident2
Surface Soil
lxlO"5
0.2
--
Outdoor Air
3xl0"5
0.2
--
All Media
4xl0"5
0.4
--
- Shaded cells indicate exceedance of the USEPA acceptable cancer risk or non-cancer hazard threshold.
1 Based on HHRA results using groundwater data collected during RI; chromium and benzo(a)pyrene were not detected in
groundwater monitoring well samples collected subsequent to the RI.
2 While child and adult resident receptors were evaluated in the HHRA, residential use would not be consistent with the
anticipated future land use of the SYW-12 Site.
-------
ENVIRONMENT
& HEALTH
Table 5. Alternative 2 Cost Estimate
Site: Honeywell Murphy's lsland/SYW-12
Location: Syracuse, NY
Phase: Feasibility Phase ( + 50% / -25%)
Base Year: 2022
Conceptual Basis: Soil Cover in Select Areas, Wetland Restoration, Biota Monitoring, and Monitored Natural Attenuation
Estimated
Estimated
Estimated
Item
Unit
Quantity
Unit Cost
Cost
Notes
DIRECT CAPITAL COST
General Conditions
WK
15
$15,000
$225,000
Trailer, fuel, small tools, consumables and safety; 1 week Mob
Mobilization
EA
1
$65,000
$65,000
One per 36-wk construction season; reflects winter condition and eagle roosting no-work periods
Air Monitoring
LS
1
$45,000
$45,000
Surveys and Layouts
EA
2
$4,500
$9,000
Pre-construction, post-construction
Irrigation
WK
4
$5,000
$20,000
Following seeding, 4 weeks per season
Railroad Protection
WK
15
$16,000
$240,000
1 Construction Manager and 1 Flagman
Temporary Fencing
LF
6,000
$10
$60,000
Truck Wash
WK
15
$7,500
$112,500
Wash rack and operation
Dust Suppression/Control
WK
15
$3,500
$52,500
5,000 gallon water truck and operation
Permits
LS
1
$15,000
$15,000
Railroad Access Permit/ Agreement
Pre-Design Survey
LS
1
$40,000
$40,000
Topographic and Tree Surveys and borings/geological eval
3 samples from each of 14 loc (3 each of four forested wetland and 2 from one upland area). For
Additional Surface Soil Sampling
LS
1
$50,000
$50,000
potential remedial footprint expansion.
Site-Wide Surface Soil Pre-Design Investigation
LS
1
$70,000
$70,000
16 locations, 3 samples each. Part 375 analysis.
Baseline Biota Monitoring
Sediment Sampling
LS
1
$9,500
$9,500
1 sample from each of 8 locations; one event
Invertebrate Sampling and Analysis
LS
1
$20,500
$20,500
8 samples from each of 2 Events (spring and summer)
Small Mammal Sampling and Analysis
LS
1
$25,000
$25,000
8 samples from each of 2 Events (spring and summer)
Workplan and Reporting
LS
1
$11,500
$11,500
Site Preparation
Clearing and Grubbing
AC
8.2
$11,000
$90,200
Non-forested wetlands and uplands only; no tree clearing. Chipped and left onsite.
Rough Grading
AC
8.2
$4,000
$32,800
Non-forested wetlands and uplands
Railroad Crossing
EA
3
$25,000
$75,000
Construction Entrance
LS
1
$16,000
$16,000
6-inch stone entrance, 50ft x 24ft, from access road along Ley Creek.
Working Pad
CY
1,500
$90
$135,000
4-ft stone, mirafi, 100 x 100-ft
Access Roadways - Installation
LF
3,000
$130
$390,000
2-ft stone, mirafi, built to 35-ft width (assume 2 lanes)
Site Access - Crane Mats
LS
1
$75,000
$75,000
Rental; 500 LF crane mats
Materials QA/QC Testing - Topsoil
EA
6
$2,500
$15,000
chemical and physical testing of imported materials; includes emerging contaminants
Materials QA/QC Testing - Fill and stone
EA
9
$2,200
$20,790
chemical and physical testing of imported materials; includes emerging contaminants
Compaction Testing
WK
8
$1,000
$8,000
during backfill only
Erosion and Sediment Control
LF
15,000
$8
$120,000
Reinforced silt fence along access road and site perimeter, twice along lakefront
Perched Wetland Construction (5.9 AC)
Import and place 12-in topsoil
CY
9,500
$53
$503,500
Placement by conventional equipment in 6-inch lifts; Infertile topsoil.
Import and place 12-in clay
CY
10,450
$54
$564,300
Placement by conventional equipment in 6-inch lifts; assumes variable grading.
Import and place internal clay berms
CY
900
$54
$48,600
1,5-ft tall berms with 3V: 1 H side slopes
Wetland elevation grading and shaping
AC
2.5
$70,000
$175,000
average deepening of 12-inches (max. of 24-inches); includes clearing and access improvements
Wetland seeding
AC
5.9
$26,000
$153,400
Cost includes installation; hand sown at 30 pounds per acre
Hand Plantings
AC
5.9
$5,000
$29,500
Assumes 8000 live stakes per acre
Wetland Berm and Grading Construction (1.6 AC)
Fine grading berm
AC
1.6
$9,000
$14,400
Grading of berm subgrade prior to placement of topsoil
Import and place 6-in topsoil
CY
1,400
$53
$74,200
Placement by conventional equipment in 6-inch lifts; 6-in infertile topsoil.
Import and place subgrade material
CY
4,800
$46
$220,800
Placement by conventional equipment in 6-inch lifts to within 3.5-ft. Includes 18-in cover materia
Geogrid Stabilization
AC
1.6
$47,000
$75,200
Placed between subgrade and topsoil
Seeding
AC
1.6
$19,000
$30,400
Modified old field successional with fertilizer and hydromulch; total berm surface area
\\syracusesvr\projects\Honeywell.1163\65696.Syw-12-Fs\Docs\Reports\FS Report\Tables\Alternatives Cost Estimates_REV 20220401.xlsx
PAGE 2
-------
ENVIRONMENT
& HEALTH
Table 5. Alternative 2 Cost Estimate
Site: Honeywell Murphy's lsland/SYW-12
Location: Syracuse, NY
Phase: Feasibility Phase ( + 50% / -25%)
Base Year: 2022
Conceptual Basis: Soil Cover in Select Areas, Wetland Restoration, Biota Monitoring, and Monitored Natural Attenuation
Estimated
Estimated
Estimated
Item
Unit
Quantity
Unit Cost
Cost
Notes
Upland Engineered Vegetative Cover (0.7 AC)
Import and place 6-in topsoil
CY
600
$53
$31,800
Placement by conventional equipment in 6-inch lifts
Import and place 18-in subgrade material
CY
1,800
$46
$82,800
Placement by conventional equipment in 6-inch lifts
Non-wetland seeding
AC
0.7
$19,000
$13,300
Modified old field successional with fertilizer and hydromulch
Transportation and Disposal
T&D of Roadway Material - C&D
TON
11,700
$80
$936,000
1.7 tons per cy; disposal at C&D landfill. Includes equipment/labor for removal
TOTAL ESTIMATED DIRECT CAPITAL COST:
$5,000,000
rounded
INDIRECT CAPITAL COST
Total Estimated Direct Capital Cost:
$5,000,000
Engineering/Management, Construction Oversight, OH&P
$950,000
6%, 8%, and 5% respectively
Contingency
$1,500,000
Scope Contingency at 30%
Institutional Controls
Environmental Easement
LS
1
$30,000
$30,000
Site Management Plan
LS
1
$50,000
$50,000
TOTAL ESTIMATED CAPITAL COST:
$7,530,000
rounded
OPERATION AND MAINTENANCE COSTS
Annual Years 1-5
Reporting and Recordkeeping
EA
1
$20,000
$20,000
Cover inspection
LS
1
$2,400
$2,400
Assumes 2 scientists/engineers, 1 days, 8 hours/day, twice annually
Groundwater Monitoring
Well inspection and sampling labor
LS
1
$9,600
$9,600
Assumes 2 scientists/engineers, 8 hours/day, twice annually, 4 days
Groundwater samples
LS
1
$12,600
$12,600
Assumes 14 samples (10 wells + QA/QC) twice annually; 28 samples total
On-site Cover Maintenance
Wetland/Non-Forest Vegetation Maintenance
AC
0.3
$26,000
$7,800
Spot seeding (5% of all areas annually) and handpulling invasive species
Cover maintenance and incidental repairs
AC
8.2
$325
$2,665
Topsoil repair, 5 cy/acre annually
Annual Years 1,3,5
Baseline Biota Monitoring
Sediment Sampling
LS
1
$9,500
$9,500
1 sample from each of 8 locations; one event
Invertebrate Sampling and Analysis
LS
1
$20,500
$20,500
1 sample from each of 8 locations; one event
Small Mammal Sampling and Analysis
LS
1
$25,000
$25,000
1 sample from each of 8 locations; one event
Workplan and Reporting
LS
1
$11,500
$11,500
\\syracusesvr\projects\Honeywell.1163\65696.Syw-12-Fs\Docs\Reports\FS Report\Tables\Alternatives Cost Estimates_REV 20220401.xlsx
PAGE 3
-------
ENVIRONMENT
& HEALTH
Table 5. Alternative 2 Cost Estimate
Site: Honeywell Murphy's lsland/SYW-12
Location: Syracuse, NY
Phase: Feasibility Phase ( + 50% / -25%)
Base Year: 2022
Conceptual Basis: Soil Cover in Select Areas, Wetland Restoration, Biota Monitoring, and Monitored Natural Attenuation
Estimated
Estimated
Estimated
Item
Unit
Quantity
Unit Cost
Cost
Notes
Annual Years 6-30
Reporting and Recordkeeping
EA
1
$20,000
$20,000
Cover inspection
LS
1
$2,400
$2,400
Assumes 2 scientists/engineers, 1 days, 8 hours/day, twice annually
Groundwater Monitoring
Well inspection and sampling labor
LS
1
$9,600
$9,600
Assumes 2 scientists/engineers, 8 hours/day, twice annually, 4 days
Groundwater samples
LS
1
$12,600
$12,600
Assumes 14 samples (10 wells + QA/QC) twice annually; 28 samples total
Years 5, 10, 15, 20, 25, 30
Five Year Review
EA
1
$15,000
$15,000
PRESENT WORTH ANALYSIS (YEARS 1-30)
Cost
DISCOUNT
FACTOR
Df=7
PRESENT WORTH
(rounded)
ESTIMATED CAPITAL COST - Year 0
$7,530,000
1.00
$7,530,000
ANNUAL O&M - YEARS 1-5
$55,065
0.82
$226,000
Average discount factor for years 1 -5
ANNUAL O&M - YEARS 1, 3, 5
$66,500
0.82
$164,000
Average discount factor for years 1, 3, 5
ANNUAL O&M - YEARS 6-30
$44,600
0.33
$371,000
Average discount factor for years 6-30
PERIODIC O&M - YEARS 5, 10, 15, 20, 25, 30
$15,000
0.36
$32,000
Average discount factor for years 5, 10, 15, 20, 25 and 30
TOTAL PRESENT WORTH ESTIMATED ALTERNATIVE COST:
$8,300,000
rounded
\\syracusesvr\projects\Honeywell.1163\65696.Syw-12-Fs\Docs\Reports\FS Report\Tables\Alternatives Cost Estimates_REV 20220401.xlsx
PAGE 4
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HONEYWELL
SYW-12 SITE
FEASIBILITY STUDY
ENVIRONMENT
& HEALTH
TABLE 6. POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRITE REQUIREMENTS (ARARS) AND TO BE CONSIDERED (TBC) MATERIALS
Medium .. _ Potential Potential
. .. .. .. Citation Requirements Comments ___
Location/Action M ARAR TBC
Potential Chemical-Specific ARARs and TBCs
Soil/fill material
6 NYCRR Part 375-6 Remedial Program
Soil Cleanup Objectives (SCOs)
Promulgated state regulation that provides guidance for SCOs for
various restricted property uses (industrial, commercial, restricted
residential, and residential), for the protection of groundwater and
ecological resources, and for unrestricted property use. Commercial use
includes passive recreational use that refers to recreational uses with
limited potential for soil contact, such as: (1) artificial surface fields; (2)
outdoor tennis or basketball courts; (3) other paved recreational
facilities used for roller hockey, roller skating, shuffle board, etc.; (4)
outdoor pools; (5) indoor sports or recreational facilities; (6) golf
courses; and (7) paved (raised) bike or walking paths [DER-10 (NYSDEC
2010)].
SCOs for restricted use (commercial, protection of ecological
resources) are potentially relevant and appropriate to SYW-12 Site
soil/fill material give the current and reasonably anticipated future
land use for commercial purposes, including a passive recreational
use, as well as consideration of the seasonal presence of eagles at
the SYW-12 Site. SCOs for unrestricted use may not be applicable,
relevant or appropriate given the current and reasonably anticipated
future land use; however, were considered for the purpose of
evaluating unrestricted conditions. SCOs for the protection of
groundwater are also considered.
Yes
No1
USEPA Soil Screening Guidance: User's
Guide (1996)
Guidance that provides methodology for developing site-specific soil
screening levels. Also provides generic soil screening levels based on
default assumptions.
Potentially relevant and appropriate to SYW-12 Site soil/fill material.
No
Yes
USEPA Regional Screening Levels
Guidance that provides human health risk-based screening values for
soil at industrial sites. Screening levels are calculated based on human
health exposure assumptions and toxicity data.
Industrial worker, outdoor worker and recreator soil screening levels
are potentially applicable for the screening of soil/fill material.
No
Yes
USEPA Ecological Screening Levels
Guidance that provides ecological risk-based screening values.
Screening levels are based on ecological exposure assumptions and
toxicity data.
To be considered. Ecological screening values are not promulgated
cleanup levels.
No
Yes
Groundwater
6 NYCRR Part 703 - Class GA Groundwater
Quality Standards
Promulgated water quality standards for fresh groundwater, including
narrative and constituent-specific standards.
Potentially applicable for SYW-12 Site groundwater.
Yes
No
NYS TOGS 1.1.1 - Ambient Water Quality
Standards and Guidance Values and
Groundwater Effluent Limitations
Guidance that summarizes groundwater standards and guidance values.
Guidance values are provided where standards are not available.
Potentially applicable for SYW-12 Site groundwater.
Yes
No
1 USEPA Region 2 considered 6 NYCRR Part 375-6 Remedial Program SCOs to be a TBC.
l:\HONEYWELL.1163\65696.SYW-12-FS\DOCS\REPORTS\FS R E P O RT\T A B LE S\T A B L E 3-1 ARARS AND TBC MATERIALS_2 021-09-14.DOCX
PAGE 1
-------
HONEYWELL
SYW-12 SITE
FEASIBILITY STUDY
ENVIRONMENT
& HEALTH
TABLE 6. POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRITE REQUIREMENTS (ARARS) AND TO BE CONSIDERED (TBC) MATERIALS
Medium
Location/Action
Citation
Requirements
Comments
Potential
ARAR
Potential
TBC
40 CFR Part 141 - Drinking Water
Standards
Promulgated federal regulation that establishes primary drinking water
regulations applicable to public water systems.
Potentially applicable for SYW-12 Site groundwater. Groundwater is
not used as a drinking water source as municipal water is available.
Yes
No
Potential Location-Specific ARARs and TBCs
NYSDOH's October 2006 Guidance for
Evaluating
Soil Vapor Intrusion in the State of New
York
Guidance document that provides thresholds for indoor air and sub-slab
soil vapor above which vapor mitigation is required.
Not currently applicable, because no buildings are present on the
SYW-12 Site. Potentially applicable if future buildings are
constructed at the SYW-12 Site.
No
Yes
Construction of
buildings
OSWER Technical Guide for Assessing and
Mitigating the Vapor Intrusion Pathway
from Subsurface Vapor Sources to Indoor
Air, OSWER Publication 9200.2-154, June
2015
Technical guidance that provides recommendations on assessment of
vapor intrusion pathways that pose an unacceptable risk to human
health.
Not currently applicable, because no buildings are present on the
SYW-12 Site. Potentially applicable if future buildings are
constructed at the SYW-12 Site.
No
Yes
6 NYCRR 608 - Use and Protection of
Waters Program
Regulatory and permit requirements for work affecting New York State
lakes, rivers, streams, and ponds.
Potentially applicable to remedial actions at the SYW-12 Site given
the overlap of the 100-year floodplain, and potential actions below
mean high water for Onondaga Lake, Ley Creek, and Onondaga
Creek.
Yes
No
Water bodies
Article 15 - Water Resources - New York
Environmental Conservation Law
Regulatory and permit requirements for work affecting New York State
lakes, rivers, streams, and ponds.
Potentially applicable to work affecting Onondaga Lake, Ley Creek,
and Onondaga Creek.
Yes
No
33 CFR 320 - 330 - Navigation and
Navigable Waters
Regulatory policies and permit requirements for work affecting waters of
the United States and navigable waterways.
Substantive, non-administrative requirements potentially applicable
Yes
No
16 (JSC 661 - Fish and Wildlife
Coordination Act
Requires protection of fish and wildlife in a stream or other water body
when performing activities that modify a stream or river.
to work affecting Onondaga Lake, Ley Creek, and Onondaga Creek.
Yes
No
6 NYCRR 663 - Freshwater wetland permit
requirements
Actions occurring in a designated freshwater wetland (within 100 feet)
must be approved by NYSDEC or its designee. Activities occurring
adjacent to freshwater wetlands must: be compatible with preservation,
protection, and conservation of wetlands and benefits; result in no more
than insubstantial degradation to or loss of any part of the wetland; and
be compatible with public health and welfare.
SYW-12 is a New York State-regulated wetland. Potentially
applicable to remedial actions at the SYW-12 Site and within 100
feet of wetlands as designated freshwater wetlands regulated by
NYSDEC.
Yes
No
Wetlands
Clean Water Act Section 404
33 CFR Parts 320 - 330
Regulatory policies and permit requirements for work affecting waters of
the United States, including wetlands.
Yes
No
Clean Water Act Section 404
40 CFR Parts 230-231
Provides for restoration and maintenance of integrity of waters of the
United States, including wetlands, through the control of dredged or fill
material discharge.
Potentially applicable; the SYW-12 Site is a delineated wetland.
Yes
No
Executive Order 11990 - Protection of
Wetlands
Executive order requires federal agencies to avoid, to the extent
possible, the long- and short-term adverse impacts associated with the
destruction or loss of wetlands if a practical alternative exists.
Yes
No
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HONEYWELL
SYW-12 SITE
FEASIBILITY STUDY
ENVIRONMENT
& HEALTH
TABLE 6. POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRITE REQUIREMENTS (ARARS) AND TO BE CONSIDERED (TBC) MATERIALS
Medium
Location/Action
Citation
Requirements
Comments
Potential
ARAR
Potential
TBC
Wetlands &
floodplains
Policy on Floodplains and Wetland
Assessments for CERCLA Actions (OSWER
Directive 9280.0-2; 1985)
Policy and guidance requiring Superfund actions to meet substantive
requirements of Executive Orders 11988 and 11990. Describes
requirements for floodplain assessment during remedial action planning.
To be considered during the remedial design. Potentially applicable
to the SYW-12 Site, a delineated wetland. Potentially applicable as
the SYW-12 Site is within the 100- and 500-year floodplains.
Yes
No
Potential Location-Specific ARARs and TBCs (continued)
Wetlands &
floodplains
40 CFR Part 6, Appendix A - Statement of
Procedures on Floodplains Management
and Wetlands Protection (January 5, 1979)
Policy and guidance for implementing Executive Orders 11988 and
11990. Requires federal agencies to evaluate the potential effects of
action proposed in wetlands and floodplains to avoid, to the extent
possible, adverse effects. Federal agencies are required to evaluate
alternatives to actions in wetlands or floodplains and to avoid or
minimize adverse impacts if not practical alternatives exist.
To be considered during the remedial design. Potentially applicable
to the SYW-12 Site, a delineated wetland. Potentially applicable as
the SYW-12 Site is within the 100- and 500-year floodplains.
Requires a floodplain assessment if the selected alternative includes
remedial activities that would potentially impact the floodplain.
Yes
No
6 NYCRR 373-2.2 - Location standards for
hazardous waste treatment, storage, and
disposal facilities -100-yr floodplain
Hazardous waste treatment, storage, or disposal facilities located in a
100-yr floodplain must be designed, constructed, operated and
maintained to prevent washout of hazardous waste during a 100-year
flood.
Not applicable or relevant and appropriate. The SYW-12 Site is
within the 100-year floodplain; however, no hazardous waste
treatment, storage, or disposal facilities are planned to be located
on the SYW-12 Site.
No
No
40 CFR Part 264.18(b) - Location
Standards - Floodplains
Hazardous waste treatment, storage, or disposal facilities located in a
100-yr floodplain must be designed, constructed, operated and
maintained to prevent washout of hazardous waste during a 100-year
flood.
Not applicable or relevant and appropriate. The SYW-12 Site is
within the 100-year floodplain; however, no hazardous waste
treatment, storage, or disposal facilities are planned to be located
on the SYW-12 Site.
No
No
Floodplains
Executive Order 11988 - Floodplain
Management
USEPA is required to conduct activities to avoid, to the extent possible,
the long- and short-term adverse impacts associated with the
occupation or modification of floodplains. The procedures also require
USEPA to avoid direct or indirect support of floodplain development
wherever there are practicable alternatives and minimize potential harm
to floodplains when there are no practicable alternatives.
Potentially applicable or relevant and appropriate. The SYW-12 Site
is located within the 100- and 500-year floodplains. Requires a
floodplain assessment if the selected alternative includes remedial
activities that would potentially impact the floodplain.
Yes
No
Executive Order 13690 - Establishing a
Federal Flood Risk Management Standard
and a Process for Further Soliciting and
Considering Stakeholder Input
Executive order establishes a Federal Flood Risk Management Standard
(FFRMS), a Process for Further Soliciting and Considering Stakeholder
Input, and amends Executive Order 11988. The FFRMS establishes a
construction standard and framework for Federally funded projects
constructed in, and affecting, floodplains, to reduce the risks and cost of
floods. Under the FFRMS, federal agency management is expanded from
the current base flood level to a higher vertical elevation and
corresponding horizontal floodplain to address current and future flood
risk to increase resiliency of projects funded with federal funds. The
Executive Order also sets forth a process for solicitation and
consideration of public input, prior to implementation of the FFRMS.
Potentially applicable or relevant and appropriate. The SYW-12 Site
is location within the 100-year and 500-year floodplains. Requires a
floodplain assessment if the selected alternative includes remedial
activities that would potentially impact the floodplain.
Yes
No
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HONEYWELL
SYW-12 SITE
FEASIBILITY STUDY
ENVIRONMENT
& HEALTH
TABLE 6. POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRITE REQUIREMENTS (ARARS) AND TO BE CONSIDERED (TBC) MATERIALS
Medium
Location/Action
Citation
Requirements
Comments
Potential
ARAR
Potential
TBC
6 NYCRR 500 - Floodplain Management
Regulations Development Permits
Promulgated state regulations providing permit requirements for
development in areas of special flood hazard (floodplain within a
community subject to a one percent or greater chance of flooding in any
given year).
Requires remedial activities to be conducted in accordance with the
local and state statutory requirements if conducted within the 100-
year and/or 500-year floodplains as defined by FEMA. The 100-year
and 500-year floodplains exist along the general lakeshore area
immediately adjacent to Onondaga Lake and includes the SYW-12
Site.
Yes
No
Railroad
Article 3, Sections 90 - 95 - New York
Railroad Law
Promulgated state regulation that provides requirements for the
construction, operation and management of New York State railroads.
Potentially applicable or relevant and appropriate. The SYW-12 Site
is bound by CSX railroad tracks to the north and east.
Yes
No
Potential Location-Specific ARARs and TBCs (continued)
Within 61 meters
(200 feet) of a
fault displaced in
Holocene time
40 CFR Part 264.18(a) - Location
Standards - Seismic considerations
New treatment, storage, or disposal of hazardous waste is not allowed.
Not applicable or relevant and appropriate. SYW-12 Site is not
located within 200 feet of a fault displaced in Holocene time, as
listed in 40 CFR 264 Appendix VI. None listed in New York State.
No
No
Within salt dome
or bed formation,
underground
mine, or cave
40 CFR Part 264.18 (c) - Location
standards; salt dome formations, salt bed
formations, underground mines and caves.
Placement of non-containerized or bulk liquid hazardous waste is not
allowed.
Not applicable or relevant and appropriate. No salt dome
formations, salt bed formations, underground mines or caves
present at the SYW-12 Site.
No
No
6 NYCRR 182
Promulgated state regulation that provides requirements to minimize
damage to habitat of an endangered species.
Potentially applicable or relevant and appropriate. No rare,
endangered or threatened wildlife species, rare plants or significant
habitats were identified at the SYW-12 Site (Revised Baseline
Yes
No
Endangered Species Act
Provides a means for conserving various species of fish, wildlife, and
plants that are threatened with extinction.
Ecological Risk Assessment, OBG 2011); however, the SYW-12 Site
serves as a winter roost site and seasonal concentration area for
bald eagles (currently listed as threatened pursuant to 6 NYCRR
182.5[b]6.iii). In accordance with 6 NYCRR 182.8, activities that are
No
No
Habitat of an
endangered or
threatened
species
50 CFR Part 17 - Endangered and
Threatened Wildlife and Plants
and
50 CFR Part 402 - Interagency Cooperation
Promulgated federal regulation that requires that federal agencies
ensure authorized, funded, or executed actions will not destroy or have
adverse modification of critical habitat.
likely to result in a 'take' of listed species are generally prohibited,
including any adverse modification of habitat or modification of
essential behavior. The occupation of the SYW-12 Site by bald eagle
is recognized by the US Fish and Wildlife Service and the NYSDEC.
Measures to ensure the continued integrity of the roost site will be
considered. One threatened plant within 2 miles of SYW-12 Site on
north shore of Onondaga Lake not anticipated to be impacted by
SYW-12 Site activities.
No
No
16 U.S.C. 668 et seq - Bald and Golden
Eagle Protection Act
Promulgated federal regulation prohibiting take of bald eagles, unless
otherwise permitted by USFWS. Take is further defined to include
pursuit, hoot, shoot at, poison, wound, kill, capture, collect, molest, or
disturb.
Potentially applicable or relevant and appropriate. The SYW-12 Site
serves as a winter roost site and seasonal concentration area for
Yes
No
Migratory Bird Treaty Act of 1918
Promulgated federal regulation for protection of migratory birds.
bald eagles (currently State-listed as Threatened). Measures to
ensure the continued integrity of the roost site will be considered.
Yes
No
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ENVIRONMENT
& HEALTH
TABLE 6. POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRITE REQUIREMENTS (ARARS) AND TO BE CONSIDERED (TBC) MATERIALS
Medium .. _ Potential Potential
. .. .. .. Citation Requirements Comments ___
Location/Action M ARAR TBC
United States Fish and Wildlife National
Bald Eagle Management Guidelines (2007)
Guidance that provides recommendations to minimize impacts to bald
eagles, particularly related to human activities with the potential to
disturb bald eagles and their ability to forage, nest and breed.
No
Yes
Conservation Plan for Bald Eagles in New
York State (March 2016)
Guidance that provides recommendations for long-term management
and conservation of bald eagles in New York.
No
Yes
Historical
property or
district
National Historic Preservation Act
36 CFR 800- Preservation of Historic
Properties Owned by a Federal Agency
Remedial actions are required to account for the effects of remedial
activities on any historic properties included on or eligible for inclusion
on the National Register of Historic Places.
Potentially applicable. A Phase 1A assessment identified the
potential for historic resources at the SYW-12 Site.
Yes
No
National Historic Preservation Act
36 CFR Part 65 - National Historic
Landmarks Program
Promulgated federal regulation requiring that actions must be taken to
preserve and recover historical/archeological artifacts found.
Yes
No
New York State Historic Preservation
Act of 1980
9 NYCRR Parts 426 - 428
State law and regulations requiring the protection of historic,
architectural, archeological and cultural property.
Yes
No
Wilderness area
Wilderness Act
50 CFR Part 35 - Wilderness Preservation
and Management
Provides for protection of federally-owned designated wilderness areas.
Not applicable or relevant and appropriate. SYW-12 Site not located
in wilderness area.
No
No
Wild, scenic, or
recreational river
Wild and Scenic Rivers Act
Provides for protection of areas specified as wild, scenic, or recreational.
Not applicable or relevant and appropriate. SYW-12 Site not located
near wild, scenic or recreational river.
No
No
Coastal zone
Coastal Zone Management Act
Requires activities be conducted consistent with approved State
management programs.
Not applicable or relevant and appropriate. SYW-12 Site not located
in coastal zone.
No
No
Coastal barrier
Coastal Barrier Resources Act
Prohibits any new Federal expenditure within the Coastal Barrier
Resource System.
Not applicable or relevant and appropriate. SYW-12 Site not located
in coastal barrier.
No
No
Protection of
waters
33 U.S.C. 1341 - Clean Water Act Section
401, State Water Quality Certification
Program
States have the authority to veto or place conditions on federally
permitted activities that may result in water pollution.
Potentially applicable to the SYW-12 Site.
Yes
Yes
Potential Action-Specific ARARs and TBCs
Institutional
controls
NYSDEC DER-33 Institutional Controls: A
Guide to Drafting and Recording
Institutional Controls, December 2010
Technical guidance document that provides guidelines for proper
development and recording of institutional controls as part of a site
remedial program.
Potentially applicable TBC when institutional controls are
implemented as a component of the selected remedy.
No
Yes
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HONEYWELL
SYW-12 SITE
FEASIBILITY STUDY
PAGE 5
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HONEYWELL
SYW-12 SITE
FEASIBILITY STUDY
ENVIRONMENT
& HEALTH
TABLE 6. POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRITE REQUIREMENTS (ARARS) AND TO BE CONSIDERED (TBC) MATERIALS
Medium
Location/Action
Citation
Requirements
Comments
Potential
ARAR
Potential
TBC
Cover systems
NYSDEC DER-10 Technical Guidance for
Site Investigation and Remediation, May
2010
Technical guidance document that provides guidelines for cover
thicknesses as they relate to property use in areas where exposed
surface soil exceeds NYCRR Part 375 SCOs. Specifically, where the
exposed surface soil at the site exceeds the applicable soil cleanup
objective for protection of human health and/or ecological resources, the
soil cover for restricted residential use, is to be two feet; for commercial
or industrial use, is to be one foot; or when an ecological resource has
been identified is to be a minimum of two feet; and when such a
concern is identified by NYSDEC, consideration should be given to
supplementing the demarcation layer to serve as an impediment to
burrowing.
Potentially applicable TBC for cover alternatives.
No
Yes
RCRA Subtitle D, 40 CFR Part 358.60 -
Closure Criteria
Regulations established under Subtitle D set federal closure
requirements including installation of a final cover system that is
designed to minimize infiltration and erosion, for owners and operators
of municipal solid waste landfill units.
Not applicable or relevant and appropriate. The SYW-12 Site is not
considered a Waste Management Area or municipal landfill for which
closure criteria for final cover systems may be relevant.
No
No
40 CFR Part 257 - Criteria for Classification
of Solid Waste Disposal Facilities and
Practices
Promulgated federal regulation that provides criteria for solid waste
disposal facilities to protect health and the environment.
Yes
No
Landfill
40 CFR Parts 264 and 265, Subpart N -
Landfills
Promulgated federal regulation that provides requirements for hazardous
waste landfill units.
Landfilling of wastes may be applicable for the SYW-12 Site.
Yes
No
Principal threat
and low level
threat waste
A Guide to Principal Threat and Low Level
Threat Wastes - Quick Reference Fact
Sheet (OSWER Superfund Publication
9380.3-06FS, November 1991)
Guidance that outlines federal expectations, definitions, and
documentation requirements related to waste considered principal or low
level threat waste.
Potentially applicable TBC.
No
Yes
Generation and
management of
solid waste
6 NYCRR 360 - Solid Waste Management
Facilities
Promulgated state regulation that provides requirements for
management of solid wastes, including disposal and closure of disposal
facilities.
Potentially applicable to alternatives including disposal of residuals
generated by treatment processes as well as capping alternatives.
Yes
No
6 NYCRR 376 - Land Disposal Restrictions
Land disposal
40 CFR Part 268 - Land Disposal
Restrictions
Promulgated federal and state regulations that provide treatment
standards to be met prior to land disposal of hazardous wastes.
Potentially applicable to residuals generated by treatment processes
if found to be hazardous waste and disposed at a landfill. Applicable
for off-site treatment and disposal if excavated soil/fill material does
not meet land disposal restrictions.
Yes
No
62 CFR 25997 - Phase IV Supplemental
Proposal on Land Disposal of Mineral
Processing Wastes
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HONEYWELL
SYW-12 SITE ENVIRONMENT
FEASIBILITY STUDY & HEALTH
TABLE 6. POTENTIALLY APPLICABLE OR RELEVANT AND APPROPRITE REQUIREMENTS (ARARS) AND TO BE CONSIDERED (TBC) MATERIALS
Medium .. _ Potential Potential
. .. ,. .. Citation Requirements Comments ___
Location/Action M ARAR TBC
Potential Action-Specific ARARs and TBCs
Green
remediation
NYSDEC DER-31 Green Remediation
Program Policy, January 2011
State and federal technical guidance documents that provide guidelines
for the development of site remediation strategies in a manner that
minimizes environmental impacts and applies green remediation
concepts (e.g., reduction in greenhouse gas emissions, energy
consumption and resource use, promotion of recycling of materials and
conservations of water, land and habitat).
Potentially applicable TBC.
No
Yes
Superfund Green Remediation Strategy,
September 2010
General
excavation
6 NYCRR 200-203, 211-212 - Prevention
and Control of Air Contamination and Air
Pollution
Provides requirements for air emission sources.
Portions potentially applicable to volatile emissions during
excavation
Yes
No
6 NYCRR 257 - Air Quality Standards
Promulgated state regulation that provides specific limits on generation
of SO2, particulates, CO2, photochemical oxidants, hydrocarbons (non-
methane), NO2, fluorides, beryllium and H2S from point sources.
Not applicable or relevant and appropriate. Dust emissions would
not be generated from a point source. Potential TBC during dust
generating activities such as during earth moving, grading, and
excavation.
No
Yes
40 CFR Part 50.1 - 50.12 - National
Ambient Air Quality Standards
Promulgated federal regulation that provides air quality standards for
pollutants considered harmful to public health and the environment.
The six principal pollutants are carbon monoxide, lead, nitrogen dioxide,
particulates, ozone, and sulfur oxides.
Potentially applicable to alternatives during which dust generation
may result, such as during earth moving, grading, and excavation.
Yes
No
NYS TAGM 4031 - Dust Suppressing and
Particle Monitoring at Inactive Hazardous
Waste Disposal Sites
State guidance document that provides limitations on dust emissions.
To be considered material where more stringent than air-related
ARARs.
No
Yes
Transportation
6 NYCRR 364 - Waste Transporter Permits
Promulgated state regulation requiring that hazardous waste transport
must be conducted by a hauler permitted under 6 NYCRR 364.
Potentially applicable for off-site transport of hazardous waste.
Yes
No
49 CFR 107, 171-174 and 177-179 -
Department of Transportation Regulations
Promulgated federal regulation requiring that hazardous waste transport
to off-site disposal facilities must be conducted in accordance with
applicable Department of Transportation requirements.
Potentially applicable for off-site transport of hazardous waste to
off-site treatment/disposal facilities.
Yes
No
Notes:
ARARs - Applicable or Relevant and Appropriate Requirements
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
CFR - Code of Federal Regulations
DER - Division of Environmental Remediation
FEMA - Federal Emergency Management Agency
FS - Feasibility Study
NYCRR - New York Code of Rules and Regulations
NYS - New York State
NYSDEC - New York State Department of Environmental Conservation
NYSDOH - New York State Department of Health
OSWER - Office of Solid Waste and Emergency Response
RCRA- Resource Conservation and Recovery Act
SCOs - Soil Cleanup Objectives
TAGM - Technical and Administrative Guidance Memorandum (NYSDEC)
TBC - To be Considered
TOGS -Technical and Operational Guidance Series
(JSC - United States Code
USEPA or EPA - United States Environmental Protection Agency
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PAGE 7
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SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
Administrative Record Index
SYW-12 Site
(New York State Inactive Hazardous Waste Disposal Site #7-34-075A)
RI/FS Activities Documents
Pre-Remedial
Investigation
Information
Citizen Participation Plan for the Onondaga Lake National Priority
List Site (January 1996)
Summary of Onondaga Lake Wetland Subsurface Analytical Data
(August 2000)
Remedial
Investigation/Feasibility
Study Work Plans
Wastebed B/Harbor Brook RI/FS Work Plan (September 2002)
Wastebed B/Harbor Brook Site Supplemental RI Work Plan
(September 2006)
SYW-12 Sources of Contamination Investigation Work Plan (May
2012)
SYW-12 Groundwater Sampling Work Plan (November 2018)
Remedial Investigation
Reports
Wastebed B/Harbor Brook Human Health Risk Assessment
(October 2009)
Wastebed B/Harbor Brook Baseline Ecological Risk Assessment
(August 2011)
SYW-12 Sources of Investigation Report (March 2014)
Wastebed B/Harbor Brook Revised Remedial Investigation Report
(March 2015)
Revised SYW-12 2019 Groundwater Investigation Report
(December 2020)
Feasibility Study Report
SYW-12 Site Feasibility Study Report (September 2022)
Naphthalene in Groundwater Memo (December 2022)
-------
Proposed Plan Released
Start of Public
Comment Period
Proposed Plan and Listserv Notice (January 18, 2023)
Notice of Public Meeting and Opportunity to Comment (January 19,
2023)
Public Meetings Held
Documentation and Transcript of January 31, 2023 Public Meeting
(Attached to the Record of Decision as Appendix V-d)
Written Comments on Proposed Plan (Attached to the Record of
Decision as Appendix V-e)
Record of Decision
Issued
SYW-12 Site Record of Decision and Responses to Comments
(Responsiveness Summary) (March 2023)
Enforcement
Documents
Wastebed B/Harbor Brook Consent Order (April 2000)
Letter from Tracy Smith to John McAuliffe of Honeywell
(November 2005)
Letter from John McAuliffe of Honeywell to Tracy Smith
(February 2014)
Letter from Tracy Smith to John McAuliffe of Honeywell
(February 2014)
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SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX IV
NEW YORK STATE DEPARTMENT OF HEALTH LETTER OF CONCURRENCE
-------
york Department
vSTATE of Health
KATHY HOCHUL
Governor
JAMf )NALD, M.D., M.P.H.
Acting Commissioner
MEGAN E. BALDWIN
Acting Executive Deputy Commissioner
January 13, 2023
Andrew Guglielmi, Director
Division of Environmental Remediation
NYS Department of Environmental Conservation
625 Broadway
Albany, New York 12233
Dear Andrew Guglielmi,
We reviewed the New York State Department of Environmental Conservation and United
States Environmental Protection Agency's January 2023 Proposed Plan for the referenced site
to determine whether the proposed remedy is protective of public health. Based on that review,
I understand that on-site soil and groundwater are contaminated with volatile organic
compounds (groundwater, only), semivolatile organic compounds, metals, pesticides, and
polychlorinated biphenyls above applicable standards, criteria, and guidance. Human
exposures to contamination at this site will be addressed by the proposed remedy as outlined
below.
• SoN: Contaminated surface soil/fill material that exceed 6 NYCRR Part 375 Commercial
Soil Cleanup Objectives from approximately 8.2 acres of the site will be excavated,
removed, and/or managed followed by the installation of a two-foot-thick coversystem
for ecological purposes which will also allow for commercial (including passive
recreational) use in accordance with 6 NYCRR Part 375. A site management plan will
be put in place and future excavations at the site will conducted in accordance with an
approved excavation plan to properly manage human exposures to remaining
contaminated soil. A surface soil pre-design investigation and tree survey will be
performed on additional areas of the site, totaling 2.2 acres, to determine whether
additional soil excavation and backfilling is needed.
• Groundwater: Use of groundwater at the site, without appropriate water quality
treatment, will be restricted by an environmental easement placed on the site.
• Soil Vapor: A soil vapor intrusion evaluation will be completed, and appropriate actions
implemented, for any buildings developed on the site.
Re: Proposed Plan
SYW-12
Site #734075A
Syracuse, Onondaga County
Empire State Plaza, Corning Tower, Albany, NY 12237 | hearth.ny.gov
-------
Periodic reviews will be completed to certify that these elements of the remedy are being
implemented and remain effective. Based on this information, I believe this remedy is protective
of public health and concur with the Proposed Plan. If you have any questions, please contact
Scarlett Messier-McLaughlin at (518) 402-7874.
Sincerely,
* I'1 fl .. v
C )i>uS ¦ * *u < *¦ X-
Christine N. Vooris, P.E., Director
Bureau of Environmental Exposure Investigation
ec: E. Lewis-Michl/K. Malone/S. McLaughlin/M. Sergott/e-File
J. Strepelis- NYSDOH CRO
L. Letteney- OCHD
D. Harrington / J. Pelton/T. Smith - NYSDEC Central Office
G. Priscott- NYSDEC Region 7
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SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
FOR THE
RECORD OF DECISION
SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
CITY OF SYRACUSE, ONONDAGA COUNTY, NEW YORK
INTRODUCTION
This Responsiveness Summary provides a summary of the public's comments and
concerns received during the public comment period related to the Proposed Plan for the
SYW-12 Site (Site), an Operable Unit of the Wastebed B/Harbor Brook Subsite of the
Onondaga Lake Superfund site, and provides the New York State Department of
Environmental Conservation (NYSDEC) and U.S. Environmental Protection Agency's
(EPA's) responses to those comments and concerns. All comments summarized in this
document have been considered in NYSDEC and EPA's final decision in the selection of
a remedy to address the contamination at the Site.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
Honeywell International, Inc., (Honeywell), under NYSDEC's oversight, conducted field
investigations at the Site from 2006 through 2020, which culminated in the completion of
a remedial investigation (Rl)1 report in March 2015 and a feasibility study (FS)2 report in
September 2022. NYSDEC and EPA's preferred remedy for the Site and the basis for that
preference were identified in a Proposed Plan.3 The Proposed Plan was released to the
public for comment on January 19, 2023. These documents were made available to the
public on NYSDEC's website at
https://www.dec.iiv.gOv/data/DecDocs/734075A/http://www.dec.ny.gov/cheniical/37558.htnil
and at information repositories maintained at the Atlantic States Legal Foundation, 658
West Onondaga Street, Syracuse, New York; NYSDEC, Division of Environmental
Remediation, 625 Broadway, Albany, New York; and NYSDEC Region 7, 615 Erie
Boulevard West, Syracuse, New York. A NYSDEC listserv bulletin notifying the public of
the availability of the above-referenced documents, the comment period commencement
and completion dates, and the date and location of the planned public meeting was issued
on January 18, 2023. A notice providing the same information was published in The
Syracuse Post-Standard on January 19, 2023. The public comment period ended on
February 18, 2023.
1 The Rl determines the nature and extent of the contamination at a site and evaluates the
associated human health and ecological risks.
2 An FS identifies and evaluates remedial alternatives to address the contamination.
3 A Proposed Plan describes the remedial alternatives considered for a site and identifies the
preferred remedy with the rationale for this preference.
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On January 31, 2023, NYSDEC conducted a public meeting at the Salina Town Hall to
inform local officials and interested citizens about the Superfund process, present the
Proposed Plan for the Site, including the preferred remedy, and respond to questions and
comments from the public. Approximately twelve people, including residents and local
government employees, attended the public meeting.
SUMMARY OF COMMENTS AND RESPONSES
Comments were received at the public meeting and in writing. Written comments were
received from:
• Diana Green at the public meeting
• Donna Muhs-McCarten, via a February 3, 2023 email
• Jessica Gorman, via a February 9, 2023 email
• Erica Roach, via a February 9, 2023 email
• Sue Eiholzer, via a February 9, 2023 email
• Tiffany Fotopoulos, via a February 9, 2023 email
• Paul Tobin, via a February 10, 2023 email
• Julie Gozan, via a February 10, 2023 email
• Jacob Eichten, via a February 10, 2023 email
• Arleen Lane, via a February 10, 2023 email
• Anthony Kratz, via a February 10, 2023 email
• Sarah Nahar, via a February 12, 2023 email
• Mary Anderson, via a February 14, 2023 email
• Julie Finch, via a February 15, 2023 email
• Onondaga County, via a February 15, 2023 letter from Jesse McMahon
• Bernadette Andaloro, via a February 16, 2023 email
• Maria Boemi, via a February 16, 2023 email
• City of Syracuse, Department of Engineering, via a February 17, 2023 letter from
Mary Robinson
• Sharon Osika-Michales, via a February 17, 2023 email
• Andrew Bowes, via a February 17, 2023 email
• Sara Bollinger, via a February 17, 2023 email
• Maryanne Adams, via a February 18, 2023 email
• Hancock Estabrook, LLP, representing Buckeye Partners, L.P., via a February
17, 2023 letter from Wendy Marsh
• Alma Lowry, Of Counsel, Law Office of Joseph J. Heath (submitted on behalf of
the Onondaga Nation), via a February 18, 2023 letter
The transcript from the public meeting can be found in Appendix V-d.
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The written comments submitted during the public comment period can be found in
Appendix V-e.
A summary of the comments provided at the public meeting and comments that were
received from the public and the Onondaga Nation during the public comment period, as
well as NYSDEC and EPA's responses to them, are provided below.
As detailed below, the comments that were received have been organized by category.
Care of Onondaga Nation Lands, Waters, and People
Comment #1: Several commenters opined that the preferred remedy affects the
Onondaga Nation's ability to care for its lands, waters, and people.
Response #1: NYSDEC and EPA recognize and respect the Onondaga Nation's cultural
and historic ties to Onondaga Lake and the sacred nature of the Lake to the Nation's
people and its traditions. While the Onondaga Nation expressed some concerns about
the selected remedy, the remedy, which is protective of human health and the
environment, preserves the mature forested area utilized as a winter foraging and
roosting area for bald eagles. The protectiveness of the implemented remedy will be
periodically evaluated.
Additional Consultation with the Onondaga Nation
Comment #2: A commenter opined that additional consultation with the Onondaga Nation
should be performed.
Response #2: NYSDEC and EPA consults with the Onondaga Nation on a regular basis
and provide documents to the Nation for its review as part of an agreement for the
Onondaga Lake National Priority List (NPL) Site and its subsites,4 and under the EPA
and NYSDEC Tribal Consultation Policies. Through consultation with NYSDEC and EPA,
the Onondaga Nation had the opportunity to review and provide input on the documents
related to the SYW-12 Site, including the RI/FS and a draft Proposed Plan. The
Onondaga Nation's comments on the draft Proposed Plan and responses to those
comments are included as an attachment to this Responsiveness Summary (see
Appendix V-f). Additional comments that were received from the Onondaga Nation during
the public comment period were considered and are addressed in this Responsiveness
Summary.
4 NYSDEC and EPA have organized the work for the Onondaga Lake NPL site into discrete units
referred to as "subsites." A subsite is a previous or current source of contamination to Onondaga
Lake.
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Potential Health Risks
Comment #3: Several commenters stated that the preferred remedy is a partial remedy,
is not fully protective of public or environmental health, the data indicates that
concentrations of polycyclic aromatic hydrocarbons (PAHs), pesticides, polychlorinated
biphenyls (PCBs), and metals (including mercury) are random, and there are
exceedances of soil standards for "passive use" {i.e., trail use) and ecological receptors
{e.g., birds, insects, and other animals) with risks to insectivorous birds and small
mammals at unacceptable levels.
Response #3: Because of the special considerations being given to the mature forested
area that provides bald eagle habitat, surface soil in areas where cover material will not
be placed may exceed Commercial Use and the Protection of Ecological Resources Soil
Cleanup Objectives (SCOs). Also, while the concentrations of contaminants vary, the
available data indicates that many of the higher contaminant concentrations are present
in the non-forested areas where cover will be placed under the selected remedy (see
ROD Appendix I, Figures 5 through 10).
The selected remedy will avoid significant habitat alteration and bald eagle disturbances.
While areas exhibiting soil concentrations greater than the Protection of Ecological Use
SCOs may remain under the selected remedy, they are expected to be protective of
community impacts to ecological receptors throughout the Site based on surface soil
Area-Weighted Average Concentration (AWAC) calculations. AWACs are considered
appropriate at evaluating potential contact with contamination throughout the site since
the small mammals and insectivorous birds present are transient within their home range
{e.g., they do not spend all of their time foraging in one single location throughout their
lifespan). Nevertheless, additional soil sampling and biota monitoring {e.g., small
mammals, earthworms) will be performed to evaluate remediation of additional areas
(See Response to Comment #12), remedy effectiveness and assess protectiveness of
ecological receptors.
The Human Health Risk Assessment (HHRA) concluded that lifetime excess cancer risk
and noncancer hazards for current and/or future utility workers, passive recreational
users, railroad workers, commercial/industrial workers and adult residents were below the
regulatory risk thresholds. Elevated hazard associated with contaminants in soil was
identified for future child residents exposed to PCBs in surface soil. However, the
anticipated future land use of the Site does not include residential use (e.g., people living
on the Site). Nevertheless, potential exposure to residual contamination will be addressed
through soil cover and engineering controls {e.g., fencing/railing) and institutional controls
(ICs) {e.g., signage, environmental easements). The potential need for additional
measures will be reviewed following sampling during the design phase and based on
management {e.g., inspections) of the trail.
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Comment #4: A commenter expressed concerns about the general methodology for
calculating AWACs because it generally assumes that contaminant levels in unsampled
locations are likely to be similar to nearby samples than more distant samples. Given the
random distribution of site contaminants, this assumption does not seem reasonable.
Response #4: While Site contaminants are randomly distributed across the SYW-12 site,
there is a pattern where higher concentrations are present (see Figures 1-6 in Appendix
3 and Figures 1-6 in Appendix 8 of the FS report). This data was used to evaluate
remedial alternatives and select a remedy. The AWACs are used as a general basis of
comparison to demonstrate, as would be expected, that remediation efforts will lower the
average concentrations across the entire site. The AWACs are not meant to finely
understand the distribution and concentrations of site contaminants, but to generally show
that the remedy will improve the conditions across the entirety of the Site.
The HHRA determined that there are no unacceptable risks to trail users prior to
remediation being performed. Although there may be SCO exceedances at specific
sample locations, risks to trail users who will be exposed to various levels of
contamination across a wider area that is represented by the AWACs are minimized by
the trail cover (a minimum thickness of one foot of crushed stone or a wooden boardwalk),
signage and dense vegetation present along the trail that is expected to deter the public
from leaving the trail. In addition, the soil at the Site is directly overlain by a detritus layer
consisting of leaf, wood, and other vegetative/organic matter. Furthermore, pre-design
sampling that will be performed will help determine if additional controls (e.g., fencing)
may be needed. Pre-design soil sampling, which may result in additional remediation,
will also be performed to update and refine the AWAC analysis and reduce uncertainties
inherent in the spatial analysis techniques used in the FS by evaluating a higher density
of sampling locations. The remedy also includes biota sampling to better evaluate impacts
that may be present across the entire site and between the remediated and un-
remediated areas.
Comment #5: Several commenters opined that NYSDEC should recalculate and publicize
the risks to the public remaining in the un-remediated areas because much of the area
that will not be covered is adjacent to the trail or between the trail and Onondaga Lake,
where site visitors may be most likely to stray from the trail. In addition, the commenters
opined that although the calculated risks for child recreators are below EPA's "acceptable
risk" level of one additional cancer per 10,000 people, site users might not want to expose
children to this risk. In addition, the commenters opined that potential visitors to the trail
need to know the actual risks created by the Site, not simply whether NYSDEC and EPA
considers those risks acceptable, so that they can make an informed decision about
potential exposures of themselves and their children. Another commenter opined that the
number of locations within the un-remediated areas where contaminant levels exceed
established standards should be acknowledged.
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Response #5: Although the risk calculated in the HHRA is closer to the upper end than
the lower end of the acceptable risk range, they are based on reasonable maximum
exposure scenarios and represent the highest level of exposure that could reasonably be
expected to occur. To support this estimate of the reasonable maximum exposure, the
exposure assumptions that are used to estimate the cancer risk typically represent the
95th percentile of the population. For example, EPA evaluates contact to residential
children assuming the ingestion of 200 milligrams of soil 350 days per year for 6 years
(ages 0-6). The calculated risks are, therefore, conservative (i.e., health-protective)
representations of potential human health risks. Children visiting and using the trail
recreationally are highly unlikely to contact site-related chemicals at this elevated
frequency since the Site will not be used for residential purposes. Passive recreational
exposures for the Site in an un-remediated state were also evaluated, which did not
indicate health concerns. With the construction of a trail that consists of one foot of
crushed stone or a wooden boardwalk, potential risks have been further reduced.
Given that risks below thresholds were indicated in the HHRA and that the remedial
measures, including the ICs, are likely to further reduce contact to contaminated soils
located near the trails, occasional recreational exposure to soils off the trail is not likely to
result in an elevated risk or hazard. Additionally, please refer to Response to Comment
#7 below regarding trail users potentially straying from the trail.
Comment #6: A commenter opined that the NYSDEC failed to acknowledge that utility
and construction workers or potential future child residents will be subject to unacceptable
noncancer risks pre-remediation. In addition, the commenter opined that the noncancer
risk to utility and construction workers is twice the acceptable level and the risk to child
residents is eight times the acceptable level. Given that more than half of the
contaminated soils will not be covered, it may continue to pose unacceptable human
health risks after the remediation has been completed.
Response #6: Exceeding the noncancer hazard index (HI) threshold of 1 does indicate
that an adverse health effect could be observed for the exposure scenario evaluated;
however, the value associated with the HI does not necessarily equate to the severity of
health effects. Rather, increases in the HI may be interpreted as having a greater potential
to cause the adverse effect associated with the chemical being characterized. For
example, an HI of 10 indicates there is a greater potential for adverse effects than an HI
of 2, but it does not necessarily mean that the severity of those effects is five times higher.
Therefore, it is important to note that an HI of 2 is not significantly greater than the
acceptable level.
The HHRA concluded that noncancer hazards associated with soil for current and/or
future utility workers, construction workers, railroad workers, and commercial/industrial
workers were below the regulatory risk thresholds. Elevated hazard was identified for
construction workers through exposure to chromium and benzo(a)pyrene in groundwater
while performing subsurface work. However, the unacceptable hazard posed by each of
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these chemicals to construction workers was based on the results obtained during the Rl;
sampling subsequent to the Rl indicates the absence of chromium and benzo(a)pyrene
in groundwater underlying the site. Thus, this exposure pathway no longer presents a
health concern. Nonetheless, the selected remedy will be protective of future utility and
construction workers. The selected remedy requires the development of a Site
Management Plan (SMP) to limit exposure to remaining contaminants, even though they
were not associated with risk or hazard in the HHRA, during future construction work at
the Site.
The HHRA determined that there are no unacceptable risks to trail users prior to
remediation being performed. While unacceptable risks were also identified for the future
child resident, future residential use of the Site is not planned and will not be permitted
as part of the selected remedy by the ICs that will be employed. ICs are commonly
employed at Superfund sites to limit the use of sites. At the Site, ICs will be used to limit
use of the Site to non-residential activities. Additionally, should a landowner of this
property seek to change the use of the site in the future to residential use, additional
remediation would be required.
Comment #7: Several commenters stated that the preferred remedy allows for public
misperception of the level of cleanup that has occurred and the associated risks.
Response #7: As stated in Response #3, because of the special considerations being
given to the mature forested area that provides bald eagle habitat, surface soil in non-
remediated areas may exceed Commercial Use and the Protection of Ecological
Resources SCOs where cover material will not be placed. Based on the current
conditions, with no remediation performed, human health risks for anticipated future uses
are acceptable, according to the HHRA. However, the potential need for additional
measures (e.g., fencing/railing, maintaining dense vegetation along the trail, improved
signage, and/or sampling) will be reviewed and implemented, if appropriate, following
sampling during the design phase and based on the management {e.g., inspections) of
the trail.
Safety of Remediation Workers
Comment #8: A commenter inquired about remediation worker safety and whether the
remediation contractor's work plans could be accessed. The commenter also inquired as
to who should be notified if remediation workers do not follow safety guidelines.
Response #8: Health and safety plans will be prepared for construction that is performed
on the Site and during future construction activities. It will be the contractor's responsibility
to develop and follow these plans. Site-related documents will be available online through
the DECinfo Locator at https://www.dec.nv.qov/data/DecDocs/734075A/ and at the
document repositories identified on page V-1 of the Responsiveness Summary. If there
are concerns about worker safety, please contact the NYSDEC project manager or the
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New York State Department of Health (NYSDOH) contact (see
https://www.dec.nv.gov/data/der/factsheet/734075acuprop.pdf for contact information).
Additional questions or concerns regarding the remedial activities at the Site or the
Onondaga Lake NPL Site should be directed to the NYSDEC Region 7 (Syracuse)
Citizen's Participation Specialist at (315) 246-7403 or the NYSDEC project manager.
Remedy Implementation and Post-Remediation Site Management
Comment #9: A commenter asked who will be responsible for implementing the remedy
selected in the ROD. Another commenter opined that it is inappropriate to transfer the
management of this heavily contaminated land to Onondaga County.
Response #9: Following the ROD, NYSDEC will negotiate with the potentially responsible
parties (PRPs) to perform the design and construction of the remedy, as well as the long-
term management of the implemented remedy. As the current property owner, the
County will be responsible for following the requirements in the SMP.
Five-Year Reviews
Comment #10: A commenter opined that the preferred remedy should include frequent
monitoring, but it is stated that monitoring will be performed only once every five years.
Response #10: The details of the monitoring at the Site will be provided in the SMP that
will be approved by NYSDEC and will include more frequent monitoring, inspections, and
maintenance of the cover {e.g., topsoil repair and reseeding). The commenter may be
confusing monitoring with five-year reviews. Because, under the selected remedy,
contaminated soils will remain on-Site above levels that will allow for unrestricted use and
unlimited exposure, CERCLA requires that the remedy be reviewed at least once every
five years {i.e., five-year reviews). The purpose of five-year reviews is to evaluate the
implementation and performance of a remedy to determine if the remedy continues to
perform as intended and is and will continue to be protective of human health and the
environment. The five-year reviews will utilize the results of the monitoring that is
performed during the preceding five years.
Consideration of Additional Alternatives
Comment #11: Several commenters opined that NYSDEC should consider additional
remedial alternatives, such as staged remediation and replanting of the forested areas,
to avoid disrupting the roosting eagles or remediation, which relies on scattered or less
intrusive methods.
Response #11: Other remedial alternatives were considered in the FS. The selected
remedy was chosen because of the special considerations being given to the mature
forested area that provides bald eagle habitat. Staged remediation with replanting of
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forested areas would take a significant timeframe to allow for mature trees to grow and
would delay restoration and availability of bald eagle roosting habitat for several decades.
As part of long-term site management, if there is an opportunity for cover placement in
the currently forested areas, its addition will be evaluated in the future (e.g., should a
storm result in the loss of a large area of mature trees).
Targeted Soil Removal
Comment #12: A commenter opined that there was no consideration of targeted soil
removal in areas with particularly high contamination levels within the forested areas and
remediation was limited to areas beyond the drip line or root line of mature trees.
Response #12: The drip zone of the large trees covers the forested area, which limits
where remediation can be performed without potentially damaging trees. Soil removal or
cover placement within the forested areas could result in damage to trees by damaging
or covering the roots, respectively. It could also result in the disturbance and/or loss of
wetland area because many of the forest areas are delineated as wetland. Should pre-
design surface soil sampling indicate that elevated contaminant concentrations are
present in surface soil/fill material and large trees will not be disturbed (e.g., within the
drip-zone of the large trees), remediation of these areas will be considered during the
design.
Assessment of the Needs of the Roosting Eagles
Comment #13: A commenter opined that NYSDEC has not required Honeywell to
analyze or justify the specific forest sections or trees that are necessary to the eagles,
simply assuming that the entire forested area must be maintained in its current state. The
commenter further opined that NYSDEC should mandate that Honeywell conduct a more
complete assessment of the needs of the roosting eagles and options for remediation
measures that will meet those needs and not result in significant tree loss. Without this
information, the commenter suggests that NYSDEC should not move forward with the
selected remedy.
Response #13: The United States Fish and Wildlife Service, which was consulted during
the remedial program for the Site, indicated that because of the importance of the trees
at the Site as roosts for wintering bald eagles, tree clearing associated with remediation
should be minimized to the extent possible. The Service also recommended that
remediation should only be considered if tree removal can be avoided or restricted to
smaller trees that are unlikely to be used by the eagles. These recommendations were
considered during the evaluation of the alternatives.
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Contaminated Soil Excavation
Comment #14: A commenter opined that the preferred remedy would relegate the Site
and its natural resources to a permanent contaminated state and that natural resources
on and around the Site will be prevented from returning to a functioning, healthy,
sustainable ecosystem. For these reasons, opined the commenter, to ensure long-term
environmental and public health protection, all or most of the contaminated soils should
be removed.
Response #14: In addition to the potential to significantly impact the bald eagle habitat at
the Site, the removal of approximately 400,000 cubic yards of contaminated material
would have significant feasibility limitations associated with excavation (e.g., stability,
water management), transportation (e.g., air quality, traffic), and disposal (e.g., landfill
capacity). NYSDEC and EPA believe that the selected remedy provides the best balance
of tradeoffs among the remedial alternatives with respect to the evaluation criteria. The
NYSDEC Division of Fish and Wildlife has been involved with the entire remedial program
and will be involved with the remedial design to ensure that, as part of site restoration,
this site continues to perform as a functioning wetland.
Invasive Species Eradication
Comment #15: A commenter encouraged the State to make more funding available for
invasive species eradication, specifically, common reed {Phragmites australis), which are
present at the Site, and for Japanese knotweed (Fallopia japonica), which are present in
Onondaga Creek.
Response #15: In areas on the Site where cover is placed and restoration is performed,
native plant species will be planted/seeded and invasive species will be managed. For
additional information regarding invasive species visit
https://www.dec.nv.gOv/animals/265.html#Terrestrial.
Signage
Comment #16: Several commenters stated that the current Onondaga County signs
stating "Stay on the Trail: Environmentally Sensitive Area" are not effective and that clear
and complete information about the health risks posed by this site to potential users must
be available.
Response #16: The potential need for additional measures (e.g., fencing/railing,
maintaining dense vegetation along the trail, improved signage, and/or sampling) will be
reviewed during the design phase and based on management {e.g., inspections) of the
trail. The NYSDEC would support revised and/or additional information being included
on signs and/or in an informational kiosk. Additional signage will need to be coordinated
with the property owner {i.e., Onondaga County) and the NYSDEC will initiate these
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discussions during the design based on concerns raised during the SYW-12 public
comment period.
Comment #17: A commenter requested that at a minimum, informative signs that provide
accurate information on the reasons that visitors should remain on the trail {e.g., "Stay on
the Trail/Contaminated Soils Present") or the NYSDEC could require the County to create
an information kiosk at the trailhead with more detail about the contaminants on-site and
the geographic scope of the remediation. With this more detailed information, the public
can make an informed choice about the exposure risks and better protect themselves and
their families.
Response #17: See Response to Comment #16. Also, please recognize that there are
no exposure concerns for recreators that stay on the trail; additionally, as noted in
Response to Comment #5, occasional recreational exposure to soils off the trail is not
likely to result in an elevated risk or hazard.
Comment #18: Several commenters stated that people have been walking off the trail
since it was constructed last year.
Response #18: As the trail was only opened for a limited time before it was closed for
the winter due to the bald eagle roosting requirements and it is currently closed for the
winter eagle roosting season, the off-trail usage is not known. Site management for the
trail will be performed by Onondaga County and will include inspections for evidence of
off-trail use. If evidence of off-trail use is observed, then additional signage and/or
restrictions may be necessary. As detailed in Response to Comment #16, additional
signage will need to be coordinated with the property owner {i.e., Onondaga County).
Comment #19: A commenter recommended placing signs stating that the land belongs
to the Onondaga Nation or acknowledging their contribution to the area.
Response #19: There is currently a sign that acknowledges the Haudenosaunee
contributions and the relationship and cultural significance of Onondaga Lake to the
Onondaga Nation, located on the Onondaga Creekwalk near the mouth of Onondaga
Lake and the entrance to the trail on the Site.
Emerging Contaminants
Comment #20: Several commenters noted that the Site includes emerging contaminants,
such as phenyl xylyl ethane (PXE) and phenyl toluyl ethane (PTE), and that because
there are no NYSDEC or EPA standards for these emerging chemicals, they will not be
monitored. Another commenter recommended consulting research published on PXE and
PTE.
Response #20: While PXE/PTE were detected, there is very little scientific literature that
has been published regarding their toxicity. EPA's Integrated Risk Information System
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(IRIS) is the first tier of EPA's recommended hierarchy of sources of human health toxicity
values used in HHRAs under the EPA Superfund program. Provisional Peer Reviewed
Toxicity Values (PPRTVs) are the second tier of human health toxicity values. There is
currently no information on PXE or PTE in IRIS, nor are there any PPRTVs for these
chemicals. In January 2018, EPA Region 2 submitted a request to EPA's Office of
Research and Development (ORD) to nominate PXE and PTE for development of
PPRTVs by ORD's National Center for Environmental Assessment (NCEA) (now referred
to as Center for Public Health and Environmental Assessment [CPHEA]). To date,
PPRTVs for the compounds have not been developed. CPHEA is evaluating whether
these chemicals are similar to other chemicals, and if so, if any comparisons can be made
about the potential toxicity of either PXE or PTE. Due to a combination of contractual
issues and the limited information on the target chemicals, it is not known at this time
when or if the screening values for PXE and PTE will be developed. ORD continues to
work on this issue.
Also, NYSDOH recently reviewed available toxicity information, performed a thorough
search of the peer reviewed toxicological literature, and looked for any recent research
from other sources for PXE and PTE. Based on its review, NYSDOH concluded that
there are limited toxicity data for PXE and none for PTE. Consequently, there are no
established toxicity values. As such, NYSDOH was not able to recommend a health-
based soil guideline for either of these chemicals.
As with any emerging contaminants, if screening values are developed and additional
investigation/action are warranted, this will be considered in the future and evaluated in
the regular five-year reviews planned for this Site.
Construction Access and Coordination
Comment #21: A representative of Onondaga County inquired about construction access
to the Site during remediation. Specifically, while Honeywell has crossed the CSX
railroad tracks for investigations in the past, Honeywell has not signed an order to perform
the remediation at this time and is not believed to have previously moved large/heavy
equipment, vehicles, workers, etc. repeatedly across the railroad tracks. The County
indicated that it believes that it is CSX's standard policy not to permit track crossings
involving heavy equipment, especially with respect to reoccurring crossings. Given
potential access issues and the landlocked nature of the Site, the County inquired as to
how access to the Site will be obtained if CSX does not allow construction access across
the railroad tracks for remediation. Also, the County inquired as to whether an increased
cost contingency has been considered for the preferred remedy in the event that access
across the CSX tracks is not granted.
Response #21: The NYSDEC will be working with PRPs to negotiate an order for
performance of the remediation following the issuance of the ROD. NYSDEC anticipates
that the performing PRPs will coordinate access to the Site with CSX and/or the County,
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with NYSDEC and EPA providing assistance, if necessary. If access is ultimately not
granted, alternative options to access the Site, including possible access orders and the
cost impacts, will be evaluated.
Minimizing Trail Closures
Comment #22: The County inquired as to how trail closures will be prevented or
minimized and how remediation in areas located under and adjacent to the existing trail
(e.g., in the wetland boardwalk area) will be performed.
Response #22: The County was notified in a March 20, 2018 letter from NYSDEC in
response to the County's Change of Use for the trail that if the trail is constructed on the
Site prior to selection of a remedy, then impacts to the trail (e.g., trail relocation/removal,
shutdowns of the trail) may be necessary to accommodate the implementation of the
remedy. During the design, accessibility and sampling data will also determine if
additional restrictions (e.g., fencing) and/or cover placement are necessary in areas under
and/or adjacent to the trail. In addition, similar to construction on other Onondaga Lake
subsites (e.g., Wastebeds 1-8, Wastebed B/Harbor Brook), coordination with the County
for trail closures will occur, as necessary.
Comment #23: The County expressed an interest in the proposed timing of the
remediation and suggested that there would be benefits from coordinating the
remediation and access, trail closures, wetland mitigation, reuse of materials, etc. The
County also mentioned potential issues regarding limitations (e.g., space for equipment,
staging of materials) if remediation and trail extension work overlapped.
Response #23: Coordination that may benefit both the remedy construction and County
plans in accordance with the schedule will be evaluated during the design. This will
include coordination regarding space for staging materials and equipment, as needed.
Further evaluation and/or coordination with the railroad companies would be needed
during design. It should be noted that throughout the entire process of investigating and
cleanup of the Onondaga Lake subsites, NYSDEC and Onondaga County have
maintained routine communications.
Reuse of Excavated Material
Comment #24: The County asked under what conditions will reuse of excavated material
not be permitted.
Response #24: The ROD clarifies that reuse of material would need to be in accordance
with NYSDEC DER-10 (Table 5.4(e)4). In addition, reuse of contaminated material will
not be permitted in the delineated wetlands and the 100-foot wetland buffer areas and
there may be limitations in stockpiling materials within floodplains and near the railroad
tracks (e.g., due to stability).
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Floodplain Concerns
Comment #25: The City of Syracuse expressed concern that the preferred remedy will
place fill within Federal Emergency Management Administration-delineated Special Flood
Hazard Area (SFHA) flood zones and that to maintain flood storage, filling of materials
must be offset by the same volume of excavation. The City asked that the amount of fill
be calculated and the preferred remedy be either modified to remove an equal amount of
soil, Alternative 3 be selected, or balance the site fill with an equal excavation outside the
SYW-12 Site, but within the Onondaga Lake SFHA.
Response #25: Floodplain impacts will be considered during the design of the remedy.
Coordination with the City and County will be performed, as appropriate.
Unaccounted for Contamination Sources
Comment #26: A commenter provided several aerial photographs that allegedly show
Solvay waste on and in the vicinity of the Site and opined that Solvay waste, as well as
spoils from in-lake dredging, may have been placed on SYW-12, and it is not clear
whether these materials were considered as contaminant sources in developing the
selected remedy. Noting discrepancies between possible Solvay waste contamination
sources listed in the Rl and FS reports and the Proposed Plan and excerpts, figures, and
aerial photos from the draft SYW-12 Source Attribution Report, dated July 2016
("Attribution Report"), prepared on behalf of Honeywell, a commenter expressed concern
that all sources of waste and contamination pathways have not been accounted for,
thereby undermining the selected remedy. The commenter stated that the Proposed
Plan, FS report, and the Attribution Report improperly focus on PAH contamination and
their potential sources and pathways to SYW-12, which is contrary to the ecological risk
assessment and the determination that PCBs are an unacceptable future human health
risk at the Site.
Response #26: The Attribution Report was not approved by NYSDEC and is not part of
the administrative record (see Appendix III), on which the ROD is based. Because of the
quality of the aerial photographs that were provided, it cannot be confirmed that Solvay
waste is present on and in the vicinity of the Site. In addition, out of approximately 60 test
pits and borings, only a thin layer of Solvay waste was observed in only one boring at the
Site.
The ROD acknowledges that potential sources of contamination at the Site include
dredge spoils from Onondaga Creek, historic dredge material from the southern portion
of Onondaga Lake, and possibly the former Marley property, Oil City properties, former
Hiawatha Boulevard Manufactured Gas Plant (MGP) subsite, former Erie Boulevard MGP
site, and Ley Creek. The historic dredge material from the southern portion of Onondaga
Lake likely contained material that was contaminated as a result of Honeywell discharges
and/or sources. The ROD states that the primary contaminants at the Site include
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benzo(a)pyrene and other assorted PAHs, PCBs, and metals. SCOs are exceeded for
several PAHs, such as benzo(a)pyrene.
Loop-the-Lake Trail Construction
Comment #27: A commenter opined that the trail is not necessary around the whole of
Onondaga Lake.
Response #27: Onondaga County is constructing the Loop-the-Lake trail and should be
contacted (https://onondaqacountyparks.com/contact/) with any questions or concerns.
Trail construction is not related to the remediation of the SYW-12 Site.
Climate Change
Comment #28: A commenter inquired whether the level of Onondaga Lake is increasing
due to climate change.
Response #28: While water levels in Onondaga Lake fluctuate as a result of weather
conditions, the level is controlled by the New York State Canal Corporation. Therefore,
increasing water levels are not anticipated to be a concern. Nevertheless, resiliency to
climate change will be considered in the design of the selected remedy.
Debris Concern
Comment #29: A commenter expressed concern about the debris {e.g., trash) that has
accumulated along the shoreline.
Response #29: While the presence of the debris is of concern, the selected remedy
addresses the contaminated materials related to the historic use of the Site. Onondaga
County is aware of the accumulated trash in the shoreline areas and performs periodic
cleanups.
V-15
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SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-a
JANUARY 2023 PROPOSED PLAN
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Proposed Plan
SYW-12 Site
Operable Unit of the Wastebed B/Harbor Brook Subsite of the Onondaga Lake
Superfund Site
Syracuse, Onondaga County, New York
NEW
YORK
STATE
Department of
Environmental
Conservation
January 2023
&EPA
Region 2
PURPOSE OF THIS DOCUMENT
This Proposed Plan describes the remedial alternatives considered for contaminated soil/fill
material and groundwater at a portion of Wetland SYW-12, referred to herein as the SYW-12
Site or the Site, which is an Operable Unit (OU) of the Wastebed B/Harbor Brook (WBB/HB)
subsite of the larger Onondaga Lake Superfund site, and identifies the preferred remedial
alternative with the rationale for this preference. For a map of the Site and a map of WBB/HB
and the surrounding area, please see the attached figures.
This Proposed Plan was developed by the New York State Department of Environmental
Conservation (NYSDEC) and the U.S. Environmental Protection Agency (EPA) in consultation
with the New York State Department of Health (NYSDOH). NYSDEC and EPA are issuing this
Proposed Plan as part of their public participation responsibilities under Section 117(a) of the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980, as amended, and Sections 300.430(f)(2) of the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP), as well as the New York State Environmental Conservation
Law (ECL) and Title 6 of the New York Code of Rules and Regulations (NYCRR) Part 375.
The nature and extent of the contamination at the Site is described in the Wastebed B/Harbor
Brook (WBB/HB) Revised Remedial Investigation Report (Rl), the SYW-12 Sources of
Contamination Investigation Report, and Revised SYW-12 Groundwater Investigation Report.
The remedial alternatives summarized in this Proposed Plan are described in the SYW-12
Site Feasibility Study Report (FS Report). These documents are contained in the
Administrative Record file for this Site. NYSDEC and EPA encourage the public to review
these documents to gain a more comprehensive understanding of the Site and the
investigation activities that have been conducted at the Site.
This Proposed Plan is being provided as a supplement to the reports listed above to inform
the public of NYSDEC's and EPA's preferred remedy and to solicit public comments related
to the remedial alternatives evaluated, including the preferred alternative.
NYSDEC and EPA's preferred alternative includes the installation of a two-foot-thick soil cover
in select areas of the Site, as well as biota monitoring to evaluate the protectiveness of
ecological resources and remedy effectiveness. Monitored natural attenuation (MNA)1 for Site
contaminants in groundwater, development of a Site Management Plan (SMP),
implementation of institutional controls (ICs), and long-term maintenance and monitoring are
also components of the proposed remedy.
The remedy described in this Proposed Plan is the preferred remedy for the Site as proposed
by NYSDEC and EPA. Changes to the preferred remedy, or a change from the preferred
remedy to another remedy, may be made if public comments or additional data indicate that
such a change will result in a more appropriate remedial action. The final decision regarding
the remedy will be made after NYSDEC and EPA have taken into consideration all public
comments on the Proposed Plan.
MARK YOUR CALENDAR
January 19, 2023 - February
18, 2023: Public comment
period on the Proposed Plan.
Public Meeting
Tuesday January 31, 2023 at
6:00 PM (snow date of
Wednesday February 1, 2023)
Open House from 5:00 - 6:00
PM
Salina Town Hall - 201 School
Road, Liverpool, NY 13088
Community Role in the
Selection Process
NYSDEC and EPA rely on public
input to ensure that the concerns
of the community are
considered in selecting an
effective remedy for each
Superfund site. To this end, this
Proposed Plan has been made
available to the public for a
public comment period which
begins on January 19, 2023 and
concludes on February 18,
2023.
As noted above, a public
meeting and an open house will
be held during the comment
period to elaborate on the
reasons for recommending the
preferred remedy and to receive
public comments. The public
meeting will include a formal
presentation by NYSDEC of the
preferred remedy and other
cleanup options for the Site.
1 MNA is the process by which a natural system's ability to attenuate contaminant(s) at a
specific site is confirmed, monitored, and quantified.
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The open house will be less formal and will provide the public an
opportunity to discuss the cleanup options with NYSDEC and
EPA representatives on a one-on-one basis.
Comments received at the public meeting, and in writing during
the comment period, will be documented and addressed in the
Responsiveness Summary Section of the Record of Decision
(ROD), the document that will formalize the selection of the
remedy.
Written comments on this Proposed Plan should be addressed
to:
Tracy A. Smith
NYS Department of Environmental Conservation
625 Broadway
Albany, NY 12233-7013
E-mail: tracv.smith@dec.nv.gov
SITE BACKGROUND
On June 23,1989, the Onondaga Lake site was added to the New York State Registry of Inactive Hazardous Waste Disposal
Sites. On December 16, 1994, Onondaga Lake, its tributaries, and the upland hazardous waste sites that have contributed
or are contributing contamination to the lake (subsites) were added to EPA's National Priorities List (NPL). This NPL listing
means that the lake system is among the nation's highest priorities for remedial evaluation and response under CERCLA as
amended, for sites where there has been a release of hazardous substances, pollutants, or contaminants.
As documented in the July 2005 ROD issued by EPA and NYSDEC for the Onondaga Lake Bottom subsite, the SYW-12
Site, also known as Murphy's Island, was administratively included in the investigation of the WBB/HB subsite. The SYW-12
Site was investigated by Honeywell as reported in the 2015 WBB/HB Revised Rl Report, 2009 Revised Human Health Risk
Assessment (HHRA) Report and hazard calculation updates (Appendix 1 of the SYW-12 Site FS Report), the 2011 Revised
Baseline Ecological Risk Assessment (BERA) Report, the 2014 SYW-12 Sources of Contamination Investigation Report and
the 2020 Revised SYW-12 Groundwater Investigation Report.
Following NYSDEC's approval of the Rl and risk assessments for the WBB/HB subsite, it was separated into two OUs.
Because many Superfund sites are complex and have multiple contamination impacts and/or geographic areas, they are
often divided into OUs for managing the site-wide response actions. The NCP (Section 300.5) defines an OU as "a discrete
action that comprises an incremental step toward comprehensively addressing site problems. This discrete portion of a
remedial response manages migration, or eliminates or mitigates a release, threat of a release, or pathway of exposure. The
cleanup of a site may be divided into OUs, depending on the complexity of the problems associated with the site. OUs address
geographical portions of a site, specific site problems, or initial phases of an action, or consist of any set of actions performed
overtime or any actions that are concurrent but located in different parts of a site." OU-1 of the WBB/HB site includes the
Lakeshore Area, the Penn-Can Property, the Railroad Area and two "Areas of Study", AOS#1 and AOS#2 (see Figure 1)
Following the issuance of an OU-1 FS Report in July 2018, an OU-1 ROD was signed in October 2018. The SYW-12 Site
(which is OU-2 of WBB/HB) was subsequently designated as New York State Inactive Hazardous Waste Site No. 734075A.
Site Description and History
Location: The Site is 23.5-acres in size and is owned by Onondaga County. The Site includes undeveloped land and a
portion of Wetland SYW-12. Wetland SYW-12 is a 45.5-acre Class I wetland, portions of which are located around the mouth
of Ley Creek along the southeastern shoreline of Onondaga Lake in Syracuse, New York. See Figure 2, Site Location.
Site Features: The Site is bounded by the CSX railroad tracks to the north and east, Onondaga Creek to the south, and
Onondaga Lake to the west. The Lower Ley Creek subsite of the Onondaga Lake NPL site is also situated to the north but is
being addressed as part of a separate remedy. A figure showing the Site layout is included as Figure 3. The Site encompasses
a total of approximately 23.5 acres with 10.4 acres of upland (i.e., non-wetland areas) and 13.1 acres of delineated wetland
between Onondaga Lake and the CSX railroad tracks (based on a 2018 wetland delineation). Mature trees typical of floodplain
forests occupy the central portion of the Site, which also serve as a roost site for wintering bald eagles (Haliaeetus
leucocephalus).
INFORMATION REPOSITORIES
The administrative record file, which contains copies of the
Proposed Plan and supporting documentation are available
online through the DECinfo Locator at
https://www.dec.nv.qov/data/DecDocs/734075A/ and at the
following locations:
Atlantic States Legal Foundation
658 West Onondaga Street
Syracuse, NY 13204
315-475-1170
New York State Department of Environmental Conservation
615 Erie Boulevard, West
Syracuse, NY 13204
315-426-7400
New York State Department of Environmental Conservation
Attn.: Tracy A. Smith
625 Broadway
Albany, NY 12233-7013
518-402-9676
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Site Geology and Hydrogeology: The local geology for the Site consists of:
• unconsolidated deposits which consist of 2 to 15 feet (ft) of reworked fill consisting of sand, silt, gravel, shell material,
and concretions below a thin layer of recently deposited wetland sediments;
• 15 to 25 ft of marl, which is a carbonate-rich sediment containing a significant amount of shells with variable amounts
of clays and silt. The 15 to 25 ft marl unit becomes gradually finer grained with depth from a sandy, shell rich marl
at the top of the unit to clayey silt marl with a trace of shell material at the bottom of the unit; and
• the geological units underlying the marl unit include silt and clay, silt and fine-grained sand/basal sand and gravel,
till, and bedrock, based on regional geologic information and data collected from nearby locations.
The depth to groundwater beneath the Site ranges from approximately 3.3 to 9.2 ft below ground surface (bgs). The
groundwater occurs in the unconsolidated unit and flows westward toward Onondaga Lake from the central and southern
portions of the Site. Groundwater on the northern portion of the Site flows north toward Ley Creek.
History of the Site: Prior to the early 1800s, the SYW-12 Site was partially underwater, with the remaining portion being
wetlands containing cedar and ash trees. Both Mud Creek (later renamed Ley Creek) and Onondaga Creek meandered
across the northern portion of the Site before flowing into Onondaga Lake. In 1822, New York State lowered the level of
Onondaga Lake by approximately 2 ft, resulting in the draining of wetlands along the lakeshore, including a portion of the
Site. The newly created land was filled in and partitioned as building lots.
In 1873, the lower 0.75 mile of Onondaga Creek was rerouted and channelized slightly south of the present-day Barge Canal.
A channel and harbor basin were also dredged at the mouth of Onondaga Creek as part of the construction of a large
amusement complex known as the Iron Pier Resort (see Figure 4). The complex included a 600-foot pavilion that was built
adjacent to the harbor. The pavilion contained venues for dining, bowling, billiards, concerts, and a carousel. Steamboats
from the harbor provided service to other resorts on the lake. The Iron Pier Resort was closed in 1906 and the pavilion was
demolished by 1908.
Following closure and demolition of the pavilion, historical maps indicate that portions of the Site, the Iron Pier channel, and
harbor basin may have been filled with refuse materials (e.g., soda ash, waste fill) from various sources. Dredged materials
were also potentially placed on the Site because of additional changes to the Onondaga Creek location and configuration,
including dredging of the Barge Canal and harbor terminal in 1915, which relocated the channel between the pre-1873
Onondaga Creek channel and the 1873 relocated Onondaga Creek channel. The Barge Canal was reportedly dredged on
several occasions between 1941 and 1954. The potential sources of contamination at the Site include dredge spoils from
Onondaga Creek, historic dredge material from the southern portion of Onondaga Lake, and possibly the former Marley
property, Oil City properties, former Hiawatha Boulevard Manufactured Gas Plant [MGP] subsite, former Erie Boulevard MGP
site, and Ley Creek.
Based on a review of historic aerial maps, the Site has changed in shape and size overtime as a result of dredge deposition
and natural erosion but has remained undeveloped and vegetated with low-lying vegetation, brush, and trees since the early
1900s.
Current Zoning and Land Use: The Site is owned by Onondaga County and is zoned as parkland within the City of Syracuse.
The surrounding area is commercial. As was noted above, CSX Railroad tracks are located immediately to the north and east
of the Site. The land is currently undeveloped and, given the prevalent wetlands throughout the Site and proximity to the CSX
Railroad tracks, future development for residential or industrial use is unlikely. Based on the land use evaluation, the
reasonably anticipated current and future use of the Site is passive recreation as part of the Onondaga County's Loop the
Lake Trail - Southeast Extension. Ecological receptors currently use the Site, and it is anticipated that they will continue to
use the undeveloped area. An extension of the Onondaga County Loop the Lake Trail, a multi-use recreational trail, has been
constructed on the Site. In February 2019, NYSDEC issued a Freshwater Wetlands Permit and Section 401 Water Quality
Certification for the project following an extended public comment period and a public hearing. In January 2021, Onondaga
County requested a modification to a 2019 permit to replace a proposed steel pile boardwalk over Onondaga Lake with a 330
linear-foot berm trail from the City of Syracuse Lake Lounge to the wetland boundary. The multi-use recreational trail
construction includes a wooden boardwalk within wetland areas and a minimum one foot of cover for passive recreational
use within the trail footprint in non-boardwalk areas in addition to ICs and signage to keep trail users on the established trail.
RESULTS OF REMEDIAL INVESTIGATION, 2012 SOURCES OF CONTAMINATION INVESTIGATION, AND 2019
GROUNDWATER INVESTIGATION
To evaluate the nature and extent of contamination at the Site, the analytical results from the Rl sampling were compared to
the respective soil cleanup objectives (SCOs) provided in 6 NYCRR Part 375 Environmental Remediation Programs for each
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land use type, including Unrestricted-Use SCOs. Unrestricted-Use SCOs represent the concentration of a constituent in soil
that, when achieved at a site, is sufficiently low such that there are no land use restrictions on the site for the protection of
public health, groundwater, and ecological resources. Additional information can be found in the RevisedRl Report. Analytical
results presented in the Revised Rl Report were compared during the feasibility study (FS) to the SCOs for Commercial Use,
Protection of Ecological Resources, and Protection of Groundwater in consideration of anticipated future land use. Current
Site groundwater conditions were also evaluated during an April 2019 groundwater elevation monitoring and sampling event.
Tables 1 and 2 (attached) summarize the Unrestricted-Use SCOs, Commercial-Use SCOs, and Protection of Ecological
Resources SCOs exceedances in shallow (0-2 ft bgs) and subsurface (deeper than 2 ft bgs) soil/fill material, respectively, for
the Site. Table 3 summarizes the New York State Class GA groundwater standards and guidance values (SGVs)
exceedances in groundwater for the Site. The primary contaminants at the Site include benzo(a)pyrene, a semi-volatile
organic compound (SVOC), and assorted polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), and
metals.
It should be noted that the Site boundary described above does not include the portions of the 45.5-acre Wetland SYW-12
that are east of the rail lines or north of Ley Creek. These areas were investigated during the Rl, and based on the results of
the investigation, are not addressed in this Proposed Plan.
Shallow Soil/Fill Material (0 to 2 ft bgs)
Volatile organic compounds (VOCs), SVOCs, pesticides, PCBs, polychlorinated dibenzo-p-dioxins/polychlorinated
dibenzofurans (PCDD/Fs), and metals were detected in shallow soil/fill material on the Site as described below. The data
were compared to the SCOs for Commercial Use, Protection of Ecological Resources, and Unrestricted Use (see Table 1).
VOCs, including chlorinated benzenes and benzene, toluene, ethylbenzene, and xylene (BTEX) compounds, were detected
in the shallow soil/fill material, but they did not exceed the SCOs. The constituents that exceeded the SCOs for Unrestricted
Use predominantly included seven SVOCs (assorted PAHs), five pesticides (4,4'-DDT, 4,4'-DDD, dieldrin, 4,4'-DDE, and
endrin), PCBs (Aroclor 1254 and Aroclor 1260), and inorganic compounds/metals (mercury, zinc, lead, chromium, cadmium,
copper, silver, and nickel).
Several of the above-mentioned constituents exceeded the following SCOs: Commercial Use SCOs, for four SVOCs
(assorted PAHs), including benzo(a)anthracene (maximum concentration of 7,300 |jg/kg [Commercial Use SCO of 1,000
jjg/kg]), benzo(a)pyrene (maximum concentration of 9,100 |jg/kg [Commercial Use SCO of 1,000 |jg/kg]),
benzo(b)fluoranthene (maximum concentration of 12,000 |jg/kg [Commercial Use SCO of 5,600 |jg/kg]), and
dibenzo(a,h)anthracene (maximum concentration of 1,100 |jg/kg [Commercial Use SCO of 560 |jg/kg]); PCBs (Aroclor 1254
and Aroclor 1260) with the highest concentration at 3,470 |jg/kg (Commercial Use SCO of 1,000 |jg/kg); and three inorganics
including mercury (maximum concentration of 8.6 mg/kg [Commercial Use SCO of 2.8 mg/kg]), copper (maximum
concentration of 330 mg/kg [Commercial Use SCO of 270 mg/kg]), and cadmium (maximum concentration of 52 mg/kg
[Commercial Use SCO of 9.3 mg/kg]). The Protection of Ecological Resources SCOs were exceeded for one SVOC
(benzo(a)pyrene at a maximum concentration of 9,100 |jg/kg [Ecological Resource SCO of 2,600 |jg/kg]); five pesticides
including 4,4'-DDT (maximum concentration of 100 |jg/kg [Ecological Resource SCO of 3.3 |jg/kg]), 4,4'-DDD (maximum
concentration of 73 |jg/kg [Ecological Resource SCO of 3.3 |jg/kg]), 4,4'-DDE (maximum concentration of 3.6 |jg/kg
[Ecological Resource SCO of 3.3 |jg/kg]), dieldrin (maximum concentration of 30 |jg/kg [Ecological Resource SCO of 6
jjg/kg]), and endrin (maximum concentration of 26 |jg/kg [Ecological Resource SCO of 14 |jg/kg]); PCBs (Aroclor 1254 and
Aroclor 1260) with the highest concentration at 3,470 jjg/kg (Ecological Resource SCO of 1,000 |jg/kg); and eight inorganic
compounds including mercury (maximum concentration of 8.6 mg/kg [Ecological Resource SCO of 0.18 mg/kg]), zinc
(maximum concentration of 780 mg/kg [Ecological Resource SCO of 109 mg/kg]), lead (maximum concentration of 390 mg/kg
[Ecological Resource SCO of 63 mg/kg]), chromium (maximum concentration of 410 mg/kg [Ecological Resource SCO of 41
mg/kg]), cadmium (maximum concentration of 52 mg/kg [Ecological Resource SCO of 4 mg/kg]), copper (maximum
concentration of 330 mg/kg [Ecological Resource SCO of 50 mg/kg]), silver (maximum concentration of 13 mg/kg [Ecological
Resource SCO of 2 mg/kg]), and nickel (maximum concentration of 87 mg/kg [Ecological Resource SCO of 30 mg/kg]).
Subsurface Soil/Fill Material (at depths greater than 2 ft bgs)
VOCs, SVOCs, pesticides, PCBs, PCDD/Fs, and inorganic compounds were detected in subsurface soil/fill material on the
Site as described below. The data were compared to the SCOs for Commercial Use, Protection of Ecological Resources,
and Unrestricted Use (see Table 2).
SVOCs were detected throughout shallower subsurface soils (2 to 16 ft bgs) but were not detected in the deeper subsurface
samples. PAHs were the most commonly detected SVOCs in the subsurface soil/fill material and accounted for most of the
exceedances observed above the Commercial Use SCOs. Limited exceedances of pesticides and PCBs were observed with
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detections only between 2 and 10 ft bgs with two Commercial Use SCO exceedances. Inorganic compounds were detected
throughout the subsurface with Commercial Use SCO exceedances for arsenic, mercury, copper, and cadmium.
Coal tar/petroleum-like impacted soils, including blebs of nonaqueous phase liquids (NAPLs), were also identified in the
location of the former Onondaga Creek channel. Stained soil and black stained sludge were found in subsurface soil in the
central part of the Site. An evaluation of data and field observations determined that the presence of stained soils and NAPL
does not necessarily correlate with elevated organics concentrations in soil and groundwater at proximate locations. This
evaluation included a comparison of subsurface soil data exceeding SCOs for the Protection of Groundwater, exceedances
of Class GA SGVs, and field observations of stained soils and NAPL.
Polytetrafluoroethylene Sheen Net Samples
Polytetrafluoroethylene (PTFE) sheen net samples were collected as part of the sources of contamination investigation. Visual
observations during the test trenching within or in the vicinity of the former Onondaga Creek channel footprint indicated that
when soils were disturbed, a sheen formed on the groundwater within the excavated trench. The results of the sheen net
sampling verified that PAHs and petroleum biomarkers were detected in this sheen that had been mobilized from the Site
soils when disturbed. The results of the sheen net sampling and the corresponding groundwater sampling indicate that the
organic compounds remain bound to the soils when undisturbed.
Groundwater
The groundwater analytical data were compared to the New York State Class GA groundwater SGVs (see Table 3). As
detailed in Table 3, there were a few VOC (ethylbenzene, isopropylbenzene and xylenes) and SVOC exceedances (4-
methylphenol, 4-nitrophenol, acenaphthene, and naphthalene) of Class GA SGVs identified during the Rl from data collected
before 2015. A supplemental groundwater investigation conducted in 2019 indicated that naphthalene, at a concentration of
23 |jg/L in one well, was the only organic compound that marginally exceeded the Class GA SGV (guidance value of 10 |jg/L),
with slightly lower detected concentrations than in historical detections (36 |jg/L in 2012). Inorganic compounds/metals
detected in Site groundwater include barium, iron, magnesium, manganese, sodium, and chloride, with Class GA SGV
exceedances primarily observed for iron, manganese, sodium, and chloride, which may be ubiquitous in the area and/or
naturally occurring as described in the Revised SYW-12 2019 Groundwater Investigation Report.
Natural attenuation of organic constituents in groundwater at the Site is discussed in the Revised SYW-12 2019 Groundwater
Investigation Report. As summarized in that report, geochemical conditions at the Site are favorable for natural attenuation
of PAHs, including naphthalene, to occur. The determination that natural attenuation is occurring is, in part, based upon
detected concentrations of ferrous iron, sulfide, and methane in groundwater and oxidation-reduction potential data that
suggest the presence of iron- and sulfate-reducing conditions in groundwater. Biodegradation of naphthalene can occur
under anaerobic conditions, particularly under iron- or sulfate-reducing conditions. Further, the presence of methane and
observed decreases in groundwater concentrations of PAHs over time such as acenaphthene and naphthalene indicate that
natural attenuation is likely occurring.
Conclusions
Based on the results of the Rl and supplemental groundwater investigation, the following conclusions have been drawn:
• The primary Site contaminants include assorted PAHs (e.g., benzo(a)pyrene), PCBs, and metals;
• As shown on Figures 5 to 10, Site contaminants in soil/fill material are randomly distributed and are likely related to
several sources, including historical placement of fill material in the former Onondaga Creek channel/Iron Pier area,
dredge spoils from Onondaga Creek, historic dredge material from the southern portion of Onondaga Lake, and
potential historical off-Site sources (i.e., former Marley property, Oil City properties, former Hiawatha Boulevard MGP
subsite, former Erie Boulevard MGP site, and Ley Creek). The Marley and Oil City properties are believed to have
impacted the Barge Canal sediment that was then dredged and placed on the Site during historical dredging
operations. Contamination at these properties is currently being addressed by the potentially responsible parties for
these sites under NYSDEC and EPA oversight; and
• There are few exceedances of the Class GA groundwater SGVs for organic constituents in Rl groundwater samples,
suggesting that organic constituents in shallow and subsurface soils are generally not mobilizing to groundwater;
however, naphthalene concentrations in subsurface soil may be contributing to localized naphthalene detected in one
monitoring well (HB-MW-29). The 2019 groundwater samples indicated that naphthalene was the only organic
compound that marginally exceeded the Class GA SGV (exceedance of the guidance value in only one well), with an
overall decrease in organic constituent concentrations overtime. Geochemical conditions at the Site are favorable
for natural attenuation of napthalene to occur.
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The Site contaminants in surface soil identified during the Rl were further evaluated during the FS to identify a targeted list of
compounds (i.e., benzo(a)pyrene, 4,4'-DDT, total PCBs, mercury, chromium and cadmium) that can serve as surrogates for
other contaminants that are most likely to drive risk and remediation, and, therefore, will be representative chemicals for
optimizing remedy protectiveness.
SCOPE AND ROLE OF ACTION
As mentioned above, there are many subsites, that are part of the cleanup of the overall Onondaga Lake NPL site. The
following are the eleven subsites that are being addressed:
1. Onondaga Lake Bottom (which includes Geddes Brook/Ninemile Creek as an OU);
2. LCP Bridge Street;
3. Semet Residue Ponds;
4. Willis Avenue;
5. WBB/HB;
6. Solvay Wastebeds 1-8;
7. General Motors - Inland Fisher Guide;
8. Town of Salina Landfill;
9. Ley Creek PCB Dredgings;
10. Lower Ley Creek; and
11. Niagara-Mohawk Hiawatha Boulevard.
For the Onondaga Lake Bottom subsite, dredging and capping activities were performed from 2012 to 2014 and 2016,
respectively. Habitat restoration activities associated with the remedy were completed in 2017. The dredged material is being
managed at a sediment consolidation area constructed on former Solvay Wastebed 13. Construction activities at the
consolidation area, which included the placement of an engineered cap, were completed in 2017. Remedial construction has
also been fully implemented at the Semet Residue Ponds, Wastebeds 1-8 OU-1, WBB/HB, LCP Bridge Street, Geddes
Brook/Ninemile Creek, Niagara-Mohawk Hiawatha Boulevard, Salina Landfill, and the Ley Creek PCB Dredgings subsites.
All the noted subsites/OUs are undergoing long-term maintenance and monitoring. Remedial actions at portions of, or
environmental media (e.g., soil, groundwater) at Wastebeds 1-8 OU-2, Willis Avenue, and General Motors - Inland Fisher
Guide (OU-1 and OU-2) subsites have been completed or are in progress. Other portions of, or media at, these subsites
are in the remedial design or RI/FS phase. The Lower Ley Creek subsite is in the remedial design phase.
The scope of the action outlined in this Proposed Plan is to address the contaminated soil/fill material and groundwater at
the SYW-12 Site. NYSDEC and EPA expect this remedy to be a final, comprehensive remedy. Due to the presence of
forested areas on the Site that are winter roosting habitat for bald eagles, some of the alternatives evaluated in this Proposed
Plan include remediation in 8.2 to 10 acres of the 23.5-acre Site that are accessible and/or non-forested so the mature trees
used for roosting are not impacted. Additional discussion is provided in the alternatives below.
Principal threat wastes are wastes that are considered source materials, i.e., materials that include or contain hazardous
substances, pollutants or contaminants that act as a reservoir for migration of contamination to groundwater, surface water,
or as a source for direct exposure. While stained soils and blebs of NAPL are present at the Site, they do not necessarily
correlate with elevated organic contaminant concentrations in soil and groundwater at proximate locations. NYSDEC and
EPA have not identified material at the Site as principal threat wastes. In addition, sediment and surface water data from
Onondaga Lake and Ley Creek indicate that contamination from the Site is not migrating off-Site.
Summary of Quantitative Site Risk Assessments
As part of the Rl process, baseline quantitative risk assessments were conducted for the Site to estimate the potential risks
to human health and the environment (see the "What is Human Health Risk and How is it Calculated?" and "What is Ecological
Risk and How is it Calculated?" text boxes below). Baseline risk assessments, consisting of a HHRA, which evaluates
potential risks to people, and a BERA, which evaluates potential risks to ecological receptors, have been performed to analyze
the potential for adverse effects caused by hazardous substance releases from a site assuming no further actions to control
or mitigate exposure to these hazardous substances are taken.
Human Health Risk Assessment
Because the Site is zoned as parkland, exposure scenarios were developed based on this current and likely future land use.
Exposure to many different media were considered in the Baseline HHRA process through a number of current and future
exposure scenarios for different potential receptors, including child and adult recreational visitors, railroad worker, utility
worker, construction worker, commercial/industrial worker, and child and adult residents.
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Exposure scenarios were developed for these populations. These scenarios were evaluated based on potential exposure
through incidental ingestion and inhalation of and dermal contact with surface soil, subsurface soil, fugitive dust, or volatile
emissions. In addition, exposure to groundwater was also evaluated.
Since the completion of the Revised HHRA Report in 2009, EPA has re-evaluated and updated toxicity information for PAHs
and issued new guidance on the methodology for assessing risks associated with the inhalation pathway of exposure. To
incorporate these updates, risk calculations for soil exposures for the most sensitive nonresidential receptor group and based
on the anticipated site use (i.e., recreators) were revised in 2018, and the risk calculations for soil exposures for the remaining
receptor groups evaluated in the HHRA which were not addressed in the 2018 evaluation were revised in 2022. Updated
risks and hazard tables resulting from all of the recalculations conducted since the 2009 HHRA are presented in Appendix 1
of the FS Report. A summary of the revised cancer risks and noncancer hazards above threshold levels for each population
in each of the areas of the Site, along with the chemicals that contribute the most to the risk or hazard, or chemicals of
concern (COCs), can be found in Table 4.
It should be noted that the lifetime excess cancer risks for utility workers, construction workers, and child residents are below
the regulatory risk threshold based on the revised hazard and risk evaluation as a result of the incorporation of updated
published cancer toxicity values for select PAHs in the evaluation. Noncarcinogenic hazards calculated for these receptors
are essentially unchanged by the EPA updates to risk assessment methods and cancer-based toxicity values. As such, the
unacceptable hazards posed to child residents by highly chlorinated PCBs in surface soil and to construction workers by
chromium and benzo(a)pyrene in groundwater, as calculated in the 2009 Revised HHRA Report, remain potential threats to
these receptor groups. However, it should be noted that the anticipated future land use of the Site does not include residential
WHAT IS HUMAN HEALTH RISK AND HOW IS IT CALCULATED?
A Superfund baseline human health risk assessment is an analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of any actions to control or mitigate these under current- and
future-land uses. A four-step process is utilized for assessing site-related human health risks for reasonable maximum
exposure scenarios.
Hazard identification: In this step, the Contaminants of Potential Concern (COPCs) at the site in various media (i.e., soil,
groundwater, surface water, and air) are identified based on such factors as toxicity, frequency of occurrence, and fate and
transport of the contaminants in the environment, concentrations of the contaminants in specific media, mobility,
persistence, and bioaccumulation.
Exposure Assessment: In this step, the different exposure pathways through which people might be exposed to the
contaminants in air, water, soil, etc. identified in the previous step are evaluated. Examples of exposure pathways include
incidental ingestion of and dermal contact with contaminated soil and ingestion of and dermal contact with contaminated
groundwater. Factors relating to the exposure assessment include, but are not limited to, the concentrations in specific
media that people might be exposed to and the frequency and duration of that exposure. Using these factors, a "reasonable
maximum exposure" (RME) scenario, which portrays the highest level of human exposure that could reasonably be
expected to occur, is calculated.
Toxicity Assessment: In this step, the types of adverse health effects associated with chemical exposures and the
relationship between magnitude of exposure (dose) and severity of adverse effects (response) are determined. Potential
health effects are chemical-specific and may include the risk of developing cancer over a lifetime or other non-cancer health
hazards, such as changes in the normal functions of organs within the body (e.g., changes in the effectiveness of the
immune system). Some chemicals can cause both cancer risks and non-cancer health hazards.
Risk Characterization: This step summarizes and combines outputs of the exposure and toxicity assessments to provide a
quantitative assessment of site risks for all COPCs. Exposures are evaluated based on the potential risk of developing
cancer and the potential for non-cancer health hazards. The likelihood of an individual developing cancer is expressed as
a probability. For example, a 10-4 cancer risk means a "one-in-ten-thousand excess cancer risk"; or one additional cancer
may be seen in a population of 10,000 people because of exposure to site contaminants under the conditions identified in
the Exposure Assessment. Current Superfund regulations for exposures identify the range for determining whether
remedial action is necessary as an individual excess lifetime cancer risk of 104 to 106, corresponding to a one-in-
tenthousand to a one-in-a-million excess cancer risk. For non-cancer health effects, a "hazard index" (HI) is calculated.
An HI represents the sum of the individual exposure levels compared to their corresponding reference doses. The key
concept for a non-cancer HI is that a threshold (measured as an HI of less than or equal to 1) exists below which non-
cancer health hazards are not expected to occur. The goal of protection is 10 6 for cancer risk and an HI of 1 for a non-
cancer health hazard. Chemicals that exceed a 10 4 cancer risk or an HI of 1 are typically those that will require remedial
action at the site and are referred to as COCs in the ROD.
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use and that the unacceptable hazard posed by chromium and benzo(a)pyrene to construction workers was based on the
results obtained during the Rl; sampling subsequent to the Rl indicate the absence of chromium and benzo(a)pyrene in
groundwater underlying the Site2, indicating there may not be an unacceptable risk attributable to chromium and
benzo(a)pyrene in groundwater.
The vapor intrusion screening in the HHRA identified chemicals with a potential to migrate to indoor air, based on factors
such as the chemical-specific vapor pressure. Because these factors apply to chemicals present in media, such as soil, fill
material, and groundwater, all media with these chemicals have the potential for future vapor intrusion concerns.
Naphthalene was identified and retained as a vapor intrusion COPC because its maximum detected concentration in Site
groundwater exceeded its groundwater vapor intrusion screening level.
Consumption of groundwater was not quantitatively evaluated in the HHRA. As mentioned above, naphthalene is the only
contaminant that is present in groundwater that exceeds the state guidance value. Naphthalene does not have a federal
drinking water standard. It should be noted though that the maximum concentration of naphthalene in groundwater of 170
|jg/L detected during the Rl exceeds both the concentration associated with a noncancer hazard quotient of 1 (6 jjg/L) and
the concentration associated with the high end (10-4) of the acceptable cancer risk range (11.7 |jg/L). A memorandum was
added to the Site file to document this finding.
The HHRA and post-HHRA evaluations concluded that potential risks associated with exposure to surface soil/fill material
(0 to 2 ft bgs) assuming passive recreational use of the Site are acceptable under current and future conditions. Potential
risks associated with exposure to surface soil/fill material (0 to 2 ft bgs) for a future child resident would not be acceptable,
if such exposures were allowed to occur.
A full discussion of the HHRA evaluation and conclusions is presented in the HHRA report with post-HHRA evaluations
presented in the FS Report.
Ecological Risk Assessment
The BERA for the Site identified current and future habitat use and potential ecological receptors. Based on the ecological
receptors identified, potentially unacceptable risk was driven by the following constituents by receptor for the Site Exposure
Area:
• Potential risk to terrestrial plants is driven by 11 metals via exposure to surface soil based on average concentrations
throughout the exposure area exceeding screening criteria for the protection of plants.
• Potential risk to soil invertebrates is driven by five metals via exposure to surface soil based on exceedances of
screening criteria for the protection of soil invertebrates and microfauna.
• Potential food chain bioaccumulation risks for insectivorous birds, as represented by the American robin (Turdus
migratorius), exceeded the risk threshold (i.e., hazard quotient [HQ] > 1.0) for lowest effect dose levels for six metals
and four organic compounds in surface soil.
• Risks to insectivorous mammals from food chain exposure, as represented by the short-tailed shrew (Blarina
brevicauda), exceeded 1.0 based on lowest effect level doses for five metals and five organic compounds in surface
soil.
• Potential food chain risks to carnivorous mammals, as represented by the red fox (Vulpes vulpes), are considered
nominal for each constituent with the exception of chromium.
• Risks to carnivorous mammals from food chain exposure, as represented by the red-tailed hawk (Buteo jamaicensis),
did not exceed 1.0 for any constituent based on lowest effect level doses.
• Potential risks to predatory mammals that may forage on terrestrial mammals and fish in the lake area abutting the
Site, as represented by the mink (Neovison vison), are considered nominal given that no HQs based on lowest effect
level doses exceeded 1.0.
In summary, the Site BERA concluded that select metals and organic compounds, namely chromium, cadmium and PCBs,
pose a potential risk to communities or organisms and to bird and mammal populations with relatively restrictive home ranges
(e.g., American robin and short-tailed shrew). A full discussion of the BERA's evaluation and conclusions is presented in the
BERA Report.
2 The Rl data used in the 2009 HHRA included data from groundwater screening samples, which are more likely to have aquifer solids
(e.g., turbidity) present, and which could result in higher concentrations than the monitoring well samples collected in 2012 and 2019.
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WHAT IS ECOLOGICAL RISK AND HOW IS IT CALCULATED?
A Superfund baseline ecological risk assessment is an analysis of the potential adverse health effects to biota caused by
hazardous substance releases from a site in the absence of any actions to control or mitigate these under current and
future land and resource uses. The process used for assessing site-related ecological risks includes:
Problem Formulation: In this step, the contaminants of potential ecological concern (COPECs) at the site are identified.
Assessment endpoints are defined to determine what ecological entities are important to protect. Then, the specific
attributes of the entities that are potentially at risk and important to protect are determined. This provides a basis for
measurement in the risk assessment. Once assessment endpoints are chosen, a conceptual model is developed to provide
a visual representation of hypothesized relationships between ecological entities (receptors) and the stressors to which
they may be exposed.
Exposure Assessment: In this step, a quantitative evaluation is made of what plants and animals are exposed to and to
what degree they are exposed. This estimation of exposure point concentrations includes various parameters to determine
the levels of exposure to a chemical contaminant by a selected plant or animal (receptor), such as area use (how much of
the site an animal typically uses during normal activities); food ingestion rate (how much food is consumed by an animal
over a period of time); bioaccumulation rates (the process by which chemicals are taken up by a plant or animal either
directly from exposure to contaminated soil, sediment or water, or by eating contaminated food); bioavailability (how easily
a plant or animal can take up a contaminant from the environment); and life stage (e.g., juvenile, adult).
Ecological Effects Assessment: In this step, literature reviews, field studies or toxicity tests are conducted to describe the
relationship between chemical contaminant concentrations and their effects on ecological receptors, on a media-, receptor-
and chemical-specific basis. To provide upper and lower bound estimates of risk, toxicological benchmarks are identified
to describe the level of contamination below which adverse effects are unlikely to occur and the level of contamination at
which adverse effects are more likely to occur.
Risk Characterization: In this step, the results of the previous steps are used to estimate the risk posed to ecological
receptors. Individual risk estimates for a given receptor for each chemical are calculated as a hazard quotient (HQ), which
is the ratio of contaminant concentration to a given toxicological benchmark. In general, an HQ above 1 indicates the
potential for unacceptable risk. The risk is described, including the overall degree of confidence in the risk estimates,
summarizing uncertainties, citing evidence supporting the risk estimates and interpreting the adversity of ecological effects.
Summary of Human Health and Ecological Risks
The results of the HHRA and post-HHRA evaluations indicate that exposure to contaminated soil, indoor air, and groundwater
present current and/or potential future unacceptable risks, and the ecological risk assessment indicates that the
contaminated soils pose an unacceptable risk.
Based upon the results of the Rl and the risk assessments, EPA and NYSDEC have determined that actual or threatened
releases of hazardous substances from the Site, if not addressed by the preferred remedy or one of the other active
measures considered, may present a current or potential threat to human health and the environment.
Subsequent to publication of the Revised BERA, the occupation of the Site by bald eagles has increased significantly,
particularly exhibited by winter roosting behavior of a large number of individuals and is recognized by the United States Fish
and Wildlife Service (USFWS) and NYSDEC. Bald eagles likely gather at the Site because of the warm water outflow from
the nearby Metropolitan Syracuse Wastewater Treatment Plant (Metro) which provides ice-free open water and the
opportunity for eagles to forage during winter months. The large trees at the Site serve as roosts for wintering bald eagles.
Location-specific applicable or relevant and appropriate requirements (ARARs) related to habitat protection, including the
Federal Bald and Golden Eagle Protection Act (16 U.S.C. 668 et seq), USFWS National Bald Eagle Management Guidelines,
Conservation Plan for Bald Eagles in New York State, and 6 NYCRR 182, provide requirements and guidance regarding the
protection of bald eagle habitat, including the "take and disturbance" of bald eagles, and limiting activities that may alter
communal roost sites and foraging areas.
As part of the FS development, USFWS provided recommendations related to soil/fill material locations to be addressed that
would also preserve trees that serve as roosts for bald eagles. The following measures were also recommended by USFWS
to provide for the continued integrity of this roost site and enable bald eagles to feed and shelter during winter:
• Minimize tree clearing as part of remediation.
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• Perform remedial activities outside the December 15 to March 15 winter roosting season to avoid disturbance to roosting
bald eagles.
The NYSDEC's March 2016 Conservation Plan for Bald Eagles in New York State cited above provides further guidelines
and actions recommended for the conservation of New York's bald eagle population and recommends that work and activities
disturbing trees be performed outside the December 1 to March 31 winter roosting season. These measures were considered
as part of the development and evaluation of remedial alternatives, in particular when balancing potential risks with remedy
elements potentially detrimental to valuable habitat.
New York State Soil Cleanup Objectives
For the SYW-12 Site, Commercial Use and Protection of Ecological Resources SCOs are applicable. SCOs are
contaminant-specific remedial action objectives for soil based on a site's current, intended, or reasonably anticipated future
use. Separate sets of SCOs were developed in consideration of public health, groundwater, and ecological resources. A
brief summary of how the SCOs were developed is presented below. For more information on the development of the SCOs,
see https://www.dec.nv.aov/docs/remediation hudson pdf/techsuppdoc.pdf.
HOW WERE SCOs DEVELOPED?
Developing the health-based SCOs (e.g., Commercial Use) required a number of exposure considerations including who
might be exposed to soil contaminants, in what ways they might be exposed, and for how long the exposure might occur.
Since these considerations can vary with the use of a site, health-based SCOs differ depending upon site use. Protection
of Groundwater SCOs are estimated based on NYSDEC's experience with impacts on groundwater from soils at inactive
hazardous waste sites. An approach was selected which estimates the amount of contamination that may be present in
water when it is in direct contact with soil for a long time, and the amount of contaminant that may leach out of
contaminated soil as water travels down through the soil column. The approach also accounts for the reduction in water
contaminant concentrations as the water in the soil travels to groundwater. To develop the Ecological Resources SCOs
the NYSDEC reviewed existing soil criteria available in the literature along with the corresponding derivation
methodologies. After an extensive review, the NYSDEC chose to adopt many of the procedures and methods developed
by the EPA Ecological Soil Screening Levels (Eco-SSL) program. In addition to protection of health, groundwater, and
ecological resources, two other considerations, the levels of Priority List contaminants in rural soils of New York State
and maximum acceptable soil contaminant concentrations, contributed to the basis of the final SCOs.
REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are specific goals to protect human health and the environment. These objectives are
based on available information and standards, such as ARARs, to-be-considered guidance, and site-specific risk-based levels
established using the risk assessments. Based on consideration of potential chemical-specific ARARs, nature and extent of
contamination, potentially unacceptable risks, the current, intended and reasonably anticipated future use of the Site and its
surroundings, and the recognized value of and use of the forested areas of the Site by the bald eagle, the following RAOs
have been established for the Site:
Groundwater
RAO for Public Health Protection
• Prevent ingestion of groundwater with contaminant levels exceeding drinking water standards and/or guidance
values.
Soil
RAOs for Public Health Protection
• Prevent ingestion/direct contact with contaminated soil above remedial goals and/or that result in unacceptable risk.
• Prevent inhalation of or exposure from contaminants volatilizing from contaminants in soil.
RAOs for Environmental Protection
• Prevent impacts to biota from ingestion/direct contact with soil causing toxicity or impacts from bioaccumulation
through the terrestrial food chain.
• Prevent, or reduce the migration of contaminants that would result in sediment or surface water contamination.
Vapor Intrusion
RAO for Public Health Protection
• Mitigate impacts to public health resulting from existing, or potential for vapor intrusion.
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NYSDEC's SCOs for Commercial Use and the Protection of Ecological Resources have been identified as remediation goals
for soil to attain these RAOs. SCOs are risk-based criteria that have been developed by the State following methods
consistent with EPA's methods/protocols/guidance and they are set at levels consistent with EPA's acceptable levels of risk
that are protective of human health and ecological exposure depending upon the existing and anticipated future use of the
Site. While the land use of the Site has historically been vacant, current and anticipated future uses of some areas could
include commercial use (including passive recreational use such as a trail). Groundwater remedial goals are the New York
State Ambient Water Quality Standards.
COCs identified for the Site include
cadmium, chromium, mercury and
other metals, benzo(a)pyrene and
other PAHs, 4,4'-DDT and other
pesticides, and PCBs. As
presented in the FS Report, an
evaluation of surface soil Area-
Weighted Average Concentrations
(AWACs) was conducted to further
understand and evaluate surface
soil concentrations pre- and post-
remedy implementation relative to
NYSDEC's SCOs (for more
information, see the textbox "What
is an "AWAC" and How is it
Calculated?"). Discussion of this
evaluation is presented below under
the Comparative Analysis of
Alternatives heading.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA § 121(b)(1), 42 U.S.C. § 9621(b)(1), mandates that remedial actions must be protective of human health and the
environment, cost-effective, and utilize permanent solutions and alternative treatment technologies and resource recovery
alternatives to the maximum extent practicable. Section 121(b)(1) also establishes a preference for remedial actions which
employ, as a principal element, treatment to permanently and significantly reduce the volume, toxicity, or mobility of the
hazardous substances, pollutants and contaminants at a site. CERCLA § 121(d), 42 U.S.C. § 9621(d), further specifies that
a remedial action must attain a level or standard of control of the hazardous substances, pollutants, and contaminants, which
at least attains ARARs under federal and state laws, unless a waiver can be justified pursuant to CERCLA § 121(d)(4), 42
U.S.C. § 9621(d)(4).
Based on the anticipated future development of the Site, expectations of the reasonably anticipated land use, as described
above, were considered in the FS to facilitate the development and evaluation of remedial alternatives. The reasonably-
anticipated land use includes passive recreational use (which is encompassed by a commercial use) and ecological use. In
addition, special consideration of the value provided by the Site's habitat and seasonal use of the Site by bald eagles was
included during the development of the alternatives. This special consideration resulted in alternatives that would not address
contamination in all areas of the Site and would leave areas with contaminant concentrations that may exceed SCOs within
approximately 13.5 to 15.3 acres of the 23.5-acre Site.
The remedial alternatives are as follows:
Alternative 1 - No Action
The Superfund program requires that the "no action" alternative be considered as a baseline for comparison with the other
alternatives. The no action remedial alternative would not include any remedial measures to address the soil/fill material and
groundwater contamination at the Site.
WHAT IS AN "AWAC" AND HOW IS IT CALCULATED?
Area-Weighted Average Concentrations (AWACs) are calculated concentrations
of select constituents representative of site-wide conditions that facilitate
comparisons between existing conditions and future conditions following
implementation of potential remedial alternatives. To develop AWACs, computer
software is used to interpolate concentrations between sample locations from
known sample data based on the premise that closer values are more similar than
values farther away and therefore the closer values should have greater influence,
or weight, in the averaging process. The result is a grid or an array of cells (2 ft x
2 ft) encompassing the entire site with each cell assigned a sample
concentration. The calculated AWAC for a given constituent is equal to the
average concentration of the interpolated grid and represents the pre-remediation
AWAC for that constituent. Where remedial activities are proposed, the exercise
is repeated using representative topsoil concentrations within the remedial
footprint and the remaining surface soil concentration in undisturbed areas. The
existing AWAC concentrations are then compared to the post-remediation AWAC
results to assess improvement and protectiveness of remedial alternatives relative
to existing conditions. Appendix 8 of the Site FS Report presents additional details
on the site-specific approach to calculating AWACs.
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Since the No Action alternative does not include any remedial measures there are no capital, annual, and present-worth costs
for this alternative:
Alternative 2 - Soil Cover in Select Areas, Wetland Restoration, Biota Monitoring, and Monitored Natural Attenuation
This alternative includes the placement of a soil cover where accessible and not detrimental to the environment (i.e., avoiding
mature tree removal, disturbance of bald eagles, etc.) and restoring wetlands in select non-forested wetland and upland areas
of the Site. The 2-foot-thick soil cover would be placed on an approximately 8.2-acre area, which would include 7.5 acres of
non-forested wetland (perched wetland cover areas on Figure 11) and 0.7 acre of non-forested upland. The soil cover would
control potential erosion of, and direct contact with, contaminated soil/fill material, as well as control the potential inhalation
of dust in these areas. To restore wetland areas, contaminated soil may be removed, and either reused on-Site or disposed
off-Site, prior to cover placement to a depth necessary to preserve wetland conditions and functions. It is estimated that clean
backfill would be transported to the Site, resulting in approximately 2,450 dump truck trips (i.e., round-trip with a 10-yard dump
truck). The remedial footprint is targeted to reduce ecological exposure while still retaining forested SYW-12 habitat to
preserve areas currently used by bald eagles for roosting. Specifically, damage to root zones through the placement of soil
cover material which would limit oxygen supply to the tree roots or removal of mature trees used for eagle roosting would be
avoided under this alternative. The remediated areas would be restored and biota monitoring performed. As described in
the "Results of Remedial Investigation" section above, because of special considerations being given to the mature trees and
bald eagle population, surface soil in non-remediated areas may exceed Commercial Use and the Protection of Ecological
Resources SCOs where cover would not be placed.
A surface soil pre-design investigation and tree survey would be performed to evaluate the addition of up to seven areas,
totaling 2.2 acres, to the remediation footprint. The areas for consideration include two areas within the forested wetland
characterized by scrub vegetation on the northern portion of the Site, four areas within the non-forested wetland on the
western portion of the Site, and one upland forested area on the southern portion of the Site (purple outlined areas on Figure
11). Should surface soil sampling and the tree survey indicate that elevated surface soil/fill material contaminant
concentrations are present and large trees would not need to be removed or disturbed (e.g., within the drip-zone of the large
trees), soil excavation and backfilling of these areas with clean material would be considered during the design.
To minimize loss of wetland acreage or function, wetland conditions and functions would be integrated into the areas where
the cover would be placed within the current wetland footprint. To improve the success of the restored wetlands, the remedial
design would consider excavation and/or grading to allow wetland functions and values. An evaluation would be conducted
as part of the cover design to promote sufficient flooding and saturation to facilitate the development of wetland soils and
hydrology appropriate for native plants and other habitat in conjunction with grading/soil profile design such that wetland
conditions and functions are addressed. Where the water budget and/or grading cannot replace wetland conditions or
functions, additional mitigation measures would be included during the design.
The soil covers would also be installed to support and preserve existing mature trees present proximate to the proposed
cover to allow for future tree succession. Additional tree-planting may be performed as part of restoration. Where cover
material is placed, a demarcation layer would be evaluated during the remedial design to delineate the boundary between
the contaminated soil/fill material and the soil cover and would be compatible with the wetland or tree growth, as necessary.
The demarcation layer would provide evidence of cap erosion and provide a warning that contaminated material may exist
below the demarcation layer.
Excavated soil reuse options and limitations (e.g., within wetland areas), impacts to the bald eagle habitat, and the final
wetland restoration approach, including opportunities to improve wetland functions and values, planting of trees and
sustainable remediation principles would be further evaluated during the pre-design and design phases. Should reuse of
excavated/graded/handled materials not be possible at the Site following remedial design evaluations, the material would
need to be managed off-Site.
Because of the Onondaga County trail construction, geotechnical concerns, and discussion and coordination with railroad
operations, the boundaries of the remedy illustrated in Figure 11 are conceptual. It is anticipated that there would be no
excavation in wetland areas adjacent to the railroad based on stability concerns. Mitigation would be necessary where
construction results in a loss of wetland acreage or function and wetland conditions cannot be returned. The extent of the
Capital Cost:
Annual operation and
maintenance (O&M) Cost:
Present-Worth Cost:
$0
$0
$0
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cover would be revisited during the design phase based on pre-design sampling and other activities and in consideration of
the trail alignment. Onondaga County has included signage requiring recreational users to remain on the trail in the design
for the multi-use recreational trail. The potential need for additional measures (e.g., fencing/railing, maintaining dense
vegetation along the trail, improved signage, and/or sampling) would be reviewed during the design phase and based on
management of the trail.
Biota monitoring would be performed to evaluate remedy effectiveness and assess protectiveness of ecological receptors. A
baseline sampling program, consisting of two sampling events, would be implemented, with subsequent sampling events
following remedy implementation using an adaptive, data-driven approach (e.g., years 3 and 5). A field assessment of Site
vegetative community composition (e.g., diversity, richness, invasive species evaluation) and qualitative wildlife community
observations would be performed to support the biota monitoring program. The field assessment would also include an
evaluation of Site trees, specifically trees that serve as roosts for bald eagles, for overall health and preservation. Specific
sample locations, species, sample and analytical methods, and frequencies would be assessed and established during the
remedial design. It is assumed that the monitoring program would consist of analysis of soil invertebrate and small mammal
tissue, with collection of co-located surface soil/fill material samples for laboratory analysis of chemical constituents. The
details related to the scope of biota sampling would be developed during the remedial design phase.
Periodic sampling and analysis of groundwater would be included as a means of detecting changes in groundwater
concentrations and monitoring the natural attenuation of naphthalene in groundwater. Natural attenuation of other
contaminants may be evaluated, if necessary. Specific monitoring locations, parameters, and frequencies would be
established during remedial design. For cost estimation purposes, it was assumed that the monitoring program would consist
of semi-annual sampling often monitoring wells with analyses for VOCs, SVOCs (including PAHs), metals, mercury, cyanide,
and cations/anions. However, the specific number of wells and analyses will be determined during remedial design or site
management.
The cover would require routine maintenance and inspection to maintain integrity and proper function.
ICs in the form of environmental easements and/or restrictive covenants would be used to limit land use to commercial
(including passive recreational), as appropriate, prevent the use of groundwater without approved treatment and require that
any intrusive activities on the Site would be conducted in accordance with a NYSDEC-approved SMP, which would include
the following:
• Institutional and Engineering Control Plan that identifies all use restrictions and engineering controls (ECs) for the Site
and documents the steps and media-specific requirements necessary to ensure the following ECs and ICs remain in
place and effective:
o environmental easements and/or restrictive covenants described above
o Site cover described above
o Future remediation/management in areas where no cover is present at the Site (e.g., due to erosion or
changes in vegetation)
o excavation plan that details the provisions for management of future excavations on the Site
o descriptions of the provisions of the ICs, including any land use or groundwater use restrictions
o a soil vapor intrusion evaluation will be completed and appropriate actions implemented for any on-Site
buildings, if they were to be constructed
o provisions for the management and inspection of the identified ECs
o protection measures to be implemented while conducting any needed subsurface soil disturbance activities,
to prevent exposure to sheens or blebs of NAPL
o maintaining Site access controls and NYSDEC notification
o steps necessary for periodic reviews and certification of the ECs and/or ICs.
• Monitoring Plan to assess the performance and effectiveness of the remedy. Elements of the monitoring plan will include
groundwater and biota monitoring, and success or repair of habitat and wetland restoration. The monitoring plan will
include assessing restoration success and repair, wetland delineation, and invasive species management during
restoration. The final monitoring program would be established during the design.
Because this alternative would result in contaminants remaining above levels that allow for unrestricted use and unlimited
exposure, CERCLA requires that the remedy for the Site be reviewed at least once every five years.
The estimated construction time of this alternative is one construction season.
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The estimated capital, annual, and present-worth costs of this alternative are as follows:
Capital Cost: $7,530,000
Annual O&M Costs: $181,000
Present-Worth Cost: $8,300,000
Alternatives 3A/3B - Surface Excavation with On-Site Reuse or Off-Site Disposal and Soil Cover/Wetland Restoration
on Perimeter and Interior Areas, Biota Monitoring, and Monitored Natural Attenuation, with Limited Tree Removal
This alternative is similar to Alternative 2, except that it includes remediation in an additional 1.8 acres in not readily accessible
non-forested wetland areas (perimeter and interior wetlands). Excavation of approximately 21,000 cubic yards (cy) of surface
soil/fill material (up to 2 ft bgs) over 7 acres would be performed prior to placement of the soil cover. In addition to the 8.2
acres of perimeter wetlands addressed under Alternative 2 with a cover, this alternative also includes an additional 1.3 acres
of cover to address interior wetland areas as indicated on Figure 12. Disturbance of approximately 0.5 acres of forested
upland/wetlands, which would result in the removal of trees, would be needed to construct a road to access the 1.3 acres of
non-forested wetlands, and the soil cover would be extended over these 0.5 acres. The total anticipated acreage of the soil
cover is approximately 10 acres. Pre-design surface soil sampling and a tree survey would be performed to evaluate the
potential need to address contaminated surface soil/fill material in approximately 1 acre of additional wetland and upland
areas based on surface soil SCOs, including one upland forested area on the southern portion of the Site and two areas of
forested wetland on the northern portion of the Site. However, because of the special considerations being given to the mature
trees and bald eagle population, surface soil in non-remediated areas may exceed Commercial Use and the Protection of
Ecological Resources SCOs in areas where a soil cover is not being placed.
Excavated contaminated soil/fill material management options are included as variations of Alternative 3. Specifically, on-Site
reuse and off-Site disposal options to a permitted facility are presented as Alternatives 3A and 3B, respectively. Alternative
3A is anticipated to result in approximately 2,650 dump truck trips, while Alternative 3B is anticipated to result in 4,200 dump
truck trips due to the off-Site disposal of excavated soil/fill material. Because of the Onondaga County trail construction,
geotechnical concerns, and discussion and coordination with railroad operations, the boundaries of the remedy illustrated in
Figure 12 are conceptual.
Because this alternative would result in contaminants remaining above levels that allow for unrestricted use and unlimited
exposure, CERCLA requires that the remedy for the Site be reviewed at least once every five years.
The estimated construction time of this alternative is one to two construction seasons.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Alternative 3A Alternative 3B
(On-Site Reuse) (Off-Site Disposal)
Capital Cost: $21,110,000 $26,150,000
Annual O&M Costs: $185,000 $185,000
Present-Worth Cost: $21,900,000 $27,000,000
Alternative 4 - Full Removal and Off-Site Disposal with Wetland Restoration and Monitored Natural Attenuation
Alternative 4 includes the mechanical excavation of soil/fill material within the forested and non-forested areas of the Site
exhibiting concentrations above 6 NYCRR Part 375 Unrestricted Use SCOs (Figure 13). This is anticipated to require the
removal of material as deep as 16 ft bgs. Approximately 400,000 cy of contaminated soil/fill material would be excavated and
disposed off-Site under this alternative. The excavated areas would be backfilled with clean fill. Excavated wetland areas
would be backfilled to existing grade using materials appropriate for wetland establishment. Appropriate wetland species
would be planted to reestablish both forested and non-forested wetlands to include wetland vegetation, shrubs and trees.
Given the number of trees and larger organic debris (e.g., chipped mature trees and brush) that would be generated from
clearing, it is estimated that 900 tons of organic debris would also require off-Site transport and management. In addition,
this alternative would include monitoring the natural attenuation of naphthalene in the groundwater. The timeframe for the
naphthalene to achieve groundwater standards would be the same as for Alternative 2. Groundwater monitoring would be
performed as part of site management.
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It is estimated that 600,000 tons of excavated soil/fill material would be transported and disposed off-Site to a permitted
facility. It is estimated that the soil/fill and organic debris would be transported off-Site over the course of four construction
seasons, resulting in approximately 56,000 truck trips. Because of the required 30-foot setback from the adjacent CSX
Railroad tracks, impacted material may need to remain on-Site. Therefore, ICs, a SMP, and periodic reviews, as described
under Alternative 2, may be necessary.
ECs (i.e., sheet piling and bulkhead) would be necessary along the perimeter of the Site to maintain stability of the excavation
walls, prevent potential impacts to the railroad tracks, and to prevent inundation from Onondaga Lake, Onondaga Creek and
Ley Creek. Further geotechnical evaluations would be necessary to evaluate sheet pile installation in the vicinity of the
railroad.
It is assumed that the soil/fill material excavated below the groundwater table would need to be dewatered prior to off-Site
transportation and disposal. Treatment of this construction water is anticipated to be necessary; a temporary water treatment
facility would be utilized to treat this construction water. Treated construction water would be managed in a manner and in
accordance with discharge requirements to be determined by NYSDEC during the remedial design phase.
Because additional geotechnical evaluations and discussion and coordination with Onondaga County and railroad operations
would need to be conducted, the remedy depiction illustrated in Figure 13 is conceptual.
Because this alternative would result in contaminants remaining above levels that allow for unrestricted use and unlimited
exposure, CERCLA requires that the remedy for the Site be reviewed at least once every five years.
The estimated construction time of this alternative is five to seven construction seasons.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Capital Cost: $281,150,000
Annual O&M Costs: $57,000
Present-Worth Cost: $281,300,000
COMPARATIVE ANALYSIS OF ALTERNATIVES
The detailed analysis consists of an assessment of the individual alternatives against each of the nine evaluation criteria (see
box below) and a comparative analysis focusing upon the relative performance of each alternative against those criteria. The
first two evaluation criteria are termed "threshold" criteria and must be satisfied for an alternative to be considered for
selection. The next five criteria are "primary balancing" criteria. These are used to make comparisons and to identify the
major tradeoffs between alternatives. The remaining two criteria are "modifying" criteria. These criteria are used in the final
evaluation of the remedial alternatives after the formal comment period and may prompt modification of the preferred remedy
that was presented in the Proposed Plan.
A comparative analysis of these alternatives based upon the evaluation criteria noted below follows.
NINE EVALUATION CRITERIA FOR FEDERAL SUPERFUND REMEDIAL ALTERNATIVES
Overall protection of human health and the environment addresses whether an alternative eliminates, reduces, or controls threats
to public health and the environment through ICs, ECs, or treatment.
Compliance with ARARs evaluates whether the alternative would meet all the applicable or relevant and appropriate requirements of
federal and state environmental statutes and other requirements that pertain to the site or provide grounds for invoking a waiver.
Long-term effectiveness and permanence considers the ability of an alternative to maintain protection of human health and the
environment overtime.
Reduction of toxicity, mobility, or volume through treatment is the anticipated performance of the treatment technologies an
alternative may employ.
Short-term effectiveness considers the period of time needed to implement an alternative and the risks the alternative may pose to
workers, residents, and the environment during implementation.
Implementability is the technical and administrative feasibility of implementing the alternative, including the availability of materials
and services.
Cost includes estimated capital and annual O&M costs, as well as present-worth costs. Present worth cost is the total cost of an
alternative overtime in terms of today's dollar value. Cost estimates are expected to be accurate within a range of+50 to -30 percent.
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State acceptance considers whether, based on its review of the RI/FS Reports and the Proposed Plan, the State supports, opposes,
and/or has identified any reservations with the selected response measure.
Community acceptance will be assessed in the ROD and refers to the public's general response to the alternatives described in the
Proposed Plan and the RI/FS Reports. Comments received on the Proposed Plan are an important indicator of community acceptance.
Overall Protection of Human Health and the Environment
Based on the reasonably anticipated future Site use, including a recreational trail, current human health hazards and risks
associated with recreational use for all receptors are acceptable based on post-HHRA re-evaluations of hazard and risk (see
Table 4). Alternative 1, no action, would not be protective of human health and the environment because it would not actively
address the contaminated soil/fill or groundwater, which pose unacceptable human health and ecological risks. Alternatives
2 through 4 would provide for human health protection relative to potential exposure to soil/fill material through ECs and ICs.
ICs, a SMP, and monitoring the natural attenuation of naphthalene in groundwater included in Alternatives 2 through 4 would
provide protection of human health relative to potential exposure to surface and subsurface soil/fill material, sheens that may
develop during soil excavations, and groundwater for receptors such as construction or utility workers. The SMP would
require special measures to address water during excavation activities. Alternative 2 would provide protectiveness through
placement of clean cover material in 8.2 acres of non-forested wetland and non-forested upland areas, in addition to ICs and
MNA for the groundwater. Alternative 3 would provide protectiveness over 10 acres through removal of surface soil/fill
material within non-forested wetlands, restoration of non-forested wetlands, placement of a soil cover within non-forested
upland areas, ICs, and MNA for the groundwater. Alternative 3 is anticipated to result in some disturbance to the eagle
habitat, since it requires removal of an approximate half-acre area that includes mature trees. Alternatives 2 and 3 would
also include the flexibility to provide added protection (as determined by pre-design soil sampling) through grading/handling
of surface soil/fill material to address additional wetland and/or upland areas, provided that eagle habitat (e.g., mature trees)
is not significantly impacted. Alternative 4 would be the most protective but would also result in the greatest impact to forested
habitat, including the eagle roosting areas, through Site-wide removal of trees.
The soil cover and/or targeted excavation of surface soil as presented in Alternatives 2 and 3 would address SCOs for
Commercial Use and Protection of Ecological Resources where the cover is placed within the non-forested wetland and
upland areas, while preserving as much of the forested bald eagle roosting habitat as possible. In order to consider
contaminant concentrations on a Site-wide basis (including contamination that would remain in the undisturbed forested
areas), an evaluation of Site-wide surface soil AWACs was performed to demonstrate the level of protectiveness that would
be achieved for remedial alternatives relative to one another and to current conditions. Exceedances of Commercial Use
SCOs in surface soil may be present in the forested areas where a soil cover is not being placed, although the AWACs
calculated for the existing conditions and conditions following implementation of Alternatives 2 and 3 illustrate improvement
in average surface soil concentrations as a result of these remedies. With respect to human health, based on this analysis
the surface soil AWACS are below SCOs for Commercial Use for chromium, mercury, 4,4-DDT and total PCBs with no
further remedy implementation (i.e., under Alternative 1). Implementation of Alternatives 2 or3 would further reduce AWACs
for these representative risk and remedy drivers and reduces AWAC values for cadmium to below the corresponding
Commercial Use SCO. Implementation of Alternatives 2 and 3 would also reduce AWAC values for benzo(a)pyrene to
concentrations marginally exceeding the corresponding Commercial Use SCO. Potential exposure risks for human receptors
to residual contamination would be addressed through ECs (e.g., soil cover, fencing/railing) and ICs (e.g., signage,
environmental easements).
In developing ecological remediation goals in sensitive habitats, consideration must be given to the intrusive nature of some
remedial activities and the potential negative impacts resulting from implementation of such remedial activities, particularly
in consideration of the extensive utilization of the Site by bald eagles and the forested habitat present. Exceedances for
Protection of Ecological Resources SCOs may be present in the forested areas where a soil cover is not being placed,
although Alternatives 2 and 3 are expected to reduce average surface soil concentrations below the SCOs for
benzo(a)pyrene. Average levels of total PCBs pre-remediation are below the Protection of Ecological Resources SCO for
PCBs and would be further reduced after implementation of Alternatives 2 or 3. Post-remediation AWACs for cadmium,
chromium, mercury, and 4,4-DDT would potentially exceed SCOs for the Protection of Ecological Resources within the top
two feet of soil, though significant reductions are anticipated under Alternatives 2 and 3.
Under Alternatives 2 and 3, a significant portion of the elevated concentrations of contaminants at the Site would be
addressed, remaining concentrations would be expected to be protective of community impacts to ecological receptors when
the Site is considered in its entirety, and significant habitat alteration and bald eagle disturbance would be avoided. As a
result, Alternatives 2 and 3 are considered to improve protection of ecological exposures. Specifically, further examination
of post-remedy exposure to constituents that would potentially exceed the SCOs for the Protection of Ecological Resources,
indicates that Alternatives 2 and 3 would reduce lowest observed adverse effect level (LOAEL)-based HQs to below 1, or
marginally above 1, for the most sensitive receptor (short-tailed shrew) evaluated in the BERA. Thus, Alternatives 2 and 3
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address protectiveness of anticipated future use and ecological receptors while observing primary tenets of Ecological Risk
Assessment Guidance for Superfund (ERAGS). Biota monitoring would also be performed under Alternatives 2 and 3 to
monitor protectiveness of ecological resources and remedy effectiveness and to determine if additional remedial actions are
necessary.
Consistent with 6 NYCRR-1.8(f) and DER-10.4.2(i), the current, intended, and reasonably anticipated future use of the Site
was considered when selecting SCOs. Alternative 1 would not be consistent with current, intended, and reasonably
anticipated future use of the Site. The soil cover in Alternative 2 would address at least 8.2 acres of non-forested wetland
and upland area surface soil/fill material exceeding SCOs consistent with current, intended, and reasonable anticipated
future use of the Site, while 15.3 acres would not be addressed. The soil coverwith added removal of surface soil/fill material
in Alternative 3 would support the current, intended, and reasonably anticipated future land use, and address at least 9.5
acres of non-forested wetland and upland areas along with 0.5 acres of forested upland, while 13.5 acres would not be
addressed. However, Alternative 3 would impact 0.5 acres of mature trees that are important habitat for the bald eagle
population. Removal of soil/fill material in Alternative 4 would support the current, intended, and reasonably anticipated future
land use and address 23.5 acres of Site area exceeding SCOs; however, it would remove and/or prevent use of the
recreational trail at the Site during the 5-to-7-year construction period and would result in Site-wide clearing of valuable
forested habitat and likely adversely affect the local bald eagle population.
Alternative 1 would not address RAOs related to potential erosion and direct contact with soil/fill material. RAOs for protection
of ecological receptors would be improved via AWACs for Alternatives 2 and 3, although SCOs at certain locations may still
be exceeded. Alternatives 2 and 3 would improve protectiveness of the environment and would provide for additional
protection of human health within non-forested wetland and upland areas and would meet RAOs through the use of soil
covers, which would control potential erosion of, and direct contact with, soil/fill material as well as control the potential
inhalation of dust in these areas. Alternative 3 would provide added protection of human health and the environment within
non-forested wetland areas as compared to Alternative 2 and would meet RAOs through soil covers and the removal of
surface soil/fill material for portions of the Site. ICs, a SMP, and monitoring would provide for continued protection of the
environment and provide a means to evaluate continued protectiveness in Alternatives 2 through 4. Alternatives 2 and 3 also
include biota monitoring for the purpose of assessing ecological protectiveness. Alternative 4 would be protective of human
health and the environment within forested and non-forested wetland and upland areas through removal of accessible
surface and subsurface soil/fill material and would allow for unrestricted use of the majority of the Site by addressing soil/fill
material exceeding SCOs for Unrestricted Use. With the exception of Alternative 4, each of the alternatives would provide
preservation of trees utilized seasonally by bald eagles for roosting.
In summary, since Alternative 1 does not provide protection of human health and the environment, this alternative does not
satisfy this threshold criterion. Alternatives 2 through 4 would satisfy this threshold criterion by providing protection of human
health and the environment. Alternatives 2 through 4 would provide varying degrees for protection of human health and the
environment through ECs and ICs. Alternative 3 is anticipated to directly address more of the Site as compared to Alternative
2, however, this is at the expense of eliminating 0.5 acres of valuable forested habitat. Alternative 4 would provide the
greatest protectiveness. but would result in the most significant impact to forested habitat, including eagle roosting, through
Site-wide removal of trees. Alternatives 2 and 3 are considered reasonably protective of human and ecological receptors by
addressing elevated soil concentrations while preserving the forested habitat, critical to overall Site ecology and utilized by
bald eagles.
Compliance with ARARS
SCOs are identified in 6 NYCRR Part 375, Environmental Remediation Programs, Subpart 375-6, effective December 14,
2006. New York State's Commercial Use and Protection of Ecological Resources SCOs at 6 NYCRR Section 375-6.3(b)
have been identified as an ARAR, TBC, or other guideline to address contaminated surface and subsurface soil3. While
surface soil at the Site contains contaminants at concentrations exceeding Commercial Use SCOs, potential exposure risks
for human receptors to residual contamination would be addressed through ECs (e.g., soil removal/cover, fencing/railing,
etc.) and ICs (e.g., signage, environmental easements). As discussed above under HHRA and Overall Protection of Human
Health and the Environment section, the Revised HHRA and subsequent re-evaluation identified acceptable risks for the
anticipated public use of the Site (e.g., recreational trail).
Because the contaminated soil/fill material would not be actively addressed under Alternative 1, it would not achieve the
SCOs. Under Alternative 2, soil/fill material exceeding SCOs would be addressed within a portion of the non-forested wetland
and upland areas (8.2 of the 23.5-acres) through the installation of a soil cover where accessible and not detrimental to the
3 Protection of Groundwater SCOs are not applicable based on provisions within NYCRR Part 375 (e.g., an environmental easement will
be put in place which provides for a groundwater use restriction; contaminated groundwater at the site is not migrating, or likely to
migrate, off-site).
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environment (e.g., tree removal, disturbance of bald eagles, etc.). In Alternative 3, as compared to Alternative 2, the
installation of a soil cover with the additional removal of surface soil/fill material within the western portion of the non-forested
wetland areas and restoration with clean material would address soil exceeding SCOs within the additional non-forested
wetland (10 of the 23.5-acres) although this would require the removal of some forested habitat. While some areas exhibiting
soil concentrations greater than the Protection of Ecological Use SCOs may remain under Alternatives 2 and 3 they are
expected to be protective of community impacts to ecological receptors throughout the Site, based on AWAC calculations,
coupled with the avoidance of significant habitat alteration and bald eagle disturbance. For Alternative 3, should reuse of
material be incorporated into the remedy, consideration for re-exposure and long-term management would be addressed in
the remedial design and O&M requirements. Alternative 4 would address surface and subsurface soil exceeding Unrestricted
Use SCOs within the footprint of the Site, including the forested and non-forested areas. Alternatives 2, 3 and 4 would
address exceedances of New York State Class GA guidance value for naphthalene through natural attenuation.
No location- or action-specific ARARs were identified for Alternative 1 (No-Action alternative). Construction methods and
safety procedures would be implemented to adhere to the location- and action-specific ARARs that are pertinent to
Alternatives 2 through 4. Specifically, ICs would be implemented in Alternatives 2 through 4 in general conformance with
NYSDEC's guidance DER-33 (see https://www.dec.nv.aov/docs/remediation hudson pdfZder33.pdf) and EPA guidance
(see https://www.epa.qov/superfund/superfund-institutional-controls-quidance-and-policv). Additionally, Alternatives 2 and 3
would mitigate potential erosion and exposure to soil/fill material where soil covers are installed and would be implemented
in general conformance with NYSDEC's DER-10 (see https://www.dec.nv.qov/requlations/67386.html). Procedures would
be implemented to adhere to the location-specific ARARs related to federal and state requirements, such as for the portion
of the Site that is a designated wetland for cultural, archeological, and historical resources. Additionally, proposed actions
would be conducted in a manner consistent with Fish and Wildlife Coordination Act requirements for the protection of
Onondaga Lake and for areas proximate to Onondaga Lake. As necessary, actions under Alternatives 2 through 4 would be
implemented in general conformance with state and federal wetland and floodplain assessment requirements in addition to
navigable waterway and New York State Railroad Law. Specifically, wetland permitting and mitigation requirements, such
as those in 6 NYCRR Part 663, Article 15 and 6 NYCRR Part 608 would be considered during the remedial design phase.
With respect to action-specific ARARs, the soil cover, wetland restoration, and excavation related activities would be
conducted consistent with applicable standards including RCRA Subtitle D, 40 CFR Part 358.60 - Closure Criteria, 40 CFR
Part 257 - Criteria for Classification of Solid Waste Disposal Facilities and Practices, and 40 CFR Parts 264 and 265, Subpart
N - Landfills and 6 NYCRR 360 - Solid Waste Management Facilities, earth moving/excavation activities would be conducted
consistent with air quality standards including 6 NYCRR 200-203, 211-212 - Prevention and Control of Air Contamination
and Air Pollution, and 40 CFR Part 50.1 - 50.12 - National Ambient Air Quality Standards, and transportation and disposal
activities would be conducted in accordance with applicable state and federal requirements including 6 NYCRR 364 - Waste
Transporter Permits and 49 CFR 107, 171-174 and 177-179 - Department of Transportation Regulations, by licensed and
permitted haulers, with disposal at permitted facilities. Under Alternative 4, construction waterwould be managed in a manner
and in accordance with discharge requirements to be determined by NYSDEC during the remedial design phase.
Location-specific ARARs related to habitat protection, including the Federal Bald and Golden Eagle Protection Act (16 U.S.C.
668 et seq), USFWS National Bald Eagle Management Guidelines, Conservation Plan for Bald Eagles in New York State,
and 6 NYCRR 182, provide requirements and guidance regarding the protection of bald eagle habitat, including the "take
and disturbance" of bald eagles, and limiting activities that may alter communal roost sites and foraging areas. Alternatives
2 and 3 can be implemented while preserving the valuable tree habitat, with minimal removal of low- to mid-story vegetation
and retaining larger-scale vegetation at the Site, whereas Alternative 4 would require the Site-wide removal of trees currently
providing high-value forested habitat used as winter eagle roosting habitat.
Long-Term Effectiveness and Permanence
Alternative 1 would involve no active remedial measures and, therefore, would not be effective in eliminating the potential
exposure to contaminants in the soil/fill material and groundwater. Unlike Alternative 1, Alternatives 2 through 4 would provide
varying levels of long-term effectiveness and permanence. Alternative 4 provides the most reduction in residual risk, however,
it requires removal of trees that enhance the overall value of Site habitat and provide eagle roosting habitat. Alternatives 2
and 3 would support the anticipated future use of the Site for a multi-use recreational trail while preserving trees utilized
seasonally by bald eagles for foraging and roosting. Alternative 3 would provide some additional level of long-term
effectiveness and permanence relative to Alternative 2 as it would result in a greater acreage of remediation although limited
tree removal would be required. Potential human health risks associated with Alternatives 2 through 4 would be reliably
addressed through ECs (e.g., soil removal/cover, fencing/railing) and/or ICs (e.g., signage, environmental easements). Each
alternative would result in minimal long-term fuel/energy consumption, greenhouse gas emissions, and impacts to water,
ecology, workers, or the community associated with long-term maintenance of the remedies.
The long-term performance of Alternatives 2, 3 and 4 could potentially be impacted as a result of erosion of the soil covers
during severe storms/weather events and associated flooding that may be more frequent or severe as a result of climate
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change. These effects would be noted and documented as a result of inspections which would be conducted in accordance
with the SMP, particularly after flood events, and mitigated as may be necessary and appropriate.
Reduction in Toxicity. Mobility, or Volume Through Treatment
Since none of the alternatives involve active treatment, there would be no reduction in toxicity, mobility, or volume in soil/fill
material through treatment provided under Alternatives 1 through 4. Reduction of mobility (i.e., potential erosion) of
contaminants in surface soil/fill material would be achieved through the installation of soil covers in select areas under
Alternatives 2 and 3. Alternative 4 would provide the greatest reduction in toxicity, mobility, and volume through the excavation
and off-Site management of contaminated surface and subsurface soil/fill material. Reduction of toxicity, mobility and volume
of representative constituents in surface soil/fill material would not be due to treatment. Under each alternative, natural
attenuation is expected to reduce groundwater naphthalene concentrations within a reasonable time frame.
Short-Term Effectiveness
Alternative 1, the no-action alternative, does not include active remedial components, and, therefore, would not present any
potential adverse impacts to workers and the community. Alternatives 2 through 4 would be implemented and constructed
using proper protective equipment to manage potential risks to on-Site workers, and proper precautions and monitoring to be
protective of the general public and the environment.
Because no action would be performed under Alternative 1, there would be no implementation time. Alternative 2 is
anticipated to be completed within one construction season, while Alternative 3 is anticipated to be completed within one to
two construction seasons. Due to the volume of surface and subsurface soil/fill material exceeding Unrestricted Use SCOs,
Alternative 4 would require a longer timeframe to attain RAOs in the forested and non-forested wetland, as excavation is
estimated to take place over five to seven construction seasons.
Impacts to the community resulting from the implementation of Alternatives 2 and 3 would primarily be due to increased truck
traffic and increased noise for the duration of construction for the soil cover under Alternative 2 and contaminated surface
soil/fill material excavation and soil cover construction under Alternative 3. Additional truck traffic and noise is anticipated for
the duration of Alternative 3B due to off-Site transport of excavated surface soil/fill material. Alternative 4 would have
significantly increased truck traffic, noise, dust and emissions compared to Alternatives 2 and 3 due to the need to clear the
Site of trees prior to surface and subsurface soil/fill material excavation for the five- to seven-year duration of construction.
The implementation of the clearing, surface and subsurface soil/fill material excavation and off-Site disposal included in
Alternative 4 would result in far greater impacts to the community, including substantially increased traffic, dust and emissions
as well as increased noise, although mitigative measures would be implemented to the extent practicable to limit the impacts
of noise, dust and traffic. Additionally, Alternative 4 would involve the addition of sheeting or other stabilization measures
along the railroad tracks and bulkhead installation along the shoreline during construction.
As it relates to traffic, transportation of cover material to the Site is anticipated to result in approximately 2,450 truck trips
under Alternative 2, while transport of cover material, excavation of surface soil/fill material, on-Site consolidation and wetland
restoration under Alternative 3A (on-Site reuse of excavated material) is anticipated to result in approximately 2,650 truck
trips. Alternative 3B (off-Site disposal of excavated material) is anticipated to result in an additional 1,550 truck trips for off-
Site disposal of excavated soil/fill material when compared to Alternative 3A. Excavation of contaminated surface and
subsurface soil/fill material, off-Site transportation and disposal and wetland restoration included in Alternative 4 would require
approximately 56,000 truck trips over four years, resulting in the greatest impact on traffic and potentially adverse effects on
local air quality. The increased traffic associated with construction of Alternatives 3 and 4 would result in a potential increase
in safety-related risks and impacts to CSX Railroad operations due to off-Site transport of excavated soil/fill material requiring
additional crossing and coordination with railroad traffic proximate to the Site.
With respect to sustainability, there is an environmental footprint inherent in implementation of each alternative as it relates
to construction and operation, as well as impacts to the community (as described above). The implementation of the
excavation and off-Site disposal included under Alternative 4 would result in far greater direct emissions and fuel consumption,
as compared to importing construction materials and construction of the soil cover included in Alternative 2 and soil cover,
surface soil/fill material excavation and management of excavated material included in Alternative 3. Construction of
Alternatives 2 and 3 would result in greater greenhouse gas impacts than Alternative 1 and construction of Alternative 4 would
result in substantially greater greenhouse gas impacts than the other alternatives. Consistent with NYSDEC and EPA policies
on green remediation, sustainability considerations will not be used to justify implementation of the no-action alternative or a
less comprehensive alternative when a more comprehensive remedy is called for, appropriate, and feasible.
Worker and community risks during remedy implementation are significantly greater for Alternative 4 compared to Alternatives
2 and 3. Specifically, the added risks to workers and the community, the added duration to achieve RAOs, the significant
19
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traffic impacts to the community, and the significantly greater environmental footprint associated with Alternative 4 would be
less effective in the short-term relative to Alternatives 2 and 3.
Implementabilitv
Alternative 1 would be the easiest alternative to implement, as there are no activities to undertake.
Alternatives 2 through 4 would employ technologies (soil covers and excavation) known to be reliable and that can be readily
implemented. Equipment, services and materials needed for these alternatives are readily available. Monitoring the
effectiveness of the soil covers under Alternatives 2 and 3 would be accomplished through inspections and maintenance to
verify continued cover integrity, visual signs of erosion, and condition of the soil cover. Areas of wetland restoration/mitigation
under Alternatives 2 and 3 would be monitored for signs of erosion, condition ofvegetation, and presence of invasive species.
A SMP and periodic reviews would also be implemented under Alternatives 2 and 3 for the purpose of monitoring and
documenting remedy effectiveness, managing remaining contamination, and implementing measures as needed to prevent
human exposures, in addition to groundwater monitoring as a means to assess potential changes in groundwater
concentrations.
The actions under Alternatives 2 through 4 would be administratively feasible. They would require access across the CSX
Railroad tracks and work in proximity to the railroad, Onondaga Lake, Onondaga Creek, and Ley Creek. Alternatives 2
through 4 would also require coordination with other agencies, including NYSDEC, New York State Department of
Transportation, NYSDOH, USEPA, USFWS, City of Syracuse, and CSX Railroad. Coordination with Onondaga County
would also be necessary since it is the property owner and for maintenance of the multi-use recreational trail.
Alternative 3, which includes Alternatives 3A (on-Site reuse of excavated material) and 3B (off-Site disposal of excavated
material), would be more difficult to implement than Alternative 2. Specifically, a geotechnical evaluation concluded that
global stability associated with excavation in the vicinity of the railroad tracks under Alternative 3 is anticipated to limit
implementability of this alternative. CSX Railroad concurrence with remedial design of the cover and excavation elements
included in this alternative would be required. Thus, stability concerns may affect the implementability of this alternative.
Additionally, Alternative 3A is less implementable than Alternative 2, because it is necessary to evaluate and identify on-Site
reuses to manage the additional spoils anticipated during implementation of Alternative 3A. Alternative 3B is less
implementable than Alternative 2 because off-Site transport and disposal included under Alternative 3B would result in
impacts to CSX Railroad operations requiring additional crossing and coordination with railroad traffic proximate to the Site.
In addition, landfill disposal capacity would require confirmation prior to implementation of Alternative 3B.
Alternative 4 would be the most difficult to implement in comparison to Alternatives 2 and 3 for the following reasons:
• There are significant implementability limitations associated with the excavation, transportation, and disposal (capacity)
for approximately 400,000 cy of soil/fill material.
• There are challenging construction water management and greater slope stability concerns relative to the active CSX
Railroad lines when compared to the shallow excavations included under Alternative 3, which would require CSX
concurrence. Construction water management using a temporary treatment system is anticipated to be significant during
the excavation, as large water volumes are anticipated due to the presence of heterogenous and permeable fill and
excavations in proximity of the on-Site wetlands, Onondaga Lake, Onondaga Creek, and Ley Creek. Excavations in the
vicinity of active railroads, subsurface utilities, and surface water bodies are anticipated to limit the implementability of
excavations in certain areas and require the costly design, procurement, and installation of shoring. As part of the
supporting geotechnical evaluations, installation of sheet piling would be evaluated and installed, if required, to support
excavations in these areas.
• There are also significant transportation concerns related to Alternative 4. The estimated volume requiring disposal is
400,000 cy (estimated to be approximately 615,000 tons). Based on a daily production rate of 500 cy per day for 10
months of the year, it is estimated that up to approximately 100,000 cy of material could be shipped off-Site each year in
7,000 truckloads (up to 35 truckloads per day) with an approximately equivalent number of trips being required for
restoration, over a duration of 5 to 7 years. During a 10-hour workday, this would equate to approximately one truck
entering or leaving the Site every 10 minutes. In addition to the potentially significant adverse effects on local air quality
and community traffic patterns, traffic of this magnitude is anticipated to result in significant adverse effects on conditions
of roadways.
• Ecological considerations limit the implementability of Alternative 4, including the removal of trees providing valuable
forested habitat and that are utilized by bald eagles. The Site serves as a winter roost site and concentration area for a
large number of bald eagles; a State-listed Threatened species. Alternative 4 would require the disturbance of 23.5 acres
and the Site-wide removal of trees that serve as an important habitat, and it is anticipated it would take several decades
to restore.
20
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Cost
The estimated capital, annual O&M, and present-worth costs for each of the alternatives are presented in the table below.
The present-worth costs were calculated using a discount rate of seven percent and a 30-year time interval for post-
construction monitoring and maintenance period (although O&M would continue as needed beyond the 30-year period, 30
years is the typical period used when estimating costs for a comparative analysis).
Alternative
Capital Cost
Annual O&M Cost
Total Present Worth Cost
1 - No Action
$0
$0
$0
2 - Soil Cover in Select Areas, Wetland
Restoration, Biota Monitoring, and MNA
$7.5 million
$181,000
$8.3 million
3A - Surface Excavation with On-Site Reuse
and Soil Cover/Wetland Restoration on
Perimeter and Interior Areas, Biota Monitoring,
MNA, with Limited Tree Removal
$21.1 million
$185,000
$21.9 million
3B - Surface Excavation with Off-Site Disposal
and Soil Cover/Wetland Restoration on
Perimeter and Interior Areas, Biota Monitoring,
MNA, with Limited Tree Removal
$26.2 million
$185,000
$27.0 million
4 - Full Removal and Off-Site Disposal with
Wetland Restoration and MNA
$281.2 million
$57,000
$281.3 million
State Acceptance
NYSDOH has reviewed this Proposed Plan and concurs with the preferred remedy detailed below.
Community Acceptance
Community acceptance of the preferred alternative will be addressed in the ROD following review of the public comments
received on the Proposed Plan.
PREFERRED REMEDY
Based upon an evaluation of the various alternatives, NYSDEC and EPA recommend Alternative 2 - Soil Cover in Select
Areas, Wetland Restoration, Biota Monitoring, and MNA as the preferred alternative. The preferred alternative includes the
installation of an 8.2-acre 2-foot-thick soil cover in select areas of the Site, as well as biota monitoring to evaluate the
protectiveness of ecological resources and remedy effectiveness. To restore wetland areas, contaminated soil may be
removed prior to cover placement to a depth necessary to preserve wetland conditions and functions. Monitoring the natural
attenuation of naphthalene in the groundwater, development of a SMP, implementation of ICs, and long-term maintenance
and monitoring are also components of the proposed remedy. A conceptual depiction of the preferred remedy is presented
in Figure 11.
The remedial footprint is targeted to reduce ecological exposure within the cover footprint and to defer remediation in the
forested SYW-12 habitat to preserve current bald eagle habitat. Specifically, damage to root zones or removal of mature trees
used for eagle roosting would be avoided under the preferred Alternative 2.
A surface soil pre-design investigation and tree survey would be performed to evaluate the addition of up to seven areas,
totaling 2.2 acres, to the remediation footprint. The areas for consideration include two areas within the forested wetland
characterized by scrub vegetation on the northern portion of the Site, four areas within the non-forested wetland on the
western portion of the Site, and one upland forested area on the southern portion of the Site (purple outlined areas on Figure
11). Should surface soil sampling and the tree survey indicate that elevated surface soil/fill material contaminant
concentrations are present and large trees would not need to be removed or disturbed (e.g., within the drip-zone of the large
trees), soil excavation and backfilling of these areas with clean material would be considered during the design.
21
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To minimize loss of wetland acreage or function, wetland conditions and functions would be integrated into the areas where
the cover would be placed within the current wetland footprint. To improve the success of the restored wetlands, the remedial
design would consider excavation and/or grading to allow for continued wetland functions and values. An evaluation would
be conducted as part of the cover design to promote sufficient flooding and saturation to facilitate the development of wetland
soils and hydrology appropriate for native plants and other habitat in conjunction with grading/soil profile design such that
wetland conditions and functions are addressed. Where the water budget and/or grading cannot replace wetland conditions
or functions, additional mitigation measures would be included during the design.
The soil covers would also be installed to support and preserve existing mature trees present proximate to the proposed
cover to allow for future tree succession. Additional tree-planting may be performed as part of restoration. Where cover
material is placed, a demarcation layer would be evaluated during the remedial design to delineate the boundary between
the contaminated soil/fill material and the soil cover and would be compatible with the wetland or tree growth, as necessary.
The demarcation layer would provide evidence of cap erosion and provide a warning that contaminated material may exist
below the demarcation layer.
Excavated soil reuse options and limitations (e.g., within wetland areas), impacts to the bald eagle habitat, and the final
wetland restoration approach, including opportunities to improve wetland functions and values, planting of trees and
sustainable remediation principles would be further evaluated during the pre-design and design phases. Should reuse of
excavated/graded/handled materials not be possible at the Site following remedial design evaluations, the material would
need to be managed off-Site.
Because of the Onondaga County trail construction, geotechnical concerns, and discussion and coordination with railroad
operations, the boundaries of the remedy illustrated in Figure 11 are conceptual. It is anticipated that there would be no
excavation in wetland areas adjacent to the railroad based on stability concerns. Mitigation would be necessary where
construction results in a loss of wetland acreage or function and wetland conditions cannot be returned. The extent of the
cover would be revisited during the design phase based on pre-design sampling and other activities and in consideration of
the trail alignment. Onondaga County has included signage requiring recreational users to remain on the trail in the design
for the multi-use recreational trail. The potential need for additional measures (e.g., fencing/railing, maintaining dense
vegetation along the trail, improved signage, and/or sampling) would be reviewed during the design phase and based on
management of the trail.
Biota monitoring would be performed to evaluate remedy effectiveness and assess protectiveness of ecological receptors. A
baseline sampling program, consisting of two sampling events, would be implemented, with subsequent sampling events
following remedy implementation using an adaptive, data-driven approach (e.g., years 3 and 5). A field assessment of Site
vegetative community composition (e.g., diversity, richness, invasive species evaluation) and qualitative wildlife community
observations would be performed to support the biota monitoring program. The field assessment would also include an
evaluation of Site trees, specifically trees that serve as roosts for bald eagles, for overall health and preservation. Specific
sample locations, species, sample and analytical methods, and frequencies would be assessed and established during the
remedial design. It is assumed that the monitoring program would consist of analysis of soil invertebrate and small mammal
tissue, with collection of co-located surface soil/fill material samples for laboratory analysis of chemical constituents. The
details related to the scope of biota sampling would be developed during the remedial design phase.
Periodic sampling and analysis of groundwater would be included as a means of detecting changes in groundwater
concentrations and monitoring the natural attenuation of naphthalene in groundwater. Natural attenuation of other
contaminants may be evaluated, if necessary. Specific monitoring locations, parameters, and frequencies would be
established during remedial design. For cost estimation purposes, it was assumed that the monitoring program would consist
of semi-annual sampling often monitoring wells with analyses for VOCs, SVOCs (including PAHs), metals, mercury, cyanide,
and cations/anions. However, the specific number of wells and analyses will be determined during remedial design or site
management.
The cover would require routine maintenance and inspection to maintain integrity and proper function.
ICs in the form of environmental easements and/or restrictive covenants would be used to limit land use to commercial
(including passive recreational), as appropriate, prevent the use of groundwater without approved treatment and require that
any intrusive activities on the Site would be conducted in accordance with a NYSDEC-approved SMP, which would include
the following:
• Institutional and Engineering Control Plan that identifies all use restrictions and ECs for the Site and documents the
steps and media-specific requirements necessary to ensure the following ECs and ICs remain in place and effective:
o environmental easements and/or restrictive covenants described above;
22
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o soil cover described above;
o future remediation/management of areas where no cover is present at the Site (e.g., due to erosion or
changes in vegetation);
o excavation plan that details the provisions for management of future excavations on the Site ;
o descriptions of the provisions of the ICs, including any land use or groundwater use restrictions;
o a soil vapor intrusion evaluation will be completed and appropriate actions implemented for any on-Site
buildings, if they were to be constructed;
o provisions for the management and inspection of the identified ECs;
o protection measures to be implemented while conducting any needed subsurface soil disturbance activities
to prevent exposure to sheens or blebs of NAPL;
o maintaining Site access controls and NYSDEC notification; and
o steps necessary for periodic reviews and certification of the ECs and/or ICs.
• Monitoring Plan to assess the performance and effectiveness of the remedy. Elements of the monitoring plan will
include groundwater and biota monitoring, and success or repair of habitat and wetland restoration/mitigation. The
monitoring plan will include assessing restoration success and repair, wetland delineation, and invasive species
management during restoration. The final monitoring program would be established during the design.
Because this alternative would result in contaminants remaining above levels that allow for unrestricted use and unlimited
exposure, CERCLA requires that the remedy for the Site be reviewed at least once every five years.
Green remediation techniques, as detailed in NYSDEC's Green Remediation Program Policy - DER-31 and EPA's Region 2
Clean and Green Policy, would be considered during remedy implementation to reduce short-term environmental impacts.
Green remediation best practices such as the following may be considered:
• Use of renewable energy and/or purchase of renewable energy credits to power energy needs during construction and/or
O&M of the remedy;
• Reduction in vehicle idling, including both on and off-road vehicles and construction equipment during construction and/or
O&M of the remedy;
• Design of the soil cover, to the extent possible, to be usable for alternate uses, require minimal maintenance (e.g., less
mowing), allow for infiltration of storm water and/or be integrated with the planned use of the property;
• Maximizing habitat value and creating habitat when possible;
• Reuse of material that would otherwise be considered a waste; and
• Use of Ultra Low Sulfur Diesel.
BASIS FOR THE REMEDY PREFERENCE
Alternative 1 does not satisfy the threshold criteria, because it does not provide protection of human health or the environment
or provide a means to attain ARARs. Alternatives 2 and 3 provide a balance between addressing the human health and
ecological risks and protecting bald eagle habitat at the Site and addressing the ARARs. Alternative 4 satisfies the threshold
criteria, however, this alternative would significantly impact the bald eagle habitat at the Site.
As described below, Alternative 2 is more effective at achieving the primary balancing criteria (long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume through treatment; short-term effectiveness; implementability; and cost)
than would be achieved under Alternatives 3 or 4.
Alternatives 2 and 3 would provide similar degrees of protectiveness relative to potential exposure to contaminated soil/fill
material and groundwater, although surface soil SCO exceedances may be present in areas where cover is not being placed.
Alternatives 2 and 3 are also comparable in terms of the primary balancing criterion, reduction of toxicity, mobility, or volume
through treatment (neither alternative employs treatment) and both would support the anticipated future use of the Site for a
multi-use recreational trail, while preserving trees utilized seasonally by bald eagles for foraging and roosting. Alternative 3
would provide some additional long-term effectiveness and permanence relative to Alternative 2, as it would result in the
remediation of a greater acreage of wetland area, though this would result in impacts to the valuable forested habitat.
However, relative to Alternative 3, Alternative 2 would better meet the primary balancing criteria for implementability, short-
term effectiveness, and cost, as Alternative 3 would potentially present geotechnical stability issues for the nearby CSX
Railroad that limit its implementability, may require an additional construction season to implement resulting in more potential
community impacts, and would require an additional cost expenditure of approximately $13-19 million.
Site-wide excavation of contaminated soil/fill material under Alternative 4 would present greater geotechnical stability
concerns along the railroad tracks as compared to Alternative 3. When considering the primary balancing criteria, Alternative
23
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4 does not compare favorably because this alternative is significantly less implementable than Alternatives 2 and 3 and cannot
be constructed without significantly impacting the forested habitat, including the bald eagle habitat. Furthermore, Alternative
4 would involve disturbing a substantial quantity of soil requiring significant water management and material transportation
and would involve challenges with slope stability and would likely have impacts on nearby railroad operations. As a result of
the additional construction challenges under Alternative 4, the alternative would take significantly longer to implement, and
the Alternative 4 cost is more than an order of magnitude greater than the costs for Alternatives 2 and 3.
Overall, while satisfying the threshold criteria, Alternative 2 best satisfies the primary balancing criteria, as it is more
implementable than Alternatives 3 and 4 and can be constructed with less short-term impacts to the community and to the
CSX Railroad. In addition, Alternative 2 is less costly than Alternatives 3 and 4.
Based on information currently available, NYSDEC and EPA believe that the preferred alternative meets the threshold criteria
and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria.
NYSDEC and EPA expect the preferred alternative to satisfy the following statutory requirements of CERCLA §121 (b): 1) be
protective of human health and the environment; 2) comply with ARARs; 3) be cost-effective; 4) utilize permanent solutions
and alternative treatment technologies or resource recovery technologies to the maximum extent practicable; and 5) satisfy
the preference for treatment as a principal element (or justify not meeting the preference).
24
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FIGURE 1
MAP LOCATION
HONEYWELL INTERNATIONAL INC.
WASTEBED B / HARBOR BROOK
GEDDES AND SYRACUSE, NY
OU-1 LOCATION
SEPTEMBER 2018
1163.61858
1:24,000
[WASTEBEDS.1 -8
ON ON DAG All/A KE
SEMET
PONDS
LAKESHORE AREA
WILLIS
AVE
, r*— -.riir * V,', I '
iSPENN-CAN PROPERTY
, w
¦ AOS#1
RAILROAD AREA
AOS#2
O'BRIEN & GERE ENGINEERS, INC.
-------
¦A sadio Towers
"J (WHEN) 6
Fort Ste Mari^
Oe Gannentaha
Sewage
Disposal
MacArthur
Stadium,.
Lights
,/Co«w«yor
gf Sewage
(ty Disposal /
¦Kort h
Smith
Map Scale: 1:1:24,000;
Map Center: 76°10'33"W 43°4'17"N
SITE LOCATION
HONEYWELL INTERNATIONAL INC.
2 ooo SYW-12 PROPOSED REMEDIAL ACTION PLAN
_J Feet SYRACUSE, NEW YORK
FIGURE 2
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
WESTERN NON-FORESTED
WETLrA N DSjTOTA L»A R E A*=T1.3
EASTERN NON-FORESTED
lWETLfANDSjTOTAL5AREA = 5.2
CSX RAILROADTKACIg;
CSX RAILROAtfJR^21S
IrWihMW
NOTE:
THE WETLAND DELINEATION IS BASED ON A
2018 DELINEATION TO REEVALUATE WETLAND
BOUNDARIES BETWEEN CSX RAILROAD TRACKS
AND ONONDAGA CREEK (ANCHOR QEA 2018).
FIGURE 3
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
SITE PLAN
HONEYWELL INTERNATIONAL INC.
SYW-12 PROPOSED REMEDIAL ACTION PLAN
SYRACUSE, NEW YORK
0 125 250
1 I 1 Feet
IZ3 FORESTED UPLAND (7.4 AC) ¦ NONFORESTED WETLAND (6.5 AC)
1Z2NONFORESTED UPLAND (3.0 AC) QSITE BOUNDARY
~ FORESTED WETLAND (6.6 AC)
-------
1220 Meters
4000 Feet
IU>eka wav
Mail I tartan
; Beach
* Rtiiusaul
Bt-ar-K
Chestn
4se >.
Lake View
trtfjx IHt
Faii-iT;it>uucLs
CFfiinnonii
Figure 4. 1898 15-minute Syracuse East USGS quadrangle, with approximate area of the SYW-12 Site
highlighted.
-------
IS Program.Office,-Westchester Counfy'GI
0.01JNI
Mdra
irosfal
:hbIwsd-io
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-18
HB-WSD-12
NOTE:
COMMERCIAL SCO= 9.3 mg/kg
POGW SCO= 7.5 mg/kg
ECO SCO= 4.0 mg/kg
J = ESTIMATED VALUE
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS
HUMAN HEALTH RISKASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
ID FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < ECO SCO
| EXCEEDED ECO SCO
~ EXCEEDED ECO AND POGW SCO
~ EXCEEDED ECO, POGW AND COMMERCIAL SCO
DEPTH
0-6"
6"- 1'
V-2
CADMIUM
RESULT IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 5
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
wm
soy®®
i'QIS Program.Qffice^Westchester CounfyljIS
o noil
iOwSI
PSWSD-10
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
WMMMmSMMBMm
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-14
HB-WSD-18
HB-WSD-12
NOTE:
COMMERCIAL SCO= 1,500 mg/kg
POGW SCO= N/A
ECO SCO= 41 mg/kg
J = ESTIMATED VALUE
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS .
HUMAN HEALTH RISK ASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
r~t
LEGEND
ID FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < ECO SCO
¦ EXCEEDS ECO SCO
I I EXCEEDS BOTH ECO AND COMMERCIAL SCO
DEPTH
0-6"
6"-r
V - 2'
CHROMIUM
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 6
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
i'QIS Program.Office,BWestchester CounfyljIS
:hbIwsd-io
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
mmimmmmwiBmwm
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-18 a\
HB-WSD-14
HB-WSD-12
HB-WSD-04
NOTE:
COMMERCIAL SCO= 2.8 mg/kg
POGW SCO= 0.73 mg/kg
ECO SCO= 0.18 mg/kg
J = ESTIMATED VALUE
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS .
HUMAN HEALTH RISK ASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
150
I Feet
SOIL ANALYTICAL RESULTS
I FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
~ < ECO SCO
LI EXCEEDED ECO SCO
~ EXCEEDED ECO AND POGW SCO
~ EXCEEDED ECO, POGW AND COMMERCIAL SCO
DEPTH
0-6"
6" - V
1' - 2'
MERCURY
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 7
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
0.01JWI
Mdra
irosfal
:hbIwsd-io
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-18 a\
HB-WSD-14
HB1WSBI12
-HB-WSD-04
NOTE:
COMMERCIAL SCO= 1.0 mg/kg
ECO SCO= 2.6 mg/kg
POGW SCO= 22 mg/kg
J = ESTIMATED VALUE
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS
HUMAN HEALTH RISKASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
ID FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < COMMERCIAL SCO
¦ EXCEEDED COMMERCIAL SCO
[ ] EXCEEDED ECO AND COMMERCIAL SCO
~ EXCEEDED ECO, POGW AND COMMERCIAL SCO
DEPTH
0-6"
6" - 1'
V-2
BENZO(A)PYRENE
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 8
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
mmm
IS Program.Office,^Westchester Counfy'Gl
0.01JNI
Mdra
jpfehi
:hbIwsd-io
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
HB-WSD-25
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-24
mmmimmmwmwm
HB-WSD-10
HB-WSD-17
HB-WSD-11
HB-WSD-18 ~
HB-WSD-12
NOTE:
COMMERCIAL SCO= 1.0 mg/kg
ECO SCO= 1,0 mg/kg
POGW SCO= 3.2 mg/kg
ND = NON-DETECT RESULT BELOW THE DETECTION LIMIT
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS .
HUMAN HEALTH RISK ASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
ID FORESTED UPLAND
~ DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < ECO SCO
1 j EXCEEDED ECO AND COMMERCIAL SCO
¦ EXCEEDED ECO, COMMERCIAL AND POGW SCO
DEPTH
0-6"
6" -1'
r -2'
TOTAL PCB
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 9
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
PSWSD-10
SAMPLE WITHIN DELINEATED NON-FORESTED WETLAND
SAMPLE WITHIN DELINEATED FORESTED WETLAND
HB-WSD-i 5
HB-WSD-23
;o o:4rJiaar.^^_k
°.°7j r^..
0.02J I ""HB-WSD*09 a
HB-WSD-07
NOTE:
ECO SCO= 0.0033 mg/kg
COMMERCIAL SCO= 47.0 mg/kg
POGW SCO= 136 mg/kg
ND = NON-DETECT RESULT BELOW THE DETECTION LIMIT
J = ESTIMATED VALUE
JN = ESTIMATED, UNCONFIRMED VALUE
HB-WSD-13
HB-WSD-05
HB-WSD-08
HB-WSD-01
COMMERCIAL, PROTECTION OF ECOLOGICAL
RESOURCES (ECO), AND PROTECTION OF
GROUNDWATER (POGW) SOIL CLEANUP OBJECTIVES
(SCOS) ARE BASED ON 6 NYCRR PART 375-6.8(B)
RESTRICTED USE SCOS
HUMAN HEALTH RISK ASSESSMENT (HHRA) ESTIMATED
ACCEPTABLE RISKS TO HUMAN RECEPTORS UNDER
ANTICIPATED SITE USE.
LEGEND
ID FORESTED UPLAND
DELINEATED FORESTED WETLAND
~ DELINEATED NON-FORESTED WETLAND
A SOIL SAMPLE
150
I Feet
SOIL ANALYTICAL RESULTS
~ < ECO SCO
' EXCEEDED ECO SCO
EXCEEDED ECO AND COMMERCIAL SCO
~ EXCEEDED ECO, POGW AND COMMERCIAL SCO
DEPTH
0-6"
6" - 1'
1'-2'
4-4-DDT
RESULTS IN SURFACE SOIL (MG/KG)
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASIBILITY STUDY
SYRACUSE. NY
FIGURE 10
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
CSX RAILROADin^gS
I ENGINEERED COVER IN NON-FORESTED AREA I
- PERCHED WETLAND COVER (7.5 ACRES)
. -
: j ENGINEERED SOIL COVER IN NON-FORESTED AREA
^ - UPLAND VEGETATED SOIL
COVER (0.7 ACRES)
UNDISTURBED EAGLE ROOSTING HABITAT
UNDISTURBED FORESTED HABITAT (15.3 ACRES)
¦SSra %\ M
• m
ALSO INCLUDES:
- WETLAND RESTORATION/MITIGATION
- GROUNDWATER MONITORING
- MONITORED NATURAL ATTENUATION
- ON-SITE REUSE AND/OR OFF-SITE DISPOSAL OF
EXCAVATED SOIL/FILL MATERIAL
- INSTITUTIONAL CONTROLS ^
- BIOTA MONITORING
- PRE-DESIGN SOIL SAMPLING AND TREE SURVEY
f j , w i iy«i
IrWihMW
FIGURE 11
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
PERCHED WETLAND COVER (7.5 AC)
l""isiTE BOUNDARY
POTENTIAL ADDITIONAL REMEDIAL
AREAS (E.G., BASED ON SOIL
SAMPLING, TREE SURVEY)
SYW-12 ALTERNATIVE 2
ENGINEERED COVER ON PERIMETER AREA (8.2 ACRES),
WETLAND RESTORATION I CREATION, BIOTA MONITORING, AND MNA
HONEYWELL INTERNATIONAL INC.
SYW-12 PROPOSED REMEDIAL ACTION PLAN
SYRACUSE, NEWYORK
POTENTIAL FUTURE TRAIL
EXTENSION
PLANNED RECREATIONAL TRAIL
ALIGNMENT
UPLAND VEGETATED SOIL COVER
(0.7 AC)
125 250
I 1 Feet
-------
I UNDISTURBED HABITAT
UNDISTURBED FORESTED HABITAT (13.5 ACRES) I
SURFACE EXCAVATION I WETLAND
l RESTORATION IN PERIMETER AND INTERIOR AREAS
RESTORED NON-FORESTED WETLAND (6.5 ACRES)
REQUIRES LIMITED DISTURBANCE / RESTORATION OF |
FORESTED HABITAT (0.5 ACRES)
I ENGINEERED SOIL COVER IN NON-FORESTED AREA
- UPLAND VEGETATED SOIL
COVER (3 ACRES)
jP|: ,
« * "Jm S3
Program Gf$c^Westcfyester County GlSafl
\
V
a- m'
W, *•
'
k\\
- e»
' i- *
^Mfnl
»^i
¦ml
/ ' Is
-}i"' ¦&!.« /"
':#fe «
'.I/ ' .• • • -.I.' J
v.k J
^ V"-.- f
'¦ r..- .r.-v
- " i. /
-, __ —
ALSO INCLUDES:
- WETLAND RESTORATION/MITIGATION
- GROUNDWATER MONITORING
- MONITORED NATURAL ATTENUATION
- ON-SITE REUSE OF EXCAVATED
SOIL/FILL MATERIAL (ALTERNATIVE 4A: TEMPORARY
ON-SITE CONSOLIDATION NOT SHOWN; LOCATION
TO BE DETERMINED)
- OFF-SITE DISPOSAL OF EXCAVATED SOIL/FILL MATERIAL
(ALTERNATIVE 4B)
- INSTITUTIONAL CONTROLS
- BIOTA MONITORING
- PRE-DESIGN SOIL SAMPLING AND TREE SURVEY
T7~~7
—I- T-r
POTENTIAL FUTURE TRAIL
EXTENSION
PLANNED RECREATIONAL TRAIL
ALIGNMENT
UPLAND VEGETATED SOIL COVER
(3 AC)
110 220
I I Feet
SURFACE EXCAVATION / WETLAND
RESTORATION (6.5 AC)
ON-SITE CONSOLIDATION AREA
(ALTERNATIVE 4A)
POTENTIAL ADDITIONAL REMEDIAL
AREAS (E.G., BASED ON SOIL
SAMPLING, TREE SURVEY)
SITE BOUNDARY
SYW-12 ALTERNATIVE 3A/B
SURFACE EXCAVATION AND ENGINEERED COVER I RESTORATION ON PERIMETER
AND INTERIOR AREAS (10 ACRES), BIOTA MONITORING, AND MNA, WITH LIMITED TREE
REMOVAL
HONEYWELL INTERNATIONAL INC.
SYW-12 PROPOSED REMEDIAL ACTION PLAN
SYRACUSE, NEW YORK
FIGURE 12
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
EXCAVATION
8-FT EXCAVATION
3.9 ACRES iL
12-FT EXCAVATION
16-FT EXCAVATION
I FULL EXCAVATION
- REMOVAL OF ALL TREES AND EXISTING HABITAT I
TO FACILITATE EXCAVATION (23.5 ACRES)
- EXCAVATION (23.5 ACRES)
r- - (i ;
MfT •
>?.'h
/r.:- -
kg i
" ^ *
NOTE:
THIS ALTERNATIVE WOULD BE EXTREMELY DIFFICULT
TO IMPLEMENT DUE TO STABILITY CONCERNS AND
PROXIMITY TO ACTIVE RAILROAD TRACKS
KStWK ¦NjCSSW " ta
'
¦¦
V :il
V 1
gate*m
(K 91 BHa*
S-UBfe :T""
*> *- m • v •
iv
HP
3 ALSO INCLUDES:
- RESTORATION
- FORESTED UPLAND (7.4 ACRES)
- NON-FORESTED UPLAND (3.0 ACRES)
- FORESTED WETLAND (6.6 ACRES)
- NON-FORESTED WETLAND (6.5 ACRES)
- MONITORED NATURAL ATTENUATION
- FULL EXCAVATION TO APPROXIMATELY
6 TO 16 FT BGS
- OFF-SITE DISPOSAL OF EXCAVATED SOIL/
FILL MATERIAL
- GROUNDWATER MONITORING
- INSTITUTIONAL CONTROLS
-------
Table 1
SYW-12 Site
Surface Soils (0-2 ft bgs)
Summary of Detected Concentrations and Part 375 SCO
Exceedances
Minimum
Maximum
NYSDEC Part 375
Number of
NYSDEC Part 375
Number of
NYSDEC Part 375
Number of
Number of
Number of
Detected
Detected
Unrestricted Use
Unrestricted Use
Restricted Use -
Commercial SCO
Restricted Use -
Ecological SCO
Parameter
Samples
Detects
Cone.
Cone.
SCOS
SCO Exceedances
Commercial SCOs
Exceedances
Ecological SCOs
Exceedances
Semivolatile Organic Compounds (nq/kq)
BENZO(A)ANTHRACENE
63
63
140
7,300
1,000
48
5,600
6
NC
0
BENZO(A)PYRENE
63
63
130
9,100
1,000
49
1,000
49
2,600
20
BENZO(B)FLUORANTHENE
63
63
180
12,000
1,000
51
5,600
10
NC
0
BENZO(K)FLUORANTHENE
63
63
63
4,500
800
40
56,000
0
NC
0
CHRYSENE
63
63
140
9,200
1,000
49
56,000
0
NC
0
DIBENZO(A,H)ANTHRACENE
63
57
63
1,100
330
22
560
9
NC
0
INDENO(1,2,3-CD)PYRENE
63
62
52
2,800
500
35
5,600
0
NC
0
Pesticides (|jq/kq)
4,4'-DDD
63
9
6.5
73
3.3
9
92,000
0
3.3
9
4,4'-DDE
63
3
0.5
3.6
3.3
1
62,000
0
3.3
1
4,4'-DDT
63
21
2.5
100
3.3
20
47,000
0
3.3
20
DIELDRIN
63
10
4.9
30
5
9
1,400
0
6
9
ENDRIN
63
1
26
26
14
1
89,000
0
14
1
PCBs (uq/kq)
AROCLOR-1254
63
58
31
2,110
NC
0
NC
0
NC
0
AROCLOR-1260
63
58
29.6
1,360
NC
0
NC
0
NC
0
Total PCBs
63
58
65.3
3,470
100
50
1,000
8
1,000
8
Metals (mq/kq)
CADMIUM
63
63
1
52
2.5
55
9.3
34
4
53
CHROMIUM
63
63
7.3
410
30
55
1,500
0
41
49
COPPER
63
63
7.3
330
50
47
270
4
50
47
LEAD
63
63
9.1
390
63
51
1,000
0
63
51
MERCURY
63
63
0.07
8.6
0.18
60
2.8
13
0.18
60
NICKEL
63
63
3.4
87
30
28
310
0
30
28
SILVER
63
57
0.34
13
2
32
1,500
0
2
32
ZINC
63
63
37
780
109
56
10,000
0
109
56
NOTES
This table presents (1) Rl Report and SCI da
ta only, (2) the detected concentration data only and (3) only parameters that exceeded the Part 375 Unrestricted, Restricted-Commercial or Restricted-
Protection of Ecological SCOs.
NC = No criteria available.
SCO = Soil Cleanup Objectives;
NYSDEC =
New York State Department of Environmental Conservation.
-------
Table 2
SYW-12 Site
Subsurface Soils (>2 ft bgs)
Summary of Detected Concentrations and Part 375 SCO Exceedances
Minimum
Maximum
NYSDEC Part
Number of
NYSDEC Part 375
Number of
NYSDEC Part 375
Number of
Number of
Number of
Detected
Detected
375 Unrestricted
Unrestricted Use
Restricted Use -
Commercial SCO
Restricted Use -
Ecological SCO
Parameter
Samples
Detects
Cone.
Cone.
Use SCOS
SCO Exceedances
Commercial SCOs
Exceedances
Ecological SCOs
Exceedances
Volatile Orqanic Compounds (
ig/kg)
2-BUTANONE
40
22
3.1
220
120
1
500,000
0
100,000
0
ACETONE
40
15
14.2
730
50
9
500,000
0
2,200
0
ETHYLBENZENE
40
22
1.2
11,200
1,000
9
390,000
0
NC
0
METHYLENE CHLORIDE
40
2
5.3
80
50
1
500,000
0
12,000
0
XYLENES, TOTAL
40
24
0.96
15,300
260
9
500,000
0
260
9
Semivolatile Orqanic Compounds (nq/kq)
4-METHYLPHENOL
21
8
84
1,800
330
4
500,000
0
NC
0
ACENAPHTHENE
40
33
53
210,000
20,000
4
500,000
0
20,000
4
BENZO(A)ANTHRACENE
40
34
161
53,000
1,000
31
5,600
15
NC
0
BENZO(A)PYREN E
40
34
307
46,000
1,000
31
1,000
31
2,600
28
BENZO(B)FLUORANTHENE
40
34
236
45,000
1,000
32
5,600
12
NC
0
BENZO(K)FLUORANTHENE
40
34
97
9,500
800
28
56,000
0
NC
0
CHRYSENE
40
34
201
59,000
1,000
31
56,000
1
NC
0
DIBENZO(A,H)ANTHRACENE
40
32
66.9
4,220
330
27
560
20
NC
0
FLUORENE
40
33
48
86,000
30,000
3
500,000
0
30,000
3
INDENO(1,2,3-CD)PYRENE
40
34
160
8,350
500
31
5,600
5
NC
0
NAPHTHALENE
40
33
43.2
380,000
12,000
6
500,000
0
NC
0
PHENANTHRENE
40
34
65.1
280,000
100,000
3
500,000
0
NC
0
PYRENE
40
34
279
140,000
100,000
2
500,000
0
NC
0
Pesticides (nq/kq)
4,4'-DDD
21
1
4.4
4.4
3.3
1
92,000
0
3.3
1
4,4'-DDT
21
3
4.9
31
3.3
3
47,000
0
3.3
3
PCBs (nq/kq)
AROCLOR-1248
40
1
1,110
1,110
NC
1
NC
1
NC
1
AROCLOR-1254
40
6
7.88
1,530
NC
3
NC
2
NC
2
AROCLOR-1260
40
6
12.2
853
NC
2
NC
0
NC
0
Total PCBs
40
6
18.3
2640
100
3
1,000
2
1,000
2
Metals (mq/kq)
ARSENIC
40
37
1.5
19.7
13
3
16
2
13
3
CADMIUM
40
31
0.31
100
2.5
13
9.3
2
4
4
CHROMIUM
40
40
3
470
30
13
1,500
0
41
8
COPPER
40
40
2.8
450
50
27
270
1
50
27
LEAD
40
40
1.5
437
63
29
1,000
0
63
29
MERCURY
40
40
0.0069
6
0.18
29
2.8
4
0.18
29
NICKEL
40
40
3.6
116
30
21
310
0
30
21
SILVER
40
28
0.23
13
2
18
1,500
0
2
18
ZINC
40
40
11
1,200
109
27
10,000
0
109
27
NOTES
This table presents (1) Rl Report and SCI da
ta only, (2) the detected concentration data only and (3) only parameters that exceeded the Part 375 Unrestricted, Restricted-Commercial or Restricted-
Protection of Ecological SCOs.
NC = No criteria available.
SCO = Soil Cleanup Objectives;
NYSDEC =
New York State Department of Environmental Conservation.
-------
Table 3
SYW-12 Site
Shallow and Intermediate Groundwater
Summary of Detected Concentrations and Class GA SGV and EPA MCL Exceedances
Number of
Number of
Minimum
Maximum
NYSDEC Class
Number of Class
EPA National Primary
Number of MCL
Parameter
Samples
Detects
Detected Cone.
Detected Cone.
GA SGVs
GA Exceedances
Drinking Water MCLs
Exceedances
Volatile Organic Compounds (|ig/L)
ETHYLBENZENE
26
3
0.48
14.8
5(S)
2
700
0
ISOPROPYLBENZENE
26
5
0.23
5.25
5(G)
1
NC
0
O-XYLENE
3
2
2.1
7.3
5(S)
1
NC
0
XYLENES, TOTAL
26
5
0.45
15.2
5(S)
2
10,000
0
Semivolatile Organic Compounds (|ig/L)
4-METHYLPHENOL
23
3
0.36
2
1(S)
1
NC
0
4-NITROPHENOL
26
1
1.1
1.1
1(S)
1
NC
0
ACENAPHTHENE
26
13
0.53
41
20(G)
1
NC
0
NAPHTHALENE
26
5
1.6
170
10(G)
4
NC
0
Pesticides (uq/L)
Alpha-BHC
23
2
0.0087
0.027
0.01(S)
1
NC
o
Metals (mq/L)
BARIUM
26
18
0.12
2
1(S)
6
2
2
CHROMIUM
26
4
0.0093
0.16
0.05(S)
1
0.1
1
IRON
26
25
0.34
62.3
0.3(S)
25
NC
0
LEAD
26
4
0.005
0.041
0.025(S)
1
0.015
2
MAGNESIUM
26
20
23
176
35(G)
15
NC
0
MANGANESE
26
26
0.086
2.1
0.3(S)
23
NC
0
SODIUM
26
26
250
3,400
20(S)
26
NC
0
Inorganics (mq/L)
BROMIDE
17
11
1.6
16.6
2(G)
9
NC
0
CHLORIDE
26
26
380
9,940
250(S)
26
NC
0
NITROGEN, AMMONIA (AS N)
3
3
5.5
36
2(S)
3
NC
0
SULFIDE
14
4
2
17.6
0.05(G)
4
NC
0
NOTES
This table presents (1) Rl Report and 2019 follow up data only, (2) the detected concentration data only and (3) only parameters that exceeded the NYSDEC Class GA
SGVs or USEPA Drinking Water MCLs.
NC = No criteria available.
(S) = Standard; (G) = Guidance Value; MCL =
Maximum Contaminant Level; EPA = Environmental Protection Agency; NYSDEC =
New York State Department of
Environmental Conservation.
-------
Table 4 - Human Health Risk Re-Evaluation Summary
Timeframe
Receptor
Exposure Medium
Cancer Risk
Non-Cancer
Hazard
Hazard/Risk Driving COCs
Current/Future
Utility Worker
Surface/Subsurface Soil
3xl0"5
0.07
--
Outdoor Air
4xl0"7
0.006
--
Shallow Groundwater
6xl0"5
0.6
--
All Media
6xl0"5
0.6
--
Current/Future
Child Recreator
Surface Soil
6xl0"5
0.9
--
Outdoor Air
2xl0"7
0.006
--
All Media
6xl0"5
0.9
--
Current/Future
Adult Recreator
Surface Soil
3xl0"5
0.05
--
Outdoor Air
9xl0"7
0.006
--
All Media
4xl0"5
0.06
--
Current/Future
Railroad Worker
Surface Soil
lxlO"5
0.2
--
Outdoor Air
2xl0"5
0.01
--
All Media
lxlO"5
0.2
--
Future
Commercial/
Industrial Worker
Surface Soil
2xl0"5
0.3
--
Outdoor Air
9xl0"5
0.07
--
All Media
2xl0"5
0.3
--
Future
Construction
Worker
Surface/Subsurface Soil
lxlO"5
0.8
--
Outdoor Air
2xl0"7
0.07
--
Shallow Groundwater
3xl0"5
7.1
Benzo(a)pyrene, chromium1
All Media
3xl0"5
8.0
Benzo(a)pyrene, chromium1
Future
Child Resident2
Surface Soil
9xl0"5
7.6
Highly chlorinated PCBs
Outdoor Air
5xl0"5
0.4
--
All Media
lxlO"4
7.9
Highly chlorinated PCBs
Future
Adult Resident2
Surface Soil
lxlO"5
0.2
--
Outdoor Air
3xl0"5
0.2
--
All Media
4xl0"5
0.4
--
- Shaded cells indicate exceedance of the USEPA acceptable cancer risk or non-cancer hazard threshold.
1 Based on HHRA results using groundwater data collected during RI; chromium and benzo(a)pyrene were not detected in
groundwater monitoring well samples collected subsequent to the RI.
2 While child and adult resident receptors were evaluated in the HHRA, residential use would not be consistent with the
anticipated future land use of the SYW-12 Site.
-------
SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-b
PUBLIC NOTICE PUBLISHED IN THE
SYRACUSE POST STANDARD
ON JANUARY 19, 2023
-------
0010556017-01
Ad Content Proof
THE NEW YORK STATE DEPART
MENT OF ENVIRONMENTAL
CONSERVATION INVITES PUBLIC
COMMENT ON THE PROPOSED
PLAN FOR THE SYW-12 SITE The
New York State Department of
Environmental Conservation
(NYSDEC) will hold an open
house from 5:00 - 6:00 PM and
a public meeting at 6:00 PM on
January 31, 2023 (snow date of
February 1, 2023) at the Salina
Town Hall located at 201
School Road, Liverpool 13088
to discuss the Proposed Plan
for the SYW-12 site (site). The
site, also referred to as Mur-
phy's island, is an operable unit
of the Onondaga Lake
Superfund site and is located
between Onondaga Lake and
the Destiny USA mall in Syra-
cuse, Onondaga County, The
Proposed Plan provides a sum-
mary of the findings of the Re-
medial Investigation and Feasi-
bility Study (Rl/FS) conducted to
determine the nature and ex-
tent of the contamination at
the site, whether this contami-
nation poses a threat to public
health and the environment,
and to identify and evaluate re
medial alternatives. The Pro-
posed Plan also identifies
NYSDEC and EPA's preferred al-
ternative to address contami-
nation at the site and the basis
for this preference. The primary
objectives of this action are to
minimize current and potential
future human health and envi-
ronmental impacts. The fea-
tures of the preferred alterna-
tive include the installation of a
two-foot-thick soil cover in se-
lect areas of the site (while pre-
serving trees used for winter
roosting by Bald Eagles), biota
(e.g., soil invertebrate, small
mammal) monitoring, moni-
tored natural attenuation of
groundwater, development of a
Site Management Plan, imple
mentation of institutional con
trols, and long-term mainte-
nance and monitoring. NYSDEC
and the U.S. Environmental Pro-
tection Agency (EPA) are issu-
ing the Proposed Plan to en-
courage and receive input and
comments from the public on
the alternatives considered in
the detailed and comparative
analyses presented in the FS
and the Proposed Plan.
Changes to the preferred alter-
Confidentiality Notice: This facsimile is intended only for its addressee and may contain information that is privileged, confidential or otherwise protected from disclosure. Dissemination, distribution or
copying of this facsimile or the information by anyone other than the intended recipient is prohibited. If you have received this facsimile in error, please notify us immediately and return the facsimile by mail.
1/17/2023
9:46AM
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Hdlive ui beieuuun ui d it;ilie-
dial alternative other than the
preferred alternative may be
made if public comments or ad-
ditional data indicate that such
a change will result in a more
appropriate remedial action.
The final decision regarding the
selected remedy will be made
after NYSDEC and EPA have
taken into consideration all
public comments. The Pro-
posed Plan, Rl report, and FS
report are available at the fol-
lowing locations, information is
also available on dec's website
at https://www.dec.ny.gov/data
/DecDocs/734075A/. Atlantic
States Legal Foundation 658
west Onondaga Street Syra-
cuse, New York 13204 315 475
1170 NYSDEC 615 Erie Boule-
vard, West Syracuse, New York
13204 2400 315 426 7400
Please call for an appointment
NYSDEC, DER 625 Broadway,
12th Floor Albany, New York
12233 7013 518 402 9676
Please call for an appointment
Written comments associated
with the remedy for the site, re-
ceived during the public com
ment period which ends on
February 18, 2023, as well as
oral comments received at the
public meeting, will be docu-
mented and addressed in the
Responsiveness Summary sec-
tion of the Record of Decision,
the document which formalizes
the selection of the remedy.
All written comments should
be addressed to: Mr. Tracy A.
Smith, Project Manager NYS
Department of Environmental
Conservation 625 Broadway,
12th Floor Albany, NY 12233
7013 tracy.smith@dec.ny.gov
(Indicate "SYW-12 Proposed
Plan Comments" in the subject
line of the e-maif)
Confidentiality Notice: This facsimile is intended only for its addressee and may contain information that is privileged, confidential or otherwise protected from disclosure. Dissemination, distribution or
copying of this facsimile or the information by anyone other than the intended recipient is prohibited. If you have received this facsimile in error, please notify us immediately and return the facsimile by mail.
1/17/2023
9:46AM
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SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-c
PUBLIC MEETING SIGN-IN SHEET
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SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-d
JANUARY 31, 2023 PUBLIC MEETING TRANSCRIPT
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Page 1
NEW YORK STATE
DEPARTMENT OF CONSERVATION
x
In re:
*
*
*
REMEDIATION SYW-12
SITE PROPOSED PLAN
*
*
*
Site:
Region
7 3 4 0 7 5 A
7
x
*
PUBLIC HEARING
o f
SYW-12 PROPOSED
PLAN
Town of Salina, New
York
Tuesday, January 31
, 2 023
Reported by:
Mary Agnes Drury, RPR, NYACR,
CLR
JOB NO. 922429
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4
January 31, 2023
5
6:00 p.m.
6
7
8
PUBLIC HEARING, held at Town of Salina
Town Hall, 201 School Road, Liverpool, New York
9
before Mary Agnes Drury, RPR, NYACR, CLR, a
10
Notary Public of the State of New York.
11
12
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15
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18
19
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2 APPEARANCES:
3
4 NEW YORK STATE DEPART OF CONSERVATION
5 BY: TRACY ALAN SMITH, Project Manager
6
7 NEW YORK STATE DEPARTMENT OF HEALTH
8 BY: MARK SERGOTT, Health Advisor
9
10 PUBLIC MEMBERS SIGN-IN SHEET:
11 Sherri Plouff
12 Mark Lafaver
13 Rick Pelotte
14 Matt Marko
15 Dale Grinolds
16 Bri Kukemy
17 Mi ke Teeling
18 Jesse McMahon
19 T om Paul
20 Clare Leary
21 Diana Green
22 Hilary-Anne Coppola
23 Michaela Kenward
2 4 D. Rob i ns on
2 5 - o 0 o -
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2 MR. PELCHECK: All right. I'm Jason
3 Pelcheck (phonetic), Section Chief with New
4 York State DEC in Albany.
5 First of all, I just wanted to
6 welcome everybody. Thank you for coming
7 here tonight to hear about our proposed
8 plan for the SYW-12 site, also commonly
9 referred to as the Murphy's Island site.
10 It's actually one of the 11 subsites that
11 are part of the overall larger Onondaga
12 Lake cleanup.
13 So January 18th we released our
14 proposed plan for all the proposed legal
15 action plan to address the SYW-12 site.
16 That started the 30-day comment period. So
17 after that comment period ends, we're going
18 to start preparing what we call our Record
19 of Decision, which is the final collected
20 remedy for the SYW-12 site. That
21 recommendation will include a response that
22 is a response to any of the comments that
23 we receive during the 30-day comment
24 period, and that includes any of the
25 comments that we receive here tonight.
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2 As Tracy will present here tonight,
3 you're going to learn about our preferred
4 remedy for the site, and it is really a
5 culmination of a comprehensive
6 investigation at the site, followed by the
7 various cleanup options that work well for
8 the site.
9 Given some of the unique
10 characteristics of the site, you'll learn
11 about the position next to the lake
12 adjacent to a railroad, its use by Bald
13 Eagles. So these are some of the factors
14 that we had to look into as we evaluated
15 different cleanup options, as well as at
16 the site what remedial techniques work best
17 for these types of game puts.
18 Tracy will also talk about the
19 preferred remedy, and then I'll hand it
20 over to Mark Sergott with the New York
21 State Department of Health. He'll talk
22 about their role in the process, and they
23 are current with the remedy. And then
24 Tracy will come back up and talk about the
25 next steps and fast forward, and then we'll
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2 open it up to the question-and-answer
3 period.
4 Overall, I'd say we'll be here for
5 about 15 minutes or so, and then we can
6 have the rest of the evening to go through
7 questions that you might have for us.
8 That's all I have.
9 MR. SMITH: All right. As Jason
10 said, thank you for coming tonight. My
11 name is Tracy Smith, I'm the Department of
12 Environment Conservation Project Manager
13 for the site.
14 As he said, this is the SYW-12 site
15 or what's commonly referred to as "Murphy's
16 Island."
17 So during the presentation Jason
18 said we'll be discussing the remedial
19 processes, the preferred and alternative
20 site backgrounds, alternatives that were
21 evaluated for the cleanup site, and then
22 the next steps. Please hold any questions
23 to the end and we'll get through them and
24 try to answer them the best we can.
25 As you know, this meeting is to
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2 discuss the preferred remediation
3 alternatives for the site. I'm not going
4 to be directly discussing or entertaining
5 questions on the Bald Eagles or the county
6 trail.
7 So this is the remediation process
8 that we follow. As part of the
9 remediation, we collect data and determine
10 the nature and the extent of the
11 contamination present.
12 We then perform a study to evaluate
13 the cleanup options.
14 Following this evaluation,
15 post-plans are released to the public for
16 review, which we're at now.
17 And then after the proposed plan,
18 the Record of Decision is made, which
19 formalizes the remedy. As Jason said, that
20 will be completed followed by design and
21 construction.
22 So we evaluated four different
23 alternatives for the site. Based on that
24 evaluation, the preferred alternative we
25 selected was Alternative 2. That includes
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2 placement of two feet of cover material in
3 selected areas of the site. Evaluations
4 are covering an additional 2.2 acres of
5 wetlands restoration with the goal of no
6 loss of wetland area, the monitoring of
7 animal and plant life, to evaluate and
8 remedy contaminated groundwater to be
9 perf ormed.
10 And in addition to this alternative,
11 this includes institutional controls and
12 site management plan.
13 Institutional controls further
14 reduce the potential for exposures at the
15 site by using controls such as restricting
16 the site's future use.
17 The site management plan until
18 include maintenance and monitoring and the
19 inspection of the covers and would address
20 any future changes in use of the site.
21 Trees used by the eagles under this
22 remedy will be protected and undisturbed by
23 this remedy.
24 So the site includes undeveloped
25 land in a portion of wetland shown in the
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2 picture here. A total wetland at site
3 SYW-12 extends beyond the boundary, it's a
4 4 5-and-a-ha1f acre wetland. The south is
5 bound by railroad tracks northeast, as you
6 canseehere.
7 Onondaga Creek itself is in the
8 upper side of the picture, and Onondaga
9 Lake to the west.
10 So the creek sub-site and the
11 Onondaga Lake site is also located to the
12 north, and that's being addressed as part
13 of a separate remedy.
14 So this picture here shows the
15 wetland and forest areas of the site.
16 There is approximately 14 acres of forest
17 areas with wetland forest shown in green
18 located primarily adjacent to Onondaga Lake
19 with the green portion there.
20 And then there is forested uplands,
21 which are indicated by the green located
22 more near the center of the site. These
23 forested areas are where many of the eagles
24 currently roost for the winter; you've
25 probably seen the photos in newspapers and
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2 online and stuff like that.
3 And then there is approximately
4 nine-and-a-half acres of non-forest areas
5 located away from the lake located along
6 the railroad tracks, six-and-a-ha1f acres
7 of wetland shown in the orange located
8 mostly along the track and some areas
9 narrowing Onondaga Lake, and then three
10 acres of non-forest with the orange hash
11 located along closer to the railroad
12 tracks.
13 So this figure shows the prior to
14 the 1800s, the site was probably
15 underwater. The lake level was higher and
16 contained cedar and ash forest. The lake
17 and Onondaga Creek sort of meandered
18 through the site at that time. In the late
19 1800s the creeks were re-routed, so they
20 came more directly into the lake. The lake
21 area was also -- the lake level was also
22 reduced with construction of the canal
23 system.
24 So this area shows the site
25 surrounded by railroad tracks, which were
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2 then present for over a hundred years.
3 There is also a music complex, the Iron
4 Pier Resort, which operated on the site in
5 the late 1800s until it closed in 1906.
6 Available information such as
7 historic maps and aerial photos indicate
8 various materials, this includes fill for
9 places as the former Iron Pier channel and
10 from the operation of the site.
11 Contaminants are likely related to
12 several sources that could have been
13 impacted Onondaga Lake. Those sediments
14 placed on the site are shown in this photo
15 here. The dredge operations in the lake
16 and the barge canal, which is bumped to the
17 site, that is where likely a lot of
18 contamination came from in dredging
19 operations.
20 So the current site use, I am sure
21 many of you are familiar with this photo
22 from Greg Craybas a couple of years ago
23 which shows how the site is a roosting area
24 for the Bald Eagles.
25 The county also recently opened a
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2 trail extension, which closed for the
3 winter on December 1st until April 1st due
4 to the Eagles roosting. There is signs
5 saying stay on the trail, you should remain
6 on the trial. And also, the county is
7 drafting a site management plan for the
8 trail, and that's going to be reviewed by
9 the DEC, with Department of Health to help
10 manage the site, the trail, its use.
11 Here is site background. So several
12 investigations have been performed at the
13 site; investigations started as far back as
14 2006 for some of them. They are summarized
15 in the field investigation report and
16 several other documents. Alternatives to
17 address the contamination that were
18 evaluated in a study. Those documents and
19 others are located online or at document
20 repository site.
21 So the contaminates present at the
22 site, surface soils that feeds the
23 ecological plumes that are used for the
24 site based on this use are polycyclic
25 aromatic hydrocarbons or PAHs, the
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2 polychlorinated biphenyls or PCBs and
3 metals such as cadmium, copper and mercury.
4 Some stained soils and blebs of
5 NAPLs, which are oil-like droplets are
6 present at the site, that is about 8 to
7 12 feet under ground surface in some areas
8 of the site. However, the impact from
9 these are -- the groundwater are pretty
10 minimal, with the groundwater pretty
11 standard with only one well that's present
12 at the site.
13 And then risk assessments were also
14 performed. These include Human Health Risk
15 Assessment HHRA and ecological risk
16 assessment. These were based on no
17 remedial activities that were performed.
18 The HHRA indicates they are
19 acceptable due to construction work at the
20 site; the PAH and groundwater if no
21 remedial work was done.
22 Past recreational uses such as a
23 trails are acceptable based on the current
24 conditions and future conditions based on
25 that health risk assessment.
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2 Ecological risk assessment included
3 several metals and organic compounds such
4 as chromium, cadmium and PCBs with risk to
5 birds and animal population and small
6 animals with small home ranges such as
7 Robins and short tails.
8 This figure shows most of the sample
9 locations that were performed during the
10 investigations. So this investigation
11 included excavation test pits, soilcrete
12 boring and collection of certain soil
13 samples and groundwater wells.
14 Due to the proximity of the
15 railroad, a geotechnical investigation was
16 also performed. Many of the higher
17 concentrations of the surface soil are
18 located in the wetland area on the north
19 part of the site in this general area in
20 the circle.
21 So here are some photos of some of
22 the test bits that were installed to
23 collect soil samples and collected
24 information during these investigations.
25 This photo here you can see some of
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2 the wood that was part of the former Iron
3 Pier channel, some of the materials that
4 were encountered during the excavations.
5 So this list here, these are the
6 objectives for the remediation were at the
7 site that have been established. I'm not
8 going to read through them, you can read
9 them up there. But the main purpose is to
10 prevent unacceptable human exposure, any
11 ecological impacts and to prevent migration
12 of contaminants to the lake.
13 These bullets are summaries in place
14 for human health, and these bullets are a
15 summary of the site's remedial action
16 objectives for the protection of the
17 environmental resources.
18 All right. These are the
19 alternatives we considered during the
20 evaluation of these study. These were
21 considered to address the contamination at
22 the site based on the remediation
23 objectives and the best available
24 technologies.
25 There were several factors that
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2 limited the alternatives we evaluated; the
3 primary one is the forest areas, the site
4 that is used when roosting of the eagles,
5 so that limits the work that can be
6 performed on the site and cutting the
7 trees .
8 Another factor is the railroad
9 tracks which limit access to site and
10 excavation due to the potential stability
11 issues.
12 So Alternative 1 is the No Action
13 Alternative. These required to evaluate
14 that as a baseline for a basis of
15 comparisons to other potential
16 alternatives. That alternative just leaves
17 the site in the current condition and it
18 doesn't provide any additional protection
19 to human health and the environment that
20 I'll discuss in detail.
21 And alternatives 3A and 3B includes
22 soilcrete excavation prior and it has a
23 similar protectiveness , but it remediates
24 approximately two more acres. The
25 alternative 3A would need material
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2 excavated on site for re-use or covering
3 while alternative 3B would have taken the
4 material to an off-site disposal area.
5 Alternative 4 is the real
6 alternative that includes full removal of
7 the contaminated materials in the wetland
8 restoration. However, this alternative
9 would result in removal of all the trees at
10 the site.
11 So this figure shows Preferred
12 Remedy Alternative 2. So the areas where
13 cover would be placed is non-forest areas
14 indicated in green and greenish-blue
15 hashing, closer to the railroad tracks
16 here .
17 There is additional areas that will
18 be evaluated for cover placement outlined
19 in pink. These additional areas will be
20 evaluated based on results from soilcrete
21 sampling that was formed as part of the
22 redesign investigation.
23 And based on how accessible they are
24 to ensure there is no lost wetland by the
25 remedy, there could be removal of some of
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2 the contaminated material prior to
3 placement of the cover.
4 Based on the special conditions, as
5 I said before, to preserve the trees and
6 not disturb the bald eagle roosting areas,
7 there may be contamination that could
8 remain in some cleanup objectives in the
9 areas where the covers cannot be placed, so
10 those areas would still be potentially
11 contaminated remaining above the cleanup
12 obj ectives.
13 So this is the list of the criteria
14 that we use to evaluate the remedial
16 So all the remedial alternatives
17 other than no action alternative we need to
18 meet the first two criteria, and the
19 protection of human health environment in
20 compliance with the state and federal
21 regulations.
22 Other criteria include long-term
23 effectiveness, short-term effectiveness,
24 how easy is it to implement, and how the
25 remedy is accepted by the community.
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2 Alternative 4, the Removal
3 Alternatives has several imp 1ementabi1ity
4 issues. This alternative assumes removal
5 from ranges of 6 to 15 feet with
6 approximately 400,000 cubic yards of
7 material being transported off-site for
8 disposal, and then backfill will be brought
9 back to the site. Also, that will result
10 in 35 truckloads of material a day for five
11 to seven years of being moved, in addition
12 to removing all the trees. There will be
13 an increased truck traffic and additional
14 worker and public safety issues due to the
15 trucks and just handling the material.
16 Potential stability issues due to
17 the railroad tracks and then water
18 management issues, since we're right next
19 to Onondaga Lake and the creek areas, and
20 then the ability to find a disposal for
21 that amount of materials.
22 So this table predicts the cost and
23 the estimate and the construction
24 timeframes. You can see here, Alternative
25 1, $0; Alternative 2, estimated
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2 $8.3 million; Alternatives 3 A and 3B are
3 approximately $22 and $27 million, and
4 Alternative 4 has the highest cost of $281
5 million.
6 So these costs also include
7 operation remedies, so they're
8 comprehensive remedies, not just the rule
9 and the materials to manage the site for
10 the long-term time period.
11 So for the years, Alternatives 2 and
12 3A and 3B are similar timeframe would take
13 one to two years to implement, and
14 Alternative 4 would take five to seven
15 years.
16 So Alternative 2 is being proposed
17 as the preferred remedy, because we think
18 it best protects the public health and
19 environment and it presents the best
20 choice. Alternative 1 would not mediate
21 any criteria for protection of human health
22 and environment and compliance.
23 Alternatives 3A and 3B would remove
24 more, but there could be stability issues
25 near the railroad tracks, it would impact a
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2 forest area maybe a half-acre to get to
3 some of the areas, and then there would be
4 work in the smaller wetland areas located
5 in the forest areas that the eagles roost
6 in.
7 And also, as discussed previously,
8 Alternative 4 being very difficult and has
9 significant short-term impact, it takes
10 longer to implement as the alternative and
11 is least cost-effective.
12 Now, I'll turn it over to Mark
13 Sergott from the Department of Health; he
14 has some slides on their role in the
15 process and to discuss a potential.
16 MR. SERGOTT: All right. Hello
17 Everybody, thank you for coming out
18 tonight. As Tracy indicated, my name is
19 Mark Sergott, I represent New York State
20 Department of Health in the Bureau of
21 Environmental Exposure Investigation.
22 Just a couple of quick slides to
23 kind of go over a couple of quick points in
24 terms of our role for this particular
25 project and really show our sign of
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2 approval and support to the proposed plan
3 that Tracy has outlined tonight.
4 So really our objective here is to
5 work with the New York State DEC on all of
6 these particular remedial projects across
7 the state. We're involved in the review
8 and approval of all the various
9 specification work plans, various remedial
10 plans that we discussed here tonight. And
11 really, we focus in on trying to identify
12 the nature and the extent of the
13 contamination with the particular sites,
14 with the particular emphasis on evaluating
15 the potential exposures to these particular
16 plans.
17 And really, the focus that is to
18 determine how in fact the public can get
19 into contact with the various environmental
20 contaminants that are associated with the
21 sites that we're discussing tonight.
22 With the data that we collect and
23 evaluate, we can make various
24 recommendations in terms of how we can
25 address the potential exposures and
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2 identify data gaps along the way. We work
3 collectively with all the agencies
4 involved, with the EPA and DEC in gathering
5 those tools with the information we need to
6 assess the overall potential of exposures.
7 Ultimately, with any remedy, it's
8 our focus from a health perspective to
9 ensure that it's protective of the public
10 health.
11 So real quick points to go over.
12 You know, what is exposure. When we talk
13 exposure, we're talking about physical
14 contact with the particular chemical
15 substances, and we're trying to figure out
16 how are people getting in touch with it.
17 And there are really three main
18 exposure factors when we work on these
19 particular sites.
20 One exposure, obviously, inhalation.
21 Normal breathing, recreating in and out of
22 trail, is it a concern or not.
23 We look at the potential of people
24 coming in direct contact with the
25 contaminants at the site.
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2 Lastly, we go through ingestion;
3 hand and mouth. People somehow ingesting
4 in some way, shape or form or consuming
5 contaminated groundwater from the water
6 wells or the water supply that may exist at
7 the site.
8 So it's important to know that one
9 or more of these physical contacts must
10 occur before a particular chemical has the
11 ability or potential to harm us as a health
12 problem, but it's also important to note
13 just because there is a potential exposure,
14 doesn't mean that you'll have a negative
15 health consequence for that particular
16 exposure that occurred.
17 The nuts and bolts of this is now
18 going through all of these exposure
19 s cenarios .
20 Now, one is really kind of go over
21 some specific components of the remedy that
22 are adequate to address these various
23 exposure concerns here.
24 Moving forward. I'm going to be
25 quite honest, right now, the site's current
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2 condition, there is minimum opportunities
3 for people to be encountering a lot of the
4 contaminants that we've been discussing
5 here tonight .
6 And the reason being, a lot of it is
7 really buried at depths, you know, there is
8 nobody right now physically out at the site
9 digging down to this particular.
10 Another property is that, you know,
11 a lot of the chemical makeup and the
12 chemical properties of the main
13 contaminants, a lot of the compounds have a
14 really good tendency of binding really
15 tightly to soilcrete particles, so there is
16 no concern at this point migrating and
17 contamination on-going at the site.
18 So when we break down the exposure
19 pathogens; again, we're looking at how in
20 terms is it going to be protected in terms
21 of preventing inhalation going forward.
22 Really as of now, no concern to be,
23 but really the inhalation concern would
24 come in is once the remedial operations
25 begin, as Tracy indicated, there will be
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2 some areas that will be excavated and other
3 areas will be extensive in bringing in
4 material and grading material. That would
5 be an opportunity where you might have the
6 possibility of, you know, contaminants
7 getting up in the dust and migrating
8 across.
9 Typically, when we're conducting
10 remedial and implementing a remedy at
11 particular sites, any sites across the
12 state, including this one, we'll be
13 monitoring the air to basically monitor,
14 you know, levels of voluntary organic
15 components, as well as particulates.
16 And really, the focus of this is to
17 ensure that the remediation, you know, the
18 operations are not negatively effecting the
19 air quality in the surrounding community;
20 based on the various guidelines and the
21 levels that it's monitored for, monitoring
22 guidelines that we look to achieve when
23 conducting remedial operations. We'll take
24 the necessary steps to halt the operations
25 to take these issues down, because you
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2 don't want to have material across the
3 site. You don't want to have dust forming.
4 You don't want to have the nuisance of
5 bothering people recreating along the trail
6 or shopping at the mall.
7 Moving forward, another aspect of
8 the remedy would be as of now, I'm not
9 aware of any particular plans going forward
10 on any future construction on this
11 particular property.
12 In the event, for whatever reason,
13 if Onondaga County shows for whatever
14 reason to construct some sort of a
15 structure or some sort of gathering spot,
16 there is a component within the remedy
17 which calls for a soilcrete intrusion
18 evaluation to be completed. And basically,
19 soilcrete vapor instruction is the process
20 in which we'll look in terms of -- and
21 again, in the event that something were to
22 be constructed, we'll take a look at the
23 data and we'll get a sense for what
24 residually is remaining at the site and
25 soilcrete vapor is the contaminants, it has
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2 the ability to volatilize through vapor,
3 very similar to how radon, if you have a
4 structure, a lot of those vapors tend to
5 concrete and accumulate and slab on the
6 principle and finding pathways of least
7 resistance into the aerospace of the
8 structure .
9 So we'll make sure in the event that
10 anything is, we'll take the proper measures
11 to ensure that whether or not soilcrete
12 vapor intrusion is a concern or not, this
13 will take the proper steps for the amount
14 of that building is on to reduce that
15 amount of exposure.
16 In terms of direct contact. Yeah,
17 right now the existing trail design
18 construction really does provide a good
19 buffer to underlying residual contamination
20 that may remain.
21 In the areas of the site where there
22 will be excavation or grading operations,
23 alternately, there will be an extensive
24 cover system that will be in place, it will
25 be with clean fill.
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2 Moving forward, in the event, again,
3 if there is any future construction and/or
4 excavation planned in these particular
5 areas as part of the site's management
6 plan, there will be an excavation plan in
7 place which will show proper measures and
8 procedures to take in the event that you
9 want to properly manage any residual
10 materials in the event that we're moving
11 that material.
12 And really, common sense approach
13 which is, I think the biggest thing in
14 terms of direct contact is, stay on the
15 trial.
16 So Onondaga County has done a good
17 job to provide buffer material in both
18 sides of the trail. There is vegetation
19 that still exists; it could be more,
20 depending on going forward, but the various
21 signs have been put up and extensive
22 wildlife areas along the trail.
23 And as part of the site management
24 practices, there will always be a routine
25 inspection of the particular remedial plans
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2 to ensure that the remedy is proven to be
4 So in the event that Onondaga County
5 as the site owner will be periodically
6 notifying us that there is signs that
7 people are migrating off the trail, that
8 they're not supposed to, then we'll have a
9 meeting of the minds and have a way to
10 provide better fencing or railing or higher
11 density vegetation. We'll work together to
12 eliminate the concerns of people migrating
13 off the trail; particularly, in the areas
14 where we're not going to be allowed to move
15 because of the sensitivity of the eagle
16 habitats and the various spots.
17 In terms of the ingestion really;
18 use good common sense, practice good
19 hygiene. Stay on the trail. There should
20 be no concern of encountering anything at
21 the site. If you don't believe anything
22 that we say tonight and you have soils on
23 your hand, minimize the hand-to-mouth
24 contact, wash your hands, keep your kids
25 off, make sure the kids are keeping their
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2 hands from the mouth.
3 And again, going forward, we
4 understand there is minimal groundwater
5 contamination. That being said, based on
6 what we found, going forward there will
7 still be a groundwater use restriction that
8 is based on the property.
9 So in the event there is particular
10 structures that are constructed, if there
11 is a need for a portable water supply,
12 we'll make the necessary accommodations
13 available for a public water supply.
14 That's really it. I hope it makes
15 sense and it's how we build the various
16 components of the remedy that protect the
17 public health, and it's proven to us that
18 we fully support the DEC Preferred
19 Remedy 2. Thank you.
20 MR. SMITH: Thank you, Mark.
21 All right. So we're near the end of
22 the presentation here.
23 These are the next steps. So public
24 comment period will close on February 18th.
25 We're accepting comments up until that
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2 date, so you can either mail in comments or
3 e-mail or write your questions today, your
4 comments on a card at this meeting, if you
5 want to, or any questions you ask tonight
6 will be incorporated.
7 Following the public comment period
8 the ROD or the Record of Decision which is
9 selected as the final remedy will be
10 drafted and it will be issued and include
11 any responses to questions that are asked
12 during the public comment period.
13 And then following the Record of
14 Decision, we will proceed with the remedial
15 design. Design, construction and
16 maintenance of the remedy is anticipated to
17 be performed by a potentially responsible
18 party or parties with DEC oversight.
19 The anticipated design may be later
20 this year or next year, followed by
21 construction, which in these times can
22 change, depending on negotiations with
23 parties and timeframes, we'll have to work
24 around schedules for the eagles, probably
25 no work between, like, with the period that
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2 the trial is shut down from December to
3 April timeframe, so there will be those
4 restrictions incorporated into the
5 construction timeframes.
6 So now I look forward to any
7 questions and call upon people to please
8 state your name so we can have it on the
9 record, and we'll try to answer any
10 questions that you have.
11 Thank you for coming tonight.
12 PUBLIC MEMBER MS. GREEN: Diana
13 Green. I've got a couple of questions for
14 you. Can I address one to Mark?
15 Mark, when you talked about public
16 safety, you didn't mention construction
17 workers, additional concerns about their
18 exposures .
19 MR. SERGOTT: Sure. Yeah.
20 Basically, when the remediation contractors
21 are working on any of these sites, they are
22 always going to be implementing their own
23 site health safety plan; it's always a
24 component of remedial construction, so
25 basically, you know, in all likelihood, I'm
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2 assuming much of the trail, not all of it
3 would be closed off, or at least sections
4 of it, to make sure that those operations
5 aren't negatively effecting anybody that
6 might be recreating on the trail. But in
7 all likelihood, the site personnel would
8 basically be implementing their own site
9 health and safety plans and community air
10 monitoring.
11 And really it falls on the site
12 contractors to ensure that they're adhering
13 to their own personalized health and safety
14 plans. I hope that answers your question.
15 PUBLIC MEMBER MS. GREEN: Who is
16 actually, you know, I guess responsible for
17 it ?
18 MR. SMITH: Yeah, to be determined.
19 I mean, Honeywell was one of the parties
20 that performed the investigations. As far
21 as cleanup of the site, we'll have to
22 negotiate with them and potentially other
23 parties that could be used for
24 contamination in that area of the lake. I
25 mean, there is potential for several other
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2 parties with discharges that we could go
3 after. We'll have to look at those and
4 have different parties at the southern end
5 of the lake or parties as National Grid or
6 Honeywell. We'll have to look at any
7 options to any other parties that could be
8 potentially responsible.
9 PUBLIC MEMBER MS. GREEN: Is there a
10 court case that Honeywell is involved in on
11 thatorno?
12 MR. SMITH: Not for the site I
13 believe right now. No, not for the site --
14 I mean, for the lake.
15 PUBLIC MEMBER: My understanding is
16 they did kind of balk on taking
17 responsibility. So it's just something
18 that's decided between the DEC and
19 Hone ywe11?
20 MR. SMITH: Yeah. We haven't
21 reached out to Honeywell yet. We wait
22 until the Record of Decision is completed,
23 so this actually lays out the remedy.
24 And if we select a no action remedy,
25 I think Honeywell will sign on. So we have
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2 to wait until the Record of Decision is
3 completed and then negotiate with Honeywell
4 or any other parties.
5 PUBLIC MEMBER: That's typical,
6 right ?
7 MR. SMITH: That's typical.
8 PUBLIC MEMBER: You wait until then?
9 MR. SMITH: Right.
10 PUBLIC MEMBER MS. GREEN: So then my
11 other question is PFTE that don't have any
12 standards; what are your thoughts about
13 that? I mean, do you plan to elaborate,
14 like, what level of soilcrete that they
15 were found and, you know, what if anything
16 is being done?
17 MR. SMITH: Yeah. So I'm a
18 supervisor of the PFTE issues. And
19 compared to other sites around Onondaga
20 Lake, the sites at SYW-12 are at lower
21 concentrations than other sites around the
22 lake.
23 PFTE isn't really a regulated
24 chemical right now. We don't have a
25 cleanup standard as the EPA hasn't really
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2 investigated it. It's still kind of -- we
3 can't really do a cleanup on it, because
4 there is no cleanup levels for it.
5 PUBLIC MEMBER MS. GREEN: Right.
6 Yeah, I understand. Yeah. And what level
7 was found on Murphy's Island?
8 MR. SMITH: I can't tell you
9 offhand; I've got numbers and other reports
10 over there, but...
11 PUBLIC MEMBER MS. GREEN: I mean, we
12 do have local experts at the university and
13 people that have done studies on that and
14 published, you know, that material, so I'm
15 hoping that the DEC can take that into
16 account.
17 MR. SMITH: Right. And in the
18 future, if there is cleanup levels that are
19 protected for as part of the long-term
20 operation maintenance of the site, we have
21 got five-year reviews that are performed by
22 the EPA, and so there is numbers that come
23 out in the future that would probably be
24 incorporated, and we look at that and say
25 okay, we've got a number now, and let's
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2 compare to what we have at the site and see
3 if anything needs to be done.
4 It would be evaluating more and more
5 the number that some numbers were
6 promulgated by that we can't cleanup in
7 that, we don't have a number for.
8 PUBLIC MEMBER MS. COPPOLA: I had a
9 couple of questions.
10 MR. SMITH: Can you state your name
11 and stuff like that?
12 PUBLIC MEMBER MS. COPPOLA:
13 Hilary-Anne Coppola.
14 So less than half of the area is
15 being remediated, right? So after that,
16 the averages of the contaminants will go
17 down, which is misleading, and so I'm
18 wondering what DEC'S plan is to adequately
19 portray the un-mediated sites to the
20 public, the averages. That's my first
21 question.
22 MR. SMITH: Yeah. So in the
23 proposed plan we do mention how averages
24 would be reused overall site-wide, it
25 doesn't mean as we stated; also, the site
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2 areas that will be cleaned up, a lot of it
3 will be contamination removal remaining at
4 the surface. We don't necessarily look at
5 the averages. The averages are more to say
6 okay, they have now been reduced, but we
7 haven't cleaned enough, so I -- can you
8 repeat your question a little more?
9 PUBLIC MEMBER MS. COPPOLA: Right.
10 It would be misleading to the public and
11 not having the scientific background to
12 understand the data and the report, so
13 they're seeing a simple reduced average for
14 the proposed remediation, which is less
15 than half the site. So I wonder if there
16 is a way that you can communicate with the
17 public that there is an un-mediated
18 portion, so those averages, there are
19 random places of contamination that are
20 hotspots, and that's reflected in the
21 random sampling and I'm curious about that
22 at the end of the trail, it's important
23 that the public know what the risks are.
24 MR. SMITH: Yeah. And so as stated
25 in the proposed plan, in several areas that
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2 we know we're not remediating the whole
3 site, because of the eagle habitat, so
4 there could be areas where there is
5 contamination present.
6 We will perform additional sampling
7 before the remedy is constructed. I think
8 we want to get more information and find
9 out if there are hotspots present. If we
10 find something that's concerning to us, we
11 would look to see if it is reachable
12 without disturbing trees or something. We
13 might look at performing some remediation
14 there. If not, it is — if it's not
15 acceptable, then maybe it's something that
16 we look at some preferred other actions
17 such as Mark said, maybe we look at some
18 fencing or something like that.
19 I think it would depend on a
20 case-by-case basis what information you
21 have. Of course, we might not get every
22 piece of information on every part of the
23 site as far as transmitting that to the
24 public, I guess that's kind of a difficult
25 issue, I guess.
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2 I think we'd have to — once again,
3 that might depend on what we find when we
4 do the additional samples. If we don't
5 find a bunch of high levels, then maybe
6 it's not a concern. If we do find a high
7 area of contamination, then I think we'll
8 try to make the public aware of that; so it
9 would vary a lot on a case-by-case basis.
10 MR. SERGOTT: But in a sense that
11 information is available to the public
12 because of the proposed decision dock is
13 showing the data across the site, and so
14 does the remedial investigation. We
15 include in the decision the document, the
16 area weighted average is really just the
17 basis of the comparison, just so it's
18 relatively the magnitude of remediation of
19 the overall site line average
20 concentration. It's not meant to be
21 misleading, it's just to say hey, the
22 remedy will reduce consultation and also
23 with the cap itself, it will be placed in
24 the area where we have the highest
25 concentrations, and we're trying to balance
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2 the, you know, remedy with disturbances to
3 the mature forest; we don't want to
4 interfere with the eagle population, we
5 don't want to disrupt the eagle population,
6 and we don't want to damage the forest,
7 impact the forest, we want to be able to
8 maintain that. So that's why we're not
9 removing the soil or covering the soilcrete
10 in those areas.
11 And I would say just generally the
12 figures that we do include aren't
13 misleading in the sense that they do show
14 that it is there, it's just not being
15 remediated.
16 PUBLIC MEMBER MS. GREEN: For
17 example, when you go on the trails, it just
18 says environmental sensitive area, which is
19 really not very forthcoming, it really
20 should say environmentally dangerous area,
21 at least, so if you want people to stay on
22 the trails.
23 You really need, I think, a little
24 bit more way of bringing up the issue to
25 people that it is dangerous.
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2 I mean, I was on the trail a few
3 months ago and, you know, the trail is
4 almost right on the shore, the beginning of
5 it. I can just see so many kids being
6 tempted to go right off the trail into the
7 water. I mean, the county is the lead, so
8 people think that the lake is okay, you
9 know. It's like there is a lot that needs
10 to be, you know, brought up to the public
11 consciousness. There is a lot of people
12 moving into the area that have no idea of
13 the history of Onondaga Lake, some who fish
14 still, you know, eat the fish that can't
15 speak the language, you know. There is all
16 kinds of ways that it has to be more
17 publicly identified.
18 MR. SERGOTT: Yeah. It would have
19 to be incorporated into some signage.
20 PUBLIC MEMBER MS. COPPOLA: Which
21 leads to my second question, which maybe
22 Mark can answer more fully.
23 So the DOH did collaborate on the
24 great fish consumption signs that Onondaga
25 County refuses to use, the City uses those.
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2 I'm concerned about the signage in the area
3 since the standards of childhood cancer has
4 changed, and that information needs to be
5 very prevalent on the site. And nowhere in
6 the proposed plans is signage given, so I'm
7 curious about what does that look like,
8 when are we going to see that and, you
9 know, are we going to see appropriate
10 signage, because we do have children in our
11 community who have extremely elevated
12 mercury, because of inadequate signing.
13 And the fact that Onondaga Lake and
14 the area is really polluted, there will be
15 children on the trail and there will be
16 people with families, and if they're not
17 really made aware of that risk and making a
18 choice, they might think they can let their
19 kids go out on the trail.
20 And I know two-year olds can put
21 dirt in their mouths very easily, so I say
22 the current signage is not appropriate for
23 thos e kids.
24 MR. SERGOTT: Sure, I can take a
25 stab at it. I don't know if it's a
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2 particular answer, but I can admit the
3 issue of signage and what to put on signs
4 is always a debate, it's always a
5 challenge, because there are so many people
6 that are coming to the table with various
7 backgrounds and various interests, you
8 know, and always want to include kind of
9 what their focus is.
10 I mean, in terms of the signage
11 that's in place right now, and this very
12 same issue came up when they completed the
13 recreation trail on the western portion,
14 which is always, I understand, the signage
15 that's is up, it's not the best suitable
16 signage for everybody.
17 But really, I respect your question.
18 I understand the concern. And really, it
19 comes down to collectively working with the
20 various entities that are involved with
21 managing these trails. I've always, in
22 addition to signage, say an
23 information-type kiosk I always thought was
24 a good idea, and I think we tried to do
25 that with west points 1 to 8 when they
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2 constructed the recreational trail on the
3 amphitheater, but through time and through
4 observation and see how the trail is being
5 managed, and at least through the
6 implementation of the site management plan,
7 again, the county will be, you know,
8 basically leading the way with ensuring
9 that people are, in fact, staying on the
10 trial.
11 And again, if it's found through
12 when the trial is opened that it's not,
13 we'll have to take the necessary
14 precautions, and if we need to expand
15 signage or provide some further information
16 to help educate people on exactly what is
17 there, that's something that we'll have to
18 deal with that at that appropriate time.
19 PUBLIC MEMBER MS. COPPOLA: So
20 regarding of the people going off the
21 trail, that's up to the county to report
22 instances, because it happens all the time.
23 Where the no fishing signs are, you can see
24 the trails down at the lakeshore where the
25 people are fishing, and I'm assuming that
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2 the county is aware of that.
3 MR. SERGOTT: Yeah, the county is
4 the owner of the property and the county is
5 in charge of the oversight of security.
6 And in the event that this is becoming a
7 bigger concern than what we're led to
8 believe -- I mean, for the time or the
9 period of time now that the trail has been
10 opened, we haven't, me personally, I
11 haven't been informed of these situations
12 occurring, but these are very real
13 discussions that I have had with the DEC
14 and the county staff and the exact same
15 concerns we had about the people migrating
16 off the trail. With west beds 1 to 8,
17 they're a little different, because we
18 actually covered the entire west bed.
19 Here, we understand that there is
20 circumstance of that in the disturbance of
21 the habitat, the wildlife, it's a challenge
22 here to portray to the public to stay on
23 the trai1 .
24 But again, even in the areas that
25 aren't covered, we can appreciate the fact
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2 over time Mother Nature has provided pretty
3 dense vegetation for the areas and provide
4 at least some sort of coverage, at least in
5 overlaying areas.
6 MR. SMITH: Yeah, the signs
7 regarding the fish are a little bit
8 different; they're a similar issue, I mean.
9 PUBLIC MEMBER MS. COPPOLA: Right.
10 I was just saying the contact is my
11 concern, it is on-going. I've got you.
12 MR. SMITH: Thank you. Anymore
13 questions?
14 Hopefully it sort of answers your
15 question. We understand the question, but
16 I think it's something we are aware of and
17 we'll have to keep an eye on as part of the
18 oversight management going forward.
19 Any other questions?
20 PUBLIC MEMBER MS. GREEN: Is the
21 level of the lake going up in general
22 because of, you know, the global warming
23 and the weather changes and that kind of
24 thing?
25 MR. SMITH: Right. The lake
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2 fluctuates a lot, but the lake level is
3 driven by the canal system, so they manage
4 all that, so I don't think it should be
5 dramatically.
6 We have instances where it will
7 raise up to higher levels, but over time,
8 it will recede back. But I think overall,
9 this is not like an upward trend, just
10 because it's managed by the canal system
11 and the elevation will drain down to the
12 Great Lakes and stuff, so I haven't seen
13 any trends .
14 I mean, it's something that we'll
15 have to keep an eye on for all the sides
16 around the lake in general, but I don't
17 think we've seen a general trend. It is
18 managed. As long it is they're in place,
19 there is no major issue.
20 Anybody else have any questions?
21 If not, I'll be available after, and
22 if you want to come up, feel free. And
23 like I said, my contact is up there and the
24 information is available on the repository
25 that is online, and I appreciate everybody
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2
coming tonight.
3
Thank you.
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2 CERTIFICATE
3
4 STATE OF NEW YORK )
5 ) s s . :
6 COUNTY OF ONONDAGA )
7
8 I, Mary Agnes Drury, a Notary Publie
9 within and for the State of New York, do
10 hereby certify that the within is a true
11 and accurate trans cript of the proceedings
12 held on January 31, 2 0 2 3.
13 That I am not related to any of the
14 parties to the action by blood or marriage;
15 and that I am in no way interested in the
16 out c ome of this matt er.
17 IN WITNESS WHEREOF, I have hereunto
18 set my hand this 23rd of February, 2023.
19
21 Mary Agne s Drury
22
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signs
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SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-e
WRITTEN COMMENTS RECEIVED DURING THE COMMENT PERIOD
-------
-—I
—J .^fK Department of
c~state Environmental
Written Comment Form Vs" conservation
RE; Proposed Remedy for SYW-12 State Superfund Site
Piease use this form if you would like to provide written comments to the New York State Department of
Environmental Conservation {DEC), This form can be returned at the registration table, mailed, or emailed
using the information below and must be received fay DEC by February 18, 2023. The proposed plan and
other project documents can be found through the DECinfo Locator'
https://vtfww.deG.nv.gov/data/DecDocs/734075A/.
Mail or email to:
Tracy Alan Smith, Project Manager
NYSDEC
625 Broadway, 12th hoor
Aibany, New York l??33-7013
tracy. smith@dee, ny_gov
(PScase Print} ^
Name: * Affiliation: (if any)
Address: r" E-mail / Phone A-
*************************************
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Department of
EnwIrsniTisntal
Conservation
-------
Smith^rac^DEC)
From: donna muhs-mccarten
Sent: Friday, February 3, 2023 7:08 PM
To: Smith, Tracy (DEC)
Subject: clean up
You don't often get email from dmuhsmccarten@gmail.com. Learn why this is important
ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or
unexpected emails.
Please clean up the are and do it well and safely including protecting the robins and small animals and place signage
there that this land belongs to the onondaga nation , or at the very least acknowledge their contribution to this area.
Thanks
l
-------
Smith^rac^DEC)
From: Jessica
Sent: Thursday, February 9, 2023 2:34 PM
To: Smith, Tracy (DEC)
Subject: Public Comment for Remediation of Murphys Island Plan
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Hello,
My name is Jessica Gorman and I grew up in Liverpool with Onondaga Lake. I am concerned that
this plan is at most a partial remedy and NOT fully protective of public or ecological health."
NYSDEC and Environmental Protection Agency (EPA) data show PAHs, pesticides, PCBs, and metals (including mercury)
distributions are random with multiple, wide-spread exceedances of soil standards that regulate risks for "passive use"
(ie. walkers, bikers) and birds, insects, and other animals. Risks to insectivorous birds and small mammals are at
unacceptable levels.
The site also includes "emerging" chemicals, such as PXE and PTE. Since there are no EPA or DEC standards for these
emerging chemicals, the DEC will not include these in monitoring.
NYSDEC should consider additional alternatives: DEC could mandate either staged remediation and replanting of the
forested areas to avoid disrupting the roosting eagles or remediation which relies on scattered or less intrusive methods.
Polluting companies should not be able to use habitat emergence to avoid their remediation responsibility.
NYSDEC should recalculate and publicize the risks remaining in the un-remediated areas.
Much of the un-remediated, forested area lies along the Murphy's Island Spur Trail or between the trail and Onondaga
Lake, where site visitors may be most likely to stray off-trail. The risks posed by accessing these areas should be re-
evaluated to ensure public safety. The calculated cancer risk for child recreators is 0.6 additional cancers for every
10,000 exposed children. Although this is below EPA's "acceptable risk" level of 1 additional cancer per 10,000 people
exposed, site users might not want to expose children to this risk for the sake of a short walk.
NYSDEC must ensure adequate and appropriate signage: Current Onondaga County signs stating "Stay on the Trail:
Environmentally Sensitive Area" is a highly ineffective control.
Clear and complete information about the health risks posed by this site to potential users must be available on-site.
People have been walking off-trail at Murphy's Island since the trail was built in 2022.
NYSDEC's proposed plan impedes the Onondaga Nation's responsibility to take care of their lands, waters, people, and
other beings by allowing toxic pollution to remain and pose a potential health risk to visitors. Murphy's Island is within
unceded Onondaga territory.
The proposed plan, without modification, allows for public misperception of the level of clean-up that has occurred and
the risks associated with recreating in and around Onondaga Lake.
l
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Jessica Gorman
2
-------
Smith^rac^DEC)
From: Erica Roach
Sent: Thursday, February 9, 2023 4:34 PM
To: Smith, Tracy (DEC)
Subject: Onondaga Lake Cleanup
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This is at most a partial remedy and NOT fully protective of public or ecological health.
• NYSDEC and Environmental Protection Agency (EPA) data show PAHs, pesticides, PCBs, and metals
(including mercury) distributions are random with multiple, wide-spread exceedances of soil standards that
regulate risks for "passive use" (ie. walkers, bikers) and birds, insects, and other animals. Risks to
insectivorous birds and small mammals are at unacceptable levels.
• The site also includes "emerging" chemicals, such as PXE and PTE. Since there are no EPA or DEC standards
for these emerging chemicals, the DEC will not include these in monitoring.
NYSDEC should consider additional alternatives: DEC could mandate either staged remediation and
replanting of the forested areas to avoid disrupting the roosting eagles or remediation which relies on
scattered or less intrusive methods. Polluting companies should not be able to use habitat emergence to avoid
their remediation responsibility.
NYSDEC should recalculate and publicize the risks remaining in the un-remediated areas.
• Much of the un-remediated, forested area lies along the Murphy's Island Spur Trail or between the trail and
Onondaga Lake, where site visitors may be most likely to stray off-trail. The risks posed by accessing these
areas should be re-evaluated to ensure public safety. The calculated cancer risk for child recreators is 0.6
additional cancers for every 10,000 exposed children. Although this is below EPA's "acceptable risk" level of 1
additional cancer per 10,000 people exposed, site users might not want to expose children to this risk for the
sake of a short walk.
NYSDEC must ensure adequate and appropriate signage: Current Onondaga County signs stating "Stay
on the Trail: Environmentally Sensitive Area" is a highly ineffective control.
Clear and complete information about the health risks posed by this site to potential users must
be available on-site. People have been walking off-trail at Murphy's Island since the trail was built in 2022.
NYSDEC's proposed plan impedes the Onondaga Nation's responsibility to take care of their lands,
waters, people, and other beings by allowing toxic pollution to remain and pose a potential health risk to
visitors. Murphy's Island is within unceded Onondaga territory.
• The proposed plan, without modification, allows for public misperception of the level of clean-up that has
occurred and the risks associated with recreating in and around Onondaga Lake.
Thank you.
Erica Roach
Sent from my iPhone
l
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Smith^rac^DEC)
From: Sue Eiholzer
Sent: Thursday, February 9, 2023 4:45 PM
To: Smith, Tracy (DEC)
Subject: NYS Department of Conservation (NYSDEC) proposed "clean up" of Murphy's Island.
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Dear Ms Smith
This is at most a partial remedy and NOT fully protective of public or ecological health.
NYSDEC and Environmental Protection Agency (EPA) data show PAHs, pesticides, PCBs, and metals (including mercury)
distributions are random with multiple, wide-spread exceedances of soil standards that regulate risks for "passive use"
(ie. walkers, bikers) and birds, insects, and other animals. Risks to insectivorous birds and small mammals are at
unacceptable levels.
The site also includes "emerging" chemicals, such as PXE and PTE. Since there are no EPA or DEC standards for these
emerging chemicals, the DEC will not include these in monitoring.
NYSDEC should consider additional alternatives: DEC could mandate either staged remediation and replanting of the
forested areas to avoid disrupting the roosting eagles or remediation which relies on scattered or less intrusive methods.
Polluting companies should not be able to use habitat emergence to avoid their remediation responsibility.
NYSDEC should recalculate and publicize the risks remaining in the un-remediated areas. Much of the un-remediated,
forested area lies along the Murphy's Island Spur Trail or between the trail and Onondaga Lake, where site visitors
may be most likely to stray off-trail. The risks posed by accessing these areas should be re-evaluated to ensure public
safety. The calculated cancer risk for child recreators is 0.6 additional cancers for every 10,000 exposed
children. Although this is below EPA's "acceptable risk" level of 1 additional cancer per 10,000 people exposed, site users
might not want to expose children to this risk for the sake of a short walk.
NYSDEC must ensure adequate and appropriate signage: Current Onondaga County signs stating "Stay on the Trail:
Environmentally Sensitive Area" is a highly ineffective control. Clear and complete information about the health risks
posed by this site to potential users must be available on-site. People have been walking off-trail at Murphy's Island
since the trail was built in 2022.
NYSDEC's proposed plan impedes the Onondaga Nation's responsibility to take care of their lands, waters, people, and
other beings by allowing toxic pollution to remain and pose a potential health risk to visitors. Murphy's Island is within
unceded Onondaga territory.
The proposed plan, without modification, allows for public misperception of the level of clean-up that has occurred and
the risks associated with recreating in and around Onondaga Lake.
Sue Eiholzer
Neighbors of the Onondaga Nation
4178 Coye Rd, Jamesville, NY 13078
l
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Smith^rac^DEC)
From:
Sent:
To:
Subject:
Tiffany F
Thursday, February 9, 2023 9:41 PM
Smith, Tracy (DEC)
Murphy's Island Public Comment
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Dear Tracy Alan Smith,
My name is Tiffany Fotopoulos and I reside at 315 Comstock Avenue, Apartment 11, Syracuse NY. My email is
tiff.fotopoulos@gmail.com. My phone number is 862-373-9065.
I am writing to comment on the proposed clean-up of Murphy's Island. I believe that the clean-up does not go far
enough to decontaminate the site, nor warn public visitors of the risks of being in areas that are not remediated. The
clean-up may also disrupt the eagles in the area, so alternatives like staged remediation and replanting of forested areas
should be considered.
Thank you,
Tiffany Fotopoulos
l
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Smith^rac^DEC)
From: paul tobin
Sent: Friday, February 10, 2023 7:57 AM
To: Smith, Tracy (DEC)
Subject: Murphy's Island Onondaga Lake
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unexpected emails.
NYSDEC and Environmental Protection Agency (EPA) data show PAHs, pesticides, PCBs, and metals
(including mercury) distributions are random with multiple, wide-spread exceedances of soil standards
that regulate risks for "passive use" (ie. walkers, bikers) and birds, insects, and other animals. Risks to
insectivorous birds and small mammals are at unacceptable levels.
The site also includes "emerging" chemicals, such as PXE and PTE. Since there are no EPA or DEC
standards for these emerging chemicals, the DEC will not include these in monitoring. We feel a closer
look needs to be taken and a more permeant solution found.
Thanks for your consideration
Paul Tobin Care Taker Society
215 Moonhaw Rd
West Shokan NY 12494
845 657 6818
i
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Smith^rac^DEC)
From: Julie Gozan
Sent: Friday, February 10, 2023 8:13 AM
To: Smith, Tracy (DEC)
Subject: Public Comment: Clean Up of Murphy's Island and Onondaga Lake
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unexpected emails.
I am writing to comment on the NYSDEC's proposed clean up of Murphy's Island on the shore of
Onondaga Lake. The proposed plan is not fully protective of public of ecological health, and allows for
public misperception of the level of clean-up that has occurred to date and the risks associated with
recreating in and around Onondaga Lake. NYSDEC and EPA data show that that toxins exceed soil
standards that regulate risks for humans who will be walking or biking on the site, as well as wildlife.
Risks to insectivorous birds and small mammals are at unacceptable levels. DEC should mandate another
solution, such as staged remediation and replanting of the forested areas to avoid disrupting the eagles
that roost on Murphy's Island.
Much of the un-remediated area lies along the Murphy's Island Spur Trail or between the trail and
Onondaga Lake, where site visitors may be most likely to stray off-trail. The risks posed by accessing
these areas should be re-evaluated to ensure public safety. Current Onondaga County signs stating "Stay
on the Trail: Environmentally Sensitive Area" is a highly ineffective control. Clear and complete
information about the health risks posed by this site to potential users must be available on-site.
Murphy's Island is within unceded Onondaga Nation territory. Therefore it is imperative to work with the
Onondaga to make sure all plans are aligned with the Nation's appraoch to caretaking for the land,
waters, animals and humans.
Thank you for your attention.
Sincerely,
Julie Gozan
828 Maryland Avenue
Syracuse, NY 13210
goza n j@ hotma i I. com
315-477-7507
i
-------
Smith^rac^DEC)
From: Jacob Eichten
Sent: Friday, February 10, 2023 11:33 AM
To: Smith, Tracy (DEC)
Subject: Onondaga Lake - Murphy's Island
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unexpected emails.
Rev. Jacob L Eichten
327 Robinson St. / Syracuse NY 13203
(315)412-1229
Greetings Tracy,
There is a moral obligation to care for the land we live with, and the current plans as outlined for Murphy's Island fall
short of reasonable good faith efforts to meet that responsibility.
Fortunately, the Onondaga Nation remains with the land, their unceded territory, and they take seriously this obligation.
Their perspective and experience is a tremendous asset to stakeholders in seeing this process through, and their leaders
must be central to all decisions made about the land. Their guidance will ensure that we are collectively taking the care
needed to heal the water and land so damaged by previous actions on this most polluted lake in the country.
Too much of what's gone on at the lake has been to hide from reality. The risks of ignoring or low-balling the situation
are too great. Let's do our best to take care of what lies before us.
Sincerely,
JACOB L. EICHTEN
Future ancestor.
PHONE +1 (315) 412-1229
(*he/him/his)
1
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Smith^rac^DEC)
From: Amala Lane
Sent: Friday, February 10, 2023 11:47 AM
To: Smith, Tracy (DEC)
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unexpected emails.
Dear Ms. Smith,
Since the NYS Department of Conservation (NYSDEC) is inviting public comments on their proposed "clean up" of
Murphy's Island, land on the shore of Onondaga Lake, here are my comments.
Murphy's Island is a roosting site for bald eagles, whose numbers can increase to nearly 100 individuals in the winter.
And that's just the start.
This is at most a partial remedy and NOT fully protective of public or ecological health.
• NYSDEC and Environmental Protection Agency (EPA) data show PAHs, pesticides, PCBs, and metals (including mercury)
distributions are random with multiple, wide-spread exceedances of soil standards that regulate risks for "passive use"
(ie. walkers, bikers) and birds, insects, and other animals. Risks to insectivorous birds and small mammals are at
unacceptable levels.
• The site also includes "emerging" chemicals, such as PXE and PTE. Since there are no EPA or DEC standards for these
emerging chemicals, the DEC will not include these in monitoring.
NYSDEC should consider additional alternatives: DEC could mandate either staged remediation and replanting of the
forested areas to avoid disrupting the roosting eagles or remediation which relies on scattered or less intrusive methods.
Polluting companies should not be able to use habitat emergence to avoid their remediation responsibility.
NYSDEC should recalculate and publicize the risks remaining in the un-remediated areas.
• Much of the un-remediated, forested area lies along the Murphy's Island Spur Trail or between the trail and Onondaga
Lake, where site visitors may be most likely to stray off-trail. The risks posed by accessing these areas should be re-
evaluated to ensure public safety. The calculated cancer risk for child recreators is 0.6 additional cancers for every
10,000 exposed children. Although this is below EPA's "acceptable risk" level of 1 additional cancer per 10,000 people
exposed, site users might not want to expose children to this risk for the sake of a short walk.
NYSDEC must ensure adequate and appropriate signage: Current Onondaga County signs stating "Stay on the Trail:
Environmentally Sensitive Area" is a highly ineffective control.
Clear and complete information about the health risks posed by this site to potential users must be available on-
site. People have been walking off-trail at Murphy's Island since the trail was built in 2022.
NYSDEC's proposed plan impedes the Onondaga Nation's responsibility to take care of their lands, waters, people, and
other beings by allowing toxic pollution to remain and pose a potential health risk to visitors. Murphy's Island is within
unceded Onondaga territory.
• The proposed plan, without modification, allows for public misperception of the level of clean-up that has occurred
and the risks associated with recreating in and around Onondaga Lake.
l
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Links to NYSDEC information
• Fact sheet for site SYW-12:
https://www.dec.ny.gov/data/der/factsheet/734075acuprop.pdf
• Proposed Plan:
https://www.dec.nv.gov/data/DecDocs/734075A/PRAP.HW.734075A.2Q23-01-19.SYW-12%20Proposed%20Plan.pdf
For questions or concerns about Onondaga Lake issues, contact A Better Future for Onondaga Lake
(BFOL): onondagalakefuture@gmail.com
For information regarding the bald eagles, contact Friends of the Onondaga Lake Bald Eagles
(FOLBE): friends.ol.baldeagles@gmail.com
For learning resources related to the Onondaga Nation, contact Neighbors of the Onondaga Nation
(NOON): noon(a)peacecouncil.net
Sincerely,
Arleen (aka Amala) Lane
501 N.Tioga St. 4A
Ithaca, NY 14850
2
-------
Smith^rac^DEC)
From: Anthony K
Sent: Friday, February 10, 2023 7:36 PM
To: Smith, Tracy (DEC)
Subject: Feedback about Murphy's Island - Onondaga Lake
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unexpected emails.
Hello,
My name is Anthony Kratz and I live at 104 Sunrise Terrace in Liverpool, NY. This is regarding feedback for the proposed
plans for Murphy's Island @ Onondaga Lake in Syracuse. I believe that the plan to put a trail through a heavily
contaminated site that has such a long history of dumping toxic and carcinogenic chemicals on it is not sound. I do not
think putting a layer of soil with signs that say not to go off the path is adequate as a short or long term solution. Short
term, people will go off the trail anyway and be exposed to potentially harmful chemicals. Long term, it's a band-aid to
not remediate the root of the issue with Murphy's Island.
The transfer of the management of this heavily polluted land to a municipality will make it the problem of the
landowners if and when people get sick because of this (if that will ever even be realized that exposure there was the
cause of their illness). I am in favor of developing the land around the lake to be used as recreation so that private
interests don't have the chance to, but I think the ultimate decision should lie with the Onondaga Nation who have been
calling Onondaga Lake a sacred area for hundreds of years. Please be sure to include a representative from the
Onondaga when making decisions about this plan. The environment is very interconnected and decisions affect all of us,
as well as animals and plants.
Thank you,
Anthony Kratz
Mobile: 315-412-2881
l
-------
Smith^rac^DEC)
From: Sarah Nahar
Sent: Sunday, February 12, 2023 7:33 AM
To: Smith, Tracy (DEC)
Subject: Please consider fully protecting Onondaga Lake
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unexpected emails.
Greetings Tracy,
My name is Sarah Nahar and I am a PhD student at Syracuse University, and a visiting instructor at SUNY-ESF. My
mailing address is 2507 E Genesee St, Syracuse, NY 13224. My email address is sarah.e.nahar@gmail.com, and phone
number is 574-612-0340.
Regarding Murphy's Island, this is at most a partial remedy and NOT fully protective of public or ecological health. Your
and the Environmental Protection Agency (EPA) data show PAHs, pesticides, PCBs, and metals (including mercury)
distributions are random with multiple, wide-spread exceedances of soil standards that regulate risks for "passive use"
(ie. walkers, bikers) and birds, insects, and other animals. Risks to insectivorous birds and small mammals are at
unacceptable levels. The site also includes "emerging" chemicals, such as PXE and PTE. Since there are no EPA or DEC
standards for these emerging chemicals, the DEC will not include these in monitoring.
NYSDEC should consider additional alternatives: DEC could mandate either staged remediation and replanting of the
forested areas to avoid disrupting the roosting eagles or remediation which relies on scattered or less intrusive methods.
Polluting companies should not be able to use habitat emergence to avoid their remediation responsibility.
NYSDEC should recalculate and publicize the risks remaining in the un-remediated areas. Much of the un-remediated,
forested area lies along the Murphy's Island Spur Trail or between the trail and Onondaga Lake, where site visitors may
be most likely to stray off-trail. The risks posed by accessing these areas should be re-evaluated to ensure public safety.
The calculated cancer risk for child recreators is 0.6 additional cancers for every 10,000 exposed children. Although this
is below EPA's "acceptable risk" level of 1 additional cancer per 10,000 people exposed, site users might not want to
expose children to this risk for the sake of a short walk.
NYSDEC must ensure adequate and appropriate signage: Current Onondaga County signs stating "Stay on the Trail:
Environmentally Sensitive Area" is a highly ineffective control. Clear and complete information about the health risks
posed by this site to potential users must be available on-site. People have been walking off-trail at Murphy's Island
since the trail was built in 2022.
NYSDEC's proposed plan impedes the Onondaga Nation's responsibility to take care of their lands, waters, people,
and other beings by allowing toxic pollution to remain and pose a potential health risk to visitors. Murphy's Island is
within unceded Onondaga territory. There must be more consultation with the Onondaga, before proceeding.
In sum, the proposed plan, without modification, allows for public misperception of the level of clean-up that has
occurred and the risks associated with recreating in and around Onondaga Lake.
Thank you for your attention to this matter.
Sarah Nahar
l
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Smith^rac^DEC)
From: Mary Anderson
Sent: Tuesday, February 14, 2023 11:18 AM
To: Smith, Tracy (DEC)
Subject: Murphy's Island Clean-Up
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unexpected emails.
Tracy,
I live in Liverpool and frequent Onondaga Park. I heard about the issue of cleaning only part of the Island and not letting
the public know the risks of the polluted areas. I am hoping the DEC will listen to concerned citizens and readjust their
plans for Murphy's Island. So much time and money has been put into restoring this sacred lake for generations to
come. Let's not fall short on the full restoration.
Thank you for your time and attention.
Rev. Mary Anderson
l
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Smith^rac^DEC)
From:
Sent:
To:
Cc:
Subject:
parkerhead@earthlink.net
Tuesday, February 14, 2023 4:21 PM
Smith, Tracy (DEC)
rebekahrrice@gmail.com
Onondaga Lake contamination
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https://aka.ms/LearnAboutSenderldentification ]
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or unexpected emails.
Tracy Alan Smith, Project Manager
NYSDEC
625 Broadway, 12th floor
Albany, NY 12233-7013
Murphy's Island, on the shore of Onondaga Lake, is a roosting site for bald eagles, whose numbers can increase to
nearly 100 individuals in the winter.
Murphy's Island and Onondaga Lake harbors toxins at levels that pose threats to public and ecological helath.
NYSDEC and Environmental Protection Agency (EPA) data show PAHs, pesticides, PCBs, and metals (including
mercury) distributions are random with
multiple, wide-spread exceedances of soil standards that regulate risks for "passive use" ie walkers, etc. and birds,
insects and other animals. The site also
includes "emerging" chemicals, such as PXE and PTE.
NYSDEC should consider additional alternatives: DEC could mandate either staged remediation and replanting of the
forested areas to avoid disrupting
the roosting eagles or remediation which relies on scattered or less intrusive methods.
NYSDEC should ensure more adequate and more appropriate signage.
Thank you,
Julie M Finch
co-clerk Indian Affairs Committee
165 West 26th st„ 5E
NY, NY 10001
parkerhead@earthlink.net (mailto:parkerhead@earthlink.net)
917-613-3788
l
-------
Smith^rac^DEC)
From: Bernadette Andaloro
Sent: Thursday, February 16, 2023 3:11 PM
To: Smith, Tracy (DEC)
Subject: NYSDEC Murphy's Island "Clean Up" Plan
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unexpected emails.
Dear Ms. Smith,
As a member of the Friends of the Onondaga Lake Eagles, I would like to submit my comments during the official
comment period open until February 18, 2023.
Let me just ask, are you kidding? This is it? I must balk at the part of your mission statement that states "to prevent,
abate, and control water, land, and air pollution, in order to enhance the health, safety and welfare, of the people of
the state..."
The proposed plan to "clean up " Murphy's Island leaves:
- More than half of the site un-remediated. Where partial remedies are proposed, the data shows that risks are still too
high for the public, birds, and small mammals.
-Emerging chemicals such as PXE and PTE are still not even monitored.
-There are no plans to even warn visitors of the risks remaining from exposure to un-remediated areas. Don't people
even have the right to decide for themselves whether they want to take the risk or not?
-Where there are signs, they need to be clear and complete. The current "Stay on the Trail: Environmentally Sensitive
Area" signage is laughable. People have been walking off the trail, vandalizing the property, and disturbing the eagles
since the trail has been built.
In summary, I feel that the current "clean up" plan or lack thereof, encourages the public to believe that the risks
associated with recreating on Murphy's Island are much lower than they really are. It's shameful.
Respectfully Submitted,
Bernadette Andaloro
143 Watertree Drive
East Syracuse, NY 13057
315-664-1398
1
-------
Smith^rac^DEC)
From: Maria Boemi
Sent: Thursday, February 16, 2023 3:12 PM
To: Smith, Tracy (DEC)
Subject: Public comment on Murphy Island clean up
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unexpected emails.
Hi Tracy,
Thank you for accepting public comments on the Murphy Island clean up initiative.
It concerns me to learn that the NYSDEC's plan leaves 50% of the contaminated site untouched and allows a public trail
through the un-remediated area, with no mandated signs that warn visitors of the risks.
Clear and complete information about the health risks posed by this site to potential users must be available on-site.
People have been walking off-trail at Murphy's Island since the trail was built in 2022.
Additionally and critically, NYSDEC's proposed plan impedes the Onondaga Nation's responsibility to take care of their
lands, waters, people, and other beings by allowing toxic pollution to remain and pose a potential health risk to
visitors. Murphy's Island is within unceded Onondaga territory. The proposed plan, without modification, allows for
public misperception of the level of clean-up that has occurred and the risks associated with recreating in and around
Onondaga Lake.
NYSDEC should consider additional alternatives: DEC could mandate either staged remediation and replanting of the
forested areas to avoid disrupting the roosting eagles or remediation which relies on scattered or less intrusive methods.
Polluting companies should not be able to use habitat emergence to avoid their remediation responsibility.
I look forward to NYSDEC's careful attention to this important matter.
Respectfully,
Maria
Name: Maria Boemi
Affiliation: NOON (Neighbors of the Onondaga Nation)
Mailing Address: 238 Greenwood PI, Syracuse, NY 13210
Email Address: mbwdimarco(5)gmail.com
Phone Number: 315-663-4881
l
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Smith^rac^DEC)
From: Sharon Osika-Michales
Sent: Friday, February 17, 2023 10:45 AM
To: Smith, Tracy (DEC)
Subject: Comments on SYW-12 Site Clean Up Plans
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unexpected emails.
Tracy Alan Smith, Project Manager
NYS Department of Environmental Conservation
625 Broadway, 12th Floor
Albany, NY 12233-7013
Tracy.smithPdec.ny.gov
Dear Mr. Smith:
The number of toxic substances in the area behind Destiny Mall is shocking. There is a smorgasbord of contaminated
material in the soil and wetland. A Superfund site must be remediated regardless whether the area is used by the public
or not. Humans are not the only species harmed by pollution, as noted in the DEC report. It is absolutely not necessary
for a public walking trail to be placed through a Superfund site if that site has not or will not be completely
remediated. This is said with the exception of the eagles' roosting area along the lake, which we should preserve. We
should not disturb the birds or their habitat as best possible.)
Keep the public out of the area for their safety, period, if there is no intention of truly cleaning it up. True remediation
means removing the tainted soil, taking it off site, then replacing with "clean" fill. Reusing contaminated soil on-site is
unacceptable. It must be removed, as suggested in Alternative 3B, which is the best of the four alternatives listed, and
less expensive than Alternative #4.
It is not a necessity that a trail be around the whole of Onondaga Lake. Pedestrians can simply turn around and continue
walking in the opposite direction when they reach the Superfund site. They can view the lake, the eagles, etc. from
several locations along the already made trail. This would also mean no additional disturbance of land or avian/other
species habitat on the north side of Onondaga Lake. A large area of wildlife habitat/wetland has already been taken from
the south side of Onondaga Lake with the construction of the Amphitheatre grounds. There is already a long, well used
walking area along the lake in Onondaga Lake Park. We should and must preserve lake areas used by wildlife.
An additional reason this area should be truly remediated is the fact that Murphy's Island is unceded land. It belongs to
our local indigenous people, who had no part in polluting it. The land was promised to be returned to them and Onondaga
County reneged on that promise. I doubt that it is in the DEC'S jurisdiction to change "ownership" of Murphy's Island, but
it is the DEC'S and/or EPA's duty to ensure the area is safe. Stating that "all is well and safe" by covering up the
contaminated areas is disingenuous.
Wth Alternative #2, the end result should not be labeled as "the area has been cleaned up and is safe" when it would be
neither.
l
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Comments on the Alternatives:
Alternative 1 is not an option.
Alternative 2 is not sufficient, leaving an unsafe area that would need continual monitoring, and only monitoring every five
years does not seem often enough. If Alternative 2 is used, the Superfund site should not be open to the public to walk
near or through.
Alternative 3B is more acceptable and safer option than Alternative 2.
Alternative 4 is too costly and invasive, and would involve too much truck traffic.
Suggestions:
1) Implement Alternative 3B.
2) Stop plans to extend the trail past Destiny Mall, and sufficiently clean up the site, while protecting the eagles' habitat.
3) Remove as few trees as possible. Leave a large buffer area of trees around where the eagles roost.
4) Plant more shrubs, bushes, trees after the land is restored.
5) Remove all contaminated soil off site. Do not reuse it. Replace with clean fill.
6) Post clear, understandable signage to the general public. Most won't know what an "Environmentally Sensitive Area"
is, nor will they care. Kids especially wonder everywhere. (The same signage issue goes for immigrants, i.e., those who
fish in Onondaga Lake a lot, who cannot read English on signs that warn of fish limits that will be eaten. Signs must be
written in English and in their languages, if this has not already been done.)
7) Don't inform the public that the Superfund Site is "cleaned up" until it is truly remediated and contaminated soil is
removed from the site.
Thank you for the opportunity to comment on the SYW-12 Site Clean Up plans.
Sincerely,
Sharon Osika-Michales
4411 Vinegar Hill Rd.
Skaneateles, NY 13152
315-685-5057
osikamis@vahoo.com
2
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Smith^rac^DEC)
From: Andrew Bowes
Sent: Friday, February 17, 2023 12:53 PM
To: Smith, Tracy (DEC)
Subject: SYW-12
Attachments: carp cemetary.jpg; flotsam 2.jpg; binky.jpg
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unexpected emails.
Tracy
I am submitting comments relative to the Murphy Island project. As the DEC is more or less committed to capping just a
portion of the site to protect the public from contaminants that have existed for decades, I applaud the State in taking
this action. The area proposed at this time is about only 25% of the whole area. It leaves unaddressed the majority of
the site. Now given the site is being made publicly accessible and with a transient and resident Bald Eagle population
making it a very high-profile area (just search bald eagles Onondaga lake on Facebook) I encourage the State to be
proactive with addressing other areas on the site.
Specifically, the shoreline.
Attached are some photos of a trip I made last summer by canoe and had a picnic dinner at sunset with my wife and at
least one eagle who landed directly above us. I term this area as an Urban Wilderness. The massive trees that exist here
must be at least 75 years old. The shoreline is a unique area that has a vibrant ecosystem that has evolved over time
mostly due to being inaccessible. That is now changing. The walkway and the addition of a boat launch in the inner
Harbor will being more humans into contact with this area. There has much been said about the chemical pollutants on
the island, but I would like to speak to accumulated trash and plastics that in some areas 2 feet thick. The presence of
the Bald Eagles has really raised the awareness of this location. I urge the State to start considering a plan to mitigate
this area as well. A barge mounted vacuum truck would be effective in suctioning up the debris that has been broken
down into smaller particles without disturbing the plants and trees that are established. Humans on the shoreline are
inevitable. The new trail will introduce more people who will be naturally attracted to water, and they will find a way. I
will be encouraging the county to create an access area that can be controlled rather just informal, one from people
travelling off the beaten path. There is an existing homeless encampment at the mouth of Ley Creek at this time. With
the number is visitors coming from outside the area attracted by the ever-popular eagles there will be more people in
canoes and kayaks venturing out along this stretch of shoreline. I also encourage the State to make more funding
available for invasive species eradication, specifically, Phragmites (which abound in the site) and for Japanese Knotweed.
There are several infestations on Onondaga creek at this time. They will make their further down the watershed. Just
look along the Delaware River in Hancock.
I am attaching some photos of the shoreline. None of the photos are staged. The amount of refuse is staggering in the
way it has melded into the landscape. Of particular interest is the carp graveyard. Easily a dozen carcasses. I suggest they
are dragged in from the nearby shoals by the Eagles for a feast. Also of note is a large, overturned tree that has a bunch
of burrows. I am thinking kingfisher birds.
If you have an opportunity to follow up I would greatly appreciate a conversation
Andrew Bowes
Syracuse NY
31-952-3832
1
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Smith^rac^DEC)
From: Bollinger, Sara
Sent: Friday, February 17, 2023 11:24 PM
To: Smith, Tracy (DEC)
Cc: caseyclearyham@gmail.com
Subject: Murphy's Island Onondaga Lake
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unexpected emails.
Hello Tracy
I am Sara Wall Bollinger, Deputy Supervisor, Town of Manlius. My personal address is 99 Thompsons St, Fayetteville
13066. 315-447-7937.
The Town has not taken a stand on Murphy's Island. I submit this email as a private person.
I support salvaging the roosting areas for bald eagles. Please note that bald eagles also roost at Delta Lake. This area
may need protection as well.
The proposed partial remedy for Murphy's Island is inadequate to protect human and animal health. Unfortunately, this
island is a cesspit of unregulated toxic waste from a previous era. At a minimum, DEC should require warning signage so
that walkers understand that the site is toxic, even after partial remediation.
I also support the ultimate plan for the Onondaga Nation, Firekeepers of the Haudenosaunee, to assume control of the
health of Onondaga Lake, as is their ancestral right. The DEC should develop all plans with regard to Onondaga Lake and
its shores in collaboration with the Onondaga Nation.
Thank you
Sara
Sara Bollinger (she/her)
Deputy Supervisor
l
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Smith^rac^DEC)
From: go
Sent: Saturday, February 18, 2023 3:38 PM
To: Smith, Tracy (DEC)
Subject: Comments about remediation options for Murphy's Island - SYW-12 Site #734075A (Syracuse,
Onondaga County)
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unexpected emails.
Tracy Alan Smith, Project Manager
NYS Department of Environmental Conservation
625 Broadway, 12th Floor
Albany, NY 12233-7013
Tracv.smith@dec.nv.gov
Dear Mr. Smith:
After looking over the alternative solutions proposed for the remediation of Murphy's Island, I prefer
Alternative 2 over the other choices. I am in favor of that one because it preserves more trees than
the others (except for #1, obviously) and will disturb the Bald Eagle roost area less than the others
would.
It is also important to provide adequate signage so that people will not venture off the trail and expose
themselves to any toxins that remain in the area. It's unfortunate that the trail was approved when
most of the lake shore is already accessible for recreational activities.
Thank you for considering my opinion.
Sincerely,
Maryanne Adams
10757 State Route 34
Cato, NY 13011
i
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COUNTY OF ONONDAGA
OFFICE OF THE ENVIRONMENT
J RYAN McMAHON II
County Executive
February 15, 2022
Tracy A. Smith
Project Manager
New York State Department of Environmental Conservation
Division of Environmental Remediation, Remedial Bureau D
625 Broadway, 12th Floor, Albany, NY 12233-7013
Dear Mr. Smith,
Onondaga County (the "County") appreciates the opportunity to submit written comment on the remedy being
proposed in the Proposed Remedial Action Plan ("PRAP") by the New York State Department of Environmental
Conservation (NYSDEC) and United States Environmental Protection Agency (EPA) in consultation with the
New York State Department of Health (NYSDOH) to address contamination related to the SYW-12 site ("site")
located in the east corner of Onondaga Lake between the lake and railroad tracks in Syracuse, Onondaga County.
The County agrees with the NYSDEC and NYSDOH selected Alternative 2 based on feasibility, timing,
ecological value, habitat preservation, and disturbances to existing uses, while still being protective of human
health. All subsequent comments submitted below are to be considered under Alternative 2.
Comment #1: Implementability. The PRAP concludes that Alternative 2 "would require access across the
CSX Railroad tracks and work in proximity to the railroad, Onondaga Lake, Onondaga Creek, and Ley
Creek." While there is precedent for Honeywell to have access to CSX property/rights of way, and
potentially including access over CSX tracks, for work on other Operable Unit remedial actions in this
general area in the past, Honeywell has not signed a Remedial Action Order at this time and is not
believed to have previously moved large/heavy equipment, vehicles, workers, etc. repeatedly across CSX
tracks. The County is of the understanding that it is CSX's standard policy not to permit track crossings
involving heavy equipment, especially with respect to re-occurring crossings. Understanding that this
access is not assumed and given the landlocked nature of the site, how is access to the site to be obtained
if CSX is not agreeable? Additionally, has a contingency of cost been considered in the proposed amount
for Alternative 2 in the event of no access across CSX tracks?
Comment #2: Trail Closure and Layout. "Alternative 2 is anticipated to be completed within one
construction season." As noted at the Public Hearing on January 31st, 2023, the remedial work will take
place with adherence to the current Article 24 permit. This implies that remedial activities will occur
concurrent to peak trail usage (May through October), as the trail is closed December through April per
the Article 24. How will the involved parties work to prevent trail closures during construction? If trail
closures become necessary, how will the involved parties work to minimize the occurrence of such
closures, and what will be the procedure for communication and timing of them?
JOHN H. MULROY CMC CENTER
421 MONTGOMERY STREET - 14™ FLOOR
SYRACUSE, NEWYORK 13202 JESSE McMAHON
TELEPHONE: 315-435-2647 Director
-------
Additionally, two potential remedial areas noted in Figure 11 "SWY-12 Alternative 2" are located under
and adjacent to the existing trail. Any area that is located within the boundaries of the existing trail was
previously studied, received a change of use, and is being managed under the current draft Interim Site
Management Plan (ISMP). Therefore, the additional investigation efforts in these potential areas seem to
only lead to disturbance and possible closures in the existing trail system.
Comment #3 - Remedial Action and Trail Work Timing. The County is interested in the proposed timing
of the Remedial work especially with regards to the additional trail construction planned for SWY-12.
Benefits that should occur from coordinating these efforts are more convenient access to the worksites; a
decrease in the occurrence of trail closures and, because joint efforts should lead to a reduction in the
need for hauling and equipment use, emissions would decrease overtime. Additional benefits that might
be realized are wetland mitigation and the opportunity to cut down on waste by re-using materials. These
benefits are explained more fully below:
Wetland Mitigation. The County contends that mitigation may be required where water budget
and/or grading cannot replace wetland conditions or functions during trail construction. If the
timing of both activities were to be coordinated, the appropriate scope changes can ensure
mitigation at the time of the Remedial Action.
Material Re-use. If the Remedial Action and trail construction are not on overlapping or have
compatible schedules, then the ability to re-use excavated material for trail construction becomes
less of an immediate solution and more discussion will be needed around the ability to stockpile
onsite. Alternative 2 suggests "... should re-use of. . . materials not be possible at the Site
following remedial design evaluations, the material would need to be managed off-site."
Regardless of timing, under what conditions would re-use not be permitted?
Potential issues to be considered associated with overlapping construction activities may include limited
space for material and equipment storage, staging, the possibility of insufficient space on site and the
accommodation of two overlapping construction projects/schedules.
We appreciate the consideration of the enclosed comments and look forward to the Agency's response.
Thank you,
Jesse McMahon
Director, Onondaga County Office of the Environment
cc: Benjamin Yaus, Onondaga County
Marty Voss, Onondaga County
Brian Kelley, Onondaga County
Mark Sergott, NYSDOH
2
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DEPARTMENT OF ENGINEERING
CITY OF SYRACUSE, MAYOR BEN WALSH
Mary E. Robison, PE To:
City Engineer
John Kivlehan
Design & Construction
Kelly Haggerty Re:
Public Buildings
Marc Romano
Mapping & Surveying
Tracy A. Smith
NYS Dept. of Environmental Conservation
625 Broadway
Albany, NY 12233-7013
SYW-12 Site
Operable Unit of Wastebed B/Harbor Brook Subsite of
Onondaga Lake Superfund Site
Comments on Proposed Plan
Date: February 17, 2023
The City of Syracuse Dept. of Engineering has reviewed the Proposed Plan for Onondaga Lake
Superfund Site SYW-12. The City appreciates the investigation and design efforts, as well as
the funding directed for the remediation of contaminated soil/groundwater along the
Onondaga Lake shoreline. We believe this effort will result in further long-term
improvements to Onondaga Lake and foster increased lake usage.
We recognize that this project is led by the New York State Department of Environmental
Conservation which supersedes the floodplain management jurisdiction of the City of
Syracuse. However, as the 23.5-acre SYW-12 site is located within the city and almost
entirely within the FEMA-delineated Special Flood Hazard Area (SFHA) Zone AE for Onondaga
Lake, the City believes that the floodplain parameters of the project must be considered to
avoid potential adverse impacts from the preferred remedial alterative. The City has recently
enforced floodplain regulations for the Onondaga County Loop the Lake trail project which is
adjacent to this site. Also, high lake levels within the last several years have caused flooding
along the lake shoreline with minor damages.
Dept. of Engineering
233 E. Washington St.
City Hall, Room 401
Syracuse, N.Y. 1 3202
Office 315 448-8200
Fax 315 448-8488
Please see the attached NFIP Firmette which shows the extent of the SFHA in this section of
Onondaga Lake. The Base Flood Elevation (BFE) is 371.2 feet NAVD88, which reaches close to
the CSX railroad embankment. Preferred Alternative 2 includes adding a 2-foot-thicksoil cap
over 8.2 acres of contaminated soils (perched wetland cover and upland vegetated soil). Fill
under this alternative is estimated to be approximately 26,500 CY. This alternative indicates
that existing soils could be removed to assist in wetland restoration, but no amount or depth
is specified.
www.syrgov.net
GROWTH. DIVERSITY. OPPORTUNITY FOR ALL.
-------
Topic: Comments on Operable Unit of Wastebed B/Harbor Brook Subsite
17 February 2023
Page 2
Per our local floodplain management law (enacted with the guidance of the NYSDEC in 2016), in order to
maintain flood storage, filling within the SFHA must be offset by the same volume of excavation. Proposed
Plan Figure 11 shows the extent of the planned fill areas. A more detailed topo map is needed (CAD
program best) to determine how much fill would actually be placed within the SFHA. Fill between existing
grade and the BFE of 371.2 NAVD88 counts as fill within the floodplain. Fill above 371.2 feet would be
above the BFE and not within the floodplain.
Adding fill to the SFHA would raise lake elevations above existing conditions under higher lake levels. The
amount of lake level rise may not be great from any one project, but multiple and future projects that fill
the floodplain will increase adverse effects. We ask that the NYSDEC calculate the fill within the SFHA using
CAD software. The city believes that Alternative 2 should be modified to remove a volume of existing soil
equal and prior to placement of the proposed soil cap within the SFHA. Removed soils would need to be
placed in upland areas off site or could be placed above the SFHA on site, in accordance with state
environmental regulations. Alternative 3 could also be implemented with a no-net fill scenario as it
includes soil removal prior to soil cap placement.
To maintain flood storage, the NYSDEC could also consider balancing site fill with equal excavation outside
of the SYW-12 site but within the Onondaga Lake SFHA. Onondaga County recently utilized this off-site in-
floodplain storage method for projects within the Onondaga Lake SFHA. Coordination with Onondaga
County for floodplain storage could be considered by NYSDEC.
We appreciate the NYSDEC's review and consideration of the city's comments. We recognize the
environmental benefits of this project and will work with the NYSDEC to avoid any potential adverse
floodplain impacts. If you have any questions on these comments, please reach out to Russell Houck, PE in
the City Engineering Department at rhouck@syr.gov. phone 315-448-8059.
Sincerely,
Mcwy E.
Mary Robison, PE
Attachments
1. FEMA Firmette
2. NYSDEC Proposed Plan Figure 11
cc: Shannon Harty, Commissioner, Onondaga County Water Environment Protection
GROWTH. DIVERSITY. OPPORTUNITY FOR ALL.
-------
National Flood Hazard Layer FIRMette
m fema
Legend
SEE FIS REPORT FOR DETAILED LEGEND AND INDEX MAP FOR FIRM PANEL LAYOUT
Without Base Flood Elevation (BFE)
Zone A, V, A99
SPECIAL FLOOD
With BFE or Depth zone ae, ao, ah, we, ar
HAZARD AREAS
Regulatory Floodway
OTHER AREAS OF
FLOOD HAZARD
OTHER AREAS
GENERAL
STRUCTURES
0.2% Annual Chance Flood Hazard, Areas
of 1% annual chance flood with average
depth less than one foot or with drainage
areas of less than one square mile zonex
Future Conditions 1% Annual
Chance Flood Hazard zonex
Area with Reduced Flood Risk due to
Levee. See Notes, zonex
Area with Flood Risk due to Levee zone o
no screen Area of Minimal Flood Hazard zonex
II I Effective LOMRs
Area of Undetermined Flood Hazard zoneD
- — - - Channel, Culvert, or Storm Sewer
I 11 I 11 I Levee, Dike, or Floodwall
OTHER
FEATURES
MAP PANELS
8 — — •
Cross Sections with 1% Annual Chance
Water Surface Elevation
Coastal Transect
Base Flood Elevation Line (BFE)
: Limit of Study
. Jurisdiction Boundary
Coastal Transect Baseline
Profile Baseline
Hydrographic Feature
Digital Data Available
No Digital Data Available
Unmapped
The pin displayed on the map is an approximate
point selected by the user and does not represent
an authoritative property location.
This map complies with FEMA's standards for the use of
digital flood maps if it is not void as described below.
The basemap shown complies with FEMA's basemap
accuracy standards
The flood hazard information is derived directly from the
authoritative NFHL web services provided by FEMA. This map
was exported on 2/14/2023 at 12:57 PM and does not
reflect changes or amendments subsequent to this date and
time. The NFHL and effective information may change or
become superseded by new data overtime.
This map image is void if the one or more of the following map
elements do not appear: basemap imagery, flood zone labels,
legend, scale bar, map creation date, community identifiers,
FIRM panel number, and FIRM effective date. Map images for
unmapped and unmodernized areas cannot be used for
regulatory purposes.
CitYjOf Syracuse
560595- "I
¦ F Lr0O DWAYi
¦AREA OF MINIMAL FLOOD!HAZARD
¦ Feet 1-6 000 76° 1015 W43°4 9 N
2,000 ' '
Basemap: USGS National Map: Orthoimagery: Data refreshed October, 2020
-------
CSX RAILROADERS
ENGINEERED COVER IN NON-FORESTED AREA
- PERCHED WETLAND COVER (7.5 ACRES)
UNDISTURBED EAGLE ROOSTING HABITAT I
J
- UNDISTURBED FORESTED HABITAT (15.3 ACRES) j
\
.
P
ENGINEERED SOIL COVER IN NON-FORESTED AREA
UPLAND VEGETATED SOIL
COVER (0.7 ACRES)
(.Si' -r
p-
I
. , 'jffl
i.
ALSO INCLUDES:
- WETLAND RESTORATION/MITIGATION
- GROUNDWATER MONITORING
- MONITORED NATURAL ATTENUATION
- ON-SITE REUSE AND/OR OFF-SITE DISPOSAL OF
EXCAVATED SOIL/FILL MATERIAL
- INSTITUTIONAL CONTROLS
- BIOTA MONITORING V
- PRE-DESIGN SOIL SAMPLING AND TREE SURVEY
POTENTIAL FUTURE TRAIL
EXTENSION
PLANNED RECREATIONAL TRAIL
ALIGNMENT
UPLAND VEGETATED SOIL COVER
(0.7 AC)
125 250
I I Feet
PERCHED WETLAND COVER (7.5 AC)
nslTE BOUNDARY
POTENTIAL ADDITIONAL REMEDIAL
AREAS (E.G.. BASED ON SOIL
SAMPLING, TREE SURVEY)
SYW-12 ALTERNATIVE 2
ENGINEERED COVER ON PERIMETER AREA (8.2 ACRES),
WETLAND RESTORATION I CREATION, BIOTA MONITORING, AND MNA
HONEYWELL INTERNATIONAL INC.
SYW-12 PROPOSED REMEDIAL ACTION PLAN
SYRACUSE, NEWYORK
FIGURE 11
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
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Harborside
I UNDISTURBED HABITAT
UNDISTURBED FORESTED HABITAT (13.5 ACRES) I
SURFACE EXCAVATION I WETLAND
l RESTORATION IN PERIMETER AND INTERIOR AREAS
RESTORED NON-FORESTED WETLAND (6.5 ACRES)
REQUIRES LIMITED DISTURBANCE / RESTORATION OF |
FORESTED HABITAT (0.5 ACRES)
ENGINEERED SOIL COVER IN NON-FORESTED AREA
, - UPLAND VEGETATED SOIL
: COVER (3 ACRES)
&
-CSX RAILROADin^^K^
ALSO INCLUDES:
- WETLAND RESTORATION/MITIGATION
- GROUNDWATER MONITORING
- MONITORED NATURAL ATTENUATION
- ON-SITE REUSE OF EXCAVATED
SOIL/FILL MATERIAL (ALTERNATIVE 4A: TEMPORARY
ON-SITE CONSOLIDATION NOT SHOWN; LOCATION
TO BE DETERMINED)
- OFF-SITE DISPOSAL OF EXCAVATED SOIL/FILL MATERIAL
(ALTERNATIVE 4B)
- INSTITUTIONAL CONTROLS
- BIOTA MONITORING
- PRE-DESIGN SOIL SAMPLING AND TREE SURVEY
Tm m i
FIGURE 12
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
POTENTIAL FUTURE TRAIL
EXTENSION
PLANNED RECREATIONAL TRAIL
ALIGNMENT
UPLAND VEGETATED SOIL COVER
(3 AC)
110 220
I I Feet
SURFACE EXCAVATION / WETLAND
RESTORATION (6.5 AC)
ON-SITE CONSOLIDATION AREA
(ALTERNATIVE 4A)
POTENTIAL ADDITIONAL REMEDIAL
AREAS (E.G., BASED ON SOIL
SAMPLING, TREE SURVEY)
SITE BOUNDARY
SYW-12 ALTERNATIVE 3A/B
SURFACE EXCAVATION AND ENGINEERED COVER I RESTORATION ON PERIMETER
AND INTERIOR AREAS (10 ACRES), BIOTA MONITORING, AND MNA, WITH LIMITED TREE
REMOVAL
HONEYWELL INTERNATIONAL INC.
SYW-12 PROPOSED REMEDIAL ACTION PLAN
SYRACUSE, NEW YORK
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HANCOCK
E
Wendy A. Marsh
Direct Dial: 315-565-4536
wmarsh{a)hancocklau>. com
February 18, 2023
Via E-mail: tracy.smith@dec.ny.gov
Tracy Alan Smith, Project Manager
New York State Department of
Environmental Conservation
625 Broadway, 12th Floor
Albany, NY 12233-7013
Re: SYW-12 Site / Site No. 734075A
302 Hiawatha Blvd. West, Rear
Syracuse (Onondaga County), New York
NYSDEC Region 7
Dear Mr. Smith:
Hancock Estabrook represents Buckeye Partners, L.P. ("Buckeye"). Buckeye offers the
following comments to the New York State Department of Environmental Conservation's
(hereinafter "NYSDEC's") January 2023 Proposed Remedial Action Plan ("PRAP") for the
remediation of the SYW-12 Site: Operable Unit of the Wastebed B/Harbor Brook Subsite of the
Onondaga Lake Superfund Site No. 734075A ("SYW-12").
I. The Failure to Account for All Sources of Waste and Contamination Pathways
Undermines the PRAP
The record appears to demonstrate that one of the primary PRPs—Honeywell International,
Inc.("Honeywell")—conducted the investigation work and presented conclusions to NYSDEC,
which were then adopted as the basis for the PRAP. Omissions and potential inaccuracies in those
conclusions undermine the PRAP. Specifically, the SYW-12 Source Attribution Report dated July
2016 ("Attribution Report"), prepared on behalf of Honeywell concludes "the chemical
constituents and the associated impacts noted at the SYW-12 Property are from non-Honeywell
sources and are unrelated to Honeywell or its predecessor companies." As this fact is demonstrably
inaccurate, it calls into the question the legitimacy of the PRAP.
We note that Honeywell, the source for these conclusions, is currently engaged in litigation
over, in relevant part, responsibility for the remediation of SYW-12. Such an economic interest
presents a strong incentive to tailor the investigation and present results that minimize the
contribution of it and its predecessors to SYW-12, and emphasize the potential contribution of
1800 AXA Tower 1,100 Madison Street, Syracuse, New York 13202 | 315.565.4500 (o) 315.565.4600 (f) | hancocklaw.com
{H5024997.1}
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|fD| HANCOCK
Hi . 1 i1 ¦"
Tracy Alan Smith
February 18, 2023
Page 2
others. We respectfully submit that the remedial action plan must be based on an even-handed and
impartial assessment of the nature of the contamination on SYW-12, as well as its potential
sources. Only then will there be a reasonable assurance that the remedial and regulatory objectives
have been uniformly and comprehensively addressed.
For example, the Remedial Investigation Report ("RI") dated March 30, 2015 reports
possible SYW-12 contamination sources that are not included in either the Feasibility Study ("FS")
or PRAP. These include:
• Materials used to fill the former Onondaga Creek channel/Iron Pier area;
• Upgradient Solvay waste found during the construction of Carousel center; and
• Potential influence from Solvay Semet material as evidence by the presence of PXE
and PTE in SYW-12 soils. (Harbor Brook RI pg. 27).
It is not clear why the 'Conceptual Site Model' in the Feasibility Study (SYW-12 FS, 2022,
p. 20), and the 'History of the Site' section in PRAP (PRAP, 2023, p.3) fail to include these
sources, especially when there is not only physical evidence that Solvay waste came to be located
on SYW-12, but also the contaminants driving the remedy were found in Solvay waste. Because
the impacts of Solvay waste on SYW-12 were not discussed in either the FS or the PRAP, a
legitimate question arises as to whether the proposed remedy adequately addresses those
contaminants.
There are several sources that describe the pathways for Solvay waste materials to have
contaminated SYW-12, which are all taken from the Attribution Report, which are briefly
summarized below.
{H5024997.1}
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fflfjk HANCOCK
Miig E S T A B ROOK"
The below excerpt of the 1912 Syracuse Plate Map of Southern Onondaga Lake taken from the
SYW-12 Attribution Report (OBG, 2016), below specifically states "Soda Ash Refuse Filling".
Tracy Alan Smith
February 18, 2023
Page 3
{H5024997.1}
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HANCOCK Tracy Alan Smith
E S TAB ROOK'1' February 18, 2023
Page 4
The below excerpt of the 1915 Canal Map of Southern Onondaga Lake taken from the Attribution
Report (OBG, 2016), specifically lists "Waste Fill Solvay Process Co." Additionally, it shows that
Onondaga Creek was straightened, potentially by relocating and filling from the adjacent Waste
Fill from Solvay Process Co.
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The below excerpt from the 1938 Aerial Photograph from the Attribution Report (OBG, 2016)
shows what appears to be white Solvay waste on SYW-12.
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The below excerpt from the 1951 Aerial Photograph from the Attribution Report (OBG, 2016)
appears to show white Solvay Waste on the adjacent Carousel center property that may have
become an upgradient source of contamination for SYW-12.
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The below excerpt from the 1958 Aerial Photograph from the Attribution Report (OBG, 2016),
appears to show the continued filling of upgradient properties which may be a source of
contamination for SYW-12.
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The below excerpt from the 1966 Aerial Photograph from the Attribution Report (OBG, 2016).
appears to show the white Solvay waste upgradient of and around SYW-12.
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The below Figure in the Onondaga Lake RI/FS Site History Report, 1992 PTI
Environmental Services, confirms that Solvay Waste Beds, including Waste Bed H, were located
on SYW-12, which is consistent with the above aerial photographs and drawings. Given the
location of Waste Bed H surrounding Onondaga Creek, it seems likely that this waste would have
been used to fill and straighten and fill the former Onondaga Creek.
Finally, the Phase IB Cultural Resource Survey produced May 7, 2013, confirms that parts
of SYW-12 were filled with Solvay waste up to 4 feet in depth in order to build up the land in front
of the Iron Pier. (OBG, 2013, p. 15).
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II. Discharges Into Onondaga Lake May Have Come to Be Located at SYW-12
Honeywell operated multiple facilities since the early 1900s that discharged wastewater
contaminants into Onondaga Lake. One such facility was the Syracuse Works complex, which
operated soda ash, sodium bicarbonate, ammonium chloride, and power plants and the Willis
Avenue chlorinated benzene and chlor-alkali plants. A detailed description of the operational
histories of these plants, as well as their contribution of contaminants to Onondaga Lake, can be
found in the 2002 TAMS Onondaga Lake Remedial Investigation Chapter 4, and in the Onondaga
Lake RI/FS Site History Report, 1992 PTI Environmental Services. The effluent contents and flow
of the east flume discharge from the Syracuse Works complex, which is depicted in an excerpt
from Figure 22 of the 1992 RI/FS (PTI) and Figure 9-1 from an EPA Onondaga Lake Study
conducted in 1971 below, is another potential source of contamination of SYW-12.
Onondaga Lake
Discharge 002
(West Flume)
meters
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NOTE :
DEGREE of light SOUTH END OF ONONDAGA LAKE
CORRESPONDS TO
DEGREE of HEAT "EAST FLUME" THERMAL DISCHARGE
FIGURE 9-1
The velocity and direction of the east flume discharge point, as depicted in the EPA heat
discharge photograph above, pushed the Solvay/Allied/Honeywell mixed wastewater effluent
across the southern basin of Onondaga Lake and likely onto the shores of SYW-12. During
seasonal flooding of SYW-12 wetland areas, this waste likely deposited in the sediments at SYW-
12.
By way of summary, it appears Waste Bed H, as well as spoils from in-lake dredging, may
have been placed on SYW-12 for the Onondaga Creek channelization. It is not clear from the FS
and/or PRAP whether this was considered as contaminant sources in developing the proposed
remedy.
III. Contaminants in the Solvav Waste
Early contents of Solvay waste sent to waste beds include mixed refuse from multiple
production facilities. In fact, from 1884 to 1940, the Solvay waste beds primarily received solids
from the soda ash and ammonia caustic soda operations, but also received some wastes from the
chlor-alkali plant "one of two major sources of mercury, as well as a major source of chlorinated
compounds, to Onondaga Lake" (TAMS, 2002, p 4-9). The mixed effluent from these plants
placed in the waste beds potentially contained naphthalene, mercury, and chlorinated benzenes,
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February 18, 2023
Page 12
which are some of the remediation drivers for SYW-12. For a more complete description of the
contaminants found in Solvay waste beds see the 2002 Onondaga Lake RI (Section 4.3).
Specifically, the east flume discharge was sampled in 1971, and it was found to contain
several of the SYW-12 remediation drivers, including cadmium, chromium, and mercury, as well
as significant daily discharges of oil and grease likely containing PAHs. (Onondaga Lake RI/FS
Site History Report, 1992 PTI Environmental Services, p 79-80). The following is the effluent
mass loading characteristics of the east flume discharge.
TABLE 19. EFFLUENT MASS LOADING CHARACTERISTICS
FOR ALLIED-SIGNAL IN 1970 CLB/DAY)
East Hum® West Hume Solwry Waste Bed Overflow
(Discharge 001) (Dtsdwg* 002) (Dtscharga 003)
Substance Maximum Avaraga Maximum Average Maximum Avaraga
Total organic carbon
6.700
4,200
1,600
880
1,160
440
Nitrite IN)
220
120
„
-
--
Nitrate (Nl
..
_
_
..
124
68.9
Organic nitrogan
2,200
180
1,400
440
54S
187
Sutfata
132,000
88,700
47,000
30,000
80,600
35,400
Suifida
78
A"
5 A
A
A
A
Chloric*
1,720,000
1,079,000
660,000
487,000
5,270,000
2,980,000
Cyanide
22
A
11,4
6.8
5,0
2.0
Fluoride
370
278
97.6
69,8
34.7
19.3
Aluminum - total
745
820
S70
240
83
33
Araanic - total
A
A
A
A
A
A
Barium - total
..
..
_
..
600
220
Cadmium - total
<30
<24
<9
<7
<3.3
<2.0
Calcium - total
448,500
355,400
leeioo
113,000
2,480,000
1,100,000
Chromium - total
22,4
<8
6.8
<3.1
4.1
<1.2
Copper - total
..
_
-
33
2.2
Iron - total
1,300
700
.320
190
410
66
Lead - total
22
IS
9.1
8.1
50
17
Manganese - total
..
..
_
_
166
17
Mercury - total®
0,83
0.27
0.524
0.245
0.3
0.025
Potassium - total
14,200
9,600
_
..
31,400
14,300
Sodium - total
560,000
398,000
382,000
231,000
1,070,000
609,000
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s
HANCOCK JTyA'ZSn!i!t
£ February 18, 2023
Page 13
TABLE 19. (com.)
East Flums West Hum# Sotvey Waste Bed Overflow
(Diseharo® 0011 (Oischar«e 0021 (Discharge 0031
Substanca Maximum Average Maximum A varan* Maximum Average
Titanium • total 22 <3.6 9.t 3.4 1.7 0.55
Zirw- total 149 60 45.4 34.0 16.S <0.55
Oil and gmam 1,500 600 - - 670 60
Phenols"1
Aloicidss (chlorine! 760 60 20,000 18,500 A A
Chlorinated hydrocarbons (except
pesticides)"
Sourc« 1899 Rafuw Act Permit Application, Part B Permit Dsteriptlon, U.S. Corp of Enainsers (Campbei 1971, pers comm.).
* - indicates not rapomd.
6 A - abMSM; equivalent to not dMtcted.
c Mercury - daily analysis on a 24-hour continuous, com posits sampla.
d Pbtneis reported at 13.4 is/day (maximum) and S.8 Ibfetay (average) in earlier submittal tor Discharge 001.
• Chlorinated hydrocarbons (except pesticides! were indicated as present in Discharges 001 and 002; however, there was no method
available at the time for analyzing these substances.
IV. The Primary Remediation Drivers Appear to be PCBs and Metals
Our review of the PRAP Site History (PRAP, 2023), Feasibility Study (FS, 2022, p. 20),
and Attribution Report (2016) indicates that they improperly place primary focus on the PAH
contamination and their potential sources and pathways to SYW-12. This is contrary to the
ecological risk assessment presented in the PRAP which notes on p. 8 that "select metals and
organic compounds, namely chromium, cadmium and PCBs, pose a potential risk to communities
or organisms and to bird and mammal populations" (PRAP, 2023, p. 8). This prior assessment
indicates that the primary remediation drivers include chromium, cadmium, and PCBs. PCBs are
a noted as an unacceptable future human health risk at the site (p.7).
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The following maps from the FS display the fact that PCBs and metals are widely
distributed over large portions of the site.
POTENTIAL FUTURE TRAIL ^^SITE BOUNDARY
EXTENSION
PLANNED RECREATIONAL TRAIL
i—J ALIGNMENT
" LOWEST CONCENTRATION (44 0 ng/kg)
SYW-12 0-2 FT INTERPOLATED CONCENTRATION SURFACE
TOTAL PCBS
APPENDIX-8
HONEYWELL INTERNATIONAL INC.
SVW-12 FEASIBlLsr* STUDY
SYRACUSE NEW YORK
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POTENTIAL FUTURE TRAIL QSITE BOUNDARY CHROMIUM 0-2 FT AVERAGE SOIL
EXTENSION RESULTS
PLANNED RECREATIONAL TRAIL _ HIGHEST CONCENTRATION (320 mg/Xg)
I J ALIGNMENT
LOWEST CONCENTRATION (12.7 mg/kg)
SYW-12 0-2 FT INTERPOLATED CONCENTRATION SURFACE
CHROMIUM
APPENDIX-8
HONEYWELL INTERNATIONAL INC
SYW-12 FEASlBlirTY STUDY
SYRACUSE NEW YORK
N 4GERE ENGINEERS IMC
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SHUm
~site BOUNDARY cadmium 0-2 FT AVERAGE SOIL RESULTS SYW-12 0-2 FT INTERPOLATED CONCENTRATION SURFACE
H HIGHEST CONCENTRATION <40.0 mg/kg) CADMIUM
LOWEST CONCENTRATION (1 53 mg/kg) APPENDIX-®
HONEYWELL INTERNATIONAL INC.
SYW-12 FEASffltUTY STUDY
SYRACUSE. NEW YORK
V. Conclusion
By way of summary, because the FS and FRAP do not fully address and discuss all of the
sources of contamination of SYW-12, including the impact of Solvay waste and the associated
remediation drivers, we respectfully submit that the preferred alternative may not fully meet the
required threshold criteria.
Thank you for your consideration of these comments as NYSDEC finalizes the remedy for
SYW-12.
Very truly yours,
Hancock Estabrook, LLP
Wendy A. Marsh
WAM/slp
cc: Mark Sergott, P.G., NYS Department of Health (beei@health.ny.gov)
{H5024997.1}
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LAW OFFICE OF JOSEPH J. HEATH
GENERAL COUNSEL FOR THE ONONDAGA NATION
ATTORNEY AT LAW
512 JAMESVILLE AVENUE
SYRACUSE, NEW YORK 13210-1502
315-447-4851
Facsimile
315-475-2465
February 18, 2023
Tracy Smith
New York State Department of Environmental Conservation
625 Broadway
Albany, NY 12233-0001
tracy.smith@dec.ny.gov
Re: Proposed Plan for Murphy's Island/SYW-12
Dear Mr. Smith:
On behalf of the Onondaga Nation, I am submitting these comments on the
Proposed Remedial Action Plan ("the Plan" or the PRAP) for Murphy's Island, also
known as SYW-12. Although these comments are being submitted within the time
frame for public review of the Plan, the Nation submits these comments in its
sovereign status and under its government-to-government relationship with New York
State, not simply as a member of the general public.
In its government-to-government role, the Onondaga Nation has been engaged
with the assessment of and remedial plan development for Murphy's Island for several
years. In October 2021, the Nation reviewed and provided comments on a draft
Feasibility Study ("FS") for Murphy's Island, which included a similar site analysis
and proposals for remediation. In July 2022, the Nation reviewed and commented on a
draft version of the Plan. In both documents, the Nation raised concerns about the
DEC's failure to consider a wider range of remedial alternatives, the minimization of
continuing risks on this site, and the very limited efforts to protect trail users from the
contaminated surface soils that will not be covered, removed, or otherwise remediated
under the preferred alternative. Unfortunately, these concerns have not been addressed
by the current Plan.
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Re: Proposed Plan for Murphy's Island
February 18, 2023
Page 2
I. The Proposed Plan Should Consider a Wider Range of Alternatives to
Protect Public Health and the Environment.
The Plan considers four options for remediation - no action, the preferred
alternative which covers contaminated soils in slightly less than half of the site with
two feet of clean top soil, an alternative that adds three small areas of soil cover to the
preferred alternative, and complete removal of all contaminated soils on the site.
Because of the strong interest in preserving certain forested areas on this property,
limiting the alternatives in this way unfairly favors the DEC's preferred alternative and
it very limited, partial remediation.
Murphy's Island poses unique remediation challenges because it has emerged as
a significant roosting site for bald eagles on Onondaga Lake. During the winter
months, bald eagles are drawn to the location because of the presence of open water
just off-shore and, at times, more than 100 bald eagles have been counted roosting in
mature trees on Murphy's Island.
The bald eagle has a special place in the history and culture of the Onondaga
Nation and the Nation is committed to protecting spaces claimed by eagles. We
recognize that the removal of a foot or more of soil or placement of thick soil covers
near the base of a tree may damage roots and result in tree death. Accordingly, the
Nation has not insisted on full removal of all contaminated soil from Murphy's Island,
as it has for other contaminated sites in and around Onondaga Lake. However, the
remedial alternatives assessed by Honeywell and evaluated by DEC fail to consider a
sufficient range of options between full remediation and no remediation and do not
properly balance the goals of protecting human health and the environment and
preserving eagles.
Over the past two years, the Nation has repeatedly requested evaluation of
alternatives that would maximize remediation within the forested areas while
maintaining a healthy stand of roost trees. Specifically, the Nation asked for
consideration of targeted soil removal in areas with particularly high contamination
levels within the forested areas and limited soil removal or remediation beyond the
drip line or root line of mature roost trees. A staged removal process where sections of
the forested area are remediated and replanted over time could also be a reasonable
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Re: Proposed Plan for Murphy's Island
February 18, 2023
Page 3
alternative to consider. Any of these options could meaningfully expand the area of
remediation on this site without destroying the bald eagle roost.
Unfortunately, DEC has not required Honeywell to consider any targeted or
staged remediation alternatives that could maximize remediation of contaminated
surface soil contamination while maintaining adequate forest cover to support roosting
bald eagles. DEC has not even required Honeywell to analyze or justify the specific
forest sections or trees that are necessary to this population, simply assuming that the
entire forested area must be maintained in its current state. DEC should mandate that
Honeywell conduct a more complete assessment of the needs of the roosting eagles
and options for remediation measures that would meet those needs and not result in
significant tree loss. Without this information, DEC should not move forward with its
preferred alternative
II. The Plan minimizes lingering human health and environmental risks in its
discussion of post-remediation contaminant levels.
Historically, Murphy's Island was used as an unregulated dump for industrial
wastes, contaminated soils, and sediments dredged from polluting waterbodies, which
were deposited haphazardly across the property. As a result, contaminants are
randomly and widely distributed across the site. Dangerously elevated levels of
contaminants may crop up in an area surrounded by less contaminated soils. In
addition, there is no reason to suppose that the forested (and untouched) areas are less
contaminated than the non-forested (and remediated) areas.
A detailed review of soil contamination data for the unremediated areas of
Murphy's Island finds multiple exceedances of applicable human health-related and
ecological protection standards at various locations. Cadmium, PCB, and
benzo(a)pyrene levels exceeded applicable human health related standards a total of 14
times across seven sampling locations. PCB levels exceeded ecological protection
standards in at least eight samples across five locations and both mercury and DDT
exceeded ecological protections standards in almost every soil sample taken with the
unremediated area. Additional contaminated sites can be anticipated within the
unsampled areas of the property.
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Re: Proposed Plan for Murphy's Island
February 18, 2023
Page 4
Most concerning, the unremediated area surrounds the hiking and biking trail
recently opened by Onondaga County on the property. Site visitors who stray off the
trail, perhaps to venture closer to eagles or to Onondaga Lake or to find a spot to sit
and watch the water (there are no benches along the trail) are risking exposure to this
lingering contamination.
DEC responds to these concerns in two ways: first, it notes that pre-remediation
health risks to most site users fall within an "acceptable" range. Second, it points to a
drop in average contaminant levels across the site post-remediation. Neither argument
is persuasive.
First, DEC fails to acknowledge that site visitors engaged in intrusive work on
the site (utility workers, construction workers) or long-term exposures (potential future
child residents) will be subject to unacceptable non-cancer risks pre-remediation. In
fact, the non-cancer risk to utility and construction workers was twice the acceptable
level and the risk to child residents was eight times the acceptable level. Given that
more than half of the site remains unremediated, there is no reason to assume that this
risk has disappeared. In other words, Murphy's Island may continue to pose
unacceptable human health risks.
In addition, for other critical groups, the human health risks of the unremediated
site hover just below "safe" levels. Specifically, the cancer and non-cancer risks
created by the unremediated site (and presumably the unremediated portion of the site)
for child recreators is quite high. The calculated cancer risk for child recreators is 0.6
additional cancers per 10,000 visitors (with unacceptable risk is defined as 1 additional
cancer per 10,000 visitors) and the calculated non-cancer risk had a rating of 0.9 (a
non-cancer risk rating of 1 is considered unacceptable).
This information is especially important because the only reason to access the
site is to engage in entirely discretionary recreational activities which can easily be
relocated to many, many other sites around Onondaga Lake and the general Syracuse
area. Potential visitors need to know the actual risks created by the site, not simply
whether DEC considers those risks acceptable, to make an informed decision about
potential exposures of themselves and their children.
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Re: Proposed Plan for Murphy's Island
February 18, 2023
Page 5
Second, DEC points to the "Area Weighted Average Concentrations" (AWACs)
and the fact that post-remediation AWACs are estimated to be lower than pre-
remediation AWACs for all contaminants. Setting aside the fact that this assertion is a
simple truism (the average of any set of numbers will always be lower if any one of
those numbers is reduced or dropped to zero), lower post-remediation AWACs for the
site as a whole says nothing about whether the unremediated portions of the site are
safe, even as defined by EPA and DEC regulations. Again, this is important because,
as noted above, site visitors are far more likely to be drawn to areas near the trail or
between the trail and Onondaga Lake - areas that will not be remediated - than to
areas adjacent to railroad tracks or more distant from the trail - the areas that will be
remediated.
Rather than continuing to present the entire site as a unit, despite its disparate
treatment in terms of remediation, DEC should assess the residual exposure risk
created by the unremediated areas of the site separately. This would provide a clearer
picture of on-going exposure risks. Alternatively, if DEC believes that some
unremediated portions of the site are unlikely to be accessed by the public, it could
assess exposure risks within a defined buffer along the planned trail or between the
trail and the lakeshore - areas where visitors are most likely to be exposed to surface
soils. At minimum, DEC should acknowledge the number of locations within the
unremediated areas where contaminant levels exceed established standards.
Finally, the Nation continues to have concerns about the general methodology
for calculating AWACs. This assessment methodology assumes that contaminant
levels to unsampled locations are likely to be more similar to closer samples than more
distant samples. Given the random distribution of site contaminants, this assumption
does not seem reasonable.
III. The Plan does not include adequate institutional or engineering controls to
protect site visitors from the unaddressed site contamination.
Although DEC's preferred alternative leaves more than half of the contaminated
site untouched, Onondaga County has been allowed to build a public hiking and biking
trail through the site. This trail is surrounded by and runs directly through the
unremediated areas of Murphy's Island. Surface soils just off the trail may exceed
health-based standards for cadmium, PCBs, or benzo(a)pyrene or contain mercury,
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Re: Proposed Plan for Murphy's Island
February 18, 2023
Page 6
pesticides, and other contaminants at levels that pose risks to ecological resources or
groundwater.
Despite these on-going risks, DEC has not required any institutional or
engineering controls geared toward properly informing site visitors of this risk or
ensuring that they remain on the trail. There is no fencing or barrier along the trail,
other than the typical bollards or low railings which are easily crossed. The Plan
references signs posted by Onondaga County "requiring visitors to remain on the trail"
(Proposed Plan, p. 22). However, as described in DEC's June 23, 2021 Response to
Public Comments for the construction permits for trail itself, those signs will read
"THIS AREA IS ENVIRONMENTALLY SENSITIVE/Visitors must stay on the trail
and in designated areas at all times." This language does not convey the risk to site
visitors themselves of straying off-trail. While one may hope that trail users are as
concerned about protecting sensitive environments as they are about protecting their
own health, the reality is that the latter is likely to be a greater concern and a stronger
motivation to stay on the trail and away from contaminated soils.
At minimum, DEC must require clear and informative signs that provide
accurate information on the reasons that visitors should remain on the trail. For
example, signs might read "Stay on the Trail/Contaminated Soils Present." Even
better, DEC could require the County to create an information kiosk at the trailhead
with more detail about the contaminants on site and the geographic scope of the
remediation. With this more detailed information, the public can make an informed
choice about the exposure risks and better protect themselves and their families.
Thank you for your attention to these comments.
Sincerely,
Afma. I. locor-cf
Alma L. Lowry, Of Counsel
cc: Onondaga Nation Council of Chiefs
Jeanne Shenandoah, Onondaga Nation
Hazel Powless, Onondaga Nation/HETF
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SYW-12 SITE
OPERABLE UNIT OF THE WASTEBED B/HARBOR BROOK SUBSITE
OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-f
ONONDAGA NATION COMMENTS ON THE DRAFT SYW-12 PROPOSED PLAN
DATED JULY 5, 2022 AND NYSDEC/EPA RESPONSES
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LAW OFFICE OF JOSEPH J. HEATH
GENERAL COUNSEL FOR THE ONONDAGA NATION
ATTORNEY AT LAW
512 JAMESVILLE AVENUE
SYRACUSE, NEW YORK 13210-1502
315-447-4851
Facsimile
315-475-2465
July 5, 2022
Tracy Smith
New York State Department of Environmental Conservation
625 Broadway
Albany, NY 12233-0001
tracy.smith@dec.ny.gov
Re: Draft Proposed Plan for Murphy's Island/SYW-12
Dear Mr. Smith:
On behalf of the Onondaga Nation, I submit these comments on the Draft
Proposed Plan ("the Plan") for Murphy's Island, also known as SYW-12. The Nation
submits these comments as part of its government-to-government relationship with
New York, not as part of the general public or the public comment period on the Plan.
On October 21, 2021, the Nation provided comments on a draft Feasibility
Study ("FS") for Murphy's Island, which included a similar analysis of the site and
proposed remediation options discussed in the Plan. The Nation raised concerns about
many issues, including the minimization of continuing risks posed by this site, the
failure to consider a wider range of remedial alternatives, the use of unjustified
analytic choices, and the reliance on trail signs to be designed and placed by Onondaga
County as institutional controls for the site. The Nation incorporates these comments
by reference here. In addition, we are concerned about misleading descriptions of the
scope of and rationale for the preferred remediation alternative ("the Preferred
Alternative"), the continued reliance on AWACs to characterize the risks posed by the
site, and the minimization of the human health risks posed by the unremediated site.
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Re: Proposed Plan for Murphy's Island
July 5, 2022
Page 2
I. The Remedy Descriptions Inaccurately Suggest that Cover Placement Was
Designed to Minimize Exposure to Surface Soil Contaminants.
In several key sections of the Plan, including the overview of the remedy on the
first page of the Plan, the initial description of the Proposed Alternatives, and the final
summary of the Preferred Alternative, all suggest that the preferred remedy of placing
a two-foot soil cover in limited locations was designed specifically to cover
documented contaminant exceedances and prevent visitor exposures to these soils.
This is inaccurate and misleading. A plainer explanation of the reasons for cover
placement should be provided.
Exceedances of the relevant standards for the six representative contaminants
analyzed in the Draft Plan and the FS are widespread across the site (see FS, Appendix
3). The placement of the proposed soil cover in Alternative 2 (the Preferred
Alternative) and Alternative 3 was, in fact, driven by the absence of mature trees or
forested areas that create roosting habitat for bald eagles, not simply the presence of
contaminants in surface soil above applicable safety criteria. The Plan should be more
transparent about this rationale, particularly since the unremediated areas in
Alternatives 2 and 3 are closest to the planned Onondaga County hiking/biking spur
trail and most likely to be encountered by visitors to the site.
On the first page of the Plan, DEC asserts that the proposed remediation of the
site "includes the installation of a two-foot-thick soil cover that would be protective for
current and/or reasonably anticipated future land uses where shallow soil contaminant
concentrations are above the 6 NYCRR Part 375 Soil Cleanup Objectives (SCOs) for
Commercial Use and the Protection of Ecological Resources. . . (p. 1, emphasis
added). In the body of the Plan, Alternative 2 is described as including "the
construction of a soil cover over select non-forested wetland and upland areas of
SYW-12 based on exceedances of 6 NYCRR Part 375 SCOs for Commercial Use and
the Protection of Ecological Resources. . . (p. 11, emphasis added). Again, in the
Preferred Remedy section, DEC states that "[t]he preferred alternative includes the
installation of a 8.2 acre 2-foot thick soil cover that would be protective for current
and/or reasonably foreseeable future land uses where shallow soil contaminations are
above the 6 NYCCR Part 375 SCOs for Commercial Use and the Protection of
Ecological Resources. . . (p. 20, emphasis added).
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Re: Proposed Plan for Murphy's Island
July 5, 2022
Page 3
These descriptions suggest that these areas were singled out to receive a soil
cover because the exceedances of commercial use or protection of ecological resources
standards were highest or posed the greatest risks here. This is simply untrue. While
the soil cover as proposed will address many exceedances of applicable standards,
including one area with particularly high contaminant levels (the area adjacent to the
railroad tracks on the eastern edge of the site), contaminant levels did not drive this
selection and there are many exceedances in the unremediated areas.
Specifically, the data shows exceedances of Commercial Use standards for three
of the six representative contaminants in the surface soils left uncovered under the
preferred alternative ("the unremediated area") and exceedances of Ecological
Protection standards for all six. Within the unremediated area, there are 14
exceedances of Commercial Use standards across 7 sampling locations and 27
exceedances of Ecological Standards across 10 sampling locations. In fact, the average
cadmium level within the unremediated area exceeds Commercial Use standards. For
PCBs, 8 samples exceeded both Commercial Use and Ecological Protection standards
across 5 locations within the unremediated area. For benzo(a)pyrene, average levels
were more than double the applicable Commercial Use standard and were higher in the
unremediated areas than in the remediated areas. For DDT and mercury, almost every
sample in the unremediated area exceeded Ecological Protection standards. This data
does not support the suggestion that the soil cover in the Preferred Alternative was
driven by contaminant exceedances.
DEC does not fully explain the choice of remediated vs unremediated areas
until the Comparative Analysis of Alternatives section. There, DEC plainly states that,
under the Preferred Alternative, "soil/fill material exceeding SCOs would be addressed
within a portion of the non-forested wetland and upland area through installation of a
soil cover where accessible and not detrimental to the environment (i.e., tree removal,
disturbance of bald eagles)" (p. 16, emphasis added). This is the first complete,
accurate, and not misleading description of the Preferred Alternative in the Plan. This
description emphasizes that the location of the soil cover is driven by tree cover and
not contaminant location. This description should be incorporated into the introduction
and the earliest description of proposed remedies rather than being relegated to the last
third of a relatively long document. In addition, the Plan should include maps showing
contaminant exceedances across the site to allow the public to make its own
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Re: Proposed Plan for Murphy's Island
July 5, 2022
Page 4
assessment of the adequacy of proposed remediation and the residual risks posed by
the site.
II. The Plan inappropriately relies on an "Area Weighted Average
Concentration" to minimize the residual contamination on site.
As noted in the Nation's comments on the Draft FS for this site, the reliance on
an "area weighted average concentration" (AWAC) is inappropriate. The Nation
incorporates its earlier comments by reference, but highlights three key points here.
First, the AWAC methodology assigns likely contaminant levels to areas
between sampled sites by assuming that contaminant levels are likely to be more
similar to closer samples than to samples that are more distant. That assumption does
not appear to be justified on this site. DEC itself notes that "site contaminants are
randomly distributed across the SWY-12 site" (p. 5). While the middle of the site tends
to have lower contaminant levels than the eastern section adjacent to the railroad, at
least two sampling locations at the western end of the site had at least some extremely
elevated contaminant levels and contaminant levels do not consistently rise or fall
across adjacent sample locations. Given that there is no clear pattern of contaminant
distribution among the sample locations, it seems unreasonable and inaccurate to
assume that the unsampled areas present such a pattern.
Second, DEC's assertion that the AWAC for the site was lower post-
remediation says nothing about whether the site is safe or whether visitors to the site
might be exposed to contaminant levels above state-established safety standards. The
critical information is whether visitors to the site are likely to be exposed to
contaminants that exceed regulatory standards. This is particularly important here,
since the unremediated areas are closest to the proposed trail location where
recreational visitors are most likely to be exposed to surface soils. The remediated
areas are more distant from the trail and are less likely to be encountered by site
visitors.
The Nation believes that DEC should assess the residual exposure risk created
by the unremediated areas of the site or, alternatively, by the areas within a reasonable
buffer along the planned trail or between the trail and the lakeshore - areas where
visitors are most likely to be exposed to surface soils. At minimum, DEC should
acknowledge the number of locations within the unremediated areas where
contaminant levels exceed established standards.
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Re: Proposed Plan for Murphy's Island
July 5, 2022
Page 5
III. The Plan does not properly characterize the human health risks presented
by the unremediated site and minimizes documented health risks without
adequate justification.
As discussed in many previous reports, the unremediated Murphy's Island site
presents unacceptable human health risks. Specifically, non-carcinogenic risks to
future utility workers, construction workers, and child residents are higher than are
considered "safe" by regulatory agencies. In fact, the non-cancer risk to utility and
construction workers was twice the acceptable level and the risk to child residents was
eight times the acceptable level. However, the Plan minimizes this risk without
sufficient justification and ignores the fact that other human health risks hover just
below "safe" levels.
First, the Plan tries to explain away the risks faced by utility and construction
workers by preferencing one set of test results over another with no justification for
this choice. DEC notes that a recent round of groundwater sampling did not find the
same dangerous levels of chromium documented in the original data and seems to
simply accept the recent data and ignore the original data. This is unacceptable.
If DEC believes that the recent groundwater data, which showed lower
chromium levels in groundwater, is more likely to be accurate than the original data,
which had higher chromium results, it should explain and provide support for that
assertion. Otherwise, all of the data should stand on its own without qualification,
which means that there may still be unacceptable risks to construction workers at the
site. DEC then goes on to state that the absence of chromium also means that there is
no benzo(a)pyrene-related health risk to workers. However, since DEC does not
recalculate overall health risks without a chromium contribution, the basis for this
characterization is unclear. DEC must better support its assertions.
Second, the Plan fails to acknowledge that the health risks posed to child
recreators on the unremediated site are very close to, although not over, the acceptable
risk levels chosen by regulatory agencies. Specifically, the cancer and non-cancer risk
created by the site for child recreators is quite high. The calculated cancer risk for child
recreators is 0.6 additional cancers per 10,000 visitors (unacceptable risk is defined as
1 additional cancer per 10,000 visitors) and the calculated non-cancer risk had a rating
of 0.9 (a non-cancer risk rating of 1 is considered unacceptable). The public should
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Re: Proposed Plan for Murphy's Island
July 5, 2022
Page 6
know the actual risks created by the site, not simply whether DEC or EPA consider
those risks to be acceptable.
Again, we direct the DEC to the Nation's October 2021 comments on the
Revised Feasibility study, which remain relevant to the Plan. Thank you for your
attention to these comments.
Sincerely,
Afma. I. locor-cf
Alma L. Lowry, Of Counsel
cc: Onondaga Nation Council of Chiefs
Jeanne Shenandoah, Onondaga Nation
Hazel Powless, Onondaga Nation/HETF
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Smith^rac^DEC)
From: Smith, Tracy (DEC)
Sent: Monday, December 12, 2022 1:26 PM
To: Alma Lowry
Cc: Jeanne Shenandoah; Joe Heath; Powless, Hazel; Nunes, Bob; Sheen, Margaret A (DEC); 'Argie Cirillo
(Cirillo.Argie@epamail.epa.gov); Singerman, Joel; Pelton, Jason M (DEC); Harrington, David (DEC);
Ransom, Beynan T (DEC); Shuman, Claudia
Subject: RE: draft SYW-12 Proposed Plan (734075A)
Alma,
Thank you for sending comments on the draft SYW-12 Proposed Plan on behalf of the Onondaga Nation. Sorry for the
delay in responding. Based on our review of the comments we have the following responses:
I. The Remedy Descriptions Inaccurately Suggest that Cover Placement Was Designed to Minimize Exposure
to Surface Soil Contaminants.
Alternatives 2 and 3 state that the "remedial footprint is ecologically focused to enhance protection to ecological
receptors by reducing ecological exposure while balancing remedial activities with habitat disruption, particularly in
consideration of the extensive utilization of the Site by the bald eagle and the overall high value of the forested SYW-12
habitat." However, we agree that additional clarification should be included in the Proposed Plan for Alternatives 2 and
3 to clarify that the soil cover (e.g., an 8.2- or 10-acre cover) will be placed where accessible and not detrimental to the
environment (i.e., avoiding mature tree removal, disturbance of bald eagles, etc.). With large, mature trees present in
the forested habitat, there are areas that are not accessible for placement of the cover system, and as such, these areas
may contain site contaminants in surface soil that exceed soil cleanup objective (SCOs). The Proposed Plan will be
revised to clarify this and will include maps from the feasibility study (FS) which include the SCO exceedances (i.e.,
Figures 1-6 from Appendix 3).
II. The Plan inappropriately relies on an "Area Weighted Average Concentration" to minimize the residual
contamination on site.
While the Proposed Plan does state that "site contaminants are randomly distributed across the SYW-12 site," there is a
pattern where higher concentrations are present (as shown on Figures 1-6 in Appendix 3 and Figures 1-6 in Appendix 8
of the FS) and we are using the data we currently have to evaluate remedial alternatives. The AWACs are used as a
general basis of comparison to demonstrate, as would be expected, that remediation efforts will lower the average
concentrations across the entire site. The AWACs are not meant to finely understand the distribution and
concentrations of site contaminants, but to generally show that the remedial program will improve the conditions across
the entirety of the site.
The human health evaluation has determined that there are no unacceptable risks to human health for trail users prior
to any remediation being performed and Area Weighted Average Concentrations (AWACs) for the site would be lower
post-remediation. Although there may be SCO exceedances at specific sample locations, risks to trail users who would
be exposed to various levels of contamination across a wider area that is represented by the AWACs are minimized by
the trail cover (a minimum thickness of 1-foot or a wooden boardwalk), institutional controls (e.g., signage) and dense
vegetation present along the trail that is expected to deter the public from leaving the trail. In addition, pre-design
sampling is included under Alternatives 2 and 3 which would be used to determine if additional controls (e.g., fencing)
may be needed. Pre-design soil sampling will also be performed to update and refine the AWACs analysis and reduce
l
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uncertainties inherent in the spatial analysis techniques used in the FS by evaluating a higher density of sampling
locations.
III. The Plan does not properly characterize the human health risks presented by the unremediated site and
minimizes documented health risks without adequate justification.
The text regarding risks to utility and construction workers, and groundwater samples will be revised/clarified as
necessary. Note that the Proposed Plan states that "chromium and benzo(a)pyrene in groundwater, as calculated in the
2009 Revised HHRA Report, remain potential threats to these receptor groups"; unacceptable risks to workers are
included in Table 4; and in the Overall Protection of Human Health and the Environment analysis, it is indicated that
under Alternatives 2 and 3, risks to workers would be addressed by institutional controls, a Site Management Plan and
monitored natural attenuation of groundwater relative to potential exposure to surface and subsurface soil/fill material,
sheens and groundwater for receptors such as construction or utility workers. It should also be noted that for the child
recreator, cancer risks are within the acceptable risk range and non-cancer hazards are below the hazard
threshold. Although the calculated risk is closer to the upper end than the lower end of the acceptable risk range and
the calculated hazard is just below the hazard threshold for the child recreator, the calculated risks and hazards are
based on reasonable maximum exposure scenarios and represent the highest level of exposure that could reasonably be
expected to occur. To support this estimate of the reasonable maximum exposure, the exposure assumptions that are
used to estimate the cancer risk and the non-cancer hazard typically represent the 95th percentile of the
population. The calculated risks are, therefore, conservative (i.e., health-protective) representations of potential
human health risks.
Your letter also referenced the October 2021 Onondaga Nation comments based on review of the draft Feasibility
Study. Please note that the Department responded to these comments in an email to you dated November 23, 2021. If
you have any questions or would like to discuss, please do not hesitate to contact me. Thanks.
Tracy A. Smith
Project Manager, Division of Environmental Remediation
New York State Department of Environmental Conservation
625 Broadway, Albany, NY 12233
P: (518) 402-9796 2-9773 | tracv.smith@dec.nv.aov
www.dec.nv.gov | Hi
--/TBS# I I ^Bfci
From: Alma Lowry
Sent: Tuesday, July 5, 2022 9:25 PM
To: Smith, Tracy (DEC)
Cc: Jeanne Shenandoah ; Joe Heath ; Powless, Hazel
; Witt, David E (DEC) ; Nunes, Bob ; Sheen,
Margaret A (DEC) ; 'Argie Cirillo (Cirillo.Argie@epamail.epa.gov)
; Singerman, Joel ; Pelton, Jason M (DEC)
; Harrington, David (DEC) ; Ransom, BeynanT (DEC)
Subject: Re: draft SYW-12 Proposed Plan (734075A)
2
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ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or
unexpected emails.
Dear Tracy:
Attached are the comments being submitted for the Nation related to the Murphy's Island
Proposed Plan. Please let me know if you have any questions.
Best,
Alma
On Thu, Jun 2, 2022 at 3:55 PM Smith, Tracy (DEC) wrote:
Attached for the Onondaga Nation's review is the draft SYW-12 Proposed Plan and associated figures and
tables. Please provide any comments on this Proposed Plan by July 5th. If you have any questions, please contact
me. Thanks.
Tracy Alan Smith
NYSDEC
625 Broadway
Albany, NY 12233-7013
(518)402-9796
Alma Lowry, Of Counsel
Law Office of Joseph Heath
General Counsel to the Onondaga Nation
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