RECORD OF DECISION
Lehigh Valley Railroad Derailment Superfund Site
LeRoy, Genesee County, New York
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United States Environmental Protection Agency
Region 2
New York, New York
September 2023
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Lehigh Valley Railroad Derailment Superfund Site
LeRoy, Genesee County, New York
Superfund Site Identification Number: NYD986950251
Operable Units: 01 (Amendment) and 02
STATEMENT OF BASIS AND PURPOSE
In 1997, New York State Department of Environmental Conservation (NYSDEC) issued
a Record of Decision (ROD) for the Lehigh Valley Railroad Derailment (LVRR)
Superfund Site (Site) located in the City of LeRoy, Genesee County, New York,
denominated by EPA as Operable Unit (OU) 1, which addressed contamination in soil
and bedrock and provided impacted properties a connection to the public waterline. In
July of 1999, following the January 1999 final listing of the Site on the National Priorities
List (NPL), the U.S. Environmental Protection Agency (EPA) concurred with the
waterline component of the NYSDEC remedy, and, subsequently, in May 2002,
concurred with the soil and bedrock components of the NYSDEC remedy. This decision
document presents a comprehensive remedy for the Site through a remedy amendment
for OU1 and the selection of a remedy for OU2 to address contamination in the
groundwater, soil, bedrock, soil vapor and surface water.
The selected remedy was 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. This ROD explains the
factual and legal basis for selecting a remedy to address the contamination at the Site.
The attached index (see Appendix III) identifies the items that comprise the
Administrative Record upon which the selected remedy is based.
The New York State Department of Environmental Conservation (NYSDEC) was
consulted in accordance with CERCLA Section 121(f), 42 U.S.C. § 9621(f), and), in
consultation with the NYS Department of Health (DOH), it partially concurs with the
selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the 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.
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DESCRIPTION OF THE SELECTED REMEDY
The Site cleanup is being addressed as two operable units. The response action
described in this document amends the OU1 remedy selected by NYSDEC in 1997 and
selects a remedy for OU2. The major components of the OU2 remedy by medium are:
1. Groundwater - For the approximately four-mile trichloroethylene (TCE) plume,
implementation of a combination of monitoring and institutional controls (ICs)
while invoking a technical impracticability (Tl) waiver for chemical-specific
groundwater standards in the Tl Zone1 because groundwater cannot be restored
in a reasonable timeframe. Outside of the Tl Zone, the groundwater standards
will remain as the final cleanup goal. Long-term monitoring and groundwater use
restrictions will be required.
2. Bedrock Vadose Zone (BVZ) - ICs and Groundwater Monitoring in the BVZ.
The BVZ and the groundwater in the Spill Zone (the 10-acre area of the original
TCE spill) are within the Tl Zone.
3. Soil in the Spill Zone - Excavation/Disposal - Soil exceeding 6 NYCRR Part 375
TCE soil cleanup objectives for commercial use (200 milligrams per kilogram
(mg/kg)) to a depth up to 10.5 feet below ground surface (bgs) will be excavated
and properly disposed of off-Site. The area will be backfilled using clean,
imported soil and/or stone underlain by a demarcation layer. Placement of topsoil
and seed to provide for one foot of clean soil cover will extend to any areas of the
Spill Zone where concentrations of TCE in surface soil exceeds 2 mg/kg, which is
the New York State (NYS) value for the protection of ecological receptors.
4. Surface Water (Section of Mud Creek): In-situ treatment of contaminated
surface water with streambed cover, ICs, and monitoring.
In addition, disturbed areas (including vegetated surfaces, roadways, sidewalks, curbs,
etc.) will be restored to their original pre-construction condition and topographic contour
following the completion of remedial construction.
5. Common Elements Applicable to all Media:
a. ICs in the form of governmental controls (see Appendix C of the Feasibility
(FS) Study Report); proprietary controls (e.g., easements on Spill Zone
parcels); and informational devices relating to groundwater, soil vapor,
and the Spill Zone (e.g., notices, publications) to limit exposure to
contaminated soil, groundwater and soil vapor;
1 The Tl Zone includes the portion of the groundwater in the Spill Zone and the plume downgradient to
Spring Creek where the federal and state drinking water and groundwater standards cannot be achieved.
(See Figure 4).
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b. Monitoring, which includes sampling of groundwater, surface water, soil
vapor and indoor air as follows:
i. A long-term groundwater and surface water monitoring program will
be implemented to track and to monitor changes in the groundwater
contamination to ensure the RAOs are attained.
ii. The groundwater data results will be used to evaluate any contaminant
migration and changes in VOC contaminants over time.
iii. Soil vapor and indoor air samples will be collected to ensure continued
protection for impacted properties.
c. Maintenance of existing sub-slab depressurization systems (SSDSs) and
installation of new systems, as needed, for impacted properties; and
d. Connection of new homes constructed over the groundwater plume to the
current municipal water supply system or the provision of a point-of-entry
treatment system if connection to the municipal system is not feasible.
With this comprehensive remedy for the Site, EPA is also amending the following
components of the NYSDEC 1997 ROD (denominated by EPA as OU1):
1. Eliminating the bedrock vapor extraction source control measure;
2. Eliminating ex-situ soil vapor extraction, as it was implemented for two years;
3. Updating the surface water standard for TCE from the original cleanup goal of 11
micrograms per liter (jjg/L) to the current NYSDEC standard of 40 |jg/L;
4. Addressing soil contamination beneath Gulf Road by implementing ICs to restrict
access and to require proper soil management if the roadbed is disturbed in the
future; and
5. Updating the RAOs to recognize the waiver of certain Federal and state drinking
water and groundwater standards at the Site because of the technical
impracticability of achieving the standards throughout the Tl Zone.
A Site Management Plan (SMP) will also be developed for long-term operation and
maintenance (O&M) to provide for:
a) reviews of the effectiveness of the engineering and institutional controls;
b) proper management of the Site remedy post-construction;
c) long-term groundwater monitoring and health and safety requirements for
managing contaminated media that remain in place under Gulf Road;
d) maintenance of existing vapor mitigation systems;
e) inspection of the plume area for new home construction and associated
installation of new vapor mitigation systems; and
f) new connections of new homes constructed over the groundwater plume
to the current municipal water supply system or the provision of a point-
of-entry treatment system if connection to the municipal system is not
feasible.
The environmental benefits of the selected remedy may be enhanced by consideration,
during the design, of technologies and practices that are sustainable in accordance
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with EPA Region 2's Clean and Green Energy Policy and NYSDEC's Green
Remediation Policy.2 This will include consideration of green remediation technologies
and practices.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in CERCLA
Section 121, 42 U.S.C. § 9621, because it: 1) is protective of human health and the
environment; 2) meets a level or standard of control of the hazardous substances,
pollutants, or contaminants that at least attain the legally applicable or relevant and
appropriate requirements under federal and state laws; 3) is cost-effective; and 4)
utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable.
Because the selected remedy will result in contaminants remaining on-Site above levels
that allow for unlimited use and unrestricted exposure, CERCLA requires that the Site
remedy be reviewed at least once every five years. Also, provisions will be made for
periodic reviews and certifications of the institutional and engineering controls. If
justified by these reviews, additional remedial action may be implemented at the Site.
ROD DATA CERTIFICATION CHECKLIST
The ROD contains the remedy selection information noted below. More details may be
found in the Administrative Record file for this remedy.
• Contaminants of concern and their respective concentrations (see Appendix II,
Tables 1-1 to 1-6 and Tables 2-1 to 2-3);
• Baseline risk represented by the contaminants of concern (see ROD, pages 14 -
21 and Appendix II, Tables 3 - 8);
• Cleanup levels established for contaminants of concern and the basis for these
levels (see ROD, page 25 and Appendix II, Table 9);
• Manner of addressing source materials constituting principal threats (see ROD,
page 42);
• Current and reasonably anticipated future land use assumptions, plus current
and potential future beneficial uses of groundwater used in the baseline risk
assessment and ROD (see ROD, page 15);
• Potential land and groundwater use that will be available at the Site as a result of
the selected remedy (see ROD, page 15);
2 See http://epa.qov/reqion2/superfund/qreen remediation. https://semspub.epa.qov/work/HQ/100000160.pdf and
also NYSDEC guidance at http://www.dec.nv.qov/docs/re-mediation hudson pdf/der31.pdf.
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• 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, pages 27, 31 and 33 and Appendix II, Tables 11a -11e);
and
• 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 45 - 47).
AUTHORIZING SIGNATURE
Evangelista
Pat
Digitally signed by Pat
Evangelista
Date: 2023.09.28
16:45:55 -04'00'
September 28, 2023
Pat Evangelista, Director
Superfund and Emergency Management Division
EPA Region 2
Date
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DECISION SUMMARY
Lehigh Valley Railroad Derailment Superfund Site
LeRoy, Genesee County, New York
United States Environmental Protection Agency
Region 2
New York, New York
September 2023
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Table of Contents
SITE NAME, LOCATION, AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
OU1 Remedy and Remedial Action 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF RESPONSE ACTION 4
SUMMARY OF SITE CHARACTERISTICS 5
Site Geology and Hydrogeology 5
NATURE AND EXTENT OF CONTAMINATION 6
Soil 6
Bedrock 7
Groundwater 8
Surface Water 12
Private Well Investigations 12
Vapor Intrusion 13
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 14
SUMMARY OF SITE RISKS 14
Human Health Risk Assessment 15
Screening Level Ecological Risk Assessment (SLERA) 20
Summary of Human Health Risks 21
REMEDIAL ACTION OBJECTIVES 21
Remediation Goals 24
Common Elements of the Alternatives 26
Bedrock Vadose Zone (BVZ) Remedial Alternatives 27
Surface Water (SW) Remedial Alternatives 29
Soil Remedial Alternatives 31
COMPARATIVE ANALYSIS OF ALTERNATIVES 33
Bedrock Alternatives 34
Surface Water Alternatives 36
Soil Alternatives 39
PRINCIPAL THREAT WASTE 41
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SELECTED REMEDY 42
Summary of the Rationale for the Selected Remedy 42
STATUTORY DETERMINATIONS 46
DOCUMENTATION OF SIGNIFICANT CHANGES 48
Attachments
APPENDIX I: FIGURES
APPENDIX II: TABLES
APPENDIX III: ADMINISTRATIVE RECORD INDEX
APPENDIX IV: STATE LETTER OF CONCURRENCE
APPENDIX V: RESPONSIVENESS SUMMARY
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SITE NAME, LOCATION, AND DESCRIPTION
The Lehigh Valley Railroad (LVRR) Derailment Superfund Site (Site) is located in
Genesee, Monroe and Livingston Counties, New York. The Site is divided into two
main areas, the Spill Zone and the Study Area. The Site is characterized by
contaminated soil, bedrock and surface water in the Town of LeRoy, Genesee County,
and by contaminated groundwater in Genesee, Monroe, and Livingston Counties.
The Spill Zone is approximately 10 acres in size and is defined as the physical location
of the 1970 train derailment which resulted in contamination of overburden soils and
bedrock with trichloroethene (TCE), in the vicinity of the former LVRR crossing at Gulf
Road (Figure 1). The Spill Zone also includes a former railroad bed, a former quarry
material staging area, and the foundation of a former hotel. Currently, the 10-acre Spill
Zone is mostly undeveloped industrial, commercial, residential, and passive
recreational land, largely covered with grass, brush, and wooded areas.
The Study Area is larger and is roughly bounded by the Oatka Creek Valley to the
north, the Dolomite Quarry and Hanson Quarry to the west, Route 5 to the south, and
Spring Creek Valley to the east (Figure 2). The Study Area includes a TCE-impacted
groundwater plume emanating from the Spill Zone which extends eastward
approximately four miles to Spring Creek. Mud Creek, an area of interest, is a
frequently-dry stream bed which carries substantial water flow during flood events and
is located approximately 600 feet (ft) to the east of the Site.
The Site cleanup is being addressed in two phases, or operable units (OUs). OU1
addresses the provision of an alternate water supply to area residences and
businesses that were or have the potential to be impacted by the LVRR-contaminated
groundwater plume, as well as contamination within the Spill Zone that is present in soil
and extending into the bedrock. OU2 addresses the approximately four-mile
contaminated groundwater plume, the contaminated groundwater discharging to
surface water, as well as contaminated vapors that may migrate into residences as a
result of soil vapor intrusion.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Site is the location of a former train derailment that occurred on December 6, 1970,
at the Gulf Road railroad crossing in the Town of LeRoy. The train, operated by the
potentially responsible party (PRP), the Lehigh Valley Railroad Company, derailed, and
two tank cars containing TCE ruptured and spilled their contents (estimated at 30,000
gallons) onto the ground. As mentioned above, this area is referred to as the 10-acre
Spill Zone. TCE is the primary contaminant of concern (COC) and is a chlorinated
volatile organic compound (VOC), commonly used as a solvent. A third car containing a
crystalline form of cyanide was also reported to have partially spilled. The cyanide was
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recovered shortly after the derailment; however, the TCE infiltrated into the ground and
was not recovered.
In early 1971, residents near the Site complained of TCE odors in homes and reported
contamination of nearby drinking water wells. The PRP conducted limited cleanup
activities at the spill location in response to the residents' concerns. Ditches were
constructed in the Spill Zone and were flooded with water to flush the TCE out of the
ground. Carbon filters were installed on several private wells to remove TCE from
drinking water.
In 1990 and 1991, the New York State Department of Health (NYSDOH) sampled
private water wells east of the Site and discovered TCE concentrations in more than 35
residential wells above the NYSDOH drinking water standard of 5 micrograms per liter
(|jg/L). Based on this information, EPA installed point-of-entry carbon treatment units
(POETs) on all contaminated private wells. In November 1991, the Site was added to
the NYS Registry of Inactive Hazardous Waste Disposal Sites.
In 1992, NYSDEC initiated a remedial investigation and feasibility study (RI/FS) under
State law for the Site, completed an Rl Report in 1996, and two FS Reports in early
1997. The NYSDEC Rl found TCE concentrations in soil ranging from 46 to 840,000
micrograms per kilogram (|jg/kg) and that a source of TCE-contamination remained in
the unsaturated soil in the Spill Zone and bedrock in the Study Area, the nearby
surface water, and the groundwater with a plume extending almost four miles east and
southeast of the Spill Zone. TCE from the original spill is also referred to in this
document as a dense non-aqueous phase liquid (NAPL) or DNAPL.
OU1 Remedy and Remedial Action
On March 28, 1997, NYSDEC issued a Record of Decision (ROD) for the Site. The
ROD selected remedy included: 1) the installation of a waterline to provide potable
water to approximately 70 affected residences and businesses near the Site; 2) the
installation of an in-situ bedrock vapor extraction (BVE) system within a 10-acre
DNAPL zone (Spill Zone); and 3) ex-situ soil vapor extraction (SVE) of approximately
10,000 cubic yards of TCE-contaminated soil. In August 1998, NYSDEC requested that
EPA approve its ROD and assume responsibility for the source-control components of
the remedy. At the same time, the State agreed to continue its work on the waterline
component of the selected remedy. In July of 1999, following the January 1999 final
listing of the Site on the National Priorities List (NPL), EPA concurred with the waterline
component of the NYSDEC remedy.
In 1999, NYSDEC performed a BVE pilot study which indicated that, while there were
uncertainties, ex-situ SVE and in-situ BVE could be effective in achieving the soil
cleanup objectives in the NYS ROD. In May 2002, EPA concurred with the BVE and
SVE components of the NYSDEC remedy.
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During 2003, the waterline component of the selected remedy was successfully
implemented. The POET systems that had been installed on the affected domestic
wells were removed, and, subsequently, the properties were connected to the
waterline. The waterline connections were completed in all four of the municipalities
that were affected by the TCE plume (Town of Wheatland, Town of LeRoy, and the
Town and Village of Caledonia). The waterline is currently providing potable water to
approximately 70 affected residences and businesses in the area.
In September 2006, LVRR entered into a settlement agreement ("Settlement
Agreement") with EPA by which LVRR conducted pre-remedial design investigations
while undertaking the remedial design of the SVE system and the OU2 RI/FS.
Additional evaluations of the feasibility of BVE were performed, as documented in
reports from 2011 through 2014, a BVE Memorandum in 2018, and a focused BVE
Report in 2019. Based upon review of the results of the pilot study and the subsequent
evaluations, EPA concluded that given the nature of the vadose zone (bedrock) and the
large fluctuations in groundwater levels found at the Site, as well as the size, migration,
and location of the TCE-mass (diffused into the saturated and unsaturated bedrock),
implementation of BVE would not remove enough mass to result in significant reduction
of contamination in the bedrock or groundwater.
Pursuant to the Settlement Agreement LVRR also undertook vapor intrusion
investigations in the Study Area. Starting in 2008, measures were initiated to protect
property owners from exposure to vapors arising from contamination in groundwater
volatilizing into soils and subsequently into residences, a process known as soil vapor
intrusion (SVI). EPA required LVRR to install vapor mitigation systems at the affected
properties. To date, more than 35 properties have been sampled to determine if
contamination has migrated into indoor air. Sub-slab depressurization systems
(SSDSs) were subsequently installed in 12 homes to mitigate potential exposures
associated with SVI.
On March 21, 2014, EPA unilaterally issued Administrative Order for Remedial Action,
Index Number CERCLA-02-2014-2010, (SVE Order) to LVRR for the remediation of
soil using SVE. An in-situ SVE system was installed and became operational in July
2015. The SVE system operated continuously in the Spill Zone for two years. Despite
removing over 284 pounds of volatile organic compounds (VOCs), the post-SVE data
indicated that cleanup goals had not been achieved. As a result, EPA determined that
continued SVE cleanup would not attain cleanup levels or accomplish RAOs and, in
July 2017, the SVE system was shut down. The residual concentrations above cleanup
goals were likely associated with rock fines present in the overburden materials that are
highly diffused into the rock matrix.
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HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Rl and FS reports and a Proposed Plan1 were released to the public for comment
on August 18, 2023. These documents were also made available to the public at
information repositories maintained at the Caledonia Public Library located at 3108
Main Street, Caledonia, New York, the Woodward Memorial Library located at Wolcott
Street, LeRoy, New York, and the EPA Region 2 Office in New York City. The
documents were also made available online at EPA's website:
https://www.epa.gov/superfund/lehigh-vallev-rr. Notices of availability for the above-
referenced documents were published in the Batavia Daily News, on EPA's website
and were distributed to various news outlets and local contacts. The public comment
period ran from August 18, 2023, to September 18, 2023. On August 29, 2023, EPA
conducted a public meeting at the Caledonia Mumford High School located at 99 North
Street, Caledonia, New York, to inform local officials and interested citizens about the
Superfund process, to explain the Proposed Plan for the Site, including the preferred
remedy and to respond to questions and comments from the approximately 14
attendees. Responses to the questions and comments received at the public meeting
and in writing during the public comment period are included in the attached
Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF RESPONSE ACTION
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP), at 40
CFR Section 300.5, defines an operable unit as a discrete action that comprises an
incremental step toward comprehensively addressing site problems. A discrete portion
of a remedial response eliminates or mitigates a release, threat of a release, or
pathway of exposure. The cleanup of a site can be divided into a number of operable
units, depending on the complexity of the problems associated with the Site.
EPA has designated two OUs for the Site. OU1 addresses the provision of an alternate
water supply to area residences and businesses that have been or have the potential
to be impacted by the LVRR contaminated groundwater plume, as well as
contamination within the Spill Zone, that is present in soil and extends into the bedrock.
The waterline component of the OU1 remedy was successfully implemented in 2003.
However, the components of the remedy addressing contaminated soil and bedrock
were not fully implemented.
OU2 addresses the approximately four-mile contaminated groundwater plume,
contaminated groundwater discharging to surface water, as well as contaminated
vapors that may migrate into residences as a result of soil vapor intrusion. The OU2 Rl
Report was completed in 2014 and the OU2 FS was completed in 2023.
1 A Proposed Plan describes the remedial alternatives considered for a site and identifies the preferred
remedy with the rationale for that preference.
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The subject of this ROD includes an amendment to the OU1 remedy and addresses
the Site contamination in OU2. The remedies selected in this ROD are considered the
final comprehensive remedy for the Site.
SUMMARY OF SITE CHARACTERISTICS
The discussion below summarizes a few essential features of the highly complex
geologic and hydrologic setting at the Site. A better understanding of the Site
conditions can be found in the Rl and FS Reports. In addition to sampling groundwater
for hazardous substances, a series of studies were conducted to better understand
how fractures in the bedrock aquifer are connected, with the goal of understanding how
the groundwater moves. The Rl also included rock coring and other sampling
techniques to analyze the extent to which contaminants had been diffused into the rock
itself, a phenomenon called matrix diffusion that is associated with certain rock
formations. The environmental media investigated during the Rl included soil, bedrock,
surface water, sediment, groundwater, and soil vapor. Samples were primarily
collected to delineate the extent of media contaminated by TCE. The results of the Rl
are summarized below.
The primary contaminants of concern at the Site are TCE and its breakdown daughter
products: cis-1,2 dichloroethene, trans-1,2 dichloroethene, 1,1 dichloroethene and vinyl
chloride.
Site Geology and Hydrogeology
A comprehensive summary of the regional geology of western New York and geology
of the Site, including the Study Area and Spill Zone, can be found in the NYSDEC
RI/FS. A summary of the geologic conditions of the Site, based on the NYSDEC RI/FS,
observations and research by LVRR's contractor, Unicorn Management Consultants
(UMC) follows.
The area geology is well documented in the NYSDEC 1996 Rl report and the LVRR
2014 Rl report as consisting generally of a carbonate series of bedrock ranging from
Silurian to Devonian in age. Bedrock units in descending order and from youngest to
oldest include the Onondaga Formation, the Bois Blanc Formation, the Akron
Formation, the Bertie Formation, and the Camillus Formation. Each generally consists
of limestone/dolomite sequences with varying amounts of sandstone, shale and chert.
The Camillus Formation, underlain by the Syracuse Formation, a dolomite/anhydrate
sequence, is considered the base of the Study Area as it produces non-potable water.
The Site is located in the Allegheny Plateau Physiographic Province in western New
York. The northeastern portion of the Study Area slopes downward toward the
northeast and Mud Creek. East of the Spill Zone, the topography slopes generally
downward toward Spring Creek along an undulating surface. North of Gulf Road/Flint
Hill Road, the topography slopes downward to the north toward Oatka Creek. The
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southeastern portion of the Spill Zone slopes downward to the east and southeast to
Mud Creek. The western section of the Spill Zone is generally higher in elevation and
contains piles of quarried rock debris, remnant of historical quarrying activities in the
area.
The major surface drainage feature at the Site includes Oatka Creek, which generally
defines the northern boundary of the Site. Mud Creek, a seasonal tributary of Oatka
Creek, flows from south to north through the western portion of the Site and
hydraulically downgradient of the Spill Zone. Other seasonal surface water features are
generally defined by the west-to-east-oriented NYS Route 5. South-to-north flowing
Spring Creek (a tributary of Oatka Creek) generally defines the eastern-most distal end
of the TCE plume with monitoring wells beyond that defining the eastern-most portion
of the Site.
The geology of the Site area generally consists of unconsolidated overburden material,
underlain by glacial till (matrix of fine to coarse grained gravel and sand and clayey silt)
and glacial fluvial deposits underlain by sedimentary bedrock dipping gently to the
south. In the eastern portion of the Site, overburden materials are underlain by
weathered limestone bedrock. However, along Spring Creek, bedrock was
encountered at depths considerably deeper than in borings advanced west of Spring
Creek. Over most of the Study Area, the Onondaga Formation is the upper most rock
unit, dipping gently to the south. However, in the northern and eastern portions of the
Study Area, some formations are exposed north and east of an erosional line resulting
in an erosional surface sloping north and east into the Oatka Creek and Spring Creek
drainages. Owing to the predominantly carbonate/dolomite nature of the bedrock, the
Study Area is characterized by karstic features including sinkholes, swallets, and
sinking streams, as well as numerous springs/seeps along Oatka Creek, Mud Creek,
and Spring Creek. The karstic nature of the Study Area bedrock has a dramatic effect
on the overall hydrogeology of the area and TCE-impacted groundwater transport
mechanisms, including documented groundwater elevation fluctuations of up to 50 ft or
more over short time periods.
NATURE AND EXTENT OF CONTAMINATION
Soil
As discussed above, the 1970 train derailment resulted in approximately 30,000
gallons of TCE and one ton of cyanide crystals being released into the Spill Zone.
Immediate cleanup of the spill included the removal of cyanide crystals and the
spreading of neutralizers to counteract the effects of any remaining cyanide that could
not be removed. TCE released by two ruptured tank cars could not be recovered at the
time of the derailment and ultimately migrated into the ground and groundwater.
Soil sampling activities were conducted by LVRR in the Spill Zone from 2010 through
2017. The sampling included the collection of approximately 250 soil samples from a
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total of 174 test borings advanced to bedrock observed at depths between
approximately one and 10.5 feet below ground surface (bgs) and arranged in a grid-like
pattern in the Spill Zone both north and south of Gulf Road. Analysis of 28 of the
samples detected TCE at concentrations ranging between 7.6 and 400 milligrams per
kilogram (mg/kg), exceeding the RAO for TCE in soil of 7 mg/kg established in the
1997 ROD. The results of these efforts were summarized in a report prepared by UMC
titled "Soil Data Summary Report, Pre-RD" submitted to EPA in December 2010.
In March 2014, EPA issued the SVE Order for remedial action that required LVRR to
perform the SVE component of the OU1 remedy for the Site. In April 2015, in-situ SVE
construction and operations on the north and south sides of Gulf Road commenced.
The full-scale systems were placed into operation in July 2015.
In September 2016, following approximately 14 months of operation, preliminary post-
SVE sampling efforts identified concentrations remaining in the overburden above
concentration-based performance objectives presented in the OU1 ROD. On July 21,
2017, the SVE system was shut down after having removed over 284 pounds of VOCs,
including TCE, over its 2-year operation. The post-SVE data indicate that cleanup
goals have not been achieved (See Figure 5). Residual concentrations are likely
associated with contaminant mass diffused into rock fragments present in the
overburden materials. Continued cleanup using in-situ SVE would not attain cleanup
levels or accomplish RAOs. For contaminants of concern and their respective
concentrations remaining in the Spill Zone soil, see Appendix II, Tables 1-1 to 1-6,
Summary of LVRR Soil Sample Analytical Results.
Bedrock
Activities related to the 2010 LVRR Rl included: bedrock coring and rock core analysis
to assess the bedrock matrix for TCE impacts; inspection of boreholes for the presence
of nonaqueous phase liquid (NAPL); geophysical testing and FLUTe (Flexible Liner
Underground Technologies) profiling to assess bedrock structure and aquifer hydraulic
characteristics; packer testing and the collection of groundwater samples to assess
aquifer hydraulic characteristics and groundwater quality at discrete intervals; and
bedrock vapor sampling to assess bedrock vadose zone TCE vapor concentrations. In
total, 44 bedrock test borings were conducted as part of the 2010 Rl. Twelve of the 44
borings were completed as FLUTe-style monitoring wells.
The bedrock coring data showed that:
• There is a substantial amount of contamination that had previously been NAPL
that has diffused into the rock matrix over time above the observed static water
level at boring location LVRR-36. There does not appear to be any NAPL below
this level.
• There is a substantial amount of TCE mass in the rock matrix (approximately 9.7
grams in a square meter of rock) below the observed static water level at boring
location LVRR-36.
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• There is a substantial amount of TCE mass in the rock matrix (approximately
three grams in a square meter of rock) above the observed static water level at
boring location LVRR-35.
• While the Nedrow and Clarence members of the Onondaga Formation contain
significant TCE mass at boring locations LVRR-36 and LVRR-35, very little
mass is evident in those units at location LVRR-33.
• Significant TCE mass extends into the top of the Camillus Formation at boring
location LVRR-35 at an elevation of approximately 655 feet above mean sea
level, corresponding to a depth of approximately 93 feet bgs.
• Most of the TCE mass at boring location LVRR-33 occurs below the static water
level in the Bertie Formation and in the top of the Camillus Formation.
• At LVRR-35 the water in the fractures is essentially in equilibrium with the matrix
pore water.
• At boring location LVRR-33, TCE concentrations in groundwater samples
collected during packer testing are generally between one and three orders of
magnitude lower than the estimated rock matrix pore water concentrations
indicating that TCE is diffusing out of the rock matrix and into the fractures in this
part of the plume.
Based on these findings, the conceptual site model was developed as follows:
The initial spill resulted in TCE as DNAPL moving downward through the thin soils, into
the bedrock matrix, and eventually encountering groundwater within the Spill Zone.
As the TCE was transported downward and predominantly eastward from the ground
surface, the TCE DNAPL moved from areas of high concentration to low concentration
diffusing into the soil, bedrock in the unsaturated (vadose) zone and dissolved into
groundwater in the saturated zone at the Spill Zone. Large fluctuations in the
groundwater table have acted as a mechanism to spread TCE from the vadose zone to
the saturated zone in the Spill Zone. Diffusion of TCE mass from the rock matrix into
the groundwater occurs within the Spill Zone as lower concentration TCE-impacted
groundwater levels rise and encounter higher concentrations in the rock matrix.
Diffusion of TCE mass from the rock matrix into groundwater occurs through a process
referred to as back diffusion. As the groundwater elevation level recedes it has a higher
TCE concentration which is transported downgradient where a portion of the TCE mass
in groundwater diffuses into bedrock. This diffusive cycle of TCE mass moving from the
bedrock to groundwater and groundwater to bedrock is continuous throughout the TCE
plume.
Groundwater
LVRR conducted Rl activities from 2008 through 2015 and the findings of the
investigations indicated that TCE and/or TCE degradation products were detected in 40
of 53 samples collected in the groundwater plume. The highest concentrations of TCE
were found in the shallow wells near the Spill Zone. Concentrations of TCE and the
presence of TCE degradation products generally decrease with depth and lateral
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distance from the Spill Zone. [See Appendix II, Tables 2-1 to 2-3, Summary of LVRR
Groundwater Sample Analytical Results.]
A comparison of recent LVRR investigations (2008-2018) with the initial NYSDEC
remedial investigations (1996) shows that the TCE plume has not changed significantly
in terms of aerial extent since at least 1996 and has achieved a steady state plume
configuration condition.
TCE concentrations in Spill Zone wells generally decrease in successively lower
stratigraphic units, but overall concentrations exceed the drinking water standard of 5
|jg/L for TCE. Groundwater samples collected from monitoring wells located in the Spill
Zone (DC-01, DC-02, DC-05, DC-15, DC-16, LVRR-35 and LVRR-36) detected TCE at
levels ranging from 450 to 4,400 |jg/L, exceeding the drinking water standard of 5 |jg/L.
(See Figure 3).
The TCE concentrations in wells located immediately downgradient of the Spill Zone
(DC-03, DC-06, DC-17, LVRR-20, LVRR-34, and LVRR-37) detected TCE at levels
ranging from 40 to 760 |jg/L. However, TCE levels generally decrease in successively
lower stratigraphic units, eventually reaching levels that do not exceed the drinking
water standard of 5 |jg/L in the lower-most karstic portion of the Camillus Formation or,
in the case of DC-17B (TCE was non-detect), the Syracuse Formation. (See Figure 3).
Groundwater samples collected from downgradient monitoring wells located by Spring
Street (DC-13, DC-14, GCM, LVRR-22, and LVRR-23) detected TCE at levels ranging
from non-detect or ND to 11 |jg/L, slightly exceeding the drinking water standard of 5
|jg/L. (See Figure 3).
Groundwater samples collected from downgradient monitoring wells located east of
Spring Creek (LVRR-38, LVRR-39, LVRR-40, LVRR-41, and LVRR-42) detected TCE
at an estimated concentration of 0.27 |jg/l. Analysis of the remaining groundwater
samples collected from wells east of Spring Creek did not detect TCE in
concentrations, exceeding laboratory reporting limits. (See Figure 3).
Based on historical groundwater quality data, the eastwardly flowing Study Area TCE-
impacted groundwater (in the upper Camillus and shallower formations) is largely
controlled by the Spring Creek fault zone and discharges to the associated surface
water features which, in turn, drain northward to Oatka Creek. However, groundwater
in lower Camillus and deeper formations is intercepted by the fault zone, and TCE
impacts are mitigated by the diluting effect of allogenic water entering the Study Area
from the south and along the fault zone itself. This is evidenced by the non-detect
concentrations of TCE in monitoring well clusters LVRR-38 through LVRR-42, as well
as residential wells located east of the Spring Creek fault zone.
Based on the findings of the Rl Report and other investigations, the overall horizontal
extent of TCE-impacted groundwater within the Study Area has been delineated. Some
minor areas of uncertainty exist in the vicinity of LVRR-37 at a depth interval between
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approximately 50 feet and 75 feet bgs, corresponding to the Bertie and upper-most
portion of the Camillus Formation. The TCE-impact groundwater plume likely extends
further to the north in this area. The overall vertical extent of TCE-impacted
groundwater has also been delineated with some minor areas of uncertainty near Spill
Zone well clusters DC-01 and LVRR-35, advanced to total depths of 160 feet and 180
feet bgs, respectively, and the vicinity of Spring Street well clusters DC-13, and LVRR-
14, advanced to total depths of approximately 60 feet bgs, corresponding generally to
the Camillus/upper Syracuse Formations. Future monitoring will help refine the
understanding of the nature and extent of contamination in these areas. (Figure 3).
Based on TCE concentration trend and distribution observations, with the exception of
the areas noted above, the horizontal and vertical extent of the TCE-impacted
groundwater plume is defined within the limits of the Study Area. Further, the
magnitude of the TCE impacts and the overall plume geometry appear to have reached
a state of dynamic equilibrium, with overall lower TCE concentrations but similar overall
plume shape and orientation in the most recent sampling events as compared to earlier
events. Further, in conjunction with these observations and considering analysis of
groundwater elevation and geophysical data, as well as stream sediment and surface
water analytical results, Spring Creek and the apparent fault zone oriented along its
course act as a discharge zone for TCE-impacted groundwater preventing plume
advancement further to the east.
Potential for Groundwater Restoration
A report, entitled, Assessment of Groundwater Restoration Potential and Technical
Impracticability (AGTI) Report, dated May 25, 2019, was prepared to assess whether it
is technically practicable, from an engineering perspective, to restore groundwater at
the Site within a reasonable timeframe. Within the AGTI Report, factors such as the
volume and duration of the release of Site-related constituents were considered in
evaluating the potential for groundwater restoration at the Site. The chemical properties
of these constituents and the volume and depth of contaminated media were also
considered. In addition, Site-specific hydrogeologic characteristics were assessed as
they relate to groundwater restoration potential. These factors are summarized below.
Site-Specific Factors Regarding Technical Impracticability
The initial spill resulted in TCE as a DNAPL moving downward through the thin soils
into the bedrock matrix, and, eventually, encountering groundwater within the Spill
Zone. As the TCE was transported downward from the ground surface, the TCE
DNAPL moved from areas of high concentration to low concentration diffusing into the
soil, bedrock in the unsaturated (vadose) zone and dissolved into groundwater in the
saturated zone at the Spill Zone.
Currently, the majority of the TCE mass is located in the rock matrix, in micro-fractures
and in pore spaces above the saturated zone dissolved into pore space groundwater,
sorbed onto the bedrock, or as vapors. The diffusion of TCE into and out of the rock
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matrix occurs dynamically within the entire plume (present day and historic) both in the
saturated and vadose zones during times of high water. This process has been
documented from the Spill Zone approximately two miles eastward to Limerock Road.
As such, the rock matrix provides a continuous source of TCE impacts to groundwater
via back diffusion. This occurs when groundwater in the fractures has TCE
concentrations that are lower than those in the adjacent bedrock matrix. This is the
cause of long-term plume persistence despite the depletion of DNAPL within the Spill
Zone. While diffusion processes have been beneficial in causing strong attenuation of
the TCE plume and in reducing mass discharge to surface water, it also presents an
impediment to plume cleanup in a reasonable timeframe.
Significant volumes of allogenic water from runoff during storm events, ranging from 3
million gallons per month (Mg/mo) to 406 Mg/mo, mix with the groundwater system in
the Study Area. The plume receives the least amount of allogenic recharge in October,
coinciding with the highest reported TCE groundwater concentrations. Water level
changes of 50 feet or more occur rapidly, in a matter of hours or days. The water level
responses within each formation are similar with very little or no lag time, indicating that
the geologic formations act as a single aquifer which is hydraulically interconnected
through a complex fracture network.
In addition to reliable field data and observations, a Discrete Fracture Network (DFN)
model was created, using FRACTRAN (a numerical model for simulation of
groundwater flow through fractured porous media such as bedrock) informed by Site
field measurements and laboratory data, to understand how the various processes
controlling plume behavior interact to result in the observed (and interpolated) plume
configuration and behavior over various time and distance scales. Mathematical
models are necessary to make informed predictions regarding future plume behavior
since no future field data are currently available for the Site. The DFN model has some
limitations. The DFN FRACTRAN model does not exactly recreate the fracture network
in 3-D space but simulates the fracture network in fracture density and fracture width
and, therefore, is not 100 percent accurate. However, this modelling approach is the
most robust simulation available for groundwater flow through fractures and diffusion
from fracture water to rock matrix, where the majority of contaminant mass is stored,
and back diffused to fracture water.
The modeling indicates that even complete removal of TCE mass from the Spill Zone
or from other areas of the overall plume footprint will not restore groundwater to its
most beneficial use or eliminate risk to human health or the environment within any
reasonable timeframe. At the LVRR Site, restoration to MCLs would be expected to
take centuries, even with the removal of all TCE from the Spill Zone. However, TCE
concentrations within the plume and downgradient discharges to surface water will
continue to decline due to natural processes.
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Technology Limitations and Site-location Factors
Because the VOC-contamination is now largely contained within the rock matrix, to be
successful, a remedial technology needs to be capable of treating contamination in
both the rock matrix and the bedrock fractures. Furthermore, an effective technology
must remain within the rock matrix over a period of time long enough to promote
treatment. A review of currently available remedial technologies identifies no viable
technologies capable of effectively treating the fractured bedrock in a full-scale
implementation. Reviewed technologies included widely used methods (e.g.,
groundwater extraction and ex-situ treatment, in-situ bioremediation or in-situ chemical
treatment), and innovative technologies (e.g., aquifer heating).
Stability of Groundwater Conditions
The TCE dissolved-phase plume is contained horizontally by natural and
anthropogenic processes. Natural controls on the plume include the Spring Creek fault
to the east, the northeast-trending regional groundwater flow to the west, an influx of
surface water from outside the footprint of the plume through karstic features to the
south, including sinkholes and solution-enlarged fractures (which result in dilution and
dispersion), and by upward vertical hydraulic gradients to the north and south.
While the extent of the plume boundary is near steady state, the presence of TCE
within the bedrock continues to be a long-term source of contamination. The diffusion
of TCE into and out of the rock matrix occurs dynamically within the entire plume
(present day and historic) both in the saturated and vadose zones during times of high
water. As such, the rock matrix provides a continuous source of TCE impacts to
groundwater via back diffusion. In addition, the influx of billions of gallons of fresh water
annually to the plume has hindered, but not stopped, the process of natural attenuation
and helps to maintain the state of dynamic equilibrium.
Surface Water
Mud Creek, a seasonal tributary of Oatka Creek, flows from south to north through the
western portion of the Site and hydraulically downgradient of the Spill Zone. Site
remedial investigations identified a large sinkhole located near the Spill Zone through
which Mud Creek flows and loses much of its water to the bedrock. Downgradient of
the sinkhole, TCE was detected in surface water samples collected at the Mud Creek
area, including the waterfall at 320 |jg/L and downstream of the waterfall at 440 |jg/L
and 380 |jg/L (See Figure 6). These TCE concentrations exceed the NYSDEC Class C
surface water quality standard of 40 |jg/L indicating that TCE-impacted groundwater
originating from the Spill Zone discharges via springs to this portion of Mud Creek.
Private Well Investigations
From 2008 to 2009, 23 private wells near the Site that were no longer used for drinking
water were included in the monitoring network and sampled for VOCs and cyanide.
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The wells were chosen based on four criteria, including spatial distribution of the wells
with respect to the groundwater plume, contaminant concentrations, groundwater flow
direction, and presence of pumping wells. The results indicated that TCE and/or TCE
degradation products were detected in the following private wells:
• Detectable concentrations of TCE were reported in the samples collected from
L-14 (70 (jg/L) and L-33B (22 mq/L). L-14 is a well located near the racetrack on
Flint Hill Road used to wet the dirt track; the water is not used for drinking. L-33B
is located on Spring Street and is used for irrigation. Both properties are
connected to the public water supply.
• An estimated concentration of vinyl chloride (0.44 |jg/L) was present in the
sample collected from M-20. M-20 is located on the museum property east of
the main parking lots. Water from this well is not used for drinking purposes.
An alternate water source was implemented for the purpose of providing a long-term
solution that addressed public health concerns with respect to the consumption of
potable water. Any existing production well is not used as potable water for drinking
purposes. The construction of a municipal water line was designed by Stearns &
Wheler, LLC in 1998 under a contract with the NYSDEC. Construction of the water line
ran from December 2001 through July 2003, and included 15 miles of 8-inch & 12-inch
diameter water mains, with a total of 70 individual service connections. Once it was put
into service, the waterline provided affected users with a clean source of potable water.
The waterline connections were completed in all four of the municipalities that were
affected by the TCE plume (Town of Wheatland, Town of LeRoy, and the Town and
Village of Caledonia). Details of the installation are provided in the "Final Remediation
Report, Water Distribution System, Lehigh Valley Railroad Derailment Site" prepared
by Stearns and Wheler, LLC in August 2003 (NYSDEC, 2003). Additionally,
decommissioning of all impacted private/domestic water supply wells that were located
within the extent of the TCE groundwater plume was conducted with the exception of
the following:
1. L-14: This well is used for non-potable utility purposes only (dust control
of a racing track), and the property owner does not wish to abandon the
well. Additionally, there are signs posted on the property indicating that
the water from the domestic well is for non-potable use only; and
2. L-33B: This well is used during the summer for garden irrigation only,
and the property owner does not wish to abandon the well. The property
owner permitted LVRR to post a "non-potable" sign next to the well. On
May 20, 2020, UMC on behalf of LVRR posted the agreed upon sign next
to the domestic well.
Vapor Intrusion
Starting in 2008, measures were initiated to protect property owners from exposure to
vapors from contamination in groundwater volatilizing into soils and subsequently into
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residences, a process known as soil vapor intrusion. To date, more than 35 properties
have been sampled to determine if contamination has migrated into indoor air. As a
result of the sampling, sub-slab depressurization systems (SSDSs) were installed in 12
homes to mitigate potential exposures associated with soil vapor intrusion (SVI) plus
one location installed a SSDS system for radon that also acts to mitigate SVI. The
mitigation systems are monitored and continue to be effective in controlling indoor TCE
vapors.
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
Land Use
The 10-acre Spill Zone is mostly undeveloped industrial, commercial, residential, and
passive recreational land, largely covered with grass, brush, and wooded areas. The
current land use over the 4.1-mile plume, designated as the Study Area, is mixed use,
including residential, recreational, agricultural, and commercial/industrial.
Groundwater Use
Because the area is served by municipal water [and there are various governmental
controls in place in the affected municipalities], it is unlikely that the groundwater
underlying the Site will be used for potable purposes in the foreseeable future.
Regional groundwater is, however, designated as a drinking water source by NYSDEC.
SUMMARY OF SITE RISKS
As part of the RI/FS for the Site, a baseline risk assessment (BRA) and a supplemental
risk evaluation for soil were conducted to estimate the current and future effects of
contaminants on human health and the environment. A BRA is an analysis of the
potential adverse human health and ecological effects of releases of hazardous
substances from a site in the absence of any actions or controls to mitigate such
releases, under current and future land, surface water and groundwater uses. It
provides the basis for taking an action and identifies the contaminants and exposure
pathways that need to be addressed by the remedial action. The BRA included a
human health risk assessment (HHRA, 2016) and a screening-level ecological risk
assessment (SLERA, 2013). In 2021, EPA conducted a soil risk evaluation that
supplemented the baseline risk assessment for the Site. This section of the ROD
summarizes the results of the 2016 HHRA and 2021 supplemental soil risk evaluations.
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Human Health Risk Assessment
A four-step process is utilized for assessing site-related human health risks for a
reasonable maximum exposure scenario:
Hazard Identification - uses the analytical data collected to identify the
contaminants of potential concern at the site 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 well-water) by which humans are
potentially exposed;
Toxicity Assessment - determines the types of adverse health effects associated
with contaminant exposures, and the relationship between magnitude of
exposure (dose) and severity of adverse effects (response); and
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 which
exceed acceptable levels, defined by the National Contingency Plan (NCP) as
an excess lifetime cancer risk greater than 1 x 10~6 - 1 x 10~4 or a Hazard Index
greater than 1; contaminants at these concentrations are considered
contaminants of concern (COCs) and are typically those that will require
remediation at the site. Also included in this section is a discussion of the
uncertainties associated with these risks.
Hazard Identification
In this step, the contaminants of potential concern (COPCs) in each medium were
identified based on such factors as toxicity, frequency of detection, fate and transport of
the contaminants in the environment, concentration, mobility, persistence and
bioaccumulation. The HHRA began with selecting COPCs in various media at the site
(i.e., groundwater, surface water and sediment) that could potentially cause adverse
effects in exposed populations. COPCs were selected by comparing the maximum
detected concentrations of each chemical identified with state and federal risk-based
screening values. The COPC screening was conducted separately for each medium of
interest and exposure area in the HHRA. A comprehensive list of all COPCs can be
found in the HHRA in the administrative record. Only site-related risk driving COCs, or
those chemicals exceeding EPA's threshold criteria, are included in Table 3.
The 2021 supplemental soil risk evaluation conducted by EPA evaluated potential
human health risk from exposure to residual TCE source in the Spill Zone soils post-
treatment with the SVE system. Unlike in the HHRA, the 2021 supplemental risk
evaluation only quantified risk from exposure to TCE in the Spill Zone soil.
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Exposure Assessment
Consistent with Superfund policy and guidance, the HHRA is a baseline human health
risk assessment and therefore assumes no remediation or institutional controls to
mitigate or remove hazardous substance releases. Cancer risks and noncancer
hazard indices were calculated based on an estimate of the reasonable maximum
exposure (RME) expected to occur under current and future conditions at the site. The
RME is defined as the highest exposure that is reasonably expected to occur at a site.
For those contaminants for which the risk or hazard exceeded the acceptable levels,
the central tendency estimate (CTE), or the average exposure, was also evaluated in
the HHRA.
The current land use at the Site, including the approximate 10-acre Spill Zone and the
resultant 4.1-mile groundwater plume, designated as the Study Area, is mixed use,
including residential, recreational, agricultural, and commercial/industrial. Future land
use is expected to remain the same. The identification and selection of potential
receptor populations in the HHRA was based on both current and potential future land
uses of the Site. Media of concern evaluated in the 2016 HHRA included groundwater,
as well as surface water and sediments in nearby Mud Creek, Oatka Creek and Spring
Creek. As such, the following receptor populations and pathways were quantitatively
evaluated in the 2016 HHRA:
• Future Resident (Adult/Child)- Ingestion of groundwater as drinking water,
dermal contact with groundwater while bathing or showering, and inhalation of
VOCs released during bathing or showering.
• Future Commercial/Industrial Worker- Ingestion of groundwater as drinking
water and dermal contact while hand washing.
• Current/Future Construction/Utility Worker- Incidental ingestion of and dermal
contact with shallow groundwater in a trench, and inhalation of vapor phase
chemicals released from groundwater to a confined space (trench).
• Current/Future Recreational User (Adult/Adolescent/Child)- incidental ingestion
of and dermal contact with surface water and sediment while wading or
swimming in Mud, Oatka, and Spring Creek.
In 2021, to supplement the HHRA, EPA conducted an additional risk evaluation for
residual TCE source in the Spill Zone soils post-treatment with a SVE system. Residual
TCE contamination in the Spill Zone is present on land zoned industrial, therefore, the
following receptor populations and pathways were evaluated:
• Current/Future Commercial Worker- incidental ingestion and inhalation of soil
particulates released from Spill Area soils; and
• Current/Future Construction Workers- incidental ingestion and inhalation of soil
particulates released from Spill Area soils.
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A summary of the exposure pathways included in the 2016 HHRA and the 2021
Supplemental Risk Evaluation for soil can be found in Table 4.
Typically, exposures are evaluated using a statistical estimate of the exposure point
concentration, which is usually an upper bound estimate of the average concentration
for each contaminant, but in some cases may be the maximum detected concentration.
A summary of the exposure point concentrations for the COCs in each medium can be
found in Table 3, while a comprehensive list of the exposure point concentrations for all
COPCs can be found in the 2016 HHRA for the site.
Toxicity Assessment
In this step, the types of adverse health effects associated with contaminant exposures
and the relationship between magnitude of exposure and 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 due to exposure to site contaminants are considered separately. Consistent
with current EPA policy, it was assumed that the toxic effects of the site-related
contaminants 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 human health risk assessment were provided by the Integrated
Risk Information System (IRIS) database, the Provisional Peer Reviewed Toxicity
Values Database (PPRTV), or another source that is identified as an appropriate
reference for toxicity values consistent with EPA guidance
(https://www.epa.gov/sites/default/files/2015-11/documents/tier3-toxicitvvalue-
whitepaper.pdf). This information is presented in Table 5 (noncancer toxicity data
summary) and Table 6 (cancer toxicity data summary). Additional toxicity information
for all COPCs is presented in the 2016 HHRA.
Risk Characterization
Noncarcinogenic risks were assessed using a hazard index (HI) approach, 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) which are thought to be safe over a lifetime of
exposure. The estimated intake of contaminants identified in environmental media
(e.g., the amount of a contaminants ingested from contaminated drinking water) is
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compared to the RfD or the RfC to derive the hazard quotient (HQ) for the contaminant
in the particular medium. The HI is obtained 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 below. The HQ for inhalation
exposures is calculated using a similar model that incorporates the RfC, rather than the
RfD.
HQ = Intake/RfD
Where: HQ = hazard quotient
Intake = estimated intake for a contaminant (mg/kg-day)
RfD = reference dose (mg/kg-day)
The intake and the RfD will represent the same exposure period (i.e., chronic,
subchronic, or acute). The key concept for a noncancer HI is that a "threshold level"
(measured as an HI of less than or equal to 1) exists at which noncancer health effects
are not expected to occur.
As previously stated, the HI is calculated by summing the HQs for all contaminants for
likely exposure scenarios for a specific population. An HI greater than 1 indicates that
the potential exists for noncarcinogenic 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 contaminants for a specific population exceeds 1, separate HI
values are then calculated for those contaminants 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. A summary of the
noncarcinogenic risks associated with these contaminants for each exposure pathway
is contained in Table 7.
As shown in Table 7, the HI for noncancer health effects exceeded EPA's threshold of
1 for adult resident (HI of 7,000), child resident (HI of 12,000), commercial/industrial
worker (HI of 43), construction/utility worker (HI of 94), adult recreator (HI of 6.6),
adolescent recreator (HI of 9.1) and child recreator (HI of 18). For the residential
receptors, the hazard was predominantly driven by inhalation exposures to TCE that
could occur during showering or bathing activities. The recreator hazards were driven
by exposure to TCE in surface water from the Mud Creek exposure unit (SW-EU1).
For the construction/utility worker, the HI of 94 was driven by exposure to TCE in Spill
Zone soil and groundwater. Similarly, exposure to TCE in groundwater and Spill Zone
soil by the commercial/industrial workers resulted in hazard estimates that exceeded
unity (Hl=43).
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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
under the conditions described in the Exposure Assessment, 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 (mg/kg-day)
SF = cancer slope factor, expressed as [1/(mg/kg-day)]
These risks are probabilities that are usually expressed in scientific notation (such as 1
x 10~4). An excess lifetime cancer risk of 1 x 10~4 indicates that one additional
incidence of cancer may occur in a population of 10,000 people who are exposed
under the conditions identified in the Exposure Assessment. Again, as stated in the
National Contingency Plan, the acceptable risk range for site-related exposure is 10"6
to 10"4
As summarized in Table 8, the total estimated cancer risks for future residents and
commercial/industrial workers exceeded EPA's target risk range of 10"6 to 10"4. The
estimated cancer risk for the child/adult resident of 3.7x10"2 was mainly driven by
exposure to TCE in groundwater. Similarly, the estimated cancer risks for the
commercial/industrial worker of 2.3x10"4 was also mainly driven by exposure to TCE in
groundwater.
Uncertainties
The procedures and inputs used to assess risks in this evaluation, as in all such
assessments, are subject to a wide variety of uncertainties. In general, the main
sources of uncertainty include:
environmental chemistry sampling and analysis
environmental parameter measurement
fate and transport modeling
exposure parameter estimation
toxicological data
Uncertainty in environmental sampling arises in part from the potentially uneven
distribution of contaminants in the media sampled. Consequently, there is significant
uncertainty as to the actual levels present. Environmental chemistry-analysis error can
stem from several sources including the errors inherent in the analytical methods and
characteristics of the matrix being sampled.
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Uncertainties in the exposure assessment are related to estimates of how often an
individual would actually come in contact with the contaminants of concern, the period
of time over which such exposure would occur, and in the models used to estimate the
concentrations of the contaminants of concern at the point of exposure.
Uncertainties in toxicological data occur in extrapolating both from animals to humans
and from high to low doses of exposure, as well as from the difficulties in assessing the
toxicity of a mixture of contaminants. These uncertainties are addressed by making
conservative assumptions concerning risk and exposure parameters throughout the
assessment. As a result, the risk assessment provides upper-bound estimates of the
risks to populations near the site and is highly unlikely to underestimate actual risks
related to the site.
More specific information concerning public health risks, including a quantitative
evaluation of the degree of risk associated with various exposure pathways, is
presented in the human health risk assessment report.
Screening Level Ecological Risk Assessment (SLERA)
The SLERA was prepared to determine whether potential adverse ecological effects
are occurring or may occur based on concentrations of contaminants of potential
ecological concern (COPECs) in sediment and surface water at the Site. Ecological
exposure was first evaluated by quantifying potential risk based on the most
conservative exposure scenarios. The results indicated that maximum concentrations
of some constituents in surface water and sediment exceeded conservative screening
criteria. However, the potential for impacts to populations from exposure to those
constituents is low when evaluated using refined benchmarks that use more realistic
exposure conditions to specific receptors. The findings of the exposure evaluation and
risk characterization support the following conclusions for the exposure area:
1) Cyanide was detected at a low concentration in surface water at one location
in Mud Creek. This however does not pose unacceptable risks for fish
communities because the pathway for exposure is incomplete as Mud Creek
upstream of Gorge Pond runs dry portions of the year and, therefore, is
unable to support fish communities.
2) Acetone was also found in in sediment at the Site but is not a Site-related
constituent as it was not associated with the spill from the train derailment.
The acetone is unlikely to adsorb to sediment and was found in similar
concentrations within and outside the historical plume. The lack of sediment
quality criteria and ecotoxicity data suggest that this analyte is unlikely to
adversely impact macroinvertebrates. Therefore, the presence of this
constituent in sediment samples is not considered Site-related and does not
pose a significant risk to benthic invertebrate populations.
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A Supplemental Ecological Risk Evaluation was performed to estimate the potential for
adverse effects to ecological receptors exposed to contaminated soils at the Site
(USEPA, 2021b). Analytical data used in the Supplemental Risk Evaluation included
TCE concentrations measured in post-SVE soil boring samples collected in August
2017 from 0.5 to 2.5 ft bgs. The risk was evaluated for surface soils because exposure
pathways to terrestrial ecological receptors are only complete in surface soil. Exposure
point concentrations (EPC) calculated by EPA were compared to the 2 mg/kg soil
cleanup objective (SCO) for protection of ecological receptors established by the
NYSDEC. The NYSDEC value assumes that the soil-to-earthworm-to-small mammal
exposure pathway is the most sensitive wildlife ingestion pathway. Based on this
comparison, EPA calculated a hazard quotient (HQ) for the Spill Zone of 230 based on
an EPC of 460.2 mg/kg. Under current conditions, placement of a stone cover as part
of the SVE system prevents the establishment of habitat to support a forage base (e.g.,
earthworms, vegetation, etc.) for ecological receptors and minimizes incidental soil
ingestion. However, if the existing cover is removed, there is a potential for future
habitat to be present for ecological receptors.
Summary of Human Health Risks
In summary, the result of the 2016 HHRA and the 2021 supplemental soil evaluation
indicated that residual TCE in Spill Zone soils, groundwater and surface water of Mud
Creek were associated with cancer and/or noncancer risk estimates that exceeded
EPA's threshold criteria. Further, as discussed in the 2016 HHRA, the presence of TCE
in groundwater was also found at levels that could be of concern for the vapor intrusion
pathway.
Basis for Action
Based upon the Rl and the quantitative human-health risk assessment and ecological
evaluation, the response action selected in this Record of Decision is necessary to
protect the public health or welfare or the environment from actual or threatened
releases of hazardous substances at and from the Site.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health and the
environment. These objectives are based on available information and standards,
such as applicable or relevant and appropriate requirements (ARARs), to-be-
considered (TBC) guidance, and site-specific risk-based levels.
The RAOs identified in the 1997 NYSDEC ROD were as follows:
- Provide for attainment of Standards, Criteria and Guidance (SCGs) for
groundwater quality and surface water quality at the limits of the area of
concern, to the extent practicable.
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- Prevent, to the extent possible, migration of contaminants in groundwater and
reduce the impacts of contaminated groundwater to the environment.
- Reduce, control, or eliminate, to the extent practicable, the soil and bedrock
contamination present at the derailment Site.
- Eliminate the potential for human and wildlife exposure to soil containing Site-
related contaminants.
- Contain, treat and/or dispose of contaminated soil in a manner consistent with
applicable state and federal regulations and guidance.
EPA is amending and supplementing these RAOs with the RAOs detailed below which
are organized by media. In developing RAOs for groundwater, EPA expects to return
usable groundwater to its beneficial uses (in this case, use as drinking water) wherever
practicable, within a timeframe that is reasonable given the characteristics of the site.
All groundwater in New York State is classified as "GA," which means it is suitable as a
source of drinking water. Therefore, applicable or relevant and appropriate
requirements for groundwater include the NYS Surface Water and Groundwater Quality
Standards and Groundwater Effluent Limitations (6 NYCRR Part 703) and the Safe
Drinking Water Act maximum contaminant levels (MCLs). EPA also acknowledges,
however, that groundwater restoration is not always achievable due to limitations in
remedial technologies and other site-specific factors. These factors may include
technology limitations, contaminant phase, contaminant depth, complexity of geological
setting, and hydraulic regime.
As discussed above, after evaluating the nature and extent of groundwater
contamination and the available remedial alternatives for groundwater, EPA has
concluded that the available technologies cannot achieve restoration of the
contaminated groundwater to drinking water standards. EPA is invoking a waiver of
ARARs due to technical impracticability (Tl) for groundwater at the Site. The PRP
documented its evaluation of the potential for groundwater restoration in the 2019 AGTI
report and identified a zone where ARARs are expected to be exceeded for the
foreseeable future. EPA acknowledged that this evaluation satisfied the requirements
for a Tl waiver.
This Tl decision applies only to the chemical-specific groundwater standards being
waived in the area where ARARs or other cleanup standards cannot be reached
(hereinafter, the Tl Zone). For the Site, the Tl Zone includes the portion of the
groundwater in the Spill Zone and the plume downgradient to Spring Creek. The
horizontal and vertical extent of the Tl Zone is illustrated on Figure 4, which shows the
Tl Zone (items 1 and 2 below) and an area around the Tl Zone as follows:
1. Red (Zone 1): depicts an area encompassing the approximately 3.1 million
square foot Spill Zone and extending vertically to the upper Camillus Formation
(a depth corresponding to approximately 120 ft bgs), resulting in a volume of
approximately 213 million cubic feet where groundwater TCE concentrations
generally exceed 1,000 |jg/L; and
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2. Yellow (Zone 2): depicts an area encompassing approximately 102 million
square feet outside of the Spill Zone area extending vertically to the base of the
Camillus Formation (ranging from approximately 120 ft bgs in the western extent
of the Study Area to outcrops occasionally near Spring Creek, and Oatka
Creek), resulting in a volume of approximately 7,821 million cubic feet where
groundwater TCE concentrations generally range from 5 |jg/L to 1,000 |jg/L. The
Tl boundary at the distal end of the TCE plume was established to include the
entire Spring Creek Fault Zone that extends just east of Spring Creek.
3. Gray (Monitoring Zone): depicts an area outside of the Tl Zone that
encompasses an approximately 39 million square foot area extending vertically
to the base of the Camillus Formation (ranging from approximately 120 ft bgs in
the western extent of the Study Area to outcrops occasionally near Spring
Creek, and Oatka Creek) resulting in a volume of approximately 2,990 million
cubic feet where TCE concentrations in groundwater generally range from non-
detect to 5 |jg/L. Outside of the Tl Zone (in the gray area), the preliminary
remediation goals (discussed below) will be used to verify compliance with the
Tl waiver.
When restoration of groundwater to beneficial uses is not practicable, EPA selects an
alternative remedial strategy that is technically practicable, protective of human health
and the environment, and satisfies statutory and regulatory requirements of CERCLA.
Consistent with the NCP, alternative remedial strategies for Tl sites typically address
three site concerns: 1) exposure control; 2) source control; and 3) aqueous plume
migration. The RAOs outlined below for groundwater, soil vapor, bedrock, surface
water and soil address these concerns.
Groundwater Remedial Action Objectives:
• Prevent current and future human exposure (via ingestion, inhalation and dermal
contact) to Site-related contaminants in groundwater that exceed federal or state
maximum contaminant levels (MCLs).
• Prevent further migration of Site-related contaminants in groundwater at levels
exceeding MCLs beyond the delineated areal extent of the groundwater
contamination or Tl Zone.
• Prevent the migration of Site-related contaminants in groundwater to surface
water that would result in exceeding applicable surface water quality standards.
Soil Vapor Intrusion (SVI) Remedial Action Objective:
• Mitigate potential current and future unacceptable risks from subsurface SVI into
indoor air.
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Bedrock Remedial Action Objectives:
• Mitigate, to the extent practicable, the Bedrock Vadose Zone (BVZ) as an
ongoing source of groundwater contamination;
• Accelerate long-term improvement to the groundwater in a reasonable time
frame; and,
• Support further risk reduction for the Site as a whole.
Soil in Spill Zone Remedial Action Objective:
• Prevent human exposure to contaminated Spill Zone soil {i.e., contaminated
overburden fill material/debris/soil) via incidental ingestion and inhalation above
levels that pose an unacceptable risk for commercial use.
Surface Water Remedial Action Objective:
• Prevent unacceptable risk to human receptors from incidental ingestion and
dermal contact exposure to contaminated surface and seep water in the Mud
Creek area by reducing contaminant levels to the more stringent federal or state
standards.
Remediation Goals
Remediation goals (RGs) are media- and contaminant-specific numerical or qualitative
federal and state standards that can be compared directly to RAOs and will be used for
developing use restrictions and other actions to prevent exposure and for assessing
the extent of the aqueous plume. To evaluate remedial alternatives and support the
RAOs, preliminary remediation goals (PRGs) for the Site were developed for soil,
groundwater and surface water. PRGs are related to RAOs and are based on state
and federal standards and are used for developing the final cleanup levels, or RGs, in
the ROD, use restrictions and other actions to prevent exposure. RGs will not be used
for achieving restoration of groundwater within the Tl Zone to the numerical goals but
will be used for assessing the extent of the aqueous plume.
As there are no chemical-specific ARARs for SVI, RGs were not specifically developed
for vapor intrusion. However, applicable TBC criteria include EPA Vapor Intrusion
Screening Levels (VISLs) and NYSDOH Final Guidance for Evaluating Soil Vapor
Intrusion in the State of New York. The most current EPA VISLs and NYSDOH criteria
will be used in the evaluation of the SVI pathway at the Site.
The 1997 NYSDEC OU1 ROD established the groundwater and surface water RGs as
follows:
- Groundwater: 5 |jg/L TCE
- Surface water: 11 |jg/L TCE
- Surface soil: 7 mg/kg TCE; 3 mg/kg 1,2-dichloroethene
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With this decision, EPA is replacing the RGs with the following (also Table 9 in
Appendix II):
Remediation Goals (RGs)
ENVIRONMENTAL
MEDIA
CONTAMINANT OF
CONCERN
RG
UNITS
Groundwater1
Trichloroethene (TCE)
5
MQ/L
cis-1,2-dichloroethene
5
MQ/L
trans-1,2-dichloroethene
5
MQ/L
1,1- dichloroethene
5
MQ/L
Vinyl Chloride
2
MQ/L
Surface Water2
Trichloroethene (TCE)
40
MQ/L
Soil3
Trichloroethene (TCE)
200
mg/kg
Footnotes:
1 Lower of the NYSDEC Class GA Groundwater Quality Standards and NY state and federal Maximum Contaminant
Levels were selected as RGs. These RGs are the ARARs being waived in the Tl Zone.
2 NYSDEC - Part 703: Surface Water Quality Standards for Class C waters (based on designation of Mud Creek).
3 6 NYCRR Part 375, Table 375-6.8(b) Commercial use Soil Cleanup Objective. The protection of groundwater SCO
was evaluated as part of the Feasibility Study but was not applied because groundwater restoration is not
practicable.
As reflected in the RG table above, the primary groundwater COCs include TCE and its
breakdown daughter products: cis- and trans-1,2 dichloroethene, 1,1,- dichloroethene
and vinyl chloride.
The OU2 Rl and AGTI Report conclude that a substantial quantity of TCE from the
original spill has diffused into the rock matrix. As such, remediation of the bedrock
matrix would be difficult as a result of the bedrock geology, as well as the size,
migration, and location of the TCE mass. Currently, there are no published ARARs,
TBCs, or other guidance specific to the BVZ. Therefore, RGs have not been identified
for the BVZ. The AGTI Report concludes that the restoration of groundwater within the
Study Area to its most beneficial use is not technically practical within a reasonable
timeframe. Therefore, BVZ RAOs are based on source reduction and exposure control.
SUMMARY OF REMEDIAL ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. § 9621(b)(1), mandates that remedial actions
must be protective of human health and the environment, cost-effective, comply with
ARARs, and utilize permanent solutions, alternative treatment technologies, and
resource recovery alternatives to the maximum extent practicable. Section 121(b)(1) of
CERCLA also establishes a preference for remedial actions that employ, as a principal
element, treatment to reduce, permanently and significantly, the volume, toxicity, or
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mobility of the hazardous substances, pollutants, and contaminants at a site. Section
121(d) of CERCLA, 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 that, at least, attains ARARs under federal and state laws, unless a
waiver can be justified pursuant to Section 121(d)(4) of CERCLA, 42 U.S.C. §
9621(d)(4).
The alternatives for addressing contamination at the Site are organized by media and
summarized below. Detailed descriptions of the remedial alternatives for addressing
the contamination found at the Site are provided in the 2023 FS Report. The
construction time for each alternative reflects only the time required to construct or
implement the remedy and does not include the time required to design the remedy,
negotiate the remedy performance with the PRP or procure contracts for design and
construction.
Common Elements of the Alternatives
The alternatives described below, with the exception of the 'No Action' alternative,
include common elements which are implementable and do not change significantly in
scope from one alternative to another as follows:
a. Institutional Controls in the form of governmental controls (see Appendix C of the
2023 FS Report); proprietary controls (e.g., easements on Spill Zone parcels);
and informational devices relating to groundwater, soil vapor, and the Spill Zone
(e.g., notices, publications) to limit exposure to contaminated soil, groundwater
and soil vapor;
b. Monitoring, which includes sampling, of groundwater, surface water, soil vapor
and indoor air as follows:
- A long-term groundwater and surface water monitoring program will be
implemented to track and to monitor changes in the groundwater
contamination to ensure the RAOs are attained.
- The groundwater data results would be used to evaluate any contaminant
migration and changes in VOC contaminants over time.
- Soil vapor and indoor air would be collected to ensure continued
protection for impacted properties.
c. Maintenance of existing sub-slab depressurization systems (SSDSs) and
installation of new systems, as needed, for impacted properties; and
d. Connection of new homes constructed over the groundwater plume to the current
municipal water supply system or the provision of a point-of-entry treatment
system if connection to the municipal system is not feasible.
The costs for the common elements discussed above that apply to groundwater and
soil vapor are outlined below. For the common elements that apply to the other media,
those costs are presented in the media-specific alternatives below.
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Cost Summary for Groundwater and Soil Vapor Common Elements
Media
Description
Capital
Costs
Present
Worth O&M
Costs'1'
Institutional
Controls
Cost
Total
Costs
Groundwater
Monitoring &
ICs
$0
$2,253,200
$524,000
$2,778,000
Soil Vapor
Monitoring &
Maintenance
$0
$659,700
$0
$660,000
(1) Present Worth costs for Groundwater and Soil Vapor Media Operation & Maintenance were
estimated for a 30-year O&M period
Bedrock Vadose Zone (BVZ) Remedial Alternatives
BVZ Alternative 1: No Action
The Superfund regulations require that the "no-action" alternative be considered as a
baseline for comparison with the other alternatives. The no-action remedial alternative
does not include any remedial measures that address the contamination at the Site.
Capital Cost:
$0
Annual O&M Cost:
$0
Present-Worth Cost:
$0
BVZ Alternative 2: Monitoring and ICs
No active remedial actions would be implemented in the BVZ under Alternative 2. An
operations and maintenance (O&M) plan would be prepared to protect workers from
TCE exposure by outlining methods and procedures for any on-Site work activities.
Additionally, ICs (consisting of deed notices and informational devices) and monitoring
(groundwater sampling) would be established to prevent the potential use and
exposure of impacted materials, as well as to monitor the groundwater quality through
sampling over time.
Capital Cost:
$0
Annual O&M Cost:
$0
Common Elements Cost:
$137,250
Present-Worth Cost:
$137,250
Construction Time:
Not Applicable
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BVZ Alternative 3a (original OU1 bedrock remedy): BVE in a 10-acre portion of the
BVZ, Monitoring and ICs:
Under this alternative, which was also part of the selected remedy in the OU1 ROD, a
BVE system would be installed within the Spill Zone to address the TCE mass that
remains within the unsaturated BVZ in the 10-acre area. This would consist of a
network of vapor extraction wells, vacuum extraction pumps, and a treatment system to
mitigate the extracted vapors. The extent of the proposed area is based on bedrock
TCE vapor with the outer most limits containing concentrations of approximately 10,000
|jg/m3. TCE within the seasonally saturated BVZ would not be addressed by this
alternative as it would not be effective.
Capital Cost:
$8.36 million
Annual O&M Cost:
$1.00 million
Common Elements Cost:
$0.14 million
Present-Worth Cost:
$9.50 million
Construction Time:
8 months
BVZ Alternative 3b: BVE in a 2-acre portion of the BVZ. Monitoring and ICs
Under this alternative, a BVE system would be installed within the Spill Zone to
address the TCE mass that remains within the unsaturated BVZ in a two-acre area.
This consists of a network of vapor extraction wells, vacuum extraction pumps, and a
treatment system to mitigate the extracted vapors. The extent of the proposed area is
based on bedrock TCE vapor data with the outermost limits containing concentrations
of approximately 1,000,000 |jg/m3. TCE within the seasonally saturated BVZ would not
be addressed by this alternative as it would not be effective.
Capital Cost:
$2.73 million
Annual O&M Cost:
$0.85 million
Common Elements Cost:
$0.14 million
Present-Worth Cost:
$3.72 million
Construction Time:
4 months
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Surface Water (SW) Remedial Alternatives
SW Alternative 1: No Action
The Superfund regulations require that the "no-action" alternative be considered as a
baseline for comparison with the other alternatives. The no-action remedial alternative
does not include any remedial measures that address the contamination at the Site.
Capital Cost:
$0
Annual O&M Cost:
$0
Present-Worth Cost:
$0
SW Alternative 2: ICs and Monitoring
No active surface water remedial action would be implemented as part of this
alternative. Improvements in surface water quality would be through natural
degradation of TCE by dispersion, dilution, volatilization, biodegradation, and abiotic
processes. Monitoring would determine if the surface water quality improved over time.
Capital Cost:
$1.76 million
Annual O&M Cost:
$0
Common Elements Cost:
$0.08 million
Present-Worth Cost:
$1.84 million
Construction Time:
Not Applicable
SW Alternative 3: Hydraulic Containment of Contaminated Groundwater with ICs and
Monitoring
This alternative would involve the installation and operation of several groundwater
extraction wells (and associated treatment and discharge of extracted groundwater) to
prevent contaminated groundwater discharges to surface water and active seeps and
flows within the Mud Creek area. A Preliminary Design Investigation (PDI) would be
undertaken and include collection of seasonal data in the Mud Creek area for flow
conditions, groundwater elevations, surface water quality, and identification of fractured
rock or karst subsurface flow pathways. Wells and piezometers would be installed, and
pump tests would be completed to refine data on groundwater level fluctuations and
flow directions, seep flow rates, changes in COC concentrations, and hydraulic
conductivity. Monitoring would determine if the surface water quality improves over
time.
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Capital Cost:
$5.43 million
Annual O&M Cost:
$5.09 million
Common Elements Cost:
$0.08 million
Present-Worth Cost:
$10.6 million
Construction Time:
1 year
SW Alternative 4: Streambed Cover with ICs and Monitoring
This alternative consists of covering the active Mud Creek stream segments and seeps
that are impacted by TCE with stones sourced from nearby quarries. The stones would
be placed such that the stream would be well below the top of the streambed cover,
thereby preventing direct human contact with TCE-impacted media. A PDI would be
conducted in order to properly assess the long-term effectiveness of the proposed
streambed cover, and to ensure its proper design and placement. Monitoring would
determine if the surface water quality improves over time.
Capital Cost:
$2.07 million
Annual O&M Cost:
$0.53 million
Common Elements Cost:
$0.08 million
Present-Worth Cost:
$2.69 million
Construction Time:
3 months
SW Alternative 5: In-situ Treatment of Contaminated Surface Water, Streambed Cover
with ICs. and Monitoring
This alternative includes the streambed cover from Alternative 4 and adds the
installation of one or more permeable treatment barriers (PTBs) to create treatment
zones as an engineered in-situ treatment process. The PTBs would also prevent any
potential human contact with TCE-impacted surface water. Once a PDI has been
completed for the Mud Creek area, the design, the number of treatment zones, their
specific location, configuration, and the process or media to be used within the
treatment zones will be determined. The PDI would collect seasonal data for flow
conditions, groundwater elevations, surface water quality samples, and identification of
fractured rock or karst subsurface flow pathways. Additional geochemical sampling and
pilot scale installation of one or more of the PTBs in potential treatment zones would be
conducted to determine performance and maintenance requirements of the PTBs.
Monitoring would determine if the surface water quality improves over time.
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Capital Cost:
$4.12 million
Annual O&M Cost:
$3.10 million
Common Elements Cost:
$0.08 million
Present-Worth Cost:
$7.31 million
Construction Time:
3 months
Soil Remedial Alternatives
Soil Alternative 1: No Action
The NCP requires that a "No Action" alternative be developed and considered as a
baseline for comparing other remedial alternatives. Under this alternative, no additional
action would be implemented beyond what was accomplished under the OU1 ROD.
Capital Cost:
$0
Annual O&M Cost:
$0
Present-Worth Cost:
$0
Soil Alternative 2: Solidification/Stabilization (S/S) or Cover System using Commercial
Land-Use Based PRG
Under this alternative, the Spill Zone overburden soils would be remediated using ex
situ solidification/ stabilization. Overburden materials exceeding the commercial land-
use PRG of 200 mg/kg for TCE in soil to depths ranging up to 10.5 ft bgs would be
excavated, mixed with Portland cement (or other material) to immobilize the
contamination, and returned to the excavation area underlain by a demarcation layer.
Post-excavation samples would be completed to ensure all impacted overburden soil
exceeding the commercial land use PRG of 200 mg/kg for TCE has been removed. In
addition, placement of topsoil and seed to provide for one foot of clean soil cover will
extend to any areas of the Spill Zone where surface soil exceeds 2 mg/kg, which is the
NYS value for the protection of ecological receptors. Community air monitoring and
dust control measures would be performed during construction activities to ensure that
VOCs are not volatilizing into the air.
On-Site ex-situ treatment of TCE-impacted overburden in a temporary treatment unit
and placing the solidified material in the excavation area would need to comply with
Resource Conservation and Recovery Act (RCRA) corrective action management unit
(CAMU) performance standards including requirements for a liner, leachate collection
system, cap, and groundwater monitoring.
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Capital Cost:
$1.37 million
Annual O&M Cost:
$0.71 million
Common Elements Cost:
$0.12 million
Present-Worth Cost:
$2.20 million
Construction Time:
20 months
Soil Alternative 3: Excavation/Disposal using Commercial Land-Use Based PRG
Under this alternative, the Spill Zone overburden material exceeding the commercial
land use PRG for TCE of 200 mg/kg would be excavated to depths of up to 10.5 ft bgs.
An estimated total of 1,150 cubic yards (yd3) (1,840 tons) of overburden would be
removed and disposed off-Site at an approved disposal facility. Post-excavation
samples would be completed to ensure all impacted overburden material exceeding the
PRG of 200 mg/kg for TCE has been removed. The area would then be backfilled
using clean, imported soil and/or stone underlain by a demarcation layer. In addition,
placement of topsoil and seed to provide for one foot of clean soil cover would extend
to areas of the Spill Zone where surface soil exceeds the 2 mg/kg value for the
protection of ecological receptors. Community air monitoring and dust control
measures would be performed during construction activities to verify volatilization of
VOCs into the air is not occurring.
Capital Cost:
$3.02 million
Annual O&M Cost:
$0.06 million
Common Elements Cost:
$0.12 million
Present-Worth Cost:
$3.20 million
Construction Time:
6 months
Soil Alternative 4: Low-Temperature Thermal Desorption (LTTD) using Commercial
Land-Use Based PRG
Under this alternative, the Spill Zone overburden material exceeding the commercial
land use PRG of 200 mg/kg would be remediated ex-situ using LTTD to depths of up to
10.5 ft bgs. An estimated total of 1,150 yd3 (1,840 tons) of overburden would be
removed, treated via LTTD. Post-excavation samples would be completed to ensure
all impacted overburden material exceeding the PRG of 200 mg/kg for TCE has been
removed. The area would then be backfilled using clean, imported soil and/or stone
underlain by a demarcation layer. In addition, placement of topsoil and seed to provide
for one foot of clean soil cover would extend to areas of the Spill Zone where surface
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soil exceeds 2 mg/kg value for the protection of ecological receptors. Community air
monitoring and dust control measures will be performed during construction activities to
verify volatilization of VOCs into the air is not occurring.
On-Site treatment of TCE-impacted overburden by ex-situ in a temporary treatment unit
and placing the treated material in the excavation area would need to comply with the
RCRA CAMU performance standards. If LTTD treatment achieves 90% reduction of
TCE or reaches 10 times the universal treatment standard (60 mg/kg), the CAMU
would not have to comply with the requirements for a liner, leachate collection system,
cap, and groundwater monitoring.
Capital Cost:
$1.82 million
Annual O&M Cost:
$0.06 million
Common Elements Cost:
$0.12 million
Present-Worth Cost:
$2.00 million
Construction Time:
16 months
COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy for a site, EPA considers the factors set forth in Section 121 of
CERCLA, 42 U.S.C. § 9621, and conducts a detailed analysis of the viable remedial
alternatives in accordance with the NCP, 40 C.F.R Section 300.430(e)(9), the EPA's
Guidance for Conducting Remedial Investigations and Feasibility Studies, OSWER
Directive 9355.3-01, and the EPA's A Guide to Preparing Superfund Proposed Plans,
Records of Decision, and Other Remedy Selection Decision Documents, OSWER
9200.1-23. P. The detailed analysis consists of an assessment of the individual
alternatives set forth in the FS against each of the nine evaluation criteria set forth at
Section 300.430(e)(9)(iii) of the NCP and a comparative analysis focusing upon the
relative performance of each alternative against those criteria.
The evaluation criteria are described below.
Threshold Criteria - The two threshold criteria described below must be met in order
for the alternatives to be eligible for selection in accordance with the NCP.
• Overall protection of human health and the environment addresses whether a
remedy provides adequate protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure scenario) are
eliminated, reduced, or controlled through treatment, engineering controls, or
institutional controls.
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• Compliance with ARARs addresses whether a remedy will meet all of the applicable
or relevant and appropriate requirements of other federal and state environmental
statutes and requirements or provide grounds for invoking a waiver.
Primary Balancing Criteria - The following five criteria are utilized to compare and
evaluate the elements of one alternative to another that meet the threshold criteria:
• Long-term effectiveness and permanence refers to the ability of a remedy to
maintain reliable protection of human health and the environment over time, once
cleanup goals have been met. It also addresses the magnitude and effectiveness
of the measures that may be required to manage the risk posed by treatment
residuals and/or untreated wastes.
• Reduction of toxicity, mobility, or volume through treatment is the anticipated
performance of the treatment technologies, with respect to these parameters, that a
remedy may employ.
• Short-term effectiveness addresses the period of time needed to achieve protection
and any adverse impacts on human health and the environment that may be posed
during the construction and implementation period until cleanup goals are achieved.
• implementability is the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement a particular option.
• Cost includes estimated capital and O&M costs, and net present-worth costs.
Modifying Criteria - The modifying two modifying criteria are used as the final
evaluation of remedial alternatives, generally after EPA has received public comment
on the RI/FS and Proposed Plan:
• State acceptance indicates if, based on its review of the Rl and FS reports and the
Proposed Plan, the State concurs with the selected remedy at the present time.
• Community acceptance refers to the public's general response to the alternatives
described in the FS report and Proposed Plan.
The following is a comparative analysis of these alternatives based upon the evaluation
criteria noted above.
Bedrock Alternatives
Overall Protection of Human Health and the Environment
BVZ Alternative 1 (No Action) would not meet the RAOs and would not be protective of
human health and the environment because no action would be taken. BVZ
Alternatives 2, 3a and 3b would address risk mitigation through the ICs. Although the
active remedial BVZ alternatives (3a and 3b) would provide for a marginal reduction in
TCE mass within the BVZ, the beneficial impact with respect to protection of human
health would be negligible given that the majority of the TCE mass would be retained
within the bedrock matrix micro pore spaces. None of the alternatives presented would
substantially improve groundwater quality as a result of the matrix diffusion
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mechanisms that occur between the bedrock matrix porewater and the groundwater
media, which would be expected to continue for a significant period of time into the
future.
Compliance with Applicable or Relevant and Appropriate Requirements
There are no current federal and/or state ARARs that are applicable for the bedrock
source material. None of the bedrock alternatives presented would be sufficient to meet
the groundwater ARAR of 5 |jg/L across the entirety of the TCE-impacted groundwater
plume or to reduce risk, in general, with regards to exposure to TCE-impacted
groundwater media.
Long-Term Effectiveness and Permanence
BVZ Alternative 1 would not have any long-term effectiveness and permanence
because no action would be taken. BVZ Alternative 2, which involves the
implementation of comment elements and ICs, would provide for a permanent and
effective means of mitigating potential exposure to TCE-impacted bedrock media and
to Site groundwater that is impacted by the TCE present within the bedrock media.
BVZ Alternatives 3a and 3b would not be expected to provide any benefit with respect
to: i) reducing TCE mass to any practical extent within the BVZ; and ii) reducing TCE
concentrations (and associated exposure risk) within the TCE-impacted groundwater
media, based on an analysis of the Site data collected through various investigations
and modeling efforts.
Reduction of Toxicity, Mobility, or Volume Through Treatment
BVZ Alternative 1 would not address the contamination through treatment, so there
would be no reduction in toxicity, mobility, or volume of the contaminants, and the
alternative does not include long-term monitoring of groundwater conditions. As a result
of the limitations and uncertainties associated with the matrix diffusion processes within
bedrock media, the unpredictable nature associated with the application of BVE in a
fractured bedrock media and any implementation of active remediation through BVE
(BVZ Alternatives 3a and 3b), would be expected to recover a very small fraction of the
TCE mass that lies within the BVZ. Consequently, only a marginal reduction of toxicity,
mobility and volume would be expected within the bedrock media when compared to
the BVZ Alternatives 1 and 2.
Short-Term Effectiveness
BVZ Alternative 1 would not have short-term adverse impacts, because no action
would be implemented. The activities associated with the BVE system installation
phase for BVZ Alternatives 3a and 3b would present a moderate to high degree of risk
to on-Site workers, and little to no risk to the community. The elevated risk associated
with the installation of the BVE system could be mitigated through the appropriate
training of on-Site personnel, and implementation of rigorous safety protocols. Once a
BVE system is operational, routine sampling and O&M activities would present a
moderate degree of risk to on-Site workers, and little to no risk to the community. In
contrast, implementation of either BVZ Alternatives 1 or 2 would not present any
increased risk to on-Site workers or the public, in general.
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Implementability
BVZ Alternative 1 would be the easiest alternative to implement, as there are no
activities to undertake. The implementability of BVZ remedial alternatives 3a and 3b
would be challenging since a large number of extraction wells would be required, there
are uncertainties with regards to their placement, and there are system operational
challenges associated with: i) a highly variable water table; and ii) matrix diffusion
processes within the bedrock media (both of which would limit that amount of TCE
mass that could be recovered by the BVE process). Additionally, the application of BVE
would not address the TCE-impacted bedrock that is present below the water table,
thus further impacting its implementability and effectiveness. In contrast, there are no
technical or administrative implementability issues associated with the BVZ Alternatives
1 and 2.
Cost
The estimated capital, O&M, and present-worth cost are discussed in detail in EPA's
Final Feasibility Study Report. For estimating costs and for planning purposes, a 3-year
time frame was used for O&M under Alternatives 3a and 3b. The cost estimates are
based on the best available information.
Cost Summary for Bedrock Media Remedial Alternatives
Alternative
Capital Cost
Present Worth
Costs
Institutional
Control Costs
Total Costs
#1 - No Action
$0
$0
$0
$0
#2 - Institutional
Controls
$0
$0
$137,250
$137,250
#3a - BVE (10-Acre
Area)
$8,356,700
$1,007,616
$137,250
$9,502,000
#3b - BVE (2-Acre
Area)
$2,729,950
$850,176
$137,250
$3,718,000
Surface Water Alternatives
Overall Protection of Human Health and the Environment
SW Alternative 1 (No Action) would not meet the RAOs and would not be protective of
human health and the environment because no activities would be taken. SW
Alternative 2: ICs and Monitoring and SW Alternative 4: Streambed Cover with ICs and
Monitoring would not be protective remedial approaches since they would not reliably
prevent unacceptable exposure in Mud Creek surface water and would not address
contaminant migration from the Spill Zone to Mud Creek. The Hydraulic Containment
(SW Alternative 3) and In-situ Treatment with Streambed Cover (SW Alternative 5)
alternatives would provide protection by eliminating unacceptable exposure through
both the containment of the TCE-impacted surface water and treatment process. A PDI
would need to be conducted in order to obtain specific data, such as seasonal surface
water flows, TCE concentrations, and pilot scale data to assist in the implementation of
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key design elements for SW Alternatives 2, 3, 4, and 5.
Compliance with Applicable or Relevant and Appropriate Requirements
The No Action alternative would not comply with NYS standards for surface water TCE
concentration within a "Class C" stream {i.e., 40 |jg/L). SW Alternative 2 (PDI and
Common Elements) and SW Alternative 4 (Streambed Cover with ICs) would not
comply with ARARs and would not provide for a reduction in TCE concentrations that
would meet the RG. Implementation of Hydraulic Containment (SW Alternative 3) and
In-Situ Treatment with Streambed Cover (SW Alternative 5) would achieve the RG for
TCE.
Long-Term Effectiveness and Permanence
The long-term effectiveness under the No Action and the ICs and Monitoring
alternatives (SW Alternatives 1 and 2) would not be achieved, as these two alternatives
do not provide for a method to address surface water TCE concentrations that exceed
the RG. Assuming favorable results are obtained from the PDI, SW Alternatives 3, 4,
and 5 could all provide for an effective long-term solution with regards to surface water
TCE-impacts in the Mud Creek area. In addition to favorable results from the PDI, the
implementation of routine O&M procedures would be another key component with
regards to the long-term effectiveness of SW Alternatives 3, 4, and 5.
Reduction of Toxicity, Mobility, or Volume Through Treatment
SW Alternative 1 (No Action) would not address the contamination through treatment
so there would be no reduction in toxicity, mobility, or volume of the contaminants.
Additionally, the No Action alternative does not include long-term monitoring of the
ongoing groundwater conditions. The No Action and the Common Elements
alternatives (SW Alternatives 1 and 2) do not provide for any reduction of toxicity,
mobility or volume of TCE impacts. Since SW Alternatives 3 and 5 provide for a
method of containment for contaminated groundwater discharging to surface water, the
two alternatives would then provide for a reduction in the toxicity, mobility and volume
of TCE with regards to the surface water pathway. Since SW Alternative 4 presents
only a physical barrier, this alternative does not provide a reduction of toxicity, mobility
or volume. SW Alternatives 3 and 5 also provides for an additional mechanism that
may result in the reduction of toxicity, mobility and volume of TCE in surface water
through a treatment process.
Short-Term Effectiveness
SW Alternative 1 (No Action) would not have short-term adverse impacts because no
action would be implemented. The system installation activities associated with SW
Alternatives 3, 4 and 5 would present a moderate to high degree of risk to on-Site
workers, and little to no risk to the community. A significant component of this risk is the
result of construction activities that would need to be conducted in largely wooded and
uneven terrain. The elevated risk associated with the installation of these remedial
systems could be mitigated through the appropriate training of on-Site personnel, use
of proper construction equipment, and implementation of safety protocols. Routine
sampling and O&M activities associated with the proposed remedial systems would
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present a moderate degree of risk to on-Site workers and little to no risk to the
community. In contrast, implementation of either the No Action or the Common
Elements alternatives would not present any increased risk to on-Site workers or the
public in general.
Implementability
Alternative 1 would be the easiest alternative to implement, as there are no activities to
undertake. No technical implementability issues are associated the No Action and
Common Elements alternatives. SW Alternatives 3, 4 and 5 would all require a PDI to
be conducted initially in order to determine the design parameters associated with their
implementation. Depending on the results of the PDI, each of these three alternatives
would require a significant amount of construction activities to be conducted within a
heavily wooded area, as well as the Mud Creek streambed itself. Access roads would
need to be constructed for construction equipment and on-Site workers to access the
various locations where system infrastructure needs to be installed. SW Alternatives 3
and 5 would require an installation phase that may take half-a-year or more to
complete. Additionally, SW Alternative 3 would require a significant footprint to house
all the necessary equipment necessary for its implementation. SW Alternatives 3 and 5
would require extensive routine O&M activities associated with their long-term
operation. This could include servicing of pumps, motors and treatment equipment,
replacement of treatment media, and/or waste disposal. In contrast, the long-term O&M
activities associated with SW Alternative 4 would be simple and straightforward, and
significantly easier to manage over the long-term.
Cost
The estimated capital, O&M, and present-worth cost are discussed in detail in the Final
Feasibility Study Report. For estimating costs and for planning purposes, a 30-year
time frame was used for O&M under Alternatives 3 through 5. The costs estimates are
based on the best available information.
Cost Summary for Surface Water Media Remedial Alternatives
Alternative
Capital Cost
Present Worth
Costs
Institutional
Control Costs
Total Costs
#1 - No Action
$0
$0
$0
$0
#2 - Institutional
Controls
$1,757,300
$0
$81,750
$1,840,000
#3 - Hydraulic
Containment
$5,427,950
$5,087,690
$81,750
$10,598,000
#4 - Streambed
Cover
$2,073,200
$533,587
$81,750
$2,689,000
#5 - In-Situ
T reatment with
Streambed Cover
$4,121,550
$3,102,250
$81,750
$7,306,000
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Soil Alternatives
Overall Protection of Human Health and the Environment
Soil Alternative 1 (No Action) would not meet the RAOs and would not be protective of
human health and the environment because no action would be taken. Except for the
No Action Alternative, all alternatives are protective of human health and the
environment. Soil Alternatives 3 and 4 reduce TCE concentrations on-Site through
physical removal. Although Soil Alternative 2 does not reduce TCE concentrations,
solidification would mitigate wind/surface water erosion and incidental
ingestion/inhalation and placement within a lined/capped CAMU would make these
alternatives equally as protective.
Compliance with Applicable or Relevant and Appropriate Requirements
EPA has identified NYSDEC's soil cleanup objectives (SCOs) (6 NYCRR § 375-6.5) as
an ARAR, a "to-be considered," or other guidance to address contaminated soil at the
Site. Refer to soil PRG in the table above. The No Action Alternative does not achieve
the soil PRGs. Since all alternatives involve removal of soil and any treatment options
would be expected to meet the soil PRGs for the soil placed back on the ground, post-
excavation soil samples would verify attainment of the PRGs. Imported soil for backfill
under Soil Alternative 3 would be tested to verify conformance with the allowable
constituent levels for imported fill soil. Since Soil Alternative 2 (solidification) would not
achieve any reduction in soil TCE concentrations, the CAMU would need to comply
with the requirements for a liner, leachate collection, cap, and groundwater monitoring.
Long-Term Effectiveness and Permanence
The No Action Alternative provides no long-term effectiveness toward achieving the
RAOs. All alternatives prevent direct contact with residual impacts. Soil Alternative 3
provides the greatest long-term effectiveness and permanence since the TCE-
impacted soil media is removed from the Site. If proven effective through pilot testing,
Soil Alternative 4 (LTTD) will permanently reduce TCE concentrations on-Site.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Soil Alternative 1, (No Action), would not address the contamination through treatment,
so there would be no reduction in toxicity, mobility, or volume of the contaminants, and
the alternative does not include long-term monitoring of groundwater conditions. Soil
Alternative 2 (solidification) would reduce the mobility but not the toxicity or volume of
TCE impacted soil media. Soil Alternative 3 (off-Site disposal) would reduce the
toxicity, mobility, and volume on-Site; however, the off-Site reduction in toxicity and/or
volume depends on the form of treatment/disposal at the Treatment, Storage and
Disposal Facility (TSDF). Soil Alternative 4 (LTTD) would reduce the volume of TCE in
the soil media but the overall reduction in volume and toxicity depends on the form of
emissions control employed.
Short-Term Effectiveness
Soil Alternative 1 would not have short-term adverse impacts because no action would
be implemented. All other soil alternatives would result in noise, dust, and vapor
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impacts; however, these are considered minimal and controllable through proper
construction techniques. Evaluation of additional emissions controls for crushing that
might be required under Soil Alternative 2 (solidification) would be considered during
pilot-testing. Except for Soil Alternative 2, the work would be sequenced to minimize
the time the excavation will remain open and safety measures would be in place.
Construction of a CAMU for Soil Alternative 2 would require an open excavation for a
significant period to install the liner and leachate collection system. Soil Alternative 4
would require significant fuel for the LTTD reactor and, since natural gas is not
available near the Site, propane or heating oil tanks would need to be kept on-Site
resulting in short-term risk to both human health and the environment.
Implementability
Alternative 1 would be the easiest alternative to implement, as there are no activities to
undertake. Soil Alternative 2 (solidification) would have significant technical and
administrative implementability issues surrounding construction of a CAMU in the Spill
Zone. Since ex-situ solidification and stabilization of the soil media does not result in a
TCE concentration reduction, the CAMU would have to comply with the requirements
for a liner, leachate collection system, cap, and groundwater monitoring. Administrative
issues include require agency approval of the CAMU design. The impacted soil media
would need to be excavated and stockpiled or placed in roll off containers pending
CAMU construction. The impacted material would need to be covered to prevent
erosion. Design and construction of a CAMU would extend the time for these remedial
alternatives by approximately 12 months. Other implementability issues include
determining the type and amount of binding agent that will effectively solidify the
impacted soil media and securing the appropriate equipment. The footprint of the
CAMU would need to be larger than the excavation area to manage the grade change
due to volume increases through the addition of the solidification agent.
Soil Alternative 3 (off-Site disposal) would require traffic coordination for off-Site
transport to the TSDF, securing a disposal contract with out-of-State TSDF, and
locating a borrow source for backfill material. Soil Alternative 4 requires a pilot test to
verify effectiveness, securing specialized equipment for LTTD, and emissions control.
Soil Alternative 4 is estimated to take up to 18 months to implement. For all active soil
alternatives, community air monitoring and dust control measures would be performed
during construction activities to verify volatilization of VOCs into the air is not occurring.
Cost
The estimated capital, O&M, and present-worth cost are discussed in detail in the
Final Feasibility Study Report. For estimating costs and for planning purposes, a 30-
year time frame was used for O&M under Alternatives 2 through 4. The costs estimates
are based on the best available information.
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Cost Summary for Soil Media Remedial Alternatives
Alternative
Capital Cost
Present Worth
Costs
Institutional
Control Costs
Total Costs
#1 - No Action
$0
$0
$0
$0
#2 - Solidification/
Stabilization
$1,368,900
$706,000
$121,750
$2,198,000
#3 - Excavation and
Proper Disposal
$3,017,897
$62,000
$121,750
$3,202,000
#3 - Low
Temperature
Thermal Desorption
$1,813,090
$62,000
$121,750
$1,997,000
State/Support Agency Acceptance
NYSDEC, in consultation with NYS Department of Health (NYSDOH), concurs with
EPA's selected remedies for the groundwater, bedrock vapor, soil vapor, soil, surface
water and the common elements applicable to the various media, however, NYSDEC
does not concur with EPA's remediation goal for soil. A letter of concurrence is
attached in Appendix IV.
Community Acceptance
Relatively few comments were received during the public comment period. Other than
correspondence from LVRR, which expressed concerns about the preferred surface
water alternative and the overall cost of the remedy, and a resident's comment on
costs of the remedy, the comments and questions received in writing and during the
public meeting tended to focus more on Site history, the costs of the prior response
actions, and other issues (e.g., connection to the waterline, soil disturbance in/around
the Spill Zone, etc.) that were not directly related to the proposed remedy. Given the
comments received, EPA believes that the public generally supports the selected
remedy. Significant comments 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 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
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analysis of alternatives, using the 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.
TCE released from the train derailment has diffused into the bedrock matrix and
continues to be an ongoing source of groundwater contamination. Contaminated
groundwater is generally not considered to be source material. As discussed in detail
in this ROD, the bedrock acts as a continual, slow source to groundwater at the Site,
and therefore does not meet the definition of principal threat waste. Additionally, soil is
not considered principal threat waste because it does not act as a significant source of
contamination to groundwater.
SELECTED REMEDY
Summary of the Rationale for the Selected Remedy
The selected remedy is intended to be a comprehensive one which addresses all
contaminated media: groundwater, soil, bedrock, surface water and vapor intrusion.
The selected remedy for the groundwater involves a Tl waiver of chemical-specific
ARARs based on the following factors: (1) the limited options available to successfully
treat contamination in fractured bedrock with extensive evidence of matrix diffusion into
the rock over a wide area; (2) the expected limited ability of the groundwater
contamination to expand beyond its current extent; and, (3) the limited potential for
treatment or containment of contamination remaining in the Spill Zone to result in a
measurable improvement in groundwater quality anywhere in the aquifer within a
reasonable time period. It also includes monitoring and institutional controls (see
common elements).
The selected remedy for the Bedrock Vadose Zone - BVZ Alternative 2: ICs and
Groundwater Monitoring was selected over BVZ Alternatives 3a and 3b. As
demonstrated in the FS, the source reduction RAOs cannot be met because of matrix
diffusion, complexity of the fracture network, and the groundwater elevation fluctuations
in the BVZ. The active remedial BVZ alternatives (3a and 3b) would not achieve any
appreciable reduction of TCE mass in the long term as a result of the matrix diffusion
mechanisms that occur between the bedrock matrix porewater and the groundwater
media, which would be expected to continue for a significant period of time into the
future. This is also a basis for EPA's Tl waiver as to restoration of groundwater. The
implementation of long-term groundwater monitoring and ICs will provide for an
effective means of mitigating potential exposure to TCE-impacted bedrock media, and
to Site groundwater that is impacted by the TCE present within the bedrock media.
The selected remedy for soil - excavation and off-Site disposal - was selected over
other alternatives because it is expected to achieve the greatest degree of long-term
effectiveness and permanence by removing impacted soils. Excavation is technically
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feasible, is a proven technology, and more reliable than the soil treatment presented in
Soil Alternatives 4 and 5. It is expected that the soil remedy will be substantially
implemented within five to six months at a cost comparable to the other alternatives
and provide for long-term reliability of the remedy.
The selected remedy for surface water - in-situ treatment of contaminated surface
water with streambed cover, ICs and monitoring - was selected over the other
Alternatives because it is expected to achieve substantial and long-term risk reduction
through treatment of contaminants, prevention of contaminant migration, and the use of
engineering and institutional controls. The surface water component of the remedy
reduces the risk within a reasonable time frame, at a cost comparable to other
alternatives, and provides for long-term reliability of the remedy. A PDI would be
undertaken and include collection of seasonal data in the Mud Creek area to refine flow
conditions, groundwater elevations, surface water quality, and fractured rock or karst
subsurface flow pathways.
Based upon the information currently available, EPA believes that the selected remedy
meets the threshold criteria and provides the best balance of trade-offs among the
other alternatives with respect to the balancing criteria. As discussed above, EPA is
invoking an ARAR waiver for specific federal and state drinking water and groundwater
standards at the Site because of the technical impracticability of achieving ARARs in
the Tl Zone.
Description of the Selected Remedy
The response action described in this document amends the OU1 remedy selected by
NYSDEC in 1997 and selects a remedy for OU2. The major components of the OU2
remedy by medium are:
1. Groundwater - For the approximately four-mile TCE plume, implementation of a
combination of monitoring and ICs while invoking a Tl waiver for chemical-
specific groundwater standards in the Tl Zone (see Figure 4) because
groundwater cannot be restored in a reasonable timeframe. Outside of the Tl
Zone, the groundwater standards will remain as the final cleanup goal. Long-
term monitoring and groundwater use restrictions will be required.
2. Bedrock Vadose Zone (BVZ) - ICs and Groundwater Monitoring in the BVZ.
The BVZ and the groundwater in the Spill Zone (the 10-acre area of the original
TCE spill) are within the Tl Zone (see Figure 4).
3. Soil in the Spill Zone - Excavation/Disposal - Soil exceeding 6 NYCRR Part
375 TCE soil cleanup objectives for commercial use (200 milligrams per
kilogram (mg/kg)) to a depth up to 10.5 feet below ground surface (bgs) will be
excavated and properly disposed of off-Site. The area will be backfilled using
clean, imported soil and/or stone underlain by a demarcation layer. Placement of
topsoil and seed to provide for one foot of clean soil cover will extend to any
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areas of the Spill Zone where concentrations of TCE in surface soil exceeds 2
mg/kg, which is the NYS value for the protection of ecological receptors.
4. Surface Water (Section of Mud Creek): In-situ treatment of contaminated
surface water with streambed cover, ICs, and monitoring.
In addition, disturbed areas (including vegetated surfaces, roadways, sidewalks, curbs,
etc.) will be restored to their original pre-construction condition and topographic contour
following the completion of remedial construction.
5. Common Elements Applicable to all Media:
a. ICs in the form of governmental controls (see Appendix C of the
Feasibility (FS) Study Report); proprietary controls (e.g., easements on
Spill Zone parcels); and informational devices relating to groundwater,
soil vapor, and the Spill Zone (e.g., notices, publications) to limit exposure
to contaminated soil, groundwater and soil vapor;
b. Monitoring, which includes sampling of groundwater, surface water, soil
vapor, and indoor air as follows:
i. A long-term groundwater and surface water monitoring program will
be implemented to track and to monitor changes in the groundwater
contamination to ensure the RAOs are attained;
ii. The groundwater data results will be used to evaluate any
contaminant migration and changes in VOC contaminants over time;
iii. Soil vapor and indoor air will be collected to ensure continued
protection for impacted properties;
c. Maintenance of existing sub-slab depressurization systems (SSDSs) and
installation of new systems, as needed, for impacted properties; and
d. Connection of new homes constructed over the groundwater plume to the
current municipal water supply system or the provision of a point-of-entry
treatment system if connection to the municipal system is not feasible.
With this comprehensive remedy for the Site, EPA is also amending the following
components of the NYSDEC 1997 ROD (denominated by EPA as OU1):
1. Eliminating the bedrock vapor extraction source control measure;
2. Eliminating ex-situ soil vapor extraction, as it was implemented for two years;
3. Updating the surface water standard for TCE from the original cleanup goal of
11 micrograms per liter (|jg/L) to the current NYSDEC standard of 40 |jg/L;
4. Addressing soil contamination beneath Gulf Road by implementing ICs to
restrict access and to require proper soil management if the roadbed is
disturbed in the future; and
5. Updating the RAOs to recognize the waiver of certain Federal and state drinking
water and groundwater standards at the Site because of the technical
Impracticability of achieving the standards throughout the Tl Zone.
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A Site Management Plan (SMP) will also be developed for long-term operation and
maintenance (O&M) to provide for:
a) reviews of the effectiveness of the engineering and institutional controls;
b) proper management of the Site remedy post-construction;
c) long-term groundwater monitoring and health and safety requirements for
managing contaminated media that remain in place under Gulf Road;
d) maintenance of existing vapor mitigation systems;
e) inspection of the plume area for new home construction and associated
installation of new vapor mitigation systems; and
f) new connections of new homes constructed over the groundwater plume
to the current municipal water supply system or the provision of a point-
of-entry treatment system if connection to the municipal system is not
feasible.
The environmental benefits of the selected remedy may be enhanced by
consideration, during the design, of technologies and practices that are sustainable in
accordance with EPA Region 2's Clean and Green Energy Policy and NYSDEC's
Green Remediation Policy.2 This will include consideration of green remediation
technologies and practices.
Expected Outcomes of the Selected Remedy
Implementation of the ROD remedy for groundwater, soil, bedrock, soil vapor, and
surface water will eliminate current and potential future exposure to contaminants in
these media and ensure that contaminated groundwater does not migrate beyond the
boundaries of the Tl Zone.
Summary of the Estimated Remedy Costs
The estimated capital and total present-worth cost of the comprehensive selected
remedy is $14,082,504. It should be noted that these cost estimates are order-of-
magnitude engineering cost estimates that 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 in the cost elements are likely to occur as a result of new information and
data collected during the engineering design of the remedy.
2 See http://epa.gov/region2/superfund/green_remediation, https://semspub.epa.gov/work/HQ/100000160.pdf, and
also NYSDEC guidance at http://www.dec.nv.qov/docs/re-mediation hudson pdfZder31.pdf.
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STATUTORY DETERMINATIONS
Section 121(b)(1) of CERCLA mandates that a remedial action must be protective of
human health and the environment, be cost-effective and utilize permanent solutions
and alternative treatment or resource recovery technologies to the maximum extent
practicable. Section 121(b)(1) also establishes a preference for remedial actions which
employ treatment to permanently and significantly reduce the volume, toxicity or
mobility of the hazardous substances, pollutants, or contaminants at the Site. Section
121(d) of CERCLA further specifies that a remedial action must attain a degree of
cleanup that satisfies ARARs under federal and state laws, unless a waiver can be
justified pursuant to section 121(d)(4) of CERCLA.
EPA has determined that the selected remedy complies with the CERCLA and NCP
provisions for remedy selection, meets the threshold criteria, and provides the best
balance of tradeoffs among the alternatives with respect to the balancing and
modifying criteria. The following sections discuss how the selected remedy meets
those statutory requirements.
Protection of Human Health and the Environment
The selected remedy will adequately protect human health and the environment by
eliminating, reducing, or controlling exposures to human and environmental receptors
through excavation, treatment, engineering controls, long-term monitoring, and ICs.
The selected soil remedy will remove and dispose of contaminated materials offsite,
thereby eliminating risk of exposure and migration of impacted soils. The selected
surface water remedy will provide long-term risk reduction and protection through both
the treatment of contaminants and a containment mechanism to prevent accidental
exposure. The selected soil gas remedy will limit exposure risks using ICs and
monitoring through maintenance of existing SSDSs and installation of new systems,
as needed, for impacted properties. The implementation of long-term groundwater
monitoring and ICs would provide for an effective means of mitigating potential
exposure to TCE-impacted bedrock media, and to Site groundwater that is impacted
by the TCE that is present within the bedrock media.
Compliance with ARARs
The selected remedy will comply with chemical- location- and action-specific ARARs
for all media except where ARARs are waived. A full list of the ARARs, TBCs and other
guidelines related to implementation of the selected remedy is presented at Tables 10a
- 10c. A discussion of the more significant ARAR issues is included below.
EPA is invoking a Tl waiver for chemical-specific groundwater ARARs in the Tl Zone
because groundwater cannot be restored in a reasonable timeframe. After evaluating
the nature and extent of groundwater contamination and the available remedial
alternatives for groundwater, EPA has concluded that the available technologies
46
-------
cannot achieve restoration of the contaminated groundwater to drinking water
standards. Outside of the Tl Zone, the ARARs will remain as the final cleanup goal.
The most stringent of the National Primary Drinking Water Standards MCLs, NYS
Groundwater Quality Standards and NYSDOH Drinking Water Quality Standards were
selected as the remediation goal for the COCs. Consistent with the RAOs and the
groundwater Tl waiver, these numerical goals will be used for assessing the extent of
the aqueous plume and ensuring the necessary use restrictions are enforced, but not
for achieving restoration of groundwater to the numerical goals/criteria.
Cost-Effectiveness
A cost-effective remedy is one whose costs are proportional to its overall effectiveness
(NCP 300.430(f)(1)(ii)(D)). Overall effectiveness is based on the evaluations of long-
term effectiveness and permanence; reduction in toxicity, mobility, and volume through
treatment; and short-term effectiveness. 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 those alternatives with O&M. The total
estimated present worth cost for implementing the selected remedy is approximately
$14 million. See Appendix II, Tables 11a -11e for detailed cost estimates.
Based on the comparison of overall effectiveness to cost, the selected remedy meets
the statutory requirement that Superfund remedies be cost effective (NCP Section
300.430(f)(1)(ii)(D)) in that it represents reasonable value for the money to be spent.
Overall effectiveness was evaluated by assessing three of the five balancing criteria in
combination (long-term effectiveness and permanence; reduction in toxicity, mobility
and volume through treatment; and short-term effectiveness). Overall effectiveness
was then compared to costs to determine cost-effectiveness. The overall effectiveness
of the selected remedy has been determined to be proportional to the costs, and the
selected remedy, therefore, represents reasonable value for the money to be spent.
Utilization of Permanent Solutions and Alternative Treatment Technologies to
the Maximum Extent Practicable
The selected remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a practicable manner for the Site. EPA
has determined that the selected remedy provides the best balance of trade-offs in
terms of the five balancing criteria, while also considering the statutory preference for
treatment as a principal element, the bias against off-Site disposal without treatment,
and state/support agency and community acceptance. The selected remedy satisfies
the criteria for long-term effectiveness and permanence by permanently reducing
and/or removing the mass of contaminants in Site soils, surface water, and soil gas,
thereby reducing the toxicity, mobility and volume of contamination.
47
-------
Preference for Treatment as a Principal Element
By using an in-situ treatment as part of the surface water alternative, the selected
remedy satisfies the statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Five-Year Review Requirements
Because this preferred alternative would result in contaminants remaining on-Site
above levels that allow for unlimited use and unrestricted exposure, CERCLA requires
that the Site remedy be reviewed at least once every five years. Provisions would also
be made for periodic reviews and certifications of the institutional and engineering
controls. If justified by these reviews, additional remedial action may be implemented at
the LVRR Site.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan, released for public comment on August 18, 2023, identified the
following preferred alternatives for the contaminated media at the Site: 1) Groundwater:
Utilization of a Tl waiver (includes monitoring and ICs); 2) Bedrock Vadose Zone
Alternative BVZ - 2: ICs and Groundwater Monitoring; 3) Soil Alternative 3: Excavation
and off-Site Disposal at a licensed disposal facility; and 4) Surface Water Alternative
SW-5: In-situ treatment of contaminated surface water with streambed cover, ICs and
monitoring as the preferred remedy.
EPA considered all comments during the public comment period to determine if any
significant changes to the remedy, as originally identified in the Proposed Plan, were
necessary. EPA has determined that no significant changes to the remedy, as originally
identified in the Proposed Plan, are necessary or appropriate.
48
-------
APPENDIX I
FIGURES
-------
J0atk3 C&fK-t -y***
[BirlKmii/Jc Till i
LIVINGSTON CO
rilgnto 2013 N:rtpfrft^»gra;?iic Socfety, kxj
Regional Map
FIGURE 1
I
Unicorn
iConftultante,
52 Federal Road
Suite 2C
Danbury. CT
00810
(2D3) 205-9000
Project Name:
Lehigh Valey Railroad
Deiairnefrt Supallril sue
Ch«fced By: mHiZDD
Project *: 2032
CreslKt 1B27.Q9
Revised: an/20
Scale: 1 m:5.D0C tl
Flte: F)g1-2_Reglonai
Legend
Approximate Spill Zone
L ¦ ¦ ¦ p
'... I Approximately Study Area
I | County Boundary
New York State
*= Approximate Study Area
-------
FIGURE 2
-------
Legend
\&qzvr up*
Spflng Cnw* Pjut Zsn*
onjwi ngm 9 nn LAIC
CAOOtnOum 1 to Wrt "~•O-201«"1
1.250 2,500
5,000
7,500
"iFeet
10,000
Maximum TCE Concentrations
May 2Q17
Protect M*m* '-««ST vw*> "Jrsjo
0**an-r*c* Ooc^-j-3 SU
Project r. 2032
N«w York St«t*
•= Approximate Study Area
i
Unicom Management
Consultants, I.T.C
52 Federal Road
So t* 2C
DanOury. CT
oeaio
(203) 205 $000
FIGURE 3
-------
FIGURE 4
-------
SCALE 1 INCH = 80 FEET
SCALE IN FEET
: appro*) rra:e:
• PRIOR REMEDIAL OBJECTIVE.
EXCEEDANCE i.OCAT|ON 5 1|
< § 2?
S S»
< o >
z
-------
Mudsw-04
Apri 2017: 14 pg/L
Mudsw-03
April 2017: 27
LVRRSP-04
December 2009: 110
Mudsp-02
Apri 2017: 3 6 pg/L
LVRRSD-55
December 2009: ND
Mudsw-02
ApH 2017:4.4 pg/L
LVRRSD-56
December 200?: 3 7J p^O.
LVRRSW-56
December 2009 ND
Mudsp-01
April 2017: 0.1 J pg/L
LVRRSD-00
December 2009: ND
Mudsp-03
I Apri 2017: 320 pg/L
I
Consultants,
rfanagen
its, I.T.C
52 Federal Road
Suite 2C
Dan bury. CT
06810
(203) 205 9000
Project Name
jeftfcp vaiey Rairoaa
Deraflmeot S»r>«fftnd Site
Checked By:
Project*: 2032
Fie: Fk^i i-1 a_MuOO^esuts
New YorK State
•=Approximate Study Area
Legend
A Uua Oee« Cranage i~:'r Oa*p M
A Oalfca Crtt* Oransge I | *oy Spl Zcnt
A Oorgc Pora I I 'AjO Cree« / Quarry vn
~ Scrrg Creek Drsnage
Scale: 1 lr S33 it
LVRRSD-57
| December 2009: ND |
LVRRSW-57
I December 2009: ND I
LVRRSW-08
I November 2012:4.8 pg/L
LVRRSD-08
I December 2009: ND
LVRRSW-08
I December 2009 ND
LVRRSD-04
| December 2009 ND |
LVRRSW-04
I December 2009 ND I
Mudcreek-01
I January 2012: 5-6 p3 - I
July 2018: 5.2 pg/L
LVRRSP-03
I December 2009: 110 yg'. I
>/
Dolomite Quarry
- TCE concentrations are in ppb (pgA.)
- Red concentrations had TCE concentrations above |
Site standard of 40
- No standard set for sediment samples
Sample Types:
SP = Spring
SD = Sediment
SW = Surface Water
LVRRSP02
December 2009: 390 pg/L
LVRRSD-03
December 2009: 48 pg/L
Mudcreek-03
I July 2018 380 pg/L
0 500 1,000
Spring/Seep. Surface Water and
Sediment Sampling Locations (Mud Creek/Quarry Area)
2009/2010. 2012. 2017 and 2018 Locations
Mu0sw-05
I April 2017: 3.2 I
Mucsw-01
I Apnl 2017: ND
Figure 6
-------
APPENDIX II
TABLES
-------
TABLE 1-1
Summary of LVRR Soil Sample Analytical Results
Focused Alternatives Analysis Report Spill Zone Soils (Operable Unit OU 1)
Lehigh Valley Railroad Derailment Superfund Site, LeRoy, NY
Parameter 1
ROD2
NYSDEC Part 375 Soil Cleanup Objectives 3
B-1
B4
BS-3
BS-4
B-5
B-5
Unrestricted
Protection of Public Health
Protection of
Groundwater
Total VOCs
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Total VOCs
Total VOCs
Total VOCs
Matrix Diffusion
Commercial
Industrial
8/23/2017
9/14/2016
8/22/2017
9/5/2017
8/24/2017
8/22/2017
8/22/2017
8/22/2017
9/6/2017
Chloromethane
NA
NA
NA
NA
6.2U
14U
68.8
5100U
5.9U
73.3U
Vinyl Chloride
20
13000
27000
20
6.2U
14U
590U
57.4U
5100U
ssou
5.9U
2800U
73.3U
1,1-Dichloroethene
330
500000
1000000
330
6.2U
14U
590U
28.7U
5100U
6S0U
5.9U
2800U
3S.SU
Carbon Disulfide
NA
NA
NA
NA
6.2U
14U
28.7U
5100U
5.9U
2800U
3S.SU
Methylene Chloride
50
500000
1000000
50
6.2U
14U
59QU
28.7U
5100U
ssou
5.9U
2800U
3S.SU
trans-1,2-L)Ch
250
500000
1000000
250
S.2U
14U
&1UUU
b.9U
36.6U
1,1-Dichloroettnane
m
240000
4H0000
m
S.2U
14U
&SUU
'M.IU
&1UUU
b.9U
'jfcj.bU
cis-1,2-DCE
3000
250
500000
1000000
250
S.3J
3.&J
5S0U
28.7U
5100U
140 J
5.9U
2800U
3S.SU
Chloroform
370
350000
700000
370
6.2U
14U
590U
28.7U
^5100^^
ssou
5.9U
2800U
3S.SU
1,1,1-Trichloroethane
680
500000
1000000
680
6.2U
14U
590U
28.7U
5100U
ssou
5.9U
2800U
3S.SU
Benzene
60
44000
89000
60
0.39J
14U
590U
28.7U
5100U
ssou
5.9U
2800U
3S.SU
1,2-Dichloroethane
20
30000
60000
20
6.2U
14U
590U
28.7U
5100U
ssou
5.9U
2800U
3S.SU
"ffichloroethene
7000
470
200000
400000
470
250J
70000
770
13S0
34666(iJ
480000J
170J
75000D
14000
Toluene
700
500000
1000000
700
6.2U
•RO
590U
28.7U
5100U
5.9U
I etrachloroettnene
1300
150000
300000
1300
S.2U
14U
&100U
b.9U
36.6U
httny I benzene
1000
'J90000
/H0000
1000
S.2U
14U
feyuu
'M.IU
&100U
b.9U
3b.bU
m,p-Xylene
260
500000
1000000
1600
6.2U
28U
590U
28.7U
5i00U
S&5U
5.9U
2800U
3S.SU
o-Xylene
260
500000
1000000
1600
6.2U
14U
590U
28.7U
5100U
SSOU
5.9U
2800U
3S.SU
Isopropylbenzene
NA
NA
NA
NA
6.2U
14U
590U
57.4U
5100U
ssou
5.9U
2800U
73.3U
Styrene
NA
NA
NA
NA
6.2U
14U
590U
28.7U
5100U
ssou
5.9U
2800U
3S.SU
1,3,5- Trim ethyl benzene
8400
190000
380000
8400
6.2U
14U
590U
57.4U
5100U
ssou
5.9U
2800U
73.3U
1,2,4-Trimethylbenzene
3600
190000
380000
3600
6.2U
14U
590U
28.7U
5100U
ssou
5.9U
2800U
3S.SU
Naphthalene
NA
NA
NA
NA
S.2U
14U
8.61 J
&1UUU
b.9U
2aouu
3b.bU
1,4-Dioxane
100
130000
250000
100
B.2U
mj
NA
&1UUU
b.9U
2HUUUJ
NA
Methycyclohexane
NA
NA
NA
NA
S.3J
14U
590U
NA
5i00U
S&5U
5.9U
2800U
NA
Cyclohexane
NA
NA
NA
NA
2.4J
14U
590U
NA
5100U
ssou
5.9U
2800U
NA
2-Butanone (MEK.)
120
500000
1000000
120
20
14U
590U
NA
5100U
ssou
18
2800U
NA
Acetone
50
500000
1000000
50
690J
14U
590U
NA
5100U
ssou
440J
2800U
NA
MTBE
930
500000
1000000
930
6.2
14U
590U
NA
5100U
ssou
5.9U
2800U
NA
n-Proplybenzene
3900
500000
1000000
3900
S.2U
14U
590U
NA
5100U
ssou
5.9U
2800U
NA
Notes:
1. Only those parameters detected at a minimum of one sample location are presented in this table. All soil results are in ug/kg (ppb).
2. March 1997 Record of Decision (ROD) Concentrations-Based Objectives in ug/kg (ppb).
3. Values per 6NYCRR Part 375 Soil Cleanup Objectives (SCOs) in ug/kg (ppb).
4. Sample not logged in by ALS; once discovered, sample was outside holding time.
Acronyms:
J = Estimated Concentration
J = Estimated Concentration
(J-) = The result is an estimated quantity, but the result may be biased low. NA = Not Analyzed or SCO not available
U = Below Laboratory Reporting Limit
UJ = Below Laboratory Reporting Limit, quantitation limit is approximate
B = Detected in blank sample
R = Rejected by data validator
Color Code:
BOLD
Detection Exceeds Regulatory Level for Toxicity Characteristic
BOLD
Detection Exceeds Part 375 Industrial SCO
BOLD
Detection Exceeds Part 375 Commercial SCO
BOLD
Detection Limit Exceeds Record of Decision Objective
-------
TABLE 1-2
Summary of LVRR Soil Sample Analytical Results
Focused Alternatives Analysis Report Spill Zone Soils (Operable Unit OU 1)
Lehigh Valley Railroad Derailment Superfund Site, LeRoy, NY
Parameter 1
ROD2
NYSDEC Part 375 Soil Cleanup Objectives 3
C-1
C-2
C-3
C-4
C-5
C-6
Unrestricted
Protection of Public Health
Protection of
Total VOCs
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Matrix Diffusion
Total VOCs
Commercial
Industrial
Groundwater
8/23/2017
9/14/2016
8/23/2017
9/5/2017
8/23/2017
8/23/2017
SV5/2017
8/22/2017
9/5/2017
8/24/2017
Chloromethane
-
NA
NA
NA
NA
1200U
32.3J
S.9U
720U
76.9
74.6
62DJ
Vinyl Chloride
-
20
13000
27000
20
1100U
2700U
1200U
57.7U
6.9U
720U
62.8U
540U
69.1 U
4.7U
1,1-Dichloroethene
-
330
500000
1000000
330
1100U
2700U
1200U
28.SU
6.9U
720U
31.4U
540U
34.6U
4.7U
Carbon Disulfide
-
NA
NA
NA
NA
HOOU
2700U
1200U
28.SU
6.9U
720U
31.4U
34.6U
4.7U
Methylene Chloride
-
50
500000
1000000
50
HOOU
2700U
1200U
28.SU
6.9U
720U
31.4U
540U
34.SU
4.7U
trans-1,2-UCt
-
1000000
250
6.9U
31.4U
540U
34.SU
4./U
1,1-Dichloroethane
-
m
240000
4H0000
m
11UUU
2/UUU
12UUU
28.SU
6.9U
31.4U
540U
34.BU
4./U
Cis-1,2-DCE
3000
250
500000
1000000
250
•HOOU
2700U
1200U
25.SU
6.9U
720U
31,4U
540U
S4.SU
32J
Chloroform
-
370
350000
700000
370
HOOU
2700U
1200U
28.SU
6.9U
720U
31.4U
540U
34.SU
4.7U
1,1,1-Trichloroethane
-
680
500000
1000000
680
HOOU
2700U
1200U
28.SU
6.9U
720U
31.4U
540U
34.SU
4.7U
Benzene
-
60
44000
89000
60
HOOU
5400
140 J
12.1J
S.9U
720U
6.59J
540U
10.7J
4.7U
1,2-Dichloroethane
-
20
30000
60000
20
HOOU
2700U
1200U
28.SU
6.9U
720U
31.4U
540U
S4.SU
4.7U
Trichloroethene
7000
470
200000
400000
470
80000
1150
26
677
1950
400J
Toluene
-
700
500000
1000000
700
18000
860J
55.4
S.9U
25.4J
41.5
4.7U
1 etrachloroethene
-
1300
150000
300000
1300
6.9U
31.4U
540U
34.SU
4./U
hthylbenzene
-
1000
'J90000
/H0000
1000
11UUU
52UU
240J
2a.su
6.9U
31.4U
M0U
34.BU
4./U
m,p-Xylene
-
260
500000
1000000
1600
•HOOU
•H000
91OJ
72.4
6.9U
720U
37.7
540U
54.9
4.7U
o-Xylene
-
260
500000
1000000
1600
HOOU
11000
870J
43.9
S.9U
81J
21.4J
540U
S4.SU
4.7U
Isopropyl benzene
-
NA
NA
NA
NA
HOOU
4000
230J
57.7U
6.9U
720U
62.8U
540U
69.1 U
4.7U
Styrene
-
NA
NA
NA
NA
HOOU
2700U
1200U
28.9U
6.9U
720U
31.4U
540U
S4.SU
4.7U
1,3,5- Tri methy Ibenzen e
-
8400
190000
380000
8400
HOOU
2700U
1200U
57.7U
6.9U
720U
62.8U
540U
69.1 U
4.7U
1,2,4- Tri methy Ibenzen e
-
3600
190000
380000
3600
HOOU
2700U
550J
42.7
S.9U
720U
31.4U
540U
S4.SU
4.7U
Naphthalene
-
NA
NA
NA
NA
4S.b
29.2J
540U
34.SU
4./U
1,4-Uioxane
-
100
190000
250000
100
11UUU
12UUU
NA
45.9U
NA
540U
NA
4./U
M ethycycloh exan e
-
NA
NA
NA
NA
¦HOOU
12000
2S00J
NA
6.9U
560J
NA
540U
NA
4.7U
Cyclohexane
-
NA
NA
NA
NA
HOOU
4200
780J
NA
S.9U
720U
NA
540U
NA
4.7U
2-Butanone (MEK.)
-
120
500000
1000000
120
HOOU
2700U
1200U
NA
6.6J
720U
NA
540U
NA
29
Acetone
-
50
500000
1000000
50
HOOU
2700U
1200U
NA
150
720U
NA
540U
NA
R
MTBE
-
930
500000
1000000
930
HOOU
2700U
1200U
NA
1.4J
720U
NA
540U
NA
4.4J
n-Proplybenzene
-
3900
500000
1000000
3900
HOOU
2700U
260J
NA
S.9U
720U
NA
540U
NA
4.7U
Notes:
i Only those parameters detected at a minimum of one sample location are presented in this table. All soil results are in
ug/kg (ppb).
2. March 1997 Record of Decision (ROD) Concentrations-Based Objectives in ug/kg (ppb).
3. Values per 6NYCRR Part 375 Soil Cleanup Objectives (SCOs) in ug/kg (ppb).
4. Sample not logged in by ALS; once discovered, sample was outside holding time.
Acronyms:
J = Estimated Concentration
(J-) = The result is an estimated quantity, but the result may be biased low. NA = Not Analyzed or SCO not available
U = Below Laboratory Reporting Limit
UJ = Below Laboratory Reporting Limit, quantitation limit is approximate
B = Detected in blank sample
R = Rejected by data validator
Color Code:
BOLD
Detection Exceeds Regulatory Level for Toxicity Characteristic
BOLD
Detection Exceeds Part 375 Industrial SCO
BOLD
Detection Exceeds Part 375 Commercial SCO
BOLD
Detection Limit Exceeds Record of Decision Objective
-------
TABLE 1-3
Summary of LVRR Soil Sample Analytical Results
Focused Alternatives Analysis Report Spill Zone Soils (Operable Unit OU 1)
Lehigh Valley Railroad Derailment Superfund Site, LeRoy, NY
Parameter 1
ROD2
NYSDEC Part 375 Soil Cleanup Objectives3
D-2
D-3
D-5
D-5N
D-5E
D-5S
D-5W
Unrestricted
Protection of Public Health
Protection of
Groundwater
Total VOCs
Total VOCs
Metrix Diffusion
Total VOCs
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Total VOCs
TCLP (ug/L)
SPLP (ug/L)
Total VOCs
Total VOCs
Commercial
Industrial
Sm/2016
8/22/2017
9/5/2017
8/22/2017
9/14/2016
8/22/2017
9/5/2017
8/24/2017
8/24/2017
8/24/2017
8/24/2017
8/24/2017
8/24/2017
Chloromethane
NA
NA
NA
NA
44. tJ
b.4U
bb.bJ
31UUU
IbUUU
NA
4UUUU
Vinyl Chloride
20
13000
2/000
20
b4UU
91,3U
b.4U
b4UU
b9.8U
3100U
1bUUU
4UUUU
1,1-Uichloroethene
500000
1000000
b4UU
4b.bU
b2UU
b.4U
b4UU
34.yu
3100U
IbUUU
bU
4UUUU
Carbon Disulfide
NA
NA
NA
NA
4b.bU
b.4U
&i.yu
3100U
IbUUU
NA
NA
4UUUU
Methylene Chloride
50
500000
1000000
50
S50U
640U
45.6U
620U
6.4U
540U
S4.SU
3100U
1600U
NA
NA
4000U
1100U
trans-1,2-DCE
250
500000
1000000
250
960U
640U
45.6U
620U
6.4U
540U
S4.SU
3100U
1600U
NA
NA
4000U
1100 J
1,1-Uichloroethane
240000
480000
b4UU
4b.bU
b.4U
b4UU
5i4.SU
3100U
IbUUU
NA
NA
CIS-1,2-DCE
3000
250
500000
1000000
b4UU
4b.bU
29
ju.yu
3100U
11UUJ
NA
NA
4UUUU
8900
Chloroform
370
350000
370
b4UU
4b.bU
b4UU
34.yu
^^SuO^^
IbUUU
bU
4UUUU
1,1,1-1 richloroethane
500000
1000000
b4UU
4b.bU
b.4U
b4UU
34.yu
3100U
IbUUU
NA
NA
Benzene
44000
60
b4UU
9.33J
0.41 J
b4UU
34.yu
3100U
1/UJ
4UUUU
1,2-Uichloroethane
20
30000
60000
20
b4UU
4b.bU
b2(JU
b.4U
b4UU
34.yu
3100U
IbUUU
4UUUU
Tnchloroethene
4/0
400000
4/0
13000
1/bU
3b30
'J/0000J
Toluene
700
500000
1000000
700
28.3J
S20U
^64^^
540U
S4.SU
3100U
770J
NA
NA
4UUUU
Tetrachloroethene
1300
150000
300000
1300
960U
640U
45.6U
620U
6.4U
540U
S4.SU
3100U
1600U
100U
5U
4UUUU
HOOU
hthylbenzene
1000
390000
/80000
1000
9bUU
4ZJ
4b.bU
b"20U
b.4U
b4UU
li4.SU
3100U
14UJ
NA
NA
4UUUU
11UUU
m,p- Xylene
260
500000
1000000
1600
19UUU
48.8
tiHJU
13U
b4UU
20.9J
3100U
/30J
NA
NA
4UUUU
11UUU
o-Xylene
260
500000
1000000
120 J
31J
b.4U
b4UU
34.yu
3100U
380J
NA
NA
4UUUU
Isopropylbenzene
NA
NA
NA
NA
b4UU
91,3U
b.4U
b4UU
b9.8U
3100U
IbUUU
NA
NA
Styrene
NA
NA
NA
NA
b4UU
4b.bU
b.4U
b4UU
34.yu
3100U
IbUUU
NA
NA
1,3,5-1 rimethylbenzene
190000
380000
b4UU
91,3U
b.4U
b4UU
34.yu
3100U
IbUUU
NA
NA
1,2,4-1 rimethylbenzene
3600
190000
380000
120 J
4b.bU
b2UU
b.4U
b4UU
34.yu
31 UJ
NA
NA
4UUUU
Naphthalene
NA
NA
NA
NA
960U
640U
45.3
S20U
6.4U
540U
S4.9U
3100U
1600U
NA
NA
4000U
HOOU
1,4-Uioxane
100
130000
250000
100
b4UU
NA
tiHJU
1iJUU
b4UU
NA
JilUUU
IbUUU
NA
NA
4UUUU
nuuu
Methycyclohexane
NA
NA
NA
NA
b/U
NA
^10J
b.4U
b4UU
NA
3100U
yisoi
NA
NA
4UUUU
nuuu
Cyclohexane
NA
NA
NA
NA
960U
210J
NA
S20U
6.4U
540U
NA
3100U
1600U
NA
NA
4UUUU
HOOU
2-Butanone (MtK.)
120
500000
1000000
120
b4UU
NA
b.4U
b4UU
NA
IbUUU
4UUUU
Acetone
50
500000
1000000
50
b4UU
NA
b.4U
b4UU
NA
IbUUU
NA
NA
MIBt
930
500000
1000000
930
b4UU
NA
b.4U
b4UU
NA
IbUUU
NA
NA
n-Proplybenzene
500000
1000000
b4UU
NA
b.4U
b4UU
NA
IbUUU
NA
NA
1. Only those parameters detected at a minimum of one sample location are presented in this table. All soil results are in ug/kg (ppb).
2. March 1997 Record of Decision (ROD) Concentrations-Based Objectives in ug/kg (ppb).
3. Values per 6NYCRR Part 375 Soil Cleanup Objectives (SCOs) in ug/kg (ppb).
4. Sample not logged in by ALS; once discovered, sample was outside holding time.
Acronyms:
J = Estimated Concentration
(J-) = The result is an estimated quantity, but the result may be biased low. NA = Not Analyzed or SCO not available
U = Below Laboratory Reporting Limit
UJ = Below Laboratory Reporting Limit, quantitation limit is approximate
B = Detected in blank sample
R = Rejected by data validator
Color Code:
BOLD
Detection Exceeds Regulatory Level for Toxicity Characteristic
BOLD
Detection Exceeds Part 375 Industrial SCO
BOLD
Detection Exceeds Part 375 Commercial SCO
BOLD
Detection Limit Exceeds Record of Decision Objective
-------
TABLE 1-4
Summary of LVRR Soil Sample Analytical Results
Focused Alternatives Analysis Report Spill Zone Soils (Operable Unit OU 1)
Lehigh Valley Railroad Derailment Superfund Site, LeRoy, NY
Parameter1
ROD 2
NYSDEC Part 375 Soil Cleanup Objectives 3
E-2
E-3
E-A
E-5
E-5N
E-5E
Unrestricted
Protection of Public Health
Protection of
Groundwater
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Total VOCs
Total VOCs4
TCLP (ug/L)
TCLP (ug/L)
SPLP (ug/L)
SPLP (ug/L)
Matrix Diffusion
Total VOCs
Total VOCs
Commercial
Industrial
8/24/2017
8/22/2017
9/5/2017
9/14/2016
8/22/2017
9/5/2017
9/14/2016
11/11/2016
8/22/2017
11/11/2016
8/22/2017
11/11/2016
8/22/2017
9/5/2017
8/24/2017
8/24/2017
Chloromethane
NA
NA
NA
NA
5.3U
65.8J-
520U
80.6
4.5U
NA
NA
S0.6
15000U
Vinyl Chloride
20
13000
27000
20
3S0U
5.3U
54.SUJ
520U
SMU
63.7U
SOOU
4.5U
NA
20U
20U
5U
5U
38.1 U
3S00U
15000U
1,1-Dichloroethene
330
500000
1000000
330
350U
5.3U
27.4UJ
520U
SMU
3i.SU
SOOU
4.5U
NA
20U
20U
5U
5U
2SU
3S00U
15000U
Carbon Disulfide
NA
NA
NA
NA
350U
5.3U
27.4UJ
520U
31 .SU
soou
4.5U
NA
NA
NA
NA
NA
2SU
3S00U
15000U
Methylene Chloride
50
500000
1000000
50
350U
5.3U
27.4UJ
520U
3i.SU
SOOU
4.5U
NA
NA
NA
NA
NA
2SU
3S00U
15000U
trans-1,2-UCt
250
500000
1000000
250
5.3U
2/.4UJ
31,9U
4.bU
NA
NA
NA
NA
NA
39UUU
1SUUUU
1,1-Uchloroethane
m
240000
480000
m
mi
b.3U
2/.4UJ
tfUUU
3i.au
4.bU
NA
NA
NA
NA
NA
2SU
3SUUU
1BUUUU
CIS-1,2-DCE
250
500000
1000000
250
b.3U
2/.4UJ
21 .UJ
632J
NA
NA
NA
NA
NA
11.3J
3900U
16000U
Chloroform
370
350000
700000
370
350U
5.3U
27.4UJ
520U
SMU
3i.SU
SOOU
4.5U
NA
20U
20U
5U
5U
2SU
1,1,1-Trichloroethane
680
500000
1000000
680
350U
5.3U
27.4UJ
520U
SMU
3i.SU
SOOU
4.5U
NA
NA
NA
NA
NA
2SU
3S00U
15000U
Benzene
60
44000
89000
60
26J
0.43 J
8.33J-
520U
6MU
6.05J
SOOU
4.5U
NA
20U
20U
5U
5U
10.5J
3S00U
15000U
1,2-Dichloroethane
20
30000
60000
20
3S0U
5.3U
27.4UJ
520U
SMU
31.SU
SOOU
4.5U
NA
20U
20U
5U
5U
2SU
3S00U
1S000U
Trichloroethene
255
785
Toluene
766
5666(5(5
1666(5(5(5
766
S4J
1.2J
47.2J-
R
\'l\
W
4.5U
NA
NA
NA
NA
NA
ih.W
3S00U
15000U
I etrachloroethene
1300
150000
300000
1300
b.3U
2/.4UJ
31,9U
4.bU
NA
bU
bU
39UUU
lauuuu
hthylbenzene
1000
390000
/"80000
1000
mi
0.29J
2/.4UJ
b2UU
BUUU
3i.au
auuu
4.bU
NA
NA
NA
NA
NA
2SU
3SUUU
lauuuu
m,p-Xylene
260
500000
1000000
1600
mi
b.3U
/4.3J-
iuuuu
-------
TABLE 1-5
Summary of LVRR Soil Sample Analytical Results
Focused Alternatives Analysis Report Spill Zone Soils (Operable Unit OU 1)
Lehigh Valley Railroad Derailment Superfund Site, LeRoy, NY
Parameter 1
ROD 2
NYSDEC Part 375 Soil Cleanup Objectives 3
E-5-5
-------
TABLE 1-6
Summary of LVRR Soil Sample Analytical Results
Focused Alternatives Analysis Report Spill Zone Soils (Operable Unit OU 1)
Lehigh Valley Railroad Derailment Superfund Site, LeRoy, NY
Parameter 1
ROD2
NYSDEC Part 375 Soil Cleanup Objectives 3
F-6
F-6N
F-6E
F-6S
F-6W
G-4
G-7
Gulf Road
Unrestricted
Protection of Public Health
Protection of
Groundwater
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Total VOCs
Total VOCs
Total VOCs
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Total VOCs
Matrix Diffusion
Total VOCs
Commercial
Industrial
9/14/2016
8/23/2017
9/6/2017
8/23/2017
8/23/2017
8/23/2017
8/23/2017
9/14/2016
8/23/2017
9/5/2017
9/14/2016
8/23/2017
9/5/2017
8/24/2017
Chloromethane
NA
NA
NA
NA
1100011
47.8J
14000U
10000U
3500U
6.4U
4.8U
7S.7U
85.5U
Vinyl Chloride
20
13000
27000
20
11000U
33000U
78.SU
14000U
10000U
30000U
3500U
6.4U
4.8U
7S.7U
650U
3S00U
85.5U
580U
1,1-Dichloroethene
330
500000
1000000
330
11000U
33000U
39.5U
14000U
10000U
30000U
3500U
6.4U
4.8U
38.4U
650U
3500U
42.7U
580U
Carbon Disulfide
NA
NA
NA
NA
11000U
33000U
39.5U
14000U
10000U
30000U
3500U
6.4U
4.8U
38.4U
650U
3500U
42.7U
580U
Methylene Chloride
50
500000
1000000
50
11000U
33000U
39.5U
14000U
10000U
30000U
3500U
6.4U
4.8U
38.4U
650U
3S00U
42.7U
580U
trans-1,2-UCt
250
500000
1000000
33UUUU
39. bU
14UUUU
3UUUUU
3bUUU
b.4U
4.8U
3U.4U
3bUUU
42./U
1,1-Dichloroethane
m
240000
480000
'm
11UUUU
33UUUU
39.bU
14UUUU
10UUUU
3UUUUU
3bUUU
b.4U
4.8U
U8.4U
tibUU
3bUUU
42./U
b8UU
ClS-1,2-DCE
3000
500000
1000000
22000
9800J
1140
14000U
10000U
6900J
26UUJ
l.bJ
4.8U
U8.4U
bbUU
3bUUU
42./U
Chloroform
370
350000
700000
370
^moou
3S.5U
140001J
10000U
3500U
6.4U
4.8U
38.4U
S50U
3500U
42.7U
58QU
1,1,1-Trichloroethane
680
500000
1000000
680
11000U
33000U
39.5U
14000U
10000U
30000U
3500U
6.4U
4.8U
38.4U
650U
3S00U
42.7U
58CXJ
Benzene
60
44000
89000
60
11000U
33000U
39.5U
14000U
10000U
30000U
3500U
6.4U
4.8U
9.59J
90J
3500U
42.7U
580U
1,2-Dichloroethane
20
30000
60000
20
11000U
33000U
39.5U
14000U
10000U
30000U
3500U
6.4U
4.8U
38.4U
S50U
3500U
7.b9J
580U
Trichloroethene
400000
810000
16100
560000
450000J
530000
690J
Toluene
766
5666(5(5
1666(5(5(5
m
SS.5U
140001J
10000U
6.4U
4.8U
36J
12UU
26.1 J
I etrachloroethene
1300
150000
300000
1300
33UUUU
6b .9
14UUUU
3UUUUU
3bUUU
b.4U
4.au
3U.4U
3bUUU
42./U
hthylbenzene
1000
'J90000
/"80000
1000
•huuuu
33UUUU
39.bU
14UUUU
10UUUU
3UUUUU
3bUUU
b.4U
4.8U
U8.4U
200J
3bUUU
42./U
28J
m,p- Xylene
260
500000
1000000
1600
ZIUUUU
33UUUU
34.3J
14UUUU
10UUUU
3UUUUU
3bUUU
1UU
4.8U
44
1JJUUU
3bUUU
44
btiUU
o-Xylene
260
500000
1000000
1600
11000U
33000U
39.5J
14000U
10000U
30000U
3500U
b.4U
4.8U
29.9J
730
370J
29.9J
580U
Isopropylbenzene
NA
NA
NA
NA
11000U
33000U
78.SU
14000U
10000U
30000U
3500U
b.4U
4.8U
7S.7U
140J
3500U
85.5U
580U
Styrene
NA
NA
NA
NA
11000U
33000U
39.5U
14000U
10000U
30000U
3500U
b.4U
4.8U
38.4U
650U
3500U
42.7U
580U
1,3,5-T rimethylbenzene
8400
190000
380000
8400
11000U
33000U
78.SU
14QQQU
10000U
30000U
3500U
b.4U
4.8U
52.9J
S50U
3S00U
85.5U
580U
1,2,4-T rimethylbenzene
3600
190000
380000
3600
11000U
33000U
39.5U
14000U
10000U
30000U
3500U
b.4U
4.8U
S4.7
650U
560J
42.7U
150 J
Naphthalene
NA
NA
NA
NA
33UUUU
14b
14UUUU
3UUUUU
3bUUU
b.4U
4.8U
23.4J
bbUU
3bUUU
b/.l
1,4-Uoxane
100
130000
i>60000
100
•huuuu
33UUUU
NA
14UUUU
10UUUU
3UUUUU
3bUUU
b.4U
4.8U
NA
bbUU
W
NA
Methycyclohexane
NA
NA
NA
NA
•huuuu
33UUUU
NA
14IMJ
10UUUU
3UUUUU
3bUUU
2.1 J
1.3J
NA
2b00
32UUJ
NA
33UJ
Cyclohexane
NA
NA
NA
NA
nooou
33000U
NA
14000U
10000U
30000U
3500U
b.4U
4.8U
NA
870
1100 J
NA
580U
2-Butanone (MEK.)
120
500000
1000000
120
•nooou
33000U
NA
14000U
10000U
30000U
3500U
b.4U
7.8
NA
650U
3S00U
NA
580U
Acetone
50
500000
1000000
50
•nooou
33000U
NA
14000U
10000U
30000U
3500U
b.4U
460J
NA
S50U
3S00U
NA
580U
MTBE
930
500000
1000000
930
•nooou
33000U
NA
14000U
10000U
30000U
3500U
b.4U
1.6J
NA
S50U
3S00U
NA
580U
n-Proplybenzene
3900
500000
1000000
3900
•nooou
33000U
NA
14000U
10000U
30000U
3500U
b.4U
4.8U
NA
S50U
3S00U
NA
580U
Notes:
1. Only those parameters detected at a minimum of one sample location are presented in this table. All soil results are in ug/kg (ppb).
2. March 1997 Record of Decision (ROD) Concentrations-Based Objectives in ug/kg (ppb).
3. Values per 6NYCRR Part 375 Soil Cleanup Objectives (SCOs) in ug/kg (ppb).
4. Sample not logged in by ALS; once discovered, sample was outside holding time.
Acronyms:
J = Estimated Concentration
(J-) = The result is an estimated quantity, but the result may be biased low. NA = Not Analyzed or SCO not available
U = Below Laboratory Reporting Limit
UJ = Below Laboratory Reporting Limit, quantitation limit is approximate
B = Detected in blank sample
R = Rejected by data validator
Color Code:
BOLD
Detection Exceeds Regulatory Level for Toxicity Characteristic
BOLD
Detection Exceeds Part 375 Industrial SCO
BOLD
Detection Exceeds Part 375 Commercial SCO
BOLD
Detection Limit Exceeds Record of Decision Objective
-------
Table 2-1 Trichloroethylene (TCE) Concentrations in Groundwater
Lehigh Valley Railroad Derailment Superfund Site, Le Roy, NY
NYSDEC TCE Sampling Results (ppb)
Unicorn TCE Sami
>ling Results (ppb)
Well ID
Total
Boring
Depth
BGS
PVC
Screened
Interval BGS
Nov-93
Jan-94
Apr-94
Jul-94
Oct-94
Jan-95
Apr-95
08-Aug/
Sept
10-Dec
11-Jan
11-Mar
Il-Jun
11-Sep
11-Dec
12-Feb
12-Jun
DC-IA
60
Open
Borehole
16.000
1,100
58,000
2,000
9,600
6,300
2,400
12,000
12,000
12,000
6,300
6,900
6,000
3,300
12.000
DC-I B
80
60-80
380
370
76
280
440
140
99
500
570
750
97
120
280
240
180
DC-IC
120
100-120
38,000
520
95
88
120
82
60
100
230
24
180
150
250
290
230
DC-I D
160
135-155
9.400
1,300
780
560
480
260
240
13
8.60
6.80
7.10
8.10
7.20
8.00
9.50
DC-2A
41.5
Open Borehole
800
380
550
2,500
930
1,000
580
51
82
100
62
170
110
32
48
DC-2 B
73.2
49.8-69.8
120
210
3,100
890
730
1,300
1,600
4,800
4.100
2.300
1,700
1.200
2,400
3,400
DC- 2 C
106.5
85.4-105.4
22
10
190
ND
4
7
3
26
12.00
9.10
8.80
7.80
10.00
9.50
9.30
DC-2 D
150.9
130.5-150.5
590
140
1,800
940
14
60
6
0.31
0.31
0.27
0.42
1.00
0.37
0.32
DC-5 A
60.5
Open Borehole
7,300
1,600
20,000
1,300
15,000
36,000
47,000
2,300
3.600
-
1,800
2,400
3,700
2, 700
5,100
DC-5 B
80.5
60-80
770
360
120
270
2,200
250
440
170
310
710
72
90
110
110
74
DC-5 C
132
110.5-130.5
470
350
20
10
15
8
13
2
1.00
1.00
0.24
0.59
0.28
1.00
0.68
DC-5 D
167
144.5-164.5
580
81
18
25
11
17
19
2
0 39
0 44
0 48
0.49
0.35
0.51
DC-06 A
30
Open Borehole
240
980
510
380
220
330
150
74
690
510
500
160
100
140
DC-06 B
55
34.8-54.8
1,100
2,100
480
1,600
1,900
1.400
1,500
5 70
150
76
1,000
3
130
1.100
DC-06 C
92.1
69.8-89.8
ND
4
320
22
ND
11
25
5
3.50
3.30
3.00
2.90
560.00
3.20
2 90
DC-06 D
138
111.8-131.8
26
ND
4
ND
ND
ND
ND
1
1
1
1
1
1
1
1
DC-15 A
65
Open Borehole
13,000
8,900
41,000
6,700
9,800
6.700
3,000
12,000
4.600
3,100
930
11,000
3,300
2,500
3,900
DC-15 B
185
160-180
140
93
47
13
18
19
210
15
5.90
1.60
1.70
2.50
1.30
1.00
1.20
DC-16
169.8
Open Borehole
6,800
1,200
8,500
410
600
3.600
4, 500
6,500
670
3,300
1.600
2.800
1,500
2,100
750
DC-16C
Not Avail.
Not Avail.
3.200
35-1
164.8
48.5-53.5
2,400
4,500
1,300
1,800
1,200
1,600
2,300
35-2
164.8
58.5-63.5
4,500
3,700
2,600
3,500
4,200
3,100
3,300
35-3
164.8
68.5-73.5
Flute well installed by UMC
710
220
120
150
370
150
130
35-4
164.8
103.5-108.5
200
130
61
33
43
40
26
35-5
164.8
115.5-120.5
200
60
39
140
Notes: TCE concentrations are in micrograms per liter (jig/1).
Blank values indicate that sampling was not performed.
-------
Table 2-2
Packer Test Groundwater Sanple Analytical Resists ^ | Mi, fllli M.-iiiapviif.H?
i
if'fiii'Sijiiuiii.-.. 1.1 < I
B¥E Data Sunutery Report
Lehigh Valley Railroad Derailment Sqperfimd Site
Index Number CERCLA-02-2006-2006
Wail ID
Sample Depth
Acetone
Biemodichloro-
Carbon
Dfcronmchloro-
cis-l,2-DCE
Trans-1,2-
Methyl
Methylene
T oluene
TCE
Vinyl
Interval
methane
Disulfide
methane
BCE
cyclohexane
Chloride
Chloride
<58"
58'- «'
63' —68'
76' -8.1'
> 140'
125.5"
"1 n
<
n
="1 0
'! 0
'1 o
<1 0
<1 o
<1 0
<71
: \T i:- ,-i
<55'
59' -64'
•¦¦¦¦ i e
•-! C
! '<
tfrf'-7r
•• i:
- ; C
¦¦ I f.
• 0
c
75" -30*
R:v
89' $4'
[ 0
1.0
-1 e
3 7
>!i4*
1.0
0
<1 0
- i
- .
145*
<5.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1 2
<1.0
<1.0
143'
LVRR-28
<25
<5.0
<5.0
<5.0
<5,0
<5.0
<5.0
<5.0
<5.0
<8.6
16
<5.0
«r-M'
<25
<5 0
<5.0
<5.0
<5.0
<1.0
<1.0
<5.0
<5.0
<5.9
1?
<5.0
WT-92'
<5.0
<1.0
<1.0
<1.0
<1.0
0.24 j
<1.0
<1.0
<1.0
<2 1
<6.4
<1.0
W - 1C2*
<5.0
isr
<1.0
"
i.\
:<:
' 0
«¦1 C1
•! I
:"1 0
95= - !00'
>113'
P:\2032 Lehigh Valt» Railroad SopMundUOSZ R|PORTS\Ref ed a I Oests.AFie-RO Bd.t Data Sur*r*ary fipi !F»v 3l\Ta&te 5 factor Test Analytical Results
-------
£
Table 2-3
Packer Test Groundwater Sanple Analytical Easiilts «1.
SrrH)-;|]j|;|ll!,S, l.f «'
BVE Data Summary Report
Lehigh \ alley Railroad Derailment Super fund Site
Index Nuiitier CE RCL A-02-2006-2006
Well ID
SaitplaDqith
BroirodteMoro-
Caibon
Chloroform
D ij roniacMoro-
cis-l,2-DCE
Trans-1,2-
Methyl
Methylene
Toluei*;
TCE
Viiiyl
Inteival
methane
Disulfide
metliaxie
DCE
cyclohexane
Chloride
Chloride
LVRR-30
<$4*
2,4 J
2.4
1.0
1.0
1.0
<1.0
<1.0
'1.0
3.5
<14
<1 0
150*-115'
<5.0
<1.0
<1.0
<1.0
<1.0
1.0
<1.0
<1.0
<1.0
<1.0
42
<1.0
127*-132'
<5.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1 5
16
<1.0
137'- !42'
<50
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1 3
<2 9
<1.0
>WV
<5 0
<1 0
<1 0
<1 0
<1.0
<1 0
<1.0
<1 0
0 7! j
<2 4
<1 n
:• i'j< _<;
<55*
i.;; J
' -
-¦1 0
2 0
•
11
' ^ £
TO'-TS*
Dry
75*-*U*
'1 u
' i:
•1
<1 0
7 .<
75> - 80' DUP
: j
• 1 0
"i G
-• 1 '
• 1 c
i :
SO' »5*
v
104' -109'
.• * J
• 1 0
0.2.1 J
! u
•: 1.0
1.1
1:6
>125'
K.
R
R
K
K.
R
K
. ij
K.
iif. _-j
<&'
Dry
75'—80*
<5.0
<1.0
<1.0
0.50 J
<1.0
0.50 J
<1.0
<1.0
<1.0
1.1
93
<1.0
75* - SO' DOT
<5.0
<1.0
<1.0
0 52 J
<1.0
0.52 J
<1.0
<1.0
<1.0
i.o
90
<1.0
SO'-IS'
<5.0
1.0
<1.0
2.4
0.57 J
0 41 J
<1.0
<1.0
<1.0
2.8
69
<1.0
96*-101*
« 0
1 d
<1 0
2 6
0 J
n tic j
108'
j •:: j
• i :
¦; o
J.A
LVPJ?.]3
ctl'
¦ j
< . 0
•1 c
•• i c
<3.5i
12'-IT
rr-xr
Di"
ar-ar
. i.!
" 2
•: :
• G
-] 0
- o
•; ••
87'-3?.'
•" 0
;
¦ 1
• G
:! •:
c
d "
i;
100'-105'
:• i
•': 0
i ! C
• ' 0
105'— 110"
<} 0
¦ ] 0
-. 0
< I 0
4.9
>110*
<1 0
<1 0
<1 0
W 65*
1 1 J
¦¦¦¦-] 0
<1 0
<1 0
n
66'-71*
<30 U J
9ti *
<] 0
: G
<1 0
<5 0
<1 0
*¦55*
Dry
55' W
• ! j?
•MO'.1
69' - 74'
' 2'.'
•0
0
: ? :
•C
2 i
76' - 311
••
•• o
•: C
:? •;;
76' 81* iM»
¦¦2'
: C
i'LJ
C
j
: i
*5'-90'
¦ :(
•.. 0
• j
• i. C
o
¦.'.j
91'-96*
'O J
'2 -j
'2 ?
'i C
1 7
'•2 C
"2 0
'2 j
i ••
>106'
j
0
•2 "j
r;
"2 G
1 j
j 5o J
Notes;
1) All concentrations are m micrograms pa"liter (ug/1).
2) J Indicates estimated concentration
3) R Indicates validation rej ected results
4) UJ Indicates analyte was not detected above the reporting limit, but is an estimate.
5) ^5.0 Indicates not detected at or above the laboratory detection hrnit.
6) Sample depth intervals are m feet belowthe ground surface.
P:\2032 Lehigh V-aiisy R*ilic*d 3ut>?ituri>A2Q32 REPOST^Remedial U*<»n\Pre-RP Mfi few ju rarwrv fipt I Rev 3|\TjtHe S Pacter Test *rva*ytcal Results
-------
Table 3
Summary of Contaminants of Concern and
Medium-Specific Exposure Point Concentrations
Scenario Timeframe: Future
Medium: Groundwater
Exposure Medium: Groundwater
Exposure
Point
Contaminant of
Concern
(COC)
Concentration
Detected
Concentration
Units
Frequency of
Detection
Exposure Point
Concentration
(EPC)
Exposure Point
Concentration
Units
Statistical
Measure
Min
Max
Shallow Groundwater-
(excavation/trench)
T richloroethylene
0.031 J
12,000 J
Hg/L
14/15
6,219
Hg/L
95% Adjusted Gamma UCL
Tap Water
T richloroethylene
0.26 J
12,000 J
Hg/L
120/214
852.4
Hg/L
97.5% KM (Chebyshev) UCL
Scenario Timeframe: Future
Medium: Soil
Exposure Medium: Soil
Exposure
Point
Contaminant of
Concern
(COC)
Concentration
Detected
Concentration
Units
Frequency of
Detection
Exposure Point
Concentration
(EPC)
Exposure Point
Concentration
Units
Statistical
Measure
Min
Max
Spill Zone Surface Soil1
T richloroethylene
0.012
810
mg/kg
7/7
460.2
mg/kg
95% Student's t-UCL
Spill Zone Surface and
Subsurface Soil2
T richloroethylene
0.012
810
mg/kg
40/40
384.3
mg/kg
97.5% Chebyshev (Mean, Sd) UCL
Scenario Timeframe: Current/Future
Medium: Surface Water
Exposure Medium: Surface Water
Exposure
Point
Contaminant of
Concern
(COC)
Concentration
Detected
Concentration
Units
Frequency of
Detection
Exposure Point
Concentration
(EPC)
Exposure Point
Concentration
Units
Statistical
Measure
Min
Max
SWEU1: Mud Creek
T richloroethylene
4.8
390
Hg/L
5/9
390
Max
Limited Data Set (<10 samples)
Definitions
EPC= exposure point concentration
J = qualifier; the analyte was positively identified; the associated numerical value is the approximate concentration of the analyte in the sample
Max= max concentration used as EPC because there were less than 10 samples in the data set
SW EU1 = Surface water exposure unit 1; encompasses samples collected from Mud Creek
Footnotes:
(1) Surface soil depth encompasses soils 0.5 ft to 2.5 ft below ground surface
(2) Surface and subsurface soil depth encompasses soil 0.5 ft to 10.5 ft below ground surface
-------
Table 4
Selection of Exposure Pathways in the 2016 HHRA
Scenario
Timeframe
Medium
Exposure
Medium
Exposure
Point
Receptor
Population
Receptor
Age
Exposure
Route
Type of
An alysis
Rationale for Selection or
Exclusion of Exposure Pathway
Current
Groundwater
Groundwater
Groundwater
Resident
Adult
Ingestion
None
(Tap Water)
Dermal
None
Inhalation
None
Residents in the area are connected to the municipal water supply, hence current exposure to site
Child
Ingestion
None
groundwater does not exist.
(0-6 years old)
Dermal
None
Inhalation
None
Comm ercial/Industrial
Adult
Ingestion
None
Commercial/Industrial workers in the area are connected to the municipal water supply, hence current
Worker
Dermal
None
exposure to site groundwater does not exist.
Current/Future
Groundwater
Indoor Air
Indoor Air
Resident
Adult/Child
Comm ercial/Industrial
Worker
Adult
Inhalation
Qual
Indoor air vapor intrusion is a potentially completed pathway.
Groundwater
Shallow Groundwater
Construction/Utility
Worker
Adult
Ingestion
Qual
Incidental ingestion of shallow groundwater while working at the site is expected to be minimal for the
Construction/Utility worker.
Dermal
Quant
Construction/Utility workers may come in contact with shallow groundwater while working at the site.
Surface water
Surface water
SW EU 1: Mud Creek(1)
Recreational User
Adult
Ingestion
Quant
Dermal
Quant
Adolescent
Ingestion
Quant
(12-18 years old)
Dermal
Quant
Child
Ingestion
Quant
(0-6 years old)
Dermal
Quant
Recreational users may come into contact with surface water while visiting Mud Creek, Oatka Creek
Surface water
SW EU2: Oatka Creek and
Recreational User
Adult
Ingestion
Quant
and Spring Creek.
Spring Creek'2'
Dermal
Quant
Adolescent
Ingestion
Quant
(12-18 years old)
Dermal
Quant
Child
Ingestion
Quant
(0-6 years old)
Dermal
Quant
Sediments
Sediments
SED EU 1: Mud Creek(3)
Recreational User
Adult
Ingestion
Quant
Dermal
Quant
Adolescent
Ingestion
Quant
(12-18 years old)
Dermal
Quant
Child
Ingestion
Quant
(0-6 years old)
Dermal
Quant
Recreational users may come into contact with sediments while visiting Mud Creek, Oatka Creek and
Sediments
SED EU2: Oatka Creek
Recreational User
Adult
Ingestion
Quant
Spring Creek.
and Spring Creek'4'
Dermal
Quant
Adolescent
Ingestion
Quant
(12-18 years old)
Dermal
Quant
Child
Ingestion
Quant
(0-6 years old)
Dermal
Quant
Future
Groundwater
Groundwater
Groundwater
Resident
Adult
Ingestion
Quant
(Tap Water)
Dermal
Quant
Inhalation
Quant
Groundwater at the site is designated as a potable water supply. Future residents may be exposed to
Child
Ingestion
Quant
site groundwater through potable uses.
(0-6 years old)
Dermal
Quant
Inhalation
Quant
Comm ercial/Industrial
Adult
Ingestion
Quant
Groundwater at the site is designated as a potable water supply. Future commercial/industrial workers
Worker
Dermal
Quant
may be exposed to site groundwater through potable uses.
-------
Selection of Exposure Pathways in the 2021 Supplemental Soil Risk Evaluation
Scenario
Timeframe
Medium
Exposure
Medium
Exposure
Point
Receptor
Pooulation
Receptor
Age
Exposure
Route
Type of
An alvsis
Rationale for Selection or
Exclusion of Exposure Pathway
Future*
Soil
Surface Soil
Spill Zone Surface Soil
Comm ercial/Industrial
Worker
Adult
Ingestion
Quant
Commercial/Industrial workers may contact surficial soil in the Spill Zone via incidental ingestion and
inhalation of volatiles released from soil. The dermal pathway was not quantitatively evaluated as
exposure to volatile contaminants, such as TCE, through the dermal pathway is expected to be de
minimus.
Permal
None
Inhalation
Quant
Surface aid
Subsurface
Soil
Spill Zone Surface and
Subsurface Soil
Construction /Utility
Worker
Adult
Ingestion
Quant
Construction/Utility workers may contact surface and subsurface soil in the Spill Zone via incidental
ingstion and inhalation of volatiles released from soil. The dermal pathway was not quantitatively
considered as exposure to volatile contaminants, such as TCE, through the dermal pathway is expected
to be de minimus.
Permal
None
Inhalation
Quant
Definitions:
Quant- quantitative
Qual- qualitative
Footnotes:
* Scenario Timeframe for each receptor has been determined to be "future" as the SVE system interrupts direct contact exposures in the current timeframe. (2021 Supplemental Risk Evaluation incorrectly indicated current and future scenario timeframes)
(1) SW EU1 - surface water exposure unit (EU) 1. This EU encompasses samples collected from Mud Creek.
(2) SW EU2- surface water exposure unit 2. This EU encompasses samples collected from Oatka Creek & Spring Creek.
(3) SEP EU1 - sediment exposure unit 1. This EU encompasses samples collected from Mud Creek.
(4) SEP EU2- sediment exposure unit 2. This EU encompasses samples collected from Oatka Creek & Spring Creek.
-------
Table 5
Non-Cancer Toxicity Data Summary
Pathway: Ingestion/Dermal
Contaminant
of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Absorp.
Efficiency
(Dermal)
Adjusted
RfD
(Dermal)
Adj. Dermal
RfD Units
Primary
Target
Organ
Combined
Uncertainty
/Modifying
Factors
Sources
of RfD Target
Organ
Dates of
RfD
T richloroethylene
Chronic
5.00E-04
mg/kg-day
1
5.00E-04
mg/kg-day
Endocrine (Thymus), Circulatory (Heart),
Developmental Immunotoxicity
10-1,000
IRIS
9/28/2011
Pathway: Inhalation
Contaminant
of Concern
Chronic/
Subchronic
Inhalation
RfC
Inhalation
RfC Units
Inhalation
RfD
(If
available)
Inhalation
RfD Units
(If available)
Primary
Target Organ
Combined
Uncertainty
/Modifying
Factors
Sources
of RfD Target
Organ
Dates of RfC
T richloroethylene
Chronic
2.00E-03
mg/m3
NA
NA
Endocrine (Thymus), Circulatory (Heart)
10, 100
IRIS
9/28/2011
Definitions:
IRIS- Integrated Risk Information System
NA- Not available
Footnotes:
(1) SW EU1- surface water exposure unit 1. This EU encompasses samples collected from Mud Creek.
(2) SW EU2- surface water exposure unit 2. This EU encompasses samples collected from Oatka Creek & Spring Creek.
(3) SED EU1- sediment exposure unit 1. This EU encompasses samples collected from Mud Creek.
(4) SED EU2- sediment exposure unit 2. This EU encompasses samples collected from Oatka Creek & Spring Creek.
-------
Table 6
Cancer Toxicity Data Summary
Pathway: Ingestion/ Dermal
Contaminant of Concern
Oral Cancer
Slope Factor
Units
Adjusted
Cancer Slope
Factor
(for Dermal)
Slope Factor
Units
Weight of
Evidence/
Cancer
Guideline
Source
Date
Trichloroethylene (Kidney)
9.3E-03
(mg/kg-day)"1
9.3E-03
(mg/kg-day)"1
CA
IRIS
9/28/2011
Trichloroethylene (NHL)
2.2E-02
(mg/kg-day)"1
2.2E-02
(mg/kg-day)"1
CA
IRIS
9/28/2011
Trichloroethylene (Liver)
1.6E-02
(mg/kg-day)"1
1.6E-02
(mg/kg-day)"1
CA
IRIS
9/28/2011
Trichloroethylene (Total)
4.60E-02
(mg/kg-day)"1
4.6E-02
(mg/kg-day)"1
CA
IRIS
9/28/2011
Pathway: Inhalation
Contaminant of Concern
Unit Risk
Units
Inhalation
Cancer Slope
Factor
Slope Factor
Units
Weight of
Evidence/
Cancer
Guideline
Source
Date
Trichloroethylene (Kidney)
1.00E-06
|ig/m3
NA
NA
CA
IRIS
9/28/2011
Trichloroethylene (NHL)
2.10E-06
|ig/m3
NA
NA
CA
IRIS
9/28/2011
Trichloroethylene (Liver)
1.00E-06
|ig/m3
NA
NA
CA
IRIS
9/28/2011
Trichloroethylene (total)
4.10E-06
|ig/m3
NA
NA
CA
IRIS
9/28/2011
Definitions:
IRIS- Integrated Risk Information System
NA- Not available
CA- Carcinogenic to humans (Post-2005 cancer classification guideline)
NHL- non-Hodgkin lymphoma
-------
Table 7
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Contaminant of
Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient*
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater
Tap Water
Trichloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity
51
-
8.8
60
Air
Water Vapor from
Bathing/Showering
T richloroethylene
Endocrine (Thymus), Circulatory (Heart)
-
6.9E+03
-
6.9E+03
Groundwater Hazard Index Total=
7.0E+03
Receptor Hazard Index Total1=
7.0E+03
Endocrine (Thymus) Hazard Index=
7.0E+03
Circulatory (Heart) Hazard Index=
7.0E+03
Developmental Immunotoxicity Hazard Index=
60
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child
Medium
Exposure
Medium
Exposure Point
Contaminant of
Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient*
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater
Tap Water
Trichloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity
85
-
12
97
Air
Water Vapor from
Bathing/Showering
T richloroethylene
Endocrine (Thymus), Circulatory (Heart)
-
1.2E+04
-
1.2E+04
Groundwater Hazard Index Total=
1.2E+04
Receptor Hazard Index Total1=
1.2E+04
Endocrine (Thymus) Hazard Index=
1.2E+04
Circulatory (Heart) Hazard Index=
1.2E+04
Developmental Immunotoxicity Hazard Index=
97
Scenario Timeframe: Future
Receptor Population: Commercial/Industrial Worker
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Contaminant of
Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient*
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater
Tap Water
T richloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity
18
-
0.89
19
-------
Groundwater Hazard Index Total=
19
Soil
Surface Soil
Spill Zone Surface Soil
T richloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity4
0.79
24
-
25
Soil Hazard Index Total2=
25
Receptor Hazard Index Total3=
43
Endocrine (Thymus) Hazard Index=
43
Circulatory (Heart) Hazard Index=
43
Developmental Immunotoxicity Hazard Index=
20
Scenario Timeframe: Future
Receptor Population: Construction/Utility Worker
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Contaminant of
Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient*
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater
Shallow Groundwater
(excavation/trench)
T richloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity
0.51
-
2.6
3.1
Air
Shallow Groundwater
(trench air)
T richloroethylene
Endocrine (Thymus), Circulatory (Heart)
-
0.026
-
0.026
Groundwater Hazard Index Total=
3.1
Soil
Surface and
Subsurface Soil
Spill Zone Surface and
Subsurface Soil
T richloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity4
2.3
89
-
91
Soil Hazard Index Total2=
91
Receptor Hazard Index Total3=
94
Endocrine (Thymus) Hazard Index=
94
Circulatory (Heart) Hazard Index=
94
Developmental Immunotoxicity Hazard Index=
5
Scenario Timeframe: Current/Future
Receptor Population: Recreator
Receptor Age: Child
Medium
Exposure
Medium
Exposure Point
Contaminant of
Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient*
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Surface Water
Surface Water
SW EU1: Mud Creek
T richloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity
1.9
-
3.9
5.8
Surface Water Hazard Index Total5=
14
Receptor Hazard Index Total6=
18
Endocrine (Thymus) Hazard Index=
5.9
Circulatory (Heart) Hazard Index=
5.8
Developmental Immunotoxicity Hazard Index=
5.8
-------
Scenario Timeframe: Current/Future
Receptor Population: Recreator
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Contaminant of
Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient*
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Surface Water
Surface Water
SW EU1: Mud Creek
T richloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity
0.35
-
2.4
2.8
Surface Water Hazard Index Total5=
6.2
Receptor Hazard Index Total6=
6.6
Endocrine (Thymus) Hazard Index=
2.8
Circulatory (Heart) Hazard Index=
2.8
Developmental Immunotoxicity Hazard Index=
2.8
Scenario Timeframe: Current/Future
Receptor Population: Recreator
Receptor Age: Adolescent
Medium
Exposure
Medium
Exposure Point
Contaminant of
Concern
Primary Target Organ
Non-Carcinogenic Hazard Quotient*
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Surface Water
Surface Water
SW EU1: Mud Creek
T richloroethylene
Endocrine (Thymus), Circulatory (Heart);
Developmental Immunotoxicity
0.64
-
2.8
3.4
Surface Water Hazard Index Total5=
8.0
Receptor Hazard Index Total6=
9.1
Endocrine (Thymus) Hazard Index=
3.5
Circulatory (Heart) Hazard Index=
3.4
Developmental Immunotoxicity Hazard Index=
3.4
Definitions
" = not applicable
COC= contaminant of concern
COPC= contaminant of potential concern
HQ= hazard quotient
SW EU1= Surface water exposure unit 1; encompasses samples collected from Mud Creek
SW EU2= surface water exposure unit 2. This EU encompasses samples collected from Oatka Creek & Spring Creek
Footnotes
*A11 non-cancer risk estimates reported to 2 significant figures
(1) Receptor Hazard Index Total for Residents represents the summed hazard quotients (HQs) for all Contaminants of Potential Concern (COPCs) in groundwater
(2) Soil Hazard Index Total represents summed HQs from exposure to TCE in soil only, not from exposure to all potential COPCs in soil
(3) Receptor Hazard Index Total represents the summed HQs for all COPCs in groundwater plus the HQs from TCE exposure in soil
(4) Developmental immunotoxicity endpoint is for TCE's RfD only (i.e., applicable to ingestion and dermal exposures)
(5) Surface Water Index Total for Recreators represents the summed HQs for all COPCs in surface water of Mud Creek (SW EU1) and Oatka Creek and Spring Creeks (SW EU2)
(6) Receptor Hazard Index Total for Recreators represents the summed HQs for all COPCs in surface water and sediments at the site
-------
Table 8
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child/Adult
Medium
Exposure
Medium
Exposure Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Groundwater
Tap Water
Trichloroethylene (Kidney)
3.2E-04
--
5.2E-05
3.7E-04
Trichloroethylene (NHL)
2.4E-04
--
3.9E-05
2.8E-04
Trichloroethylene (Liver)
1.7E-04
--
2.8E-05
2.0E-04
Air
Water Vapor from
Bathing/Showering
Trichloroethylene (Kidney)
--
1.7E-02
--
1.7E-02
Trichloroethylene (NHL)
--
1.3E-02
--
1.3E-02
Trichloroethylene (Liver)
--
6.1E-03
--
6.1E-03
Groundwater Cancer Risk Total1=
3.7E-02
Receptor Total Cancer Risk=
3.7E-02
Scenario Timeframe: Future
Receptor Population: Commercial/Industrial Worker
Receptor Age: Adult
Medium
Exposure
Medium
Exposure Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Groundwater
Tap Water
Trichloroethylene
1.5E-04
--
7.4E-06
1.6E-04
Groundwater Cancer Risk Total1=
1.6E-04
Receptor Total Cancer Risk 2=
2.3E-04
Footnotes:
(1) Groundwater Cancer Risk Total represents summed cancer risk from all Contaminants of Potential Concern (COPC) in groundwater
(2) Receptor Total Cancer Risk for Commercial/Industrial Workers represents the summed risk from exposure to all COPCs in groundwater (1.6E-4) and
risk from exposure to TCE in soil (7.6E-5)
-------
Table 9: Remediation Goals (RGs)
Lehigh Valley Railroad Derailment Superfund Site, Le Roy, NY
ENVIRONMENTAL
MEDIA
CONTAMINANT OF
CONCERN
RG
UNITS
Groundwater1
Trichloroethene (TCE)
5
MQ/L
cis-1,2-dichloroethene
5
MQ/L
trans-1,2-dichloroethene
5
MQ/L
1,1- dichloroethene
5
MQ/L
Vinyl Chloride
2
MQ/L
Surface Water2
Trichloroethene (TCE)
40
MQ/L
Soil3
Trichloroethene (TCE)
200
mg/kg
Footnotes:
1 "Lower of the NYSDEC Class GA Groundwater Quality Standards and NY state and federal Maximum Contaminant
Levels were selected as RGs. These RGs are the ARARs being waived in the Tl Zone.
2 NYSDEC - Part 703: Surface Water Quality Standards for Class C waters (based on designation of Mud Creek).
36 NYCRR Part 375, Table 375-6.8(b) Commercial use Soil Cleanup Objective. The protection of groundwater SCO
was evaluated as part of the Feasibility Study but was not applied because groundwater restoration is not practicable.
-------
TABLE 10 a
CHEMICAL-SPECIFIC ARARs, TBCs, and Other Guidance
FEASIBILITY STUDY
LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
LEROY, NEW YORK
Standard, Requirement, Criteria or
Limitation
Citation or Reference
Description/Comments
Air:
New York State Air Quality Classifications and
Standards
6 NYCRR Parts 256 and 257
Establishes air quality standards protective of public health. Applicable to
point source emissions from treatment technologies. Potentially applicable to
disruptive activities.
National Primary and Secondary Ambient Air
Quality Standards (NAAQS)
40 CFR Part 50
Establishes primary and secondary ambient air quality standards to protect
public health and welfare. Applicable to point source emissions from
treatment technologies. Potentially applicable to disruptive activities.
Soil:
Environmental Remediation Programs
6 NYCRR Part 375-6
Remedial Program SCOs
Applies to the development and implementation of the remedial programs for
soil and other media. Includes the SCO tables at 375-6.8.
Soil Cleanup Guidance
DEC Commissioner Policy
CP-51 Soil Cleanup
Guidance, October 2010
Guidance for NYSDEC and remedial parties to provide a uniform and
consistent process in determining soil cleanup levels for SSF, BCP, VCP,
ERP, Spill Response Program (SRP), and RCRA Corrective Action Program
Sites.
USEPA Superfund Soil Screening Guidance
(SSG)
Technical Background
Document and Users Guide,
1996 revisions
Presents a framework for developing risk-based, soil screening levels (SSL)
for protection of human health. Provides a flexible, tiered approach to site
evaluation and screening level development.
USEPA Supplemental Guidance for
Developing Soil Screening Levels for
Superfund Sites
2002 Companion Guide to
the 1996 SSG
Builds upon the soil screening framework in the original 1996 guidance
focusing specific elements of soil screening evaluation that differ for
residential, non-residential, and construction scenarios.
USEPA Preliminary Remediation Goals
(PRGs)
USEPA Region 9, PRG
Table, October 2004
Presents contaminant toxicity values, PRGs, and SSL for residential and non-
residential scenarios based on human health criteria and groundwater
protection.
USEPA Risk Assessment Guidance for
Superfund (RAGS) Part C
Publication 9285.7-01 C,
October 1991
Provides guidance on the human health risk evaluations of remedial
alternatives that are conducted during the feasibility study, during selection
and documentation of a remedy, and during and after remedy
implementation.
USEPA Regional Screening Levels (RSLs)
Composite Worker Soil Table
November 2022
Establishes RSLs for the composite worker.
Surface Water:
Federal Water Pollution Control Act (CWA)
CWA §304
40 CFR Part 131
Establishes criteria for setting water quality standards for surface water
bodies based on the latest scientific data on impacts that a constituent
concentration has on a particular aquatic species and/or human health;
criteria used as guidance by states in setting water quality standards.
-------
National Recommended Water Quality Criteria
63 Federal Register 68354
Established national recommended water quality criteria for a range of
contaminants including PCBs in freshwater.
NYSDEC Water Quality Standards and
Classifications
6 NYCRR Parts 700-701.14,
701.19-702.17, 702.22-703.5,
703.7-706
Establishes surface water quality standards and effluent limitations.
New York State Division of Water TOGS
Ambient Water Quality Standards and
Guidance Values
TOGS 1.1.1
Provides screening criteria for groundwater and surface water.
New York State Surface Water and
Groundwater Quality Standards and
Groundwater Effluent Limitations
6 NYCRR Part 703
Establishes numerical standards for groundwater and surface water
cleanups.
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TABLE 10 b
LOCATION-SPECIFIC ARARs, TBCs, AND OTHER GUIDANCE
FEASIBILITY STUDY
LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
LEROY, NEW YORK
Standard, Requirement, Criteria or
Limitation
Citation or Reference
Description/Comments
General Requirements for Site Remediation:
USEPA Corrective Action Management
Units (CAMUs)
40 CFR 264.552
Outlines the conditions under which USEPA can designate an area as a
CAMU to be used for managing CAMU-eligible wastes for implementing
corrective action or facility cleanup. Outlines minimum treatment
The National Historic Preservation Act
(NHPA)
16 U.S.C. §470
A review of the Site's descriptive data suggests the potential for the
discovery of both historic and prehistoric resources within the project area.
A Stage IA Cultural Resource Survey (CRS) has been carried out for the
project area where the waterline was constructed. An additional Stage IA
CRS will be conducted within the Spill Zone. These areas will be subject
to a subsequent Stage IB CRS field survey where construction-related
impacts are scheduled to occur.
The Endangered Species Act
16 U.S.C. § 1531
The U.S. Fish and Wildlife Service will be consulted to determine whether
endangered or threatened species and/or their habitats exist on or in the
vicinity of the Site during the remedial design phase of the project.
The Fish and Wildlife Coordination Act
(FWCA)
16 U.S.C. §661
In accordance with the FWCA, state and federal wildlife agencies will be
consulted when wetlands and water resources may be or are being
impacted.
New York State Endangered and
Threatened Species of Fish and Wildlife;
Species of Concern; Incidental Take
Permits Regulations
6 NYCRR Part 182
Establishes lists of endangered, threatened, and special concern species;
recovery and restoration plans, experimental population designation;
permit requirements; special rules; penalties, and enforcement.
Floodplains and Wetlands:
Floodplain Management, Executive Order
No. 11988
Portions of the project area adjacent to Mud Creek and Spring Creek are
located within the 100-year and 500-year floodplain. As remedial activities
are proposed for the 100-year or 500-year floodplain, a floodplain
assessment will be performed during remedial design to minimize or avoid
the adverse effects of a 500-year event, and to protect against the spread
of contaminants and the long-term disabling of remedial treatment
systems. This assessment will include a delineation of the floodplain on a
Site map in relation to areas of contamination and remedial activities, a
discussion of the effects of the proposed remedial action on the floodplain,
and measures to minimize potentially adverse floodplain impacts.
The Federal Water Pollution Control Act
33 U.S.C. § 1344
A Wetlands Delineation Work Plan will be developed and any requisite
mitigative measures resulting from the delineation work will be addressed
during remedial design and construction.
Protection of Wetlands, Executive Order
No. 11990
40 CFR Part 6, Appendix A
-------
USEPA Statement of Procedures on
Floodplain Management and Wetlands
Protection
40 CFR Part 6, Appendix A,
Sections 3 and 4
Establishes requirements associated with actions that have impacts on
wetlands or floodplains.
New York State Freshwater Wetlands
Regulations
6 NYCRR Parts 662-665
Establishes permit requirement regulations, wetland maps and
classifications. On-site CERCLA response actions are exempt from permit
requirements pursuant to CERCLA Section 121(e), although such
activities must comply with substantive requirements of these regulations.
New York State Floodplain Development
Permits
6 NYCRR Part 500
Describes permitting requirements for development in floodplains. On-site
CERCLA response actions are exempt from permit requirements pursuant
to CERCLA Section 121 (e), although such activities must comply with
substantive requirements of these regulations.
Clean Water Act Section 404
40 CFR Part 230 and 33
CFR Parts 320-330
Prohibits discharge into wetlands.
Waterways:
New York State - Use and Protection of
Waters
6 NYCRR Part 608
Establishes requirements with excavation or placement of fill in navigable
waters.
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TABLE 10 c
ACTION-SPECIFIC ARARs, TBCs, and Other Guidance
FEASIBILITY STUDY
LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
LEROY, NEW YORK
Standard, Requirement, Criteria or
Limitation
Citation or Reference
Description/Comments I
Air:
NYSDEC Guidance for Fugitive Dust and
Particulate Monitoring
NYSDEC Program
Policy DER-10,
ADDendix 1B
Establishes guidance for community air monitoring and controls to monitor and
mitigate fugitive dusts during intrusive activities at NYS SSF, ERP, BCP, and
VCP Sites. Potentially applicable for disruptive activities.
National Ambient Air Quality Standards
for Hazardous Air Pollutants
40 CRF Part 61
Excavation and Fugitive Dust Emissions
40 CFR Part 254.25
Ambient Air Quality Standards
6 New York Code of
Rules and Regulations
(NYCRR) Part 200.6
NYSDEC Control of Toxic Ambient Air
Contaminants, Air Guide I
NYSDOH Guidelines forTCE in Air
ATSDR Environmental Media Evaluation
Guides for Indoor Air-Screening Levels
Solid and Hazardous Waste:
NYSDEC Solid Waste Management
Facilities
6 NYCRR Part 360
Describes procedures for transferring, processing, recovering, storing,
reclaiming, or disposing non-hazardous solid waste.
NYSDEC Solid Waste Transporters
6 NYCRR Part 364
Establishes procedures to protect the environment from mishandling and
mismanagement of all regulated waste transported from a site of generation to
the site of ultimate treatment, storage, or disposal. Potentially applicable for
alternatives involving off-site disposal.
NYSDEC Hazardous Waste Manifest
System and Related Standards for
Generators
6 NYCRR Part 372
Establish standards for generators and transporters of hazardous waste and
standards for generators, transporters, and treatment, storage or disposal
facilities relating to the use of the manifest system and its recordkeeping
requirements.
NYSDEC and USEPA Land Disposal
Restrictions
6 NYCRR Part 376
40 CFR 268.40
Identifies hazardous wastes that are restricted from land disposal and defines
those limited circumstances under which an otherwise prohibited waste may be
land disposed. Describes chemical-specific treatment requirements for land
disposal of hazardous waste. Potentially relevant to off-site waste disposal
alternatives.
USEPA Corrective Action Management
Units (CAMUs)
40 CFR 264.552
Outlines the conditions under which USEPA can designate an area as a CAMU
to be used for managing CAMU-eligible wastes for implementing corrective
action or facility cleanup. Outlines min. design requirements.
DOT Hazardous Materials Regulations
49 CFR Parts 107 and
171
Establishes requirements for shipping of hazardous materials. Potentially
applicable for alternatives involving off-site disposal.
-------
Table 11a: Total Cost for the Selected Remedy
Media
Description
Capital Cost
O&M Cost
Institutional
Controls Costs
Present-Worth
Cost
Groundwater
TI waiver (includes
monitoring)
$0
$2,253,200
$524,000
$2,778,000
Soil Vapor
Intrusion
Indoor air
$0
$659,704
$0
$659,704
Bedrock
Vadose Zone
Alternative BYZ - 2:
ICs and Groundwater
Monitoring
$0
$0
$137,250
$137,250
Soil
Alternative 3 -
excavation and off-Site
disposal
$3,017,897
$62,000
$121,750
$3,202,000
Surface Water
Alternative SW-5: In-
situ treatment of
contaminated surface
water with streambed
cover, ICs and
monitoring
$4,121,550
$3,102,250
$81,750
$7,305,550
Total
$14,082,504
Note: The soil alternative includes one foot of clean soil cover
in areas of the Spill Zone where surface soil exceeds 2 mg/kg,
which is the SCO value for the protection of ecological
receptors.
24
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&
L nic-orn Management
Consul tanIs. LLC
Table 11b
FS TABLE 4.1-1
INSTITUTIONAL CONTROLS AND MONITORING FOR PORTION OF GROUNDWATER PLUME
PROPOSED FOR A TECHNICAL IMPRACTICABILITY WAIVER
FEASIBILITY STUDY REPORT
LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
INDEX NUMBER: CERCLA-02-2006-2006
LEROY, NEW YORK
Item
Unit
Total
Quantity
Units
Cost
Cost
Groundwater Sampling'1'
Groundwater Samolina OM&M - Year 1
Field Labor
2
events
$ 36,000
$ 72,000
Equipment Rentals and Consumables
2
events
$ 14,600
$ 29,200
Hotel, Vehicle, and Per Diem Costs
2
events
$ 11,000
$ 22,000
Laboratory Analytical
2
events
$ 27,900
$ 55,800
Data Validation
2
events
$ 10,000
$ 20,000
Project Management, Notificaitons, Sheduling, and Reporting
1
unit
$ 50,400
$ 50,400
Subtotal Annual Groundwater Sampling OM&M Cost - Year 1
$ 249,400
Groundwater Samolina OM&M (Years 2 to 5)
Field Labor
2
events
$ 24,000
$ 48,000
Equipment Rentals and Consumables
2
events
$ 9,700
$ 19,400
Hotel, Vehicle, and Per Diem Costs
2
events
$ 7,400
$ 14,800
Laboratory Analytical
2
events
$ 16,500
$ 33,000
Data Validation
2
events
$ 10,000
$ 20,000
Project Management, Notificaitons, Sheduling, and Reporting
1
unit
$ 50,400
$ 50,400
Total Annual Groundwater Sampling OM&M Cost (Years 2 to 5)
$ 185,600
Annual Groundwater SamDlina OM&M Costs (Years 2 to 5):
Number of Years ( n ):
4
Discount Rate (/ ):
7%
p/A value:
3.387
Subtotal Groundwater Sampling OM&M Present Worth (Years 2 to 5):
$ 628,627
Groundwater Samolina OM&M (Years 6 to 30)
Field Labor
1
event
$ 24,000
$ 24,000
Equipment Rentals and Consumables
1
event
$ 9,700
$ 9,700
Hotel, Vehicle, and Per Diem Costs
1
event
$ 7,400
$ 7,400
Laboratory Analytical
1
event
$ 16,500
$ 16,500
Data Validation
1
event
$ 10,000
$ 10,000
Project Management, Notificaitons, Sheduling, and Reporting
1
unit
$ 50,400
$ 50,400
Total Annual Groundwater Sampling OM&M Cost (Years 6 to 30)
$ 118,000
Annual Groundwater Samplinq OM&M Costs (Years 6 to 30):
Number of Years ( n ):
25
Discount Rate (/ ):
7%
p/A value:
11.654
Subtotal Groundwater Sampling OM&M Present Worth (Years 6 to 30):
$ 1,375,172
Total Groundwater Sampling OM&M Present Worth (Years 1 to 30):
$ 2,253,199
(continued on next page)
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&
L nicorn Management
^=C»nsnltan l.a. LLC
Table 11b
FS TABLE 4.1-1
INSTITUTIONAL CONTROLS AND MONITORING FOR PORTION OF GROUNDWATER PLUME
PROPOSED FOR A TECHNICAL IMPRACTICABILITY WAIVER
FEASIBILITY STUDY REPORT
LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
INDEX NUMBER: CERCLA-02-2006-2006
LEROY, NEW YORK
Item
Unit
Total
Quantity
Units
Cost
Cost
Institutional Controls (ICs) and Maintenance Costs (2)
Informational Devices
Environmental Easements
Legal Fees
124
parcels
$
2,000
$
248,000
Recording Fees
124
parcels
$
250
$
31,000
Publications (1 per county/year)
30
years
$
1,500
$
45,000
Site ODeration And Maintenance(3)
30
years
$
5,000
$
150,000
Site Manaqernent Plan
1
unit
$
50,000
$
50,000
Subtotal
$
524.000
Total Cost
$
2,778,000
Notes and Assumptions:
(1) The groundwater sampling program will be conducted as described below
• The first groundwater monitoring event will include all well/cluster locations (estimated 150 samples in total)
• All subsequent groundwater monitoring events include 22 well/cluster locations (estimated 90 samples in total) as follows:
• 13 perimeter wells
• 4 source area wells
• 5 wells located downgradient of the source area
• Costs assume a semi-annual sampling schedule for Years 1-5, and annual sampling thereafter.
• Modifications to the proposed the long-term monitoring plan may be necessary based on the results of the sampling data
(2) ICs for groundwater media include Governmetal Controls (refer to Appendix C) & Informational Devices (Deed Notices and Publications).
Each property within the groundwater plume would require an associated deed notice. Additionally, publication of a notice in the local
newspaper of each of the three counties affected by the groundwater plume would be required annually. Note that Informational Devices
would also apply to Indoor Air; however costs for these ICs are not included in the cost summary table for Indoor Air in order to avoid
duplication of costs. Please note that there are no costs associated with implementation of Governmental Controls.
(3) This includes estimated costs associated with maintenance of the well network, and annual inspections that would include identifying
any new homes built within the plume area, any new connections to the public water line, any new SSD system installations, and any
soil vapor intrusion investigations that may have been conducted. Findings would be documented in an accompanying annual report.
-------
f .
Unicorn Management
^SConaultants, LLC
Table 11c
FS TABLE 4.2-1
VAPOR INTRUSION ALTERNATIVE COST ESTIMATE
FEASIBILITY STUDY REPORT
LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND
SITE INDEX NUMBER: CERCLA-02-2006-2006
LEROY, NEW
'ORK
Unit
Total
Item
Quantity
Units
Cost
Cost
Indoor Air OM&M
Field Labor (Annualized)
1
EST
$
8,320
$
8,320
Equipment Rentals and Consumables (Annualized)
1
EST
$
307
$
307
Hotel, Vehicle, and Per Diem Costs (Annualized)
1
EST
$
2,290
$
2,290
Laboratory Analytical (Annualized)
1
EST
$
4,845
$
4,845
Data Validation (Annualized)
1
EST
$
2,167
$
2,167
Annual Soil Vapor Intrusion (SVI) Mitigation System Inspections
1
EST
$
2,535
$
2,535
Annual Cost of System Operation
1
EST
$
2,000
$
2,000
Project Management, Notificaitons, Sheduling, and Reporting
1
EST
$
5,500
$
5,500
Annual Reporting
1
EST
$
25,200
$
25,200
Total Annual Indoor Air OM&M Cost (Accounts for Annualized Costs)
$
53,163
Annual Indoor Air Monitorina OM&M Costs:
Number of Years ( n ):
30
Discount Rate (i ):
7%
p/A value:
12.409
Total Indoor Air OM&M Present Worth (PW):
$
659,704
Total Cost
$
659,704
Notes and Assumptions:
Long-Term Monitoring Scope for Indoor Air:
- Air Samples will be collected every 3 years and analyzed for VOCs by TO-15 analysis.
- In general 3 samples will be collected at 13 locations. Additional samples will be collected as necessary.
- Duplicate samples will be collected at a rate of 1 per 20 samples.
- Analytical cost for TO-15 + Tentatively Identified Compounds (TICs) cost ~ $275 per sample.
- Sampling events may require up to 2 mobilizations based on property owner and subcontractor availability.
- SVI Mitigation System Inspections will be conducted annually.
- Assumes 2 personnel required for sampling events and 1 personnel required for oversight.
- Note that costs associated with new SVI system installations are not included here
- Additional Institutional Controls for VI include Environmental Easements for all 124 parcels within the plume
boundary. (See Table 4.1-1; not included here to avoid duplication of costs)
-------
Table 11c
FS TABLE 4.3-1
BEDROCK VADOSE ZONE ALTERNATIVE
#2 INSTITUTIONAL CONTROLS
COST SUMMARY
Item
Quantity
Units
Unit
Cost
Total
Cost
Institutional Controls|1>
Informational Devices
Environmental Easements
Legal Fees
9
parcels
$
15,000
$
135,000
Recording Fees
9
parcels
$
250
$
2,250
Subtotal:
$
137,250
Total Cost
$
137,250
Notes:
(1) Insitutional Controls for Bedrock media include Informational Devices only, which consist of Environmental Easements for nine (9) affected parcels
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Table 11d
© Benchmark
— FS TABLE 4.5-7
SOIL ALTERNATIVE #3: EXCAVATION/DISPOSAL USING COMMERCIAL LAND-
USE BASED PRG
CLEANUP LEVEL 200 MG/KG
FEASIBILITY STUDY REPORT
LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
INDEX NUMBER CERCLA-02-2006-2006
Item
Qudfitity
Units
Unit1
Cost
Total
Cost
Pre-Remediation Work
Screening Pilot Study
Survey Limits of Excavation and Soil Cover System
Erosion Control
Temporary Construction Fencing
Remedial Action Work Plan
1
1
1
800
1
EST
EST
EST
LF
EST
$ 50,000
$ 10,000
$ 10,000
$ 10
$ 40,000
$ 50,000
$ 10,000
$ 10,000
$ 8,000
$ 40,000
Subtotal:
lm£acted Soil Removal and Treatment
Excavate Soils for Screening
Load/Haul/Dispose as Hazardous Waste 2
Backfill and Compaction (Imported Soil) Replace all Less tops
Topsoil 4" on top of excavation
Post-Excavation Confirmatory Sampling
Bottom Samples (1/900 sf)
Sidewall (1/30LF)
1900
1900
1777
123
11
35
Ton
Ton
Ton
Ton
EA
EA
$ 7
$ 1,000
$ 25
$ 40
$ 100
$ 100
$ 118,000
$ 13,300
$ 1,900,000
$ 44,432
$ 4,909
$ 1,106
$ 3,533
Subtotal:
Removal of stone ballast and vapor barrier liner; placement of
1
LS
$ 40,000.00
$ 1,967,280
$ 40,000
Subtotal:
$ 40,000
Subtotal Capital Cost
Contractor Mobilization/Demobilization (5%)
Health and Safety (2%)
Engineering/Contingency (35%)
$ 2,125,280
$ 106,264
$ 42,506
$ 743,848
Total Capital Cost
$ 3,017,897
Institutional Controls
Environmental Easements 3
O&M Plan
Subtotal:
1
1
LS
LS
$ 106,750.00
$ 15,000.00
$ 106,750
$ 15,000
$ 121,750
Total Institutional Controls
$ 121,750
Annual Performance Report I 1 I LS I $ 5,000.00
$ 5,000
Annual Certification OM&M Present Worth (PW);
Number of Years (n):
Interest Rate (I):
p/A value:
30
7%
12.40
Annual Certification OM&M Present Worth (PW):
$ 62,000
Total Institutional Controls and OM&M Present Worth (PW):
$ 183,750
Total Cost $ 3,202,000
Notes
1) Unit costs developed based on Benchmark's experience with remedial projects except where noted.
2) Verbal Quote from Waste Management {PQ Canada).Quote from Mitkem Resources July 2022
3) Estimated cost for environmental easements on 7 parcels within Spill Zone having exceedances above Residential use. In addition, deed notices will be
required to prevent groundwater use, these costs are included in Table 4.1-1 "Groundwater Cost Table".
-------
Table 11e
FS TABLE 4.4 -5
SURFACE WATER ALTERNATIVE #5
IN-SITU TREATMENT WITH STREAM BED COVER
COST SUMMARY
Item
Quantity
Units
Unit
Cost
Total
Cost
Pre-Remedial Design Investigation
Test Well Installation/Samplinq
Workplan Preparation
Installation of Testing Wells (contractor)
Field Oversight & sample colllection
Periodic/Seaonal data collection & analysis
Laboratory Analysis
Data Validation
1
40
100
80
400
400
unit
wells
worker-days
worker-days
samples
samples
$ 30,000
$ 10,000
$ 2,000
$ 2,000
$ 250
$ 125
$ 30,000
$ 400,000
$ 200,000
$ 160,000
$ 100,000
$ 50,000
Subtotal:
$ 940,000
Pilot Testinq - In-Situ Treatment Barrier
Workplan Preparation
Installation of Pilot Scale Treatment Barrier
Reagent/Equipment to be used in Barrier
Contractor/Equipment Rentals
Field Oversight & sample colllection
Laboratory Analysis
Data Validation
Remedial System Design
1
1
1
1
20
20
20
1
unit
unit
unit
rental
worker-days
samples
samples
unit
$ 30,000
$ 200,000
$ 50,000
$ 25,000
$ 2,000
$ 250
$ 125
$ 70,000
$ 30,000
$ 200,000
$ 50,000
$ 25,000
$ 40,000
$ 5,000
$ 2,500
$ 70,000
Subtotal:
$ 422,500
Remedial System Installation
Treatment Barrier Installation
Construction of Access Roads on Property
Installation of Treatment Barriers
Reagent/Equipment to be used in Barrier
Consultant Oversight
1
2
1
20
EST
barriers
unit
worker-days
$ 50,000
$ 200,000
$ 100,000
$ 2,000
$ 50,000
$ 400,000
$ 100,000
$ 40,000
Subtotal:
$ 590,000
Streambed Cover Installation
Construction of Access Roads on Property
Materials for Stone Cover
Installation (Contractor)
Consultant Oversight
1
1800
1
60
unit
cu. Yards
unit
worker-days
$ 50,000
$ 50
$ 200,000
$ 2,000
$ 50,000
$ 90,000
$ 200,000
$ 120,000
Subtotal:
$ 460,000
Pipinq and Equipment Pad Installation
Piping Materials and Labor (Contractor)
Concrete Equipment Pad Installation
Consultant Oversight
600
1
25
linear feet
unit
worker-days
$ 200
$ 30,000
$ 2,000
$ 120,000
$ 30,000
$ 50,000
Subtotal:
$ 200,000
Eauioment Eunchase & Installation
Remedial System Purchase
Shed/Building Construction for equipment
System Installation, Startup & Testing (Contractor)
Electrical Power Drop & Service Installation
Consultant Oversight
1
1
1
1
20
unit
unit
unit
unit
worker-days
$ 100,000
$ 75,000
$ 30,000
$ 20,000
$ 2,000
$ 100,000
$ 75,000
$ 30,000
$ 20,000
$ 40,000
Subtotal:
$ 265,000
Operation & Maintenance/Long-term Monitoring Workplan
$ 25,000
Subtotal Capital Cost
Contractor Mobilization/Demobilization (5%)
Health and Safety (2%)
Engineering/Contingency (35%)
$ 2,902,500
$ 145,125
$ 58,050
$ 1,015,875
Total Capital Cost
$ 4,121,550
Institutional Controls|1)
Informational Devices
Environmental Easements
Legal Fees
Recording Fees
Signage (2)
Monitorinq ®
Site Operation And Maintenance
1
1
1
30
30
parcel
parcel
parcel
years
years
$ 15,000
$ 250
$ 5,000
$ 1,050
$ 1,000
$ 15,000
$ 250
$ 5,000
$ 31,500
$ 30,000
Subtotal:
$ 81,750
Annual Operation Maintenance & Monitoring (OM&M)
LaboryMaterials & Rentals
Electrical Costs
Waste Disposal
Spare Parts & Miscellaneous Materials
System Analytical Sampling
Data Validation
Quarterly Reporting, Data Review & Project Management
1
1
1
1
1
1
1
EST
EST
EST
EST
EST
EST
EST
$ 120,000
$ 15,000
$ 25,000
$ 30,000
$ 10,000
$ 10,000
$ 40,000
$ 120,000
$ 15,000
$ 25,000
$ 30,000
$ 10,000
$ 10,000
$ 40,000
Total Annual OM&M Cost
$ 250,000
Annual OM&M Present Worth (PW):
Number of Years (n):
Discount Rate (I):
p/A value:
$ 30
$ 0
$ 12
Annual OM&M Present Worth (PW):
$ 3,102,250
Total Cost|4) $ 7,306,000
Notes:
(1) Institutional Controls for surface water media include Informational Devices (Environmental Easement & Signage), Monitoring and Maintenance
(2) Signage to be posted along property boundary to indicate that surface water on the property is not suitable for recreational use
(3) Costs presented include annual sampling for up to seven (7) surface water samples per year for TCE analysis
(4) All costs are estimated based on favorable results from the Pre-Remedial Design Investigation (PDI), and are subject to change
based on the actual data obtained from the the PDI
-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
615364
08/18/2023
ADMINISTRATIVE RECORD INDEX FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
36
Administrative Record
Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
611178
Undated
RESTRICTED USE SOIL CLEANUP OBJECTIVES - TABLE
375-6 FOR THE LEHIGH VALLEY RAILROAD SITE
3
Chart /Table
608837
03/01/1969
GENESEE COUNTY SOIL SURVEY FOR MARCH 1969
FOR LEHIGH VALLEY RAILROAD SITE
252
Report
391195
12/07/1970
NEWSPAPER ARTICLES - THE DAILY NEWS: HEALTH
OFFICIAL CITES DANGERS OF DERAILMENT - THE
LEHIGH VALLEY RAILROAD SITE
1
Publication
114980
03/14/1971
TCE SPILL REPORT AT NORTH LEROY, NEW YORK
26
Report
SOZANSKI,NESTOR (LEHIGH VALLEY
RAILROAD COMAPNY)
115170
03/20/1991
REQUEST OF THE ARRANGEMENT FOR BOTTLED
WATER DELIVERY AND INSTALLATION GRANULAR
ACTIVATED CARBON WATER TREATMENT SYSTEMS,
LEHIGH VALLEY RAILROAD DERAILMENT SITE
2
Letter
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY)
O TOOLE,MICHAEL,J (NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
391207
04/01/1991
NYSHD FACT SHEET: LEHIGH VALLEY RAILROAD SPILL
FOR THE LEHIGH VALLEY RAILROAD SITE
8
Publication
391173
04/04/1991
POLLUTION REPORT NO. 1 FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MAGRIPLES,NICK (US
ENVIRONMENTAL PROTECTION
AGENCY)
114977
04/16/1991
ACTION MEMORANDUM: REQUEST FOR BOTTLED
WATER EXPEDITED REMOVAL ACTION AT THE
LEHIGH VALLEY RAILROAD SITE
3
Memorandum
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD,C (US
ENVIRONMENTAL PROTECTION
AGENCY)
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
391215
05/01/1991
CORRESPONDENCE REGARDING PROPOSED SITE FOR
THE MONROE COUNTY LANDFILL FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Letter
THOMAS,LEE,M (US ENVIRONMENTAL
PROTECTION AGENCY)
391217
05/01/1991
CORRESPONDENCE REGARDING APRIL 24, 1991
PUBLIC MEETING MINUTES FOR THE LEHIGH VALLEY
RAILROAD SITE
18
Letter
TAWADROS,GAD (US ENVIRONMENTAL
PROTECTION AGENCY)
BASILE,MICHAEL (US ENVIRONMENTAL
PROTECTION AGENCY)
391174
05/20/1991
POLLUTION REPORT NO. 3 FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
TAWADROS,GAD (US ENVIRONMENTAL
PROTECTION AGENCY)
391506
06/24/1991
CORRESPONDENCE REGARDING INVESTIGATION OF
RESIDENTIAL WATER TREATMENT SYSTEMS FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Letter
TAWADROS,GAD (US ENVIRONMENTAL
PROTECTION AGENCY)
391507
06/24/1991
CORRESPONDENCE REGARDING PRE-FILTER
MAINTENANCE AND REPLACEMENT FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Letter
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
391179
07/03/1991
POLLUTION REPORT NO. 4 FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
TAWADROS,GAD (US ENVIRONMENTAL
PROTECTION AGENCY)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
391175
07/16/1991
POLLUTION REPORT NO. 5 FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
TAWADROS,GAD (US ENVIRONMENTAL
PROTECTION AGENCY)
488496
08/01/1991
FRACTURE TRACE ANALYSIS FOR THE LEHIGH VALLEY
RAILROAD SITE
13
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(BIONETICS CORPORATION)
391170
09/23/1991
FINAL DRAFT PRELIMINARY ASSESSMENT REPORT
FOR THE LEHIGH VALLEY RAILROAD SITE
163
Report
391210
10/01/1991
US EPA REGION II FACT SHEET: LEHIGH VALLEY
RAILROAD DERAILMENT SITE FOR THE LEHIGH
VALLEY RAILROAD SITE
2
Publication
391238
10/03/1991
CORRESPONDENCE REGARDING EPA SITE ACTIVITIES
FOR THE LEHIGH VALLEY RAILROAD SITE
5
Letter
D AMATO,ALFONSE,M (US CONGRESS)
SIDAMON-ERISTOFF,CONSTANTINE (US
ENVIRONMENTAL PROTECTION
AGENCY)
391239
10/04/1991
CORRESPONDENCE REGARDING EPA SITE ACTIVITIES
FOR THE LEHIGH VALLEY RAILROAD SITE
5
Letter
MOYNIHAN,DANIEL,P (UNITED STATES
SENATE)
SIDAMON-ERISTOFF,CONSTANTINE (US
ENVIRONMENTAL PROTECTION
AGENCY)
391219
10/08/1991
CORRESPONDENCE REGARDING REQUEST FOR
COMMENTS ON PUBLIC MEETING NOTICE FOR THE
LEHIGH VALLEY RAILROAD SITE
7
Letter
391197
10/18/1991
NEWSPAPER ARTICLE - DEMOCRAT AND CHRONICLE:
1970 SPILL STILL HAUNTS 3 COUNTIES - THE LEHIGH
VALLEY RAILROAD SITE
1
Publication
391220
10/22/1991
PUBLIC MEETING AGENDA - OCTOBER 22, 1991 FOR
THE LEHIGH VALLEY RAILROAD SITE
1
Meeting Document
391212
10/22/1991
PUBLIC MEETING NOTICE FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Publication
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
114979
11/04/1991
NOTICE OF POTENTIAL LIABILITY AND REQUEST FOR
INFORMATION SUBMITTED TO LEHIGH VALLEY
RAILROAD COMPANY, LEHIGH VALLEY RAILROAD
DERAILMENT SITE
12
Letter
SCHWAB,JAMES,E (LEHIGH VALLEY
RAILROAD COMAPNY)
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY)
120574
11/20/1991
POLLUTION REPORT NO. 7 FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD,C (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
110139
12/01/1991
REMOVAL ADMINISTRATIVE RECORD INDEX AND
DOCUMENTS FOR THE LEHIGH VALLEY RAILROAD
SITE
282
List/Index
MATHEIS,KEVIN,M (US
ENVIRONMENTAL PROTECTION
AGENCY)
(US ENVIRONMENTAL PROTECTION
AGENCY)
391505
12/05/1991
CORRESPONDENCE REGARDING CONCERN FROM
RESIDENTS REGARDING EPA RESPONSE ACTIVITIES
FOR THE LEHIGH VALLEY RAILROAD SITE
4
Letter
391176
12/06/1991
POLLUTION REPORT NO. 8 FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
391205
12/20/1991
LEHIGH VALLEY RAILROAD COMPANY (LVRR)
RESPONSE TO US EPA 104E REQUEST FOR
INFORMATION REGARDING THE LEHIGH VALLEY
RAILROAD SITE
183
Letter
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
120575
12/26/1991
POLLUTION REPORT NO. 9 FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD,C (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
391616
01/15/1992
PUBLIC NOTICE - DEMOCRAT AND CHRONICLE: THE
US EPA ANNOUNCES THE AVAILABILITY OF THE
ADMINISTRATIVE RECORD FOR THE LEHIGH VALLEY
RAILROAD DERAILMENT SITE - THE LEHIGH VALLEY
RAILROAD SITE
2
Publication
391201
01/16/1992
NEWSPAPER ARTICLE - CALEDONIA ADVERTISER: EPA
INSTALLS CARBON FILTER SYSTEMS FOR HOMES
AFFECTED BY LEHIGH VALLEY RAILROAD - THE
LEHIGH VALLEY RAILROAD SITE
4
Publication
391202
01/21/1992
NEWSPAPER ARTICLE -EPA FILES FROM SPILL
AVAILABLE AT LIBRARY - THE LEHIGH VALLEY
RAILROAD SITE
4
Publication
391203
01/21/1992
NEWSPAPER ARTICLE -EPA INSTALLS CARBON FILTER
SYSTEMS FOR HOMES AFFECTED BY LEHIGH VALLEY
RAILROAD SPILL - THE LEHIGH VALLEY RAILROAD SITE
1
Publication
120570
01/28/1992
POLLUTION REPORT NO. 10 FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD,C (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
120571
02/21/1992
POLLUTION REPORT NO. 11 FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD,C (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
391504
04/01/1992
NYSDOH SITE UPDATE - APRIL 1992 FOR THE LEHIGH
VALLEY RAILROAD SITE
2
Other
391503
04/08/1992
CORRESPONDENCE REGARDING REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) UPDATE
TO RESIDENTS FROM NYSDEC FOR THE LEHIGH
VALLEY RAILROAD SITE
3
Letter
391259
04/16/1992
CORRESPONDENCE REGARDING COMPLETED
INSTALLATION OF GRANULATED ACTIVATED CARBON
WATER TREATMENT SYSTEMS AT RESIDENCES AND
TRANSMITTAL OF SAMPLING RESULTS FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Letter
O TOOLE,MICHAEL,J (NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
SALKIE,RICHARD (US ENVIRONMENTAL
PROTECTION AGENCY)
391177
05/06/1992
POLLUTION REPORT NO. 12 FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
188617
05/08/1992
DEPOSITION OF NESTOR SOZANSKI - LEHIGH VALLEY
RAILROAD DERAILMENT SITE
44
Meeting Document
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
391230
05/08/1992
CONCURRENCE COPY OF US EPA 104E
SUPPLEMENTAL REQUEST FOR INFORMATION SENT
TO LEHIGH VALLEY RAILROAD COMPANY FOR THE
LEHIGH VALLEY RAILROAD SITE
4
Letter
OLSON,ROBERT,W (LEHIGH VALLEY
RAILROAD COMPANY)
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY)
188616
05/27/1992
DEPOSITION OF GEORGE L. MARSHALL - LEHIGH
VALLEY RAILROAD DERAILMENT SITE
43
Meeting Document
120573
06/02/1992
POLLUTION REPORT NO. 13 FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD,C (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
391178
06/02/1992
POLLUTION REPORT NO. 13 FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Report
CALLAHAN,KATHLEEN (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
114981
06/17/1992
RESPONSE TO THE REQUEST FOR INFORMATION
SUBMITTED TO THE LEHIGH VALLEY RAILROAD CO.,
LEHIGH VALLEY RAILROAD DERAILMENT SITE
152
Letter
FISCHER,DOUGLAS (US
ENVIRONMENTAL PROTECTION
AGENCY)
CAPRA,JAMES,J (LAW OFFICES OF
DONOVAN LEISURE NEWTON &
IRVINE)
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
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Doc Type:
Addressee Name/Organization:
Author Name/Organization:
539191
06/17/1992
LEHIGH VALLEY RAILROAD COMPANY'S
SUPPLEMENTAL RESPONSE TO US EPA 104E
REQUEST FOR INFORMATION FOR THE LEHIGH
VALLEY RAILROAD SITE
51
Document Packet
114982
09/03/1992
RESPONSE TO THE REQUEST FOR INFORMATION
SUBMITTED TO THE LEHIGH VALLEY RAILROAD CO.,
LEHIGH VALLEY RAILROAD DERAILMENT SITE (WITH
ATTACHMENTS)
59
Letter
FISHER,DOUGLAS (US
ENVIRONMENTAL PROTECTION
AGENCY)
CAPRA,JAMES,J (LAW OFFICES OF
DONOVAN LEISURE NEWTON &
IRVINE)
391222
11/19/1992
PUBLIC MEETING AGENDA - NOVEMBER 19, 1992
FOR THE LEHIGH VALLEY RAILROAD SITE
2
Meeting Document
391199
11/20/1992
NEWSPAPER ARTICLE: CONTAMINATED WATER
HASN'T HARMED - THE LEHIGH VALLEY RAILROAD
SITE
1
Publication
539190
03/25/1993
LEHIGH VALLEY RAILROAD COMPANY'S
SUPPLEMENTAL RESPONSE TO US EPA 104E
REQUEST FOR INFORMATION FOR THE LEHIGH
VALLEY RAILROAD SITE
3
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | FISCHER,DOUGLAS (US
ENVIRONMENTAL PROTECTION
AGENCY)
(LAW OFFICES OF DONOVAN LEISURE
NEWTON & IRVINE) |CAPRA,JAMES,J
(LAW OFFICES OF DONOVAN LEISURE
NEWTON & IRVINE)
115169
05/13/1993
FINAL POLLUTION REPORT, POLREP 15, LEHIGH
VALLEY RAILROAD DERAILMENT SITE
6
Report
PAVLOU,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY) | SALKIE,RICHARD,C (US
ENVIRONMENTAL PROTECTION
AGENCY) |ZACHOS,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
MATHEIS,KEVIN,M (US
ENVIRONMENTAL PROTECTION
AGENCY)
-------
I
DocID:
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Title:
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Author Name/Organization:
391211
05/14/1993
US EPA REGION II FACT SHEET: SUPERFUND
RESPONSE ALERT FOR THE LEHIGH VALLEY RAILROAD
SITE
1
Publication
391502
05/26/1993
CORRESPONDENCE REGARDING NYSDEC TAKE OVER
OF OPERATIONS AND MAINTENANCE FOR THE 35
GAC WATER TREATMENT SYSTEMS FOR THE LEHIGH
VALLEY RAILROAD SITE
2
Letter
PAVLOU,GEORGE (US
ENVIRONMENTAL PROTECTION
AGENCY)
VICKERSON,TOM (NYS DEC)
115005
10/01/1996
REMEDIAL INVESTIGATION REPORT, VOLUMES 1-3,
THE LEHIGH VALLEY RAILROAD SITE
1208
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
(RUST ENVIRONMENT &
INFASTRUCTURE)
188544
10/01/1996
HYDROGEOLOGIC INVESTIGATION AND FISH AND
WILDLIFE IMPACT ANALYSIS FOR THE LEHIGH VALLEY
RAILROAD SITE
323
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
(RUST ENVIRONMENT &
INFASTRUCTURE)
188545
10/01/1996
ADDENDUM TO HYDROGEOLOGIC INVESTIGATION
REPORT - LEHIGH VALLEY RAILROAD DERAILMENT
SITE
43
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
(RUST ENVIRONMENT &
INFASTRUCTURE)
115007
01/01/1997
FEASIBILITY STUDY REPORT, LEHIGH VALLEY
RAILROAD SITE
569
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
(RUST ENVIRONMENT &
INFASTRUCTURE) | (TAMS
CONSULTANTS INCORPORATED)
611277
01/08/1997
WATER SUPPLY ALTERNATIVES MAP FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Figure/Map/ Drawing
(RUST ENVIRONMENT &
INFASTRUCTURE)
115004
02/01/1997
FACT SHEET: PROPOSED REMEDIAL ACTION PLAN,
AND PUBLIC MEETING INVITATION, LEHIGH VALLEY
RAILROAD DERAILMENT SITE, TOWN OF LEROY,
GENESEE COUNTY, NEW YORK
4
List/Index
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
115006
02/01/1997
FEASIBILITY STUDY REPORT, INACTIVE HAZARDOUS
WASTE SITE, SURFACE SOIL REMEDIATION, LEHIGH
VALLEY RAILROAD SITE
55
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
391206
02/01/1997
NYSDEC FACT SHEET: PROPOSED REMEDIAL ACTION
PLAN FEBRUARY 1997 - THE LEHIGH VALLEY
RAILROAD SITE
4
Publication
391172
03/24/1997
HEALTH CONSULTATION FOR THE LEHIGH VALLEY
RAILROAD SITE
26
Report
488828
03/28/1997
NYSDEC RECORD OF DECISION MARCH 1997 FOR THE
LEHIGH VALLEY RAILROAD SITE
74
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
188534
04/01/1997
HAZARD RANKING SYSTEM SITE INSPECTION
QUESTIONNAIRE FOR THE LEHIGH VALLEY RAILROAD
SITE
162
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
655886
11/06/1997
REVISED SVE PERFORMANCE TEST REPORT FOR THE
LEHIGH VALLEY RAILROAD SITE
138
Report
(RUETGERS NEASE CHEMICAL
COMPANY)
(GOLDER ASSOCIATES INCORPORATED)
188536
12/18/1997
HEALTH CONSULTATION - LEHIGH VALLEY RAILROAD
DERAILMENT SITE
28
Report
(DEPARTMENT OF HEALTH AND
HUMAN SERVICES)
204463
03/01/1998
HAZARD RANKING SYSTEM DOCUMENTATION
PACKAGE, VOLUME 1 OF 3 FOR LEHIGH VALLEY
RAILROAD SITE
66
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(ROY F. WESTON INCORPORATED)
204464
03/01/1998
HAZARD RANKING SYSTEM DOCUMENTATION
PACKAGE, VOLUME 2 AND 3 OF 3 FOR LEHIGH
VALLEY RAILROAD SITE
2454
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(ROY F. WESTON INCORPORATED)
188480
09/01/1998
PROPOSED WATER DISTRIBUTION SYSTEM FOR THE
LEHIGH VALLEY RAILROAD SITE
21
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
(STEARNS & WHELER, LLC)
188479
10/07/1998
SUBMITTAL OF LEHIGH VALLEY PROPOSED WATER
DISTRIBUTION SYSTEM
1
Letter
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
MOLOUGHNEY,JOSEPH (NEW YORK
STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
363475
01/01/1999
NPL SITE LISTING NARRATIVE
2
188527
01/08/1999
REVIEW OF REMEDIAL INVESTIGATION (OCTOBER
1996), FEASIBILITY STUDY FOR OPERABLE UNIT 1
(JANUARY 1997) AND OPERABLE UNIT 2 (FEBRUARY
1997), RECORD OF DECISION (MARCH 1997) - LEHIGH
VALLEY RAILROAD SITE
4
Memorandum
LYNCH,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
MUSUMECI,GRACE (US
ENVIRONMENTAL PROTECTION
AGENCY)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
114983
01/19/1999
FEDERAL REGISTER NOTICES 1998 & 1999 (NATIONAL
PRIORITIES LIST PROPOSED AND FINAL RULES),
LEHIGH VALLEY RAILROAD DERAILMENT SITE
1
Other
488769
01/25/1999
PHASE 1A CULTURAL RESOURCE SURVEY - LEHIGH
VALLEY WATER PROJECT FOR THE LEHIGH VALLEY
RAILROAD SITE
68
Report
(IT CORPORATION)
115009
02/01/1999
FINAL ENVIRONMENTAL IMPACT STATEMENT,
GENESEE COUNTY PUBLIC WATER SUPPLY
PROGRAM, LEHIGH VALLEY RAILROAD SITE
249
Report
(CLARK PATTERSON ASSOCIATES)
188551
03/02/1999
COMPLETION OF DESIGN OF WATERLINE IN THE
CALEDONIA-LEROY AREA - LEHIGH VALLEY RAILROAD
DERAILMENT SITE
1
Letter
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
MOLOUGHNEY,JOSEPH (NEW YORK
STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
114184
04/09/1999
DRAFT EX-SITU SOIL VAPOR EXTRACTION AND IN-
SITU BEDROCK VAPOR EXTRACTION PILOT TEST
REPORT FOR THE LEHIGH VALLEY RAILROAD
DERAILMENT SITE, PREPARED BY NYSDEC - NO FINAL
REPORT WAS PUBLISHED BY THE NYSDEC
844
Report
(NEW YORK DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
(IT CORP)
188501
06/25/1999
INTENTION OF THE TOWN OF LEROY TO FORM A
WATER DISTRICT IN THE LIME ROCK PORTION OF THE
TOWN - LEHIGH VALLEY RAILROAD SITE
1
Letter
MOLOUGHNEY,JOSEPH (NEW YORK
STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
KEMP,JOHN,T (NONE)
488770
07/14/1999
PHASE IB CULTURAL RESOURCE SURVEY - LEHIGH
VALLEY WATER PROJECT FOR THE LEHIGH VALLEY
RAILROAD SITE
59
Report
(IT CORPORATION)
114180
07/23/1999
MEMORANDUM TO JEANNE M. FOX, REGIONAL
ADMINISTRATOR, U.S. EPA, FROM RICHARD L. CASPE,
P.E., DIRECTOR, EMERGENCY AND REMEDIAL
RESPONSE DIVISION, U.S. EPA, REGARDING
CONCURRENCE WITH THE RECORD OF DECISION FOR
THE LEHIGH VALLEY RAILROAD DERAILMENT SITE
3
Memorandum
FOX,JEANNE,M (US ENVIRONMENTAL
PROTECTION AGENCY)
CASPE,RICHARD,L (US
ENVIRONMENTAL PROTECTION
AGENCY)
114181
07/27/1999
LETTER TO MICHAEL J. O'TOOLE, JR., P.E., NEW YORK
STATE DEPARTMENT OF ENVIRONMENTAL
CONSERVATION FROM JEANNE M. FOX, REGIONAL,
U.S. EPA, REGARDING THE RECORD OF DECISION FOR
THE LEHIGH VALLEY RAILROAD DERAILMENT SITE
2
Letter
O TOOLE,MICHAEL,J (NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
FOX,JEANNE,M (US ENVIRONMENTAL
PROTECTION AGENCY)
-------
I
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Title:
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Addressee Name/Organization:
Author Name/Organization:
188530
07/27/1999
RECORD OF DECISION FOR THE LEHIGH VALLEY
RAILROAD DERAILMENT SITE
75
Report
FOX,JEANNE,M (US ENVIRONMENTAL
PROTECTION AGENCY)
CASPE,RICHARD,L (US
ENVIRONMENTAL PROTECTION
AGENCY)
114182
08/27/1999
LETTER TO RICHARD L. CASPE, U.S. EPA, REGION II,
FROM MICHAEL J. O'TOOLE, JR., NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL CONSERVATION
REGARDING THE LEHIGH VALLEY RAILROAD
DERAILMENT SITE
1
Letter
CASPE,RICHARD,L (US
ENVIRONMENTAL PROTECTION
AGENCY)
O TOOLE,MICHAEL,J (NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
488475
08/27/1999
CORRESPONDENCE REGARDING CONSTRUCTION OF
THE WATERLINE REMEDY FOR THE LEHIGH VALLEY
RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | CASPE,RICHARD,L (US
ENVIRONMENTAL PROTECTION
AGENCY)
(NYS DEPARTMENT OF
ENVIRONMENTAL
CONSERVATION)! O'TOOLE,MICHAEL
(NYS DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
188487
09/08/1999
INITIAL RELEASE PUBLIC HEALTH ASSESSMENT -
LEHIGH VALLEY RAILROAD SITE
25
Memorandum
(NEW YORK STATE DEPARTMENT OF
HEALTH)
115018
10/01/1999
FACT SHEET: UPDATE ON WATERLINE INSTALLATION
PLANS, LEHIGH VALLEY RAILROAD SPILL AREA
4
Report
(NYS DEC)
188513
03/03/2000
GENESEE COUNTY WATER SUPPLY SYSTEM
PROGRAM - PROPOSED MODIFICATIONS - LEHIGH
VALLEY RAILROAD SITE
5
Memorandum
PAOLETTA,DAVID,P (NONE)
188564
03/14/2000
SUBMITTAL OF 95% DESIGN OF WATER
DISTRIBUTION SYSTEM - LEHIGH VALLEY RAILROAD
DERAILMENT SITE
1
Letter
ENGLISH,ANDREW (NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
LYNCH,KEVIN (US ENVIRONMENTAL
PROTECTION AGENCY)
188623
04/14/2000
US ENVIRONMENTAL PROTECTION AGENCY REQUEST
FOR ASSISTANCE OF THE DEPARTMENT OF JUSTICE
WITH ISSUES RELATING TO THE LIABILITY OF THE
LEHIGH VALLEY RAILROAD DERAILMENT SITE
2
Letter
CAPRA,JAMES,J (LAW OFFICES OF
DONOVAN LEISURE NEWTON &
IRVINE)
TENENBAUM,ALAN (US DEPARTMENT
OF JUSTICE)
197280
04/18/2000
CONTRACT DRAWINGS WATER DISTRIBUTION
SYSTEM LEHIGH VALLEY RAILROAD DERAILMENT SITE
NEW YORK NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION CONTRACT NO. 1
2000 FOR THE LEHIGH VALLEY RAILROAD SITE
34
Figure/Map/ Drawing
(STEARNS & WHELER, LLC)
488771
08/06/2000
PHASE IB CULTURAL RESOURCE SURVEY - LEHIGH
VALLEY WATER PROJECT FOR THE LEHIGH VALLEY
RAILROAD SITE
63
Report
(IT CORPORATION)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
188531
12/13/2000
CORRESPONDENCE PERTAINING TO NYSDEC MARCH
1997 RECORD OF DECISION FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Letter
O TOOLE,MICHAEL,J (NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
FOX,JEANNE,M (US ENVIRONMENTAL
PROTECTION AGENCY)
539245
01/01/2001
UNICORN MANAGEMENT CONSULTANTS QUALITY
MANAGEMENT PLAN FOR THE LEHIGH VALLEY
RAILROAD SITE
31
Work Plan
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
188567
03/07/2001
TRANSMITTAL OF VISUAL CLASSIFICATION OF ROCK -
LEHIGH VALLEY RAILROAD DERAILMENT SITE
13
Correspondence
TREJO,FRANCISCO (LEHIGH VALLEY
ROAD DERAILMENT SUPERFUND SITE)
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
115017
03/13/2001
PUBLIC HEALTH ASSESSMENT FOR THE LEHIGH
VALLEY RAILROAD SITE
26
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(NYS Department of Health)
188519
10/29/2001
PROPERTY OWNERS REQUESTING NECESSARY LEGAL
AND GOVERNMENTAL ACTION TO PROVIDE AND
INSURE THAT THE CURRENT PUBLIC WATER
INSTALLATION PROJECT IN NEGOTIATIONS LEADING
UP TO THE DESIGN AND CONSTRUCTION PHASE -
LEHIGH VALLEY RAILROAD SITE
5
Memorandum
(LEROY TOWN BOARD)
MOLOUGHNEY,JOSEPH (NEW YORK
STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
188609
12/21/2001
FACT SHEET - WATERLINE INSTALLATION AT THE
LEHIGH VALLEY RAILROAD DERAILMENT SITE
2
Other
488477
01/14/2002
CORRESPONDENCE REGARDING REVISED RISK
ASSESSMENT FOR THE LEHIGH VALLEY RAILROAD
SITE
6
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(US ENVIRONMENTAL PROTECTION
AGENCY) | NACE,CHARLES (US
ENVIRONMENTAL PROTECTION
AGENCY)
188532
05/21/2002
CORRESPONDENCE PERTAINING TO NYSDEC MARCH
1997 RECORD OF DECISION FOR THE LEHIGH VALLEY
RAILROAD SITE
10
Letter
O TOOLE,MICHAEL,J (NEW YORK STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
KENNY,JANE,M (US ENVIRONMENTAL
PROTECTION AGENCY)
182586
08/26/2002
AERIAL PHOTOGRAPHIC LAND USE/LAND COVER AND
WETLAND ANALYSIS FOR THE LEHIGH VALLEY
RAILROAD SITE
26
Report
GAROFALO, DONALD
(ENVIRONMENTAL PHOTOGRAPHIC
INTERPRETATION CENTER (EPIC))
114996
02/01/2003
FACT SHEET: STATUS REPORT FOR WATERLINE
INSTALLATION, LEHIGH VALLEY RAILROAD SPILL SITE
2
Other
(NYS DEC)
114986
08/01/2003
FINAL REMEDIATION REPORT: WATER DISTRIBUTION
SYSTEM, LEHIGH VALLEY RAILROAD DERAILMENT
SITE
8
Report
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
(STEARNS & WHELER, LLC)
188612
09/23/2003
REVIEW AND COMMENTS ON FINAL REMEDIATION
REPORT - LEHIGH VALLEY RAILROAD DERAILMENT
SITE
1
Letter
FALKENBURG,TITUS,J (STEARNS &
WHELER)
CRUDEN,MICHAEL (NY STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
188613
09/30/2003
REVIEW OF FINAL REMEDIATION REPORT WATER
DISTRIBUTION SYSTEM - LEHIGH VALLEY RAILROAD
DERAILMENT SITE
1
Letter
CRUDEN,MICHAEL (NY STATE
DEPARTMENT OF ENVIRONMENTAL
CONSERVATION)
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
115016
10/01/2003
FINAL REMEDIATION REPORT, WATER DISTRIBUTION
SYSTEM, LEHIGH VALLEY RAILROAD DERAILMENT
SITE
732
Report
(NYS DEC)
(STEARNS & WHELER, LLC)
539214
12/16/2004
CORRESPONDENCE REGARDING AMERICAN PREMIER
UNDERWRITERS' CONCERNS ON REVISED VERSION
OF APPENDIX 2 ADDENDUM TO FOSTER WHEELER'S
WORK PLAN FOR THE LEHIGH VALLEY RAILROAD SITE
3
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | WIEDER,MARLA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(BLANK ROME
LLP) | CONTE,JONATHAN,A (BLANK
ROME LLP)
539274
09/27/2005
ADDENDUM TO THE DOCUMENT ENTITLED FINAL
WORK PLAN FOR REMEDIAL
INVESTIGATION/FEASIBILITY STUDY DATED 02/2002
FOR THE LEHIGH VALLEY RAILROAD SITE
11
Work Plan
114989
09/22/2006
SETTLEMENT AGREEMENT AND ORDER ON CONSENT
FOR PRE-REMEDIAL DESIGN INVESTIGATIONS,
REMEDIAL DESIGN, AND REMEDIAL
INVESTIGATION/FEASIBILITY STUDY, LEHIGH VALLEY
RAILROAD SITE
38
Legal Instrument
KENNEDY,JAMES,C (LEHIGH VALLEY
RAILROAD COMPANY)
(US ENVIRONMENTAL PROTECTION
AGENCY)
488789
09/22/2006
STATEMENT OF WORK FOR THE LEHIGH VALLEY
RAILROAD SITE
14
Report
488774
10/01/2006
FINAL GUIDANCE FOR EVALUATING SOIL VAPOR
INTRUSION IN THE STATE OF NEW YORK FOR THE
LEHIGH VALLEY RAILROAD SITE
92
Other
(NEW YORK STATE DEPARTMENT OF
HEALTH)
165607
10/23/2006
SUBMITTAL OF THE PROJECT SCHEDULE TO
IMPLEMENT THE WORK PLAN AND THE STATEMENT
OF WORK FOR THE LEHIGH VALLEY RAILROAD
COMPANY
8
Letter
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
TREJO,FRANCISCO (LEHIGH VALLEY
ROAD DERAILMENT SUPERFUND SITE)
165610
11/06/2006
QUALITY ASSURANCE PROJECT PLAN FOR SAMPLING
AND ANALYSIS - LEHIGH VALLEY RAILROAD
COMPANY
117
Work Plan
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
165613
11/06/2006
HEALTH AND SAFETY PLAN SITE INVESTIGATIONA
ACTIVITIES - LEHIGH VALLEY RAILROAD COMPANY
163
Work Plan
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
608705
02/28/2008
CORRESPONDENCE REGARDING COMMENTS FOR
DRAFT LETTER DATED 02/26/2008 FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(LEHIGH VALLEY ROAD DERAILMENT
SUPERFUND SITE) |TREJO,FRANCISCO
(LEHIGH VALLEY ROAD DERAILMENT
SUPERFUND SITE)
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
114990
03/01/2008
FACT SHEET: COMMUNITY UPDATE, LEHIGH VALLEY
RAILROAD DERAILMENT SITE
2
List/Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
115013
03/14/2008
INDOOR AIR MONITORING PLAN, LEHIGH VALLEY
RAILROAD DERAILMENT SITE
15
Report
TREJO,FRANCISCO (LEHIGH VALLEY
ROAD DERAILMENT SUPERFUND SITE)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
608708
03/19/2008
CORRESPONDENCE REGARDING INDOOR AIR
MONITORING PLAN DATED 03/14/2008 FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Letter
(LEHIGH VALLEY ROAD DERAILMENT
SUPERFUND SITE) |TREJO,FRANCISCO
(LEHIGH VALLEY ROAD DERAILMENT
SUPERFUND SITE)
(US ENVIRONMENTAL PROTECTION
AGENCY) IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
115010
03/26/2008
QUALITY ASSURANCE PROJECT PLAN FOR SAMPLING
AND ANALYSIS, LEHIGH VALLEY RAILROAD SITE
123
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
115012
03/26/2008
SITE HEALTH AND SAFETY PLAN, SITE INVESTIGATION
ACTIVITIES, LEHIGH VALLEY RAILROAD SITE
162
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
488536
04/01/2008
EPA APPROVAL OF THE QUALITY ASSURANCE
PROJECT PLAN AND THE HEALTH AND SAFETY PLAN
BOTH DATED 03/26/2008 FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
114998
04/04/2008
COMMUNITY INVOLVEMENT PLAN, LEHIGH VALLEY
RAILROAD DERAILMENT SITE, TOWN OF LEROY,
GENESEE COUNTY, NEW YORK
33
Work Plan
(US ENVIRONMENTAL PROTECTION
AGENCY)
(ECOLOGY AND ENVIRONMENT
INCORPORATED)
488539
06/26/2008
CORRESPONDENCE REGARDING THE RI/FS WORK
PLAN SECTION 3.3.1 (SITE RECONNAISSANCE) TASKS
FOR THE LEHIGH VALLEY RAILROAD SITE
14
Email
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
115011
11/12/2008
VLF SURVEY, LEHIGH VALLEY RAILROAD SITE
23
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
(HAGER-RICHTER GEOSCIENCE)
610996
01/12/2009
NPL LISTING HISTORY FOR THE LEHIGH VALLEY
RAILROAD SITE
2
Other
189962
02/12/2009
SUBMITTAL OF AMENDMENT NUMBER 2 FOR
INDOOR AIR MONITORING PLAN - LEHIGH VALLEY
RAILROAD DERAILMENT SITE
2
Letter
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
672262
02/12/2009
LVRR DERAILMENT SITE HISTORICAL TCE SAMPLING
DATA SUMMARY FOR THE LEHIGH VALLEY RAILROAD
SITE
1
Figure/Map/ Drawing
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
488547
03/19/2009
CORRESPONDENCE REGARDING SUBMITTAL OF
AMENDMENT NO. 3 FOR INDOOR AIR MONITORING
PLAN - RESAMPLING ACTIVITIES FOR THE LEHIGH
VALLEY RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
608827
04/01/2009
FIELD INVESTIGATION FOR REMEDIAL
INVESTIGATION WORK PLAN FOR LEHIGH VALLEY
RAILROAD SITE
8
List/Index
611014
04/01/2009
STATEMENT OF WORK FOR REMEDIAL
INVESTIGATION / FEASIBILITY STUDY OVERSIGHT FOR
THE LEHIGH VALLEY RAILROAD SITE
6
Report
488834
04/24/2009
SITE RECONNAISSANCE TECHNICAL MEMORANDUM
01 FOR THE LEHIGH VALLEY RAILROAD SITE
121
Report
(LEHIGH VALLEY RAILROAD COMAPNY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
488837
05/06/2009
CORRESPONDENCE REGARDING THE MEETING ON
05/12/2009 FOR PRESENTATION OF TECHNICAL
MEMORANDUM - DERAILMENT PROJECT/ UMC
2032 FOR THE LEHIGH VALLEY RAILROAD SITE
2
Email
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
488835
05/12/2009
TECHNICAL MEMORANDUM MEETING: PROPOSED
CHANGES TO PHASE 1 REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) FOR THE
LEHIGH VALLEY RAILROAD SITE
44
Publication
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
611024
06/15/2009
CORRESPONDENCE REGARDING ORIGINAL LIST OF
DOMESTIC WELLS WITH GAC ACCESS STATUS FOR
THE LEHIGH VALLEY RAILROAD SITE
5
Email
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(NJ DEPARTMENT OF
ENVIRONMENTAL
PROTECTION) | MORAS,JAMES (NJ
DEPARTMENT OF ENVIRONMENTAL
PROTECTION)
115070
07/02/2009
UNICORN MANAGEMENT CONSULTANTS RESPONSE
TO EPA COMMENTS FROM THE MAY 12, 2009 SITE
RECONNAISSANCE TECHNICAL MEMORANDUM
MEETING FOR THE LEHIGH VALLEY RAILROAD SITE
49
Letter
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
488838
07/02/2009
CORRESPONDENCE REGARDING 05/12/2009 SITE
RECONNAISSANCE TECHNICAL MEMORANDUM
MEETING FOR REMEDIAL INVESTIGATION /
FEASIBILITY STUDY FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
608874
09/01/2009
FACT SHEET PRE-DESIGN ACTIVITIES TO BEGIN AT
STATE SUPERFUND SITE FOR LEHIGH VALLEY
RAILROAD SITE
2
Letter
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
152556
10/02/2009
FINAL SCOPE OF WORK FOR VAPOR INTRUSION
MITIGATION AND ADDITIONAL INVESTIGATION FOR
LEHIGH VALLEY RAILROAD SITE
11
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
115000
10/13/2009
REMEDIAL DESIGN WORK PLAN, LEHIGH VALLEY
RAILROAD DERAILMENT SITE, LEROY, NEW YORK
58
Work Plan
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
114999
10/16/2009
CORRESPONDENCE REGARDING REMEDIAL DESIGN
WORK PLAN, LEHIGH VALLEY RAILROAD DERAILMENT
SITE, LEROY, NY
4
Letter
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
TREJO,FRANCISCO (LEHIGH VALLEY
ROAD DERAILMENT SUPERFUND SITE)
608881
10/28/2009
LETTER PERTAINING TO THE FINAL SCOPE OF WORK
DATED 10/02/2009 REGARDING VAPOR INTRUSION
MITIGATION AND ADDITIONAL INVESTIGATION FOR
THE LEHIGH VALLEY RAILROAD SITE
4
Letter
TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
115071
10/30/2009
ADDENDUM 2 REMEDIAL INVESTIGATION /
FEASIBILITY STUDY WORK PLAN FOR THE LEHIGH
VALLEY RAILROAD SITE
21
Work Plan
HANLON,KERRY,M (UNICORN
MANAGEMENT CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
488553
10/30/2009
CORRESPONDENCE REGARDING REMEDIAL
INVESTIGATION / FEASIBILITY STUDY WORKPLAN
ADDENDUM 2 FOR THE LEHIGH VALLEY RAILROAD
SITE
6
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(US ENVIRONMENTAL PROTECTION
AGENCY) |SIMON,MICHELLE (US
ENVIRONMENTAL PROTECTION
AGENCY)
526643
12/07/2009
CORRESPONDENCE REGARDING REMEDIAL DESIGN
WORK PLAN COMMENTS CONFERENCE CALL FOR
THE LEHIGH VALLEY RAILROAD SITE
4
Email
OLIVO,PAUL (US ENVIRONMENTAL
PROTECTION AGENCY)
HANLON,KERRY,M (UNICORN
MANAGEMENT CONSULTANTS, LLC)
608884
12/07/2009
CORRESPONDENCE REGARDING NYSDEC'S
11/03/2009 COMMENTS FOR LEHIGH VALLEY
RAILROAD SITE
3
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(LEHIGH VALLEY ROAD DERAILMENT
SUPERFUND SITE) |TREJO,FRANCISCO
(LEHIGH VALLEY ROAD DERAILMENT
SUPERFUND SITE)
488779
12/09/2009
CORRESPONDENCE REGARDING EPA'S APPROVAL OF
THE REMEDIAL DESIGN WORK PLAN DATED
10/13/2009 REVISED BY THE AMENDING LETTER
DATED 12/09/2009 FOR THE LEHIGH VALLEY
RAILROAD SITE
2
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
488561
12/14/2009
SUBMITTAL REGARDING CONCEPTUAL DESIGNS OF
PROPOSED SOIL VAPOR INTRUSION MITIGATION
SYSTEMS FOR THE LEHIGH VALLEY RAILROAD SITE
30
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | SIMON,MICHELLE (US
ENVIRONMENTAL PROTECTION
AGENCY)
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
480503
02/11/2010
CORRESPONDENCE REGARDING SOIL VAPOR
MITIGATION AND SAMPLING SCHEDULE FOR THE
LEHIGH VALLEY RAILROAD SITE
3
Email
114997
06/01/2010
FACT SHEET: COMMUNITY UPDATE, LEHIGH VALLEY
RAILROAD DERAILMENT SITE
2
List/Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
488792
06/15/2010
UPDATED COMBINED PROJECT SCHEDULES FOR THE
LEHIGH VALLEY RAILROAD SITE
12
Chart /Table
488797
07/22/2010
CORRESPONDENCE REGARDING REMEDIAL
INVESTIGATION / FEASIBILITY STUDY WELLS
INSTALLATION STATUS AND THE PROPOSED FIELD
MODS FOR THE REMAINING MONITORING WELLS
FOR THE LEHIGH VALLEY RAILROAD SITE
9
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
488803
07/28/2010
ADDENDUM 3 TO THE REMEDIAL INVESTIGATION /
FEASIBILITY STUDY WORK PLAN FOR THE LEHIGH
VALLEY RAILROAD SITE
11
Work Plan
(LEHIGH VALLEY RAILROAD COMAPNY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
488807
09/07/2010
ADDENDUM 4 TO THE REMEDIAL INVESTIGATION /
FEASIBILITY STUDY WORK PLAN FOR THE LEHIGH
VALLEY RAILROAD SITE
12
Work Plan
(LEHIGH VALLEY RAILROAD COMAPNY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
480509
12/17/2010
CORRESPONDENCE REGARDING SUBMITTAL OF
REVISED ESA MEMORANDUM FOR THE LEHIGH
VALLEY RAILROAD SITE
55
Email
(UNICORN MANAGEMENT
CONSULTANTS)
488850
01/27/2011
TRANSMITTAL OF THE PRE-REMEDIAL DESIGN SOIL
DATA SUMMARY REPORT ADDENDUM FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610677
01/27/2011
CORRESPONDENCE REGARDING PRE-REMEDIAL
DESIGN SOIL DATA SUMMARY REPORT ADDENDUM
FOR THE LEHIGH VALLEY RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY)IOLIVO,PAUL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
488781
02/01/2011
PRE-REMEDIAL DESIGN BEDROCK DATA SUMMARY
REPORT FOR THE LEHIGH VALLEY RAILROAD SITE
5146
Report
(LEHIGH VALLEY RAILROAD COMAPNY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
610678
02/01/2011
INDOOR AIR MONITORING PROGRAM SUMMARY
FOR THE LEHIGH VALLEY RAILROAD SITE
2
Other
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
610696
03/08/2011
PROJECT SCHEDULE FOR THE LEHIGH VALLEY
RAILROAD SITE
2
Other
488858
08/02/2011
UNICORN MANAGEMENT CONSULTANTS, LLC'S
REVISED FIGURE 2 - PLUME, DATED 08/02/2011 FOR
THE LEHIGH VALLEY RAILROAD SITE
1
Figure/Map/ Drawing
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
348908
09/01/2011
HISTORICAL MONITORING WELLTCE ANALYTICAL
RESULTS FOR THE LEHIGH VALLEY RAILROAD SITE
3
Chart /Table
348905
12/01/2011
HISTORICAL MONITORING WELLTCE ANALYTICAL
RESULTS FOR THE LEHIGH VALLEY RAILROAD SITE
2
Chart /Table
114991
01/01/2012
APPROXIMATE EXTENT OF GROUNDWATER
CONTAMINATION AREA, LEHIGH VALLEY RAILROAD
SITE
1
Figure/Map/ Drawing
611070
01/05/2012
NY STATE HISTORIC PRESERVATION OFFICE'S REVIEW
AND OPINION ON THE PHASE 1 CULTURAL
RESOURCES INVESTIGATION REPORT FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
114992
01/30/2012
MONITORING WELLS WITH TCE CONCENTRATIONS IN
BETWEEN HIGH SCHOOL AND SPILL AREA IN LE ROY,
NY, LEHIGH VALLEY RAILROAD SITE
1
Figure/Map/ Drawing
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
348907
02/02/2012
GENESEE, MONROE AND LIVINGSTON COUNTIES SITE
UPDATE FOR THE LEHIGH VALLEY RAILROAD SITE
2
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
611092
03/30/2012
EXPOSURE SCENARIOS AND ASSUMPTIONS
MEMORANDUM FOR OU1 INDEX NO. CERCLA-02-
2006-2006 FOR THE LEHIGH VALLEY RAILROAD SITE
60
Memorandum
611094
04/03/2012
SIGN-IN SHEET FOR MEETING HELD ON 04/03/2012
FOR THE LEHIGH VALLEY RAILROAD SITE
1
Meeting Document
611065
04/09/2012
NEWSPAPER ARTICLE - DEMOCRAT AND CHRONICLE:
41 YEARS LATER AND NO CLEANUP DATED
04/01/2012 AND US EPA RCRA SUBTILE C SITE
IDENTIFICATION FORM FOR THE LEHIGH VALLEY
RAILROAD SITE
9
Other
611099
04/10/2012
ADDENDUM 5 TO THE REMEDIAL INVESTIGATION /
FEASIBILITY WORK PLAN FOR THE LEHIGH VALLEY
RAILROAD SITE
10
Work Plan
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
611097
04/12/2012
VAPOR INTRUSION INVESTIGATION RESULTS FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
689611
05/01/2012
INDOOR AIR MONITORING MAP FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Figure/Map/ Drawing
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
611066
06/25/2012
NEWSPAPER ARTICLE - FREE DAILY: GRADUATION
CLEARS UPSTATE STUDENTS' MYSTERY TWITCHING
FOR THE LEHIGH VALLEY RAILROAD SITE
1
Publication
348903
08/01/2012
COMMUNITY UPDATE AUGUST 2012 FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
611119
08/23/2012
NPL LISTING HISTORY FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Other
611107
09/25/2012
CORRESPONDENCE REGARDING PROJECT
COORDINATION FINAL SCHEDULE AND ACTION
ITEMS FROM MEETING HELD 09/19/2012 FOR THE
LEHIGH VALLEY RAILROAD SITE
4
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
471679
10/01/2012
BEDROCK DATA SUMMARY REPORT PRE-REMEDIAL
DESIGN FOR THE LEHIGH VALLEY RAILROAD SITE
5163
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
611111
10/09/2012
CORRESPONDENCE REGARDING RESPONSE TO US
EPA'S LETTER DATED 09/25/2012 ADDRESSING THE
PROJECT COORDINATION FINAL SCHEDULE AND
ACTION ITEMS FROM MEETING HELD 09/19/2012
FOR THE LEHIGH VALLEY RAILROAD SITE
4
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611114
10/19/2012
CORRESPONDENCE REGARDING RISK ASSESSMENT
DELIVERABLE UPDATE FOR THE LEHIGH VALLEY
RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
580262
12/01/2012
DRAFT TECHNICAL MEMORANDUM REMEDIAL
ALTERNATIVE SCREENING AND REMEDIAL
ALTERNATIVE EVALUATION FOR THE LEHIGH VALLEY
RAILROAD SITE
19
Report
(UNICORN MANAGEMENT
CONSULTANTS)
610580
01/10/2013
CORRESPONDENCE REGARDING RESPONSE TO
RECOMMENDATIONS OUTLINED IN LETTER
REFERENCING VAPOR INTRUSION DATED 11/27/2012
FOR THE LEHIGH VALLEY RAILROAD SITE
10
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
610581
01/14/2013
CORRESPONDENCE REGARDING REVIEW OF
PATHWAY ANALYSIS REPORT SUBMITTED ON
11/21/2012 FOR THE LEHIGH VALLEY RAILROAD SITE
41
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
610582
01/22/2013
TRANSMITTAL OF THE UNIFORM HAZARDOUS
WASTE MANIFEST AND CERTIFICATE OF DISPOSAL
FOR DRUMS REMOVED FROM THE LEHIGH VALLEY
RAILROAD SITE
3
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610587
02/08/2013
CORRESPONDENCE ACKNOWLEDGING RECEIPT OF
COMMENTS ON PATHWAY ANALYSIS REPORT FOR
THE LEHIGH VALLEY RAILROAD SITE
8
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610602
02/18/2013
CORRESPONDENCE REGARDING REPLY TO PATHWAY
ANALYSIS CONFERENCE CALL MINUTES FOR THE
LEHIGH VALLEY RAILROAD SITE
7
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
543504
03/01/2013
REVISED SCREENING LEVEL ECOLOGICAL RISK
ASSESSMENT FOR THE LEHIGH VALLEY RAILROAD
SITE
888
Report
LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(URS CORPORATION)
610604
03/01/2013
REVISED SCREENING LEVEL ECOLOGICAL RISK
ASSESSMENT FOR THE LEHIGH VALLEY RAILROAD
SITE
37
Report
(URS CORPORATION)
610607
03/21/2013
CORRESPONDENCE REGARDING SUBCONTRACTOR
SOIL VAPOR EXTRACTION REMEDIAL DESIGN
PROPOSAL: OBJECTIVES, BASIS AND CONDITIONS
FOR THE LEHIGH VALLEY RAILROAD SITE
14
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
610609
03/25/2013
PATHWAY ANALYSIS REPORT FOR THE LEHIGH
VALLEY RAILROAD SITE
111
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
543509
05/15/2013
ADDENDUM 1 INDOOR AIR MONITORING REPORT
FOR THE LEHIGH VALLEY RAILROAD SITE
233
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
610624
07/02/2013
CORRESPONDENCE REGARDING ADDENDUM 1 TO
THE STATEMENT OF WORK - BEDROCK VAPOR
SAMPLING PROPOSED MONITORED NATURAL
ATTENUATION SAMPLING FOR THE LEHIGH VALLEY
RAILROAD SITE
16
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/18/2023 REGION ID: 02
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
610625
07/02/2013
CORRESPONDENCE REGARDING SCREENING LEVEL
ECOLOGICAL RISK ASSESSMENT - REVISION 1 AND
RESPONSE TO COMMENTS FOR THE LEHIGH VALLEY
RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610177
07/19/2013
LVRR'S RESPONSE TO EPA 06/10/2013 COMMENTS
ON THE DRAFT INDOOR AIR MONITORING REPORT
FOR THE LEHIGH VALLEY RAILROAD SITE
5
Letter
LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610627
08/14/2013
CORRESPONDENCE REGARDING REVIEW OF QUALITY
ASSURANCE PROJECT PLAN FOR THE LEHIGH VALLEY
RAILROAD SITE
2
Email
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
610629
08/14/2013
CORRESPONDENCE REGARDING MONITORED
NATURAL ATTENUATION OF GROUNDWATER
SAMPLING FOR THE LEHIGH VALLEY RAILROAD SITE
4
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610630
08/15/2013
CORRESPONDENCE REGARDING BEDROCK VAPOR
SAMPLING FOR THE LEHIGH VALLEY RAILROAD SITE
12
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610632
08/27/2013
CORRESPONDENCE REGARDING SOIL REMEDIAL
DESIGN PID DOCUMENTATION FOR THE LEHIGH
VALLEY RAILROAD SITE
13
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
580265
09/01/2013
REVISED SCREENING LEVEL ECOLOGICAL RISK
ASSESSMENT FOR THE LEHIGH VALLEY RAILROAD
SITE
897
Report
(URS CORPORATION)
610633
09/04/2013
CORRESPONDENCE IN RESPONSE TO LETTER OF
08/14/2013 REGARDING MONITORED NATURAL
ATTENUATION OF GROUNDWATER SAMPLING FOR
THE LEHIGH VALLEY RAILROAD SITE
9
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
610640
09/16/2013
CORRESPONDENCE REGARDING MONITORED
NATURAL ATTENUATION GROUNDWATER SAMPLING
FOR THE LEHIGH VALLEY RAILROAD SITE
5
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
543516
09/25/2013
SOIL REMEDIAL DESIGN REPORT COMPLETION FOR
THE LEHIGH VALLEY RAILROAD SITE
347
Report
LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE, PLLC)
-------
I
DocID:
Doc Date:
Title:
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Doc Type:
Addressee Name/Organization:
Author Name/Organization:
610643
10/01/2013
BEDROCK DATA SUMMARY REPORT FOR THE LEHIGH
VALLEY RAILROAD SITE
88
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
610644
10/10/2013
TRANSMITTAL OF BEDROCK DATA SUMMARY
REPORT AND RESPONSE TO EPA COMMENTS ON
BEDROCK DATA SUMMARY REPORT FOR THE LEHIGH
VALLEY RAILROAD SITE
14
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610650
11/04/2013
CORRESPONDENCE REGARDING 2013 VAPOR
INTRUSION RESULTS AND PRELIMINARY
RECOMMENDATIONS FOR THE LEHIGH VALLEY
RAILROAD SITE
7
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611554
01/29/2014
CORRESPONDENCE REGARDING SOIL VAPOR
INTRUSION MITIGATION INSPECT TRIP REPORT FOR
JANUARY 13-16, 2014, FOR THE LEHIGH VALLEY
RAILROAD SITE
2
Memorandum
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
283851
03/21/2014
ADMINISTRATIVE ORDER NO. CERCLA-02-2014-2010
FOR REMEDIAL ACTION FOR THE LEHIGH VALLEY
RAILROAD SITE
20
Legal Instrument
MUGDAN,WALTER,E (US
ENVIRONMENTAL PROTECTION
AGENCY)
689612
04/01/2014
WATERFALL AND SEEP PHOTOGRAPHS APRIL 2014
FOR OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
3
Photograph
453629
04/14/2014
NOTICE OF INTENT TO COMPLY INDEX NUMBER
CERCLA-02-2014-2010 FOR REMEDIAL ACTION SOIL
VAPOR EXTRACTION FOR THE LEHIGH VALLEY
RAILROAD SITE
1
Letter
INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
HILL,MARGARET,A (BLANK ROME LLP)
611575
05/20/2014
CORRESPONDENCE REGARDING QUALITY
MANAGEMENT PLAN FOR THE LEHIGH VALLEY
RAILROAD SITE
1
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
526645
06/19/2014
ADDENDUM 1 TO THE INDOOR AIR MONITORING
REPORT FOR THE LEHIGH VALLEY RAILROAD SITE
570
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
611578
06/23/2014
TECHNICAL IMPRACTICABILITY WAIVER
PRESENTATION FOR THE LEHIGH VALLEY RAILROAD
SITE
71
Other
611580
06/26/2014
CORRESPONDENCE REGARDING MONITORED
NATURAL ATTENUATION SAMPLING FOR THE LEHIGH
VALLEY RAILROAD SITE
31
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(US ENVIRONMENTAL PROTECTION
AGENCY) | LAPOMA,JENNIFER (US
ENVIRONMENTAL PROTECTION
AGENCY)
611583
07/31/2014
DATA EVALUATION REPORT FOR THE LEHIGH VALLEY
RAILROAD SITE
21
Report
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
611584
08/01/2014
REMEDIAL ACTION WORK PLAN COMPENDIUM
VOLUME 1 FOR THE LEHIGH VALLEY RAILROAD SITE
26
Work Plan
611586
08/06/2014
CORRESPONDENCE REGARDING TECHNICAL
MEMORANDUM DATA EVALUATION REPORT FOR
THE LEHIGH VALLEY RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
568524
09/01/2014
REMEDIAL ACTION WORKPLAN COMPENDIUM OU-1
FOR THE LEHIGH VALLEY RAILROAD SITE
962
Work Plan
611589
09/05/2014
PUBLIC COMMENT DRAFT HEALTH CONSULTATION
FOR LEHIGH VALLEY RAILROAD SITE
27
Email
611593
09/19/2014
CORRESPONDENCE REGARDING SAMPLING OF
CALEDONIA LEROY ROAD FOR THE LEHIGH VALLEY
RAILROAD SITE
3
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
611597
10/02/2014
CORRESPONDENCE REGARDING PROPOSED DISCRETE
FRACTURE NETWORK NUMERICAL MODELING OF
MASS TRANSFER BACK DIFFUSION FOR THE LEHIGH
VALLEY RAILROAD SITE
5
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611600
10/29/2014
CORRESPONDENCE REGARDING REMEDIAL ACTION
STATEMENT OF WORK FOR SOIL VAPOR EXTRACTION
INSPECTION OF THE PILOT TEST SYSTEM FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
611601
10/29/2014
TRANSMITTAL OF REMEDIAL ACTION WORK PLAN
FOR THE LEHIGH VALLEY RAILROAD SITE
4
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611154
10/30/2014
ADDENDUM 7 TO THE REMEDIAL INVESTIGATION /
FEASIBILITY STUDY WORK PLAN FOR THE LEHIGH
VALLEY RAILROAD SITE
24
Work Plan
611602
10/30/2014
ADDENDUM 7 REMEDIAL INVESTIGATION /
FEASIBILITY STUDY WORK PLAN FOR THE LEHIGH
VALLEY RAILROAD SITE
22
Work Plan
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
689638
11/06/2014
TRANSMITTAL OF THE PRE-REMEDIAL DESIGN
BEDROCK VAPOR EXTRACTION DATA SUMMARY
REPORT FOR OU1 FOR THE LEHIGH VALLEY RAILROAD
SITE
2
Letter
INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
689637
11/06/2014
PRE-REMEDIAL DESIGN BEDROCK VAPOR
EXTRACTION DATA SUMMARY REPORT FOR OU1 FOR
THE LEHIGH VALLEY RAILROAD SITE
6837
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
611156
11/12/2014
US EPA'S REVIEW OF THE REVISED DRAFT REMEDIAL
INVESTIGATION REPORT AND RESPONSES TO
COMMENTS DATED 08/2014 FOR THE LEHIGH
VALLEY RAILROAD SITE
6
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
611157
12/03/2014
CORRESPONDENCE REGARDING RESPONSE TO US
EPA'S REVIEW AND COMMENT LETTER DATED
11/12/2014 ON THE REMEDIAL INVESTIGATION
REPORT FOR THE LEHIGH VALLEY RAILROAD SITE
5
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
488822
12/04/2014
TRILLIUM INCORPORATED'S REVISED DATA
EVALUATION REPORT FOR THE LEHIGH VALLEY
RAILROAD SITE
18
Report
471828
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - PART 1 FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
382
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471829
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - PART 2 TABLES 1 - 230
FOR OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
17692
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471830
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDICES A - E FOR OU2
FOR THE LEHIGH VALLEY RAILROAD SITE
805
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471831
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDICES F - H FOR OU2
FOR THE LEHIGH VALLEY RAILROAD SITE
2549
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471832
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDICES 1 - K FOR OU2
FOR THE LEHIGH VALLEY RAILROAD SITE
3193
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471833
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDICES L - 0 FOR OU2
FOR THE LEHIGH VALLEY RAILROAD SITE
3011
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471834
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDIX P FOR OU2 FOR
THE LEHIGH VALLEY RAILROAD SITE
1811
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471835
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDICES Q - U FOR
OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
2230
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
471836
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDICES V - X FOR OU2
FOR THE LEHIGH VALLEY RAILROAD SITE
440
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471837
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDIX Y FOR OU2 FOR
THE LEHIGH VALLEY RAILROAD SITE
8137
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471838
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDIX Z FOR OU2 FOR
THE LEHIGH VALLEY RAILROAD SITE
180
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
471839
12/10/2014
FINAL REMEDIAL INVESTIGATION REPORT -
GROUNDWATER PLUME - APPENDIX AA FOR OU2
FOR THE LEHIGH VALLEY RAILROAD SITE
175
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
611158
12/16/2014
US EPA'S APPROVAL OF THE QUALITY ASSURANCE
PROJECT PLAN DATED 08/2014 FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
611159
12/16/2014
US EPA'S APPROVAL OF THE REVISED DRAFT
REMEDIAL INVESTIGATION REPORT DATED 12/2014
FOR THE LEHIGH VALLEY RAILROAD SITE
1
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
611607
12/16/2014
CORRESPONDENCE REGARDING PATHWAYS
ANALYSIS REPORT DRAFT DATED NOVEMBER 24,
2014, FOR THE LEHIGH VALLEY RAILROAD SITE
1
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
610843
02/10/2015
CORRESPONDENCE REGARDING REVISED SCREENING
LEVEL ECOLOGICAL RISK ASSESSMENT REPORT -
FEBRUARY 2015 FOR THE LEHIGH VALLEY RAILROAD
SITE
1
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
610844
02/10/2015
CORRESPONDENCE REGARDING REVIEW OF
PROPOSED DISCRETE FRACTURE NETWORK
NUMERICAL MODELING FOR THE LEHIGH VALLEY
RAILROAD SITE
1
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
348906
03/01/2015
COMMUNITY UPDATE MARCH 2015 FOR THE LEHIGH
VALLEY RAILROAD SITE
2
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
672287
03/01/2015
SVE PILOT TEST REPORT, REVISED FOR THE LEHIGH
VALLEY RAILROAD SITE
152
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE, PLLC)
-------
I
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
610856
03/05/2015
CORRESPONDENCE REGARDING REVIEW AND
COMMENTS ON THE SOIL VAPOR EXTRACTION PILOT
TEST REPORT FOR JANUARY 2015 FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
610872
06/03/2015
SUPPLEMENTAL MONITORED NATURAL
ATTENUATION WORKPLAN USEPA OPERABLE UNIT 2
FOR THE LEHIGH VALLEY RAILROAD SITE
87
Work Plan
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
610874
06/08/2015
CORRESPONDENCE REGARDING SOIL VAPOR
EXTRACTION SYSTEM INSTALLATION TRIP REPORT -
JUNE 1 TO JUNE 5, 2015, FOR THE LEHIGH VALLEY
RAILROAD SITE
5
Memorandum
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610875
06/09/2015
CORRESPONDENCE REGARDING SUPPLEMENTAL
MNA SAMPLING FOR THE LEHIGH VALLEY RAILROAD
SITE
2
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(US ENVIRONMENTAL PROTECTION
AGENCY) | LOPEZ,SERGIO (US
ENVIRONMENTAL PROTECTION
AGENCY)
610882
06/25/2015
CORRESPONDENCE REGARDING REVIEW AND
COMMENTS ON THE SUPPLEMENTAL MONITORED
NATURAL ATTENUATION SAMPLING FOR THE LEHIGH
VALLEY RAILROAD SITE
3
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
610887
07/24/2015
ADDENDUM 2 TO THE INDOOR AIR MONITORING
REPORT FOR THE LEHIGH VALLEY RAILROAD SITE
35
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
610889
08/27/2015
MONITORED NATURAL ATTENUATION WORKPLAN
USEPA OPERABLE UNIT 2 FOR THE LEHIGH VALLEY
RAILROAD SITE
27
Work Plan
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
610890
08/27/2015
TRANSMITTAL OF MONITORED NATURAL
ATTENUATION WORKPLAN USEPA OPERABLE UNIT 2
FOR THE LEHIGH VALLEY RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610893
08/28/2015
CORRESPONDENCE REGARDING REVISED
MONITORED NATURAL ATTENUATION DISCRETE
FRACTURE NUMERICAL MODELING FOR THE LEHIGH
VALLEY RAILROAD SITE
6
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610894
09/08/2015
FINAL MONITORING NATURAL ATTENUATION
WORKPLAN USEPA OPERABLE UNIT 2 FOR THE
LEHIGH VALLEY RAILROAD SITE
19
Work Plan
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
610895
09/08/2015
TRANSMITTAL OF MONITORED NATURAL
ATTENUATION WORKPLAN USEPA OPERABLE UNIT 2
FOR THE LEHIGH VALLEY RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610896
09/16/2015
CORRESPONDENCE REGARDING COMMENTS ON THE
DRAFT BASELINE HUMAN HEALTH RISK ASSESSMENT
DATED FEBRUARY 2015 FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
610897
10/06/2015
CORRESPONDENCE REGARDING RESPONSE TO
COMMENTS ON THE DRAFT BASELINE HUMAN
HEALTH RISK ASSESSMENT DATED FEBRUARY 2015
FOR THE LEHIGH VALLEY RAILROAD SITE
7
Memorandum
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
655870
11/11/2015
TECHNICAL MEMORANDUM FOR RESULTS FROM
BRAVO BEDROCK VAPOR EXTRACTION TREATABILITY
STUDY FOR THE LEHIGH VALLEY RAILROAD SITE
50
Memorandum
(CH2M HILL)
611307
01/01/2016
COMMUNITY UPDATE JANUARY 2016 FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Other
(US ENVIRONMENTAL PROTECTION
AGENCY)
611339
01/07/2016
AECOM'S RESPONSE TO 09/16/2015 REVIEW OF THE
DRAFT BASELINE HUMAN HEALTH RISK ASSESSMENT
DATED 02/2015, REVISED FOR THE LEHIGH VALLEY
RAILROAD SITE
8
Memorandum
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
611334
01/11/2016
TRANSMITTAL OF THE FINAL BASELINE HUMAN
HEALTH RISK ASSESSMENT FOR THE LEHIGH VALLEY
RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611337
02/04/2016
SIX MONTH REMEDIAL STATUS REPORT FOR OU1
FOR THE LEHIGH VALLEY RAILROAD SITE
10
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE,
PLLC)| FORBES,TOM (BENCHMARK
ENVIRONMENTAL ENGINEERING &
SCIENCE, PLLC)
611336
02/23/2016
US EPA REVIEW OF THE SOIL VAPOR EXTRACTION SIX-
MONTH PROGRESS REPORT, 02/2016 FOR OU1 FOR
THE LEHIGH VALLEY RAILROAD SITE
2
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
610916
02/24/2016
REVISED SIX MONTH REMEDIAL STATUS REPORT FOR
OU1 FOR THE LEHIGH VALLEY RAILROAD SITE
17
Report
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE,
PLLC)| FORBES,TOM (BENCHMARK
ENVIRONMENTAL ENGINEERING &
SCIENCE, PLLC)
689574
02/26/2016
FINAL BASELINE HUMAN HEALTH RISK ASSESSMENT
FOR OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
335
Report
(AECOM)
610917
02/26/2016
TRANSMITTAL OF THE SOIL VAPOR EXTRACTION SIX-
MONTH PROGRESS REPORT FOR OU1 FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611332
02/26/2016
TRANSMITTAL OF THE FINAL BASELINE HUMAN
HEALTH RISK ASSESSMENT FOR THE LEHIGH VALLEY
RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611331
03/01/2016
US EPA APPROVAL OF THE FINAL BASELINE HUMAN
HEALTH RISK ASSESSMENT FOR 03/01/2016 FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
611322
03/15/2016
ADDENDUM 3 TO THE INDOOR AIR MONITORING
REPORT FOR THE LEHIGH VALLEY RAILROAD SITE
17
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611343
06/24/2016
CORRESPONDENCE REGARDING SOIL VAPOR
EXTRACTION NETWORK FIELD TESTING FOR OU1 FOR
THE LEHIGH VALLEY RAILROAD SITE
5
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE,
PLLC) | FORBES,TOM (BENCHMARK
ENVIRONMENTAL ENGINEERING &
SCIENCE, PLLC)
611344
07/06/2016
TRANSMITTAL OF THE SOIL VAPOR EXTRACTION
SYSTEM EVALUATION FOR OU1 FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
611342
07/31/2016
CORRESPONDENCE REGARDING THE SOIL VAPOR
EXTRACTION NETWORK FIELD TESTING WORK PLAN
FOR OU1 FOR THE LEHIGH VALLEY RAILROAD SITE
3
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE,
PLLC) | FORBES,TOM (BENCHMARK
ENVIRONMENTAL ENGINEERING &
SCIENCE, PLLC)
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
08/18/2023 REGION ID: 02
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
611328
09/07/2016
CORRESPONDENCE REGARDING THE PLANNED
INITIAL POST-REMEDIAL CONFIRMATORY BORING
PROGRAM FOR THE LEHIGH VALLEY RAILROAD SITE
4
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE,
PLLC)| FORBES,TOM (BENCHMARK
ENVIRONMENTAL ENGINEERING &
SCIENCE, PLLC)
610934
02/10/2017
TRANSMITTAL OF INDOOR AIR MONITORING
LOCATION MAPS FOR THE LEHIGH VALLEY RAILROAD
SITE
4
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610950
03/29/2017
CORRESPONDENCE REGARDING REVIEW AND
COMMENTS ON THE DRAFT ASSESSMENT OF
GROUNDWATER RESTORATION POTENTIAL AND
TECHNICAL IMPRACTICABILITY FOR THE LEHIGH
VALLEY RAILROAD SITE
11
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
610958
05/15/2017
CORRESPONDENCE REGARDING RESPONSE TO EPA
COMMENTS RECEIVED ON MARCH 29, 2017,
REFERENCE: OP-3689 FOR THE LEHIGH VALLEY
RAILROAD SITE
25
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610965
06/29/2017
PRESENTATION SLIDES FOR LEHIGH VALLEY
RAILROAD AND EPA MEETING FOR THE LEHIGH
VALLEY RAILROAD SITE
57
Other
(US ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS)
610967
07/19/2017
CORRESPONDENCE REGARDING RESPONSE TO
SETTLEMENT AGREEMENT ISSUES FOR THE LEHIGH
VALLEY RAILROAD SITE
6
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
610974
11/01/2017
TECHNICAL EVALUATION - BEDROCK VAPOR
EXTRACTION FOR SOURCE AREA REMEDIATION - FOR
THE LEHIGH VALLEY RAILROAD SITE
7
Letter
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
610975
12/07/2017
CORRESPONDENCE REGARDING DRAFT ASSESSMENT
OF GROUNDWATER RESTORATION POTENTIAL AND
TECHNICAL IMPRACTICABILITY - SEPTEMBER 2016 -
MEETING FOR THE LEHIGH VALLEY RAILROAD SITE
6
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | BADALAMENTI,SALVATORE
(US ENVIRONMENTAL PROTECTION
AGENCY)
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
611486
01/31/2018
CORRESPONDENCE REGARDING DRAFT ASSESSMENT
OF GROUNDWATER RESTORATION POTENTIAL AND
TECHNICAL IMPRACTICABILITY REPORT FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
610978
03/01/2018
FOCUSED ALTERNATIVES ANALYSIS REPORT FOR THE
LEHIGH VALLEY RAILROAD SITE
31
Report
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE, PLLC)
689691
03/01/2018
VAPOR INTRUSION EVALUATION FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
135
Report
(AECOM)
611487
04/05/2018
CORRESPONDENCE REGARDING RESPONSE TO EPA
COMMENTS ON THE DRAFT ASSESSMENT OF
GROUNDWATER RESTORATION POTENTIAL AND
TECHNICAL IMPRACTICABILITY REPORT FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | INFURNA,MICHAEL (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
620714
04/28/2018
ADDENDUM 5 TO THE INDOOR TO THE INDOOR AIR
MONITORING REPORT FOR THE LEHIGH VALLEY
RAILROAD SITE
283
Report
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
689575
07/01/2018
REVISED TCE DATA FOR MUD CREEK SAMPLING FOR
OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
2
Figure/Map/ Drawing
(UNICORN MANAGEMENT
CONSULTANTS)
611492
07/02/2018
CORRESPONDENCE REGARDING REVIEW OF
FOCUSED ALTERNATIVES ANALYSIS REPORT FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Letter
MAGEE,CHRISTOPHER (NEW YORK
STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
DOROSKI,MELISSA,A (NEW YORK STATE
DEPARTMENT OF HOUSING)
611498
10/22/2018
CORRESPONDENCE REGARDING EVALUATION OF
BEDROCK VAPOR EXTRACTION PILOT TESTING FOR
THE LEHIGH VALLEY RAILROAD SITE
3
Memorandum
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
543524
02/19/2019
REVISED SCREENING LEVEL ECOLOGICAL RISK
ASSESSMENT FOR THE LEHIGH VALLEY RAILROAD
SITE
125
Report
(URS CORPORATION)
689556
04/04/2019
REVISED EVALUATION OF BEDROCK VAPOR
EXTRACTION PILOT TESTING FOR THE LEHIGH VALLEY
RAILROAD SITE
4
Memorandum
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
655871
05/13/2019
A PILOT STUDY OF TCE VAPOR EXTRACTION IN
FRACTURED LIMESTONE FOR THE LEHIGH VALLEY
RAILROAD SITE
15
Report
(NY STATE DEPT OF ENVIRONMENTAL
CONSERVATION (NYSDEC))
689617
06/04/2019
GROUNDWATER ASSESSMENT, RESTORATION
ALTERNATIVES AND TECHNICAL IMPRACTICABILITY
FOR OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
479
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
689618
06/04/2019
TRANSMITTAL OF THE GROUNDWATER
ASSESSMENT, RESTORATION ALTERNATIVES AND
TECHNICAL IMPRACTICABILITY FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
628292
07/03/2019
WORK PLAN FOR THE SAMPLING OF EMERGING
CONTAMINATES (PFAS AND 1,4-DIOXANE) FOR THE
LEHIGH VALLEY RAILROAD SITE
70
Work Plan
(NY STATE DEPT OF ENVIRONMENTAL
CONSERVATION (NYSDEC))
(UNICORN MANAGEMENT
CONSULTANTS)
628293
07/24/2019
CORRESPONDENCE REGARDING TRIP REPORT
EMERGING CONTAMINATE SAMPLING 7/16/2019
FOR THE LEHIGH VALLEY RAILROAD SITE
1
Memorandum
(UNICORN MANAGEMENT
CONSULTANTS)
689577
11/26/2019
NYSDEC'S COMMENTS ON THE DRAFT FEASIBILITY
STUDY REPORT FOR OU2 FOR THE LEHIGH VALLEY
RAILROAD SITE
9
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
689571
02/06/2020
CORRESPONDENCE REGARDING INDIVIDUAL TOWN
ZONING MAPS FOR OU2 FOR THE LEHIGH VALLEY
RAILROAD SITE
8
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
590428
03/30/2020
TRANSMITTAL OF THE ADDENDUM 7 TO THE
INDOOR AIR MONITORING REPORT FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Letter
JON,MARIA (US ENVIRONMENTAL
PROTECTION AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS)
590429
03/30/2020
ADDENDUM 7 TO THE INDOOR AIR MONITORING
REPORT FOR THE LEHIGH VALLEY RAILROAD SITE
249
Letter
(LEHIGH VALLEY RAILROAD COMPANY)
(UNICORN MANAGEMENT
CONSULTANTS)
689564
05/12/2020
CORRESPONDENCE REGARDING NYSDEC CONCERNS
WITH THE RAOS BEING PROPOSED FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
3
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
689566
05/27/2020
CORRESPONDENCE REGARDING THE MODIFICATION
TO THE SUGGESTED RAOS FOR OU2 FOR THE LEHIGH
VALLEY RAILROAD SITE
5
Email
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
689554
07/15/2020
US EPA AND NYSDEC COMMENTS ON THE JUNE 2019
DRAFT FEASIBILITY STUDY REPORT FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
14
Letter
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
689557
08/17/2020
UNICORN MANAGEMENT CONSULTANTS' RESPONSE
TO US EPA AND NYSDEC COMMENTS ON THE JUNE
2019 DRAFT FEASIBILITY STUDY REPORT FOR THE
LEHIGH VALLEY RAILROAD SITE
12
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
689590
10/28/2020
REVISED HEALTH AND SAFETY PLAN FOR OU2 FOR
THE LEHIGH VALLEY RAILROAD SITE
161
Work Plan
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
689560
11/02/2020
CORRESPONDENCE REGARDING TAX PARCELS
WITHIN THE SPILL ZONE/SOURCE AREA FOR THE
LEHIGH VALLEY RAILROAD SITE
7
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | WIEDER,MARLA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
689576
12/11/2020
CORRESPONDENCE REGARDING PARCELS, ZONING,
CURRENT SOIL CONCENTRATIONS AND ICIAP FOR
OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
281
Memorandum
(US ENVIRONMENTAL PROTECTION
AGENCY) | WIEDER,MARLA (US
ENVIRONMENTAL PROTECTION
AGENCY)
689569
12/16/2020
CORRESPONDENCE REGARDING THE STUDY AREA TO
BE INCLUDED IN THE REVISED FEASIBILITY STUDY FOR
OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
2
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689603
02/09/2021
CORRESPONDENCE REGARDING THE RESPONSE TO
US EPA EMAIL ON 02/03/2021 FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
4
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | WIEDER,MARLA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689579
03/25/2021
NYSDEC PRESENTATION ON THE OUTSTANDING
ISSUES WITH EPA REGARDING THE FEASIBILITY
STUDY, SOIL CLEANUP OBJECTIVE AND Tl WAIVER
FOR OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
11
Meeting Document
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
625501
06/13/2021
REMEDIAL EVALUATION WORK PLAN FOR THE
LEHIGH VALLEY RAILROAD SITE
28
Work Plan
(UNICORN MANAGEMENT
CONSULTANTS)
(BENCHMARK ENVIRONMENTAL
ENGINEERING & SCIENCE, PLLC)
692960
10/05/2021
ADDENDUM 8 TO THE INDOOR AIR MONITORING
REPORT FOR OU2 FOR THE LEHIGH VALLEY RAILROAD
SITE
48
Report
JON,MARIA (US ENVIRONMENTAL
PROTECTION AGENCY)
TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689065
10/26/2021
SUPPLEMENTAL RISK EVALUATION FOR THE LEHIGH
VALLEY RAILROAD SITE
18
Memorandum
JON,MARIA (US ENVIRONMENTAL
PROTECTION AGENCY)
FILIPOWICZ,URSZULA (US
ENVIRONMENTAL PROTECTION
AGENCY)
689066
10/29/2021
SUPPLEMENTAL ECOLOGICAL RISK EVALUATION FOR
THE LEHIGH VALLEY RAILROAD SITE
5
Memorandum
JON,MARIA (US ENVIRONMENTAL
PROTECTION AGENCY)
Debofsky,Abigail,R (U.S.
ENVIRONMENTAL PROTECTION
AGENCY)
689570
11/29/2021
CORRESPONDENCE REGARDING THE BEDROCK
VAPOR EVALUATION AREAS FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
689565
11/30/2021
DOMESTIC WELL STATUS FOR 2019 TO 2021 FOR
OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
94
Memorandum
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689609
12/15/2021
ZONING MAPS AROUND PLUME FOOTPRINT
REFERENCE MAP FOR OU2 FOR THE LEHIGH VALLEY
RAILROAD SITE
1
Figure/Map/ Drawing
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
689584
01/26/2022
TRANSMITTAL OF THE DRAFT PROPOSED APPROACH
FOR SPILL AREA SOILS FOR OU2 FOR THE LEHIGH
VALLEY RAILROAD SITE
1
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
655878
02/25/2022
CORRESPONDENCE REGARDING DRAFT OUTLINE FOR
FEASIBILITY STUDY ALTERNATIVES EVALUATION
BEDROCK VADOSE ZONE FOR US EPA TO REVIEW FOR
THE LEHIGH VALLEY RAILROAD SITE
10
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
689593
04/28/2022
CORRESPONDENCE REGARDING THE MUD CREEK
SURFACE WATER SAMPLING FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
3
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689552
05/06/2022
CORRESPONDENCE REGARDING THE REVISED
FEASIBILITY STUDY SCHEDULE FOR THE LEHIGH
VALLEY RAILROAD SITE
2
Email
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
629303
08/03/2022
US EPA NOTICE OF DISAPPROVAL OF THE DRAFT
REVISED FEASBILITY STUDY REPORT FOR THE LEHIGH
VALLEY RAILROAD SITE
3
Letter
(BLANK ROME LLP) | (UNICORN
MANAGEMENT CONSULTANTS, LLC)
DUDA,DAMIAN (US ENVIRONMENTAL
PROTECTION AGENCY)
580288
08/03/2022
LETTER OF FEASIBILITY STUDY DISAPPROVAL FOR THE
LEHIGH VALLEY RAILROAD SITE
3
Letter
HILL,MARGARET,A (BLANK ROME
LLP) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
DUDA,DAMIAN (US ENVIRONMENTAL
PROTECTION AGENCY)
629648
09/30/2022
REMEDIAL ACTION REPORT FOR SOIL VAPOR
EXTRACTION FOR OU1 FOR THE LEHIGH VALLEY
RAILROAD SITE
9
Report
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I
DocID:
Doc Date:
Title:
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Doc Type:
Addressee Name/Organization:
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629649
09/30/2022
EPA APPROVAL OF THE REMEDIAL ACTION REPORT
FOR IN SITU SOIL VAPOR EXTRACTION FOR OU1 FOR
THE LEHIGH VALLEY RAILROAD SITE
1
Memorandum
654292
12/15/2022
US EPA NOTICE OF DISAPPROVAL OF DRAFT REVISED
FEASIBILITY STUDY REPORT 09/12/2022 IN
ACCORDANCE WITH THE INDEX NO. CERCLA -02-
2006-2006 FOR THE LEHIGH VALLEY RAILROAD SITE
299
Letter
(BLANK ROME LLP) | (UNICORN
MANAGEMENT CONSULTANTS, LLC)
DUDA,DAMIAN (US ENVIRONMENTAL
PROTECTION AGENCY)
692961
01/10/2023
ADDENDUM 9 TO THE INDOOR AIR MONITORING
REPORT FOR OU2 FOR THE LEHIGH VALLEY RAILROAD
SITE
Report
JON,MARIA (US ENVIRONMENTAL
PROTECTION AGENCY)
TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689586
03/30/2023
US EPA COMMENTS ON THE DRAFT REVISED
FEASIBILITY STUDY REPORT FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
5
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | DUDA,DAMIAN (US
ENVIRONMENTAL PROTECTION
AGENCY)
689596
04/11/2023
UNICORN MANAGEMENT CONSULTANTS' RESPONSE
TO US EPA COMMENTS ON THE DRAFT REVISED
FEASIBILITY STUDY REPORT FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
3
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | DUDA,DAMIAN (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689587
05/01/2023
US EPA RESPONSE TO UNICORN MANAGEMENT
CONSULTANTS LETTER DATED 04/11/2023 FOR OU2
FOR THE LEHIGH VALLEY RAILROAD SITE
3
Memorandum
(US ENVIRONMENTAL PROTECTION
AGENCY)
689599
05/08/2023
NYSDEC COMMENTS ON THE DRAFT FEASIBILITY
STUDY SUBMITTED 02/10/2023 FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
212
Memorandum
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
689613
05/16/2023
US EPA TRANSMITTAL OF THE NYSDEC COMMENTS
ON THE DRAFT REVISED FEASIBILITY STUDY REPORT
FOR OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
10
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | DUDA,DAMIAN (US
ENVIRONMENTAL PROTECTION
AGENCY)
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
-------
ADMINISTRATIVE RECO
11 $nLh
FINAL
08/18/2023
Site Name: LEHIGH VALLEY RAILROAD
CERCLIS ID: NYD986950251
OUID: 02
SSID: 027S
Action:
I
REGION ID: 02
DocID:
Doc Date:
Title:
Image Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
689604
05/18/2023
CORRESPONDENCE REGARDING THE RESPONSE TO
US EPA AND NYSDEC COMMENTS ON THE FEBRUARY
2023 FEASIBILITY STUDY REPORT FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
5
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | DUDA,DAMIAN (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689610
05/22/2023
CORRESPONDENCE REGARDING COMMENTS ON THE
REVISED FEASIBILITY STUDY FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Email
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | DUDA,DAMIAN (US
ENVIRONMENTAL PROTECTION
AGENCY)
689602
06/29/2023
NYSDEC COMMENTS ON THE FEASIBILITY STUDY
SUBMITTED JUNE 15, 2023 FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
2
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(NEW YORK STATE DEPARTMENT OF
ENVIRONMENTAL CONSERVATION)
689615
07/18/2023
US EPA AND NYSDEC COMMENTS ON THE DRAFT
FEASIBILITY STUDY REPORT FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
3
Letter
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
(US ENVIRONMENTAL PROTECTION
AGENCY) | DUDA,DAMIAN (US
ENVIRONMENTAL PROTECTION
AGENCY)
689605
07/27/2023
FINAL FEASIBILITY STUDY REPORT FOR OU2 FOR THE
LEHIGH VALLEY RAILROAD SITE
506
Report
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
689606
07/27/2023
TRANSMITTAL OF THE FINAL FEASIBILITY STUDY
REPORT FOR OU2 FOR THE LEHIGH VALLEY RAILROAD
SITE
1
Letter
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS,
LLC) |TREJO,FRANCISCO (UNICORN
MANAGEMENT CONSULTANTS, LLC)
689616
07/28/2023
CORRESPONDENCE REGARDING REVISED FIGURES
FOR OU2 FOR THE LEHIGH VALLEY RAILROAD SITE
3
Email
(US ENVIRONMENTAL PROTECTION
AGENCY) | JON,MARIA (US
ENVIRONMENTAL PROTECTION
AGENCY)
(UNICORN MANAGEMENT
CONSULTANTS, LLC)
692975
8/17/2023
PROPOSED PLAN FOR OU2 FOR THE LEHIGH VALLEY
RAILROAD SITE
28
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
692975
8/17/2023
PROPOSED PLAN FOR OU2 FOR THE LEHIGH VALLEY
RAILROAD SITE
28
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
689553
08/26/2021
CORRESPONDENCE REGARDING A PATH FORWARD
ON THE FEASIBILITY STUDY REPORT FOR OU2 FOR
THE LEHIGH VALLEY RAILROAD SITE
15
Letter
DUDA,DAMIAN (US ENVIRONMENTAL
PROTECTION AGENCY)
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APPENDIX IV
STATE LETTER OF CONCURRENCE
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Division of Environmental Remediation, Office of the Director
625 Broadway, 12th Floor, Albany, New York 12233-7011
P: (518) 402-9706 I F: (518) 402-9020
www.dec.ny.gov
September 28, 2023
Pat Evangelists, Director
Emergency and Remedial Response Division
U.S. Environmental Protection Agency Region II
290 Broadway
New York, NY 10007-1866
RE: USEPA Record of Decision
Lehigh Valley Railroad Derailment (NYS ID 819014)
LeRoy, Genesee County
Dear Pat Evangelista,
The New York State Department of Environmental Conservation (Department) has completed its
review of the U.S. Environmental Protection Agency's (EPA) Record of Decision (ROD) for Operable
Units (OU) 1 and 2, received on September 21, 2023, for the Lehigh Valley Railroad Derailment
Superfund Site (New York Site ID 819014). The ROD addresses groundwater, bedrock vapor, soil, soil
vapor, and surface water while proposing amendments to the Department's Record of Decision (1997)
for bedrock vapor, soil, and surface water. As noted below, the Department concurs with the selected
remedies for common elements, groundwater, bedrock vapor, soil vapor, soil, and surface water;
however, the Department does not concur with the preliminary remediation goal for soil.
I. The Department concurs with the following:
• Common Elements - Institutional controls (ICs); long-term monitoring of
groundwater, surface water, soil vapor, and indoor air; maintenance of existing
sub-slab depressurization systems; connection to the municipal water supply for
new construction over the groundwater plume (or installation of a point-of-entry
system to be provided by EPA or the responsible party(s));
• Groundwater - Sitewide groundwater monitoring and Technical Impracticability
(Tl) Waiver for the Tl Zone;
• Bedrock Vapor - Alternative 2: ICs and Groundwater Monitoring;
« Soil Alternative 3 - Excavation and off-site disposal (see below regarding the
soil cleanup objective);
• Surface Water Alternative 5 - In-situ treatment of contaminated surface water
with stream bed cover and ICs and monitoring;
• Development of a Site Management Plan;
• Incorporation of green remediation techniques and technologies; and
• Select modifications to the NYSDEC 1997 OU1 ROD:
i. Eliminating ex-situ soil vapor extraction;
/~NEW
i YORK
Department of
Environmental
Conservation
-------
ii. Updating the surface water standard from 11 [jg/L to the current NYSDEC
standard of 40 |jg/L; and
iii. Addressing soil contamination beneath Gulf Road by implementing ICs to
restrict access and to require proper soil management if the roadbed is
disturbed in the future.
II. The Department does not concur with the following:
• Soil Cleanup Objective/preliminary remediation goals - The Department does
not concur with the soil alternative because the Department believes the protection
of groundwater soil cleanup objectives, not the commercial use soil cleanup
objectives, should be utilized to prevent further groundwater contamination from the
remaining contaminated soil. EPA should consider applying the more restrictive
state standard and EPA has not given an acceptable justification for refusing to
apply the standard that New York State would apply at this site. The Department of
Health (DOH) also suggests that EPA consider using the protection of groundwater
soil cleanup objectives. Please see the attached letter from DOH.
The Department appreciates the opportunity to review the ROD for this site. Please feel free to reach
out to the project manager, Jenelle Gaylord, at 518-402-9791 or Jenelle.gaylord@dec.ny.gov with any
questions.
Sincerely,
Andrew Guglielmi - Director
New York State Department of Environmental Conservation
Division of Environmental Remediation
Enclosure
ec: David Harrington, NYSDEC, David.harrinton@dec.ny.gov
Michael Cruden, NYSDEC, michael.cruden@dec.ny.gov
Jeffrey Dyber, NYSDEC, Jeffrey.dyber@dec.ny.gov
Jenelle Gaylord, NYSDEC, Jenelle.gaylord@dec.ny.gov
David Pratt, NYSDEC Region 8, David.pratt@dec.ny.gov
Christopher Budd, NYSDOH, christopher.budd@health.ny.gov
Melissa Doroski, NYSDOH, melissa.doroski@health.ny.gov
Justin Deming, NYSDOH,
Doug Garbarini, Garbarini.Doug.epa.gov
Maria Jon, EPA, Jon.Maria@epa.gov
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KATHY HOCHUL
Governor
CoiT'irss^oner
JAMES ¥, McDCNALD, M.D., M.P.H.
MEGAN E. BALDWIN
Acting Executive Depuc. Coni/iiosicnei
August 16, 2023
Andrew Guglielmi, Director
Division of Environmental Remediation
NYS Dept. of Environmental Conservation
625 Broadway
Albany, NY 12233
Dear Andrew Guglielmi,
We have reviewed the U.S. Environmental Protection Agency's (EPA) August 2023
Proposed Plan for the referenced site to determine whether the remedy is protective of public
health. I understand that human exposures to contamination associated with this site will be
addressed by the remedy as described below.
• Soil: Soil exceeding 6 NYCRR Part 375 soil cleanup objectives for commercial use will
be excavated and properly disposed of off-site. The area will be backfilled using clean,
imported soil and/or stone underlain by a demarcation layer. Future excavations at the
. site will be conducted in accordance with an approved excavation plan to properly
manage human exposures to remaining contaminated soil. While the use of soil cleanup
objectives for commercial use is protective of public health, given the intended use of the
site we recommend that EPA consider using the soil cleanup objective forthe protection
of groundwater.
• Groundwater: For an approximately four-mile trichloroethene (TCE) plume, the remedy
will include a combination of monitoring and institutional controls to prevent exposure to
contaminated groundwater. A long-term groundwater monitoring program will be
implemented to track and to monitor changes in the groundwater contamination to
ensure the RAOs are attained. Use of groundwater at the site, without approved water
quality treatment, will be restricted by an environmental easement placed on the site.
New homes constructed over the groundwater plume will be connected to the current
municipal water supply system or provided with a point-of-entry treatment system (if
connection to the municipal system is not feasible) as needed.
Re: Proposed Plan
Lehigh Valley Railroad
Site #819014
LeRoy, Genesee County
Empire State Plaza, Corning Tower, Albany, NY 12237.health nv.gov
-------
Surface Water: Surface water will be treated in-situ, a streambed cover will be
constructed, and monitoring will be conducted.
• Soil Vapor: Existing sub-slab depressurization systems will be maintained, and new
systems will be installed, as needed.
Periodic reviews will be completed to certify that these elements of the remedy are in
place and remain effective. Based on this information, and with the understanding that
protections will be in place during the remediation to prevent the community from being exposed
to site-related contaminants and particulates, I believe the proposal is protective of public health
and concur with the remedial plan. If you have any questions, please contact me at (518) 402-
0445.
Sincerely,
Cii-iisim > I {-v? i J
Christine N. Vooris, P.E., Director
Bureau of Environmental Exposure Investigation
ec: K. Malone / J. Deming / C. Budd / e-File
A. Bonarnici / C. Nieastro - NYSDOH WRO
D. Brodie-GCHD
M. Grove - LCDQH
S. O'Neii ~ MCDPH
D. Harrington / M. Cruden /' J. Dyber / J. Gaylord ~ NYSDEC Central Office
D. Pratt - NYSDEC Region 8
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APPENDIX V
RESPONSIVENESS SUMMARY
-------
APPENDIX V
RESPONSIVENESS SUMMARY
Table of Contents
Appendix V: Introduction
Summary of Community Relations Activities
Summary of Comments and EPA Responses
Appendix V - Attachment A - Proposed Plan
Appendix V - Attachment B - Public Notice - Batavia News - Commencement
of
Public Comment Period
Appendix V - Attachment C - August 29, 2023 Public Meeting Transcript
Appendix V - Attachment D - Written Comments
-------
RESPONSIVENESS SUMMARY FOR THE
RECORD OF DECISION
LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
LEROY, GENNESSEE COUNTY, NEW YORK
INTRODUCTION
This Responsiveness Summary provides a summary of citizens' comments and
concerns received during the public comment period for the Lehigh Valley
Railroad Derailment Superfund Site (Site) selected remedy as presented in the
Proposed Plan. A Responsiveness Summary is required by the regulations
promulgated under the Superfund statute. This summary also provides the
responses by the U.S. Environmental Protection Agency (EPA) to those
comments and concerns. All comments received were considered in EPA's
selection of the comprehensive remedy covering Operable Units (OUs) 1 and 2
for the Site.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The Remedial Investigation (Rl), Risk Assessment, and Feasibility Study (FS) for
the Site describe the nature and extent of the contamination, identify the risks to
human health and the environment, and evaluate remedial alternatives to
address the contamination, respectively. EPA, in consultation with the New York
State Department of Environmental Conservation (NYSDEC), identified the
preferred remedy and the basis for that preference in an August 2023 Proposed
Plan. These documents, including the Proposed Plan, were made available to
the public in information repositories maintained at the EPA Docket Room in the
Region 2 offices in New York, New York, the Caledonia Public Library in
Caledonia, New York, and the Woodward Memorial Library LeRoy, New York.
The documents were also made available on EPA's website for the LVRR Site
located at www.epa.gov/superfund/lehigh-vallev-rr.
A notice of the commencement of the public comment period, the public meeting
date, a description of EPA's preferred remedy, EPA contact information, and the
availability of the above-referenced documents were published online and in the
Batavia News, a local newspaper, on August 18, 2023. The 30-day public
comment period ran from August 18, 2023 to September 18, 2023.
EPA held a public meeting on August 29, 2023 at 6:00 P.M. at the Caledonia
Mumford High School in Caledonia, New York to discuss the findings of the Rl,
the remedial alternatives in the FS, and the proposed remedy. Fourteen (14)
persons attended the meeting, including federal, state and local governmental
officials, as well as area businesspeople, residents, journalists and
representatives of the Lehigh Valley Railroad Company (LVRR), a potentially
responsible party (PRP) for the Site.
-------
SUMMARY OF COMMENTS AND EPA RESPONSES
A summary of the comments/questions received at the public meeting on August
29, 2023, and those received in writing, as well as EPA's responses to those
comments is provided below. A comment letter was received during the public
comment period from Unicorn Management Consultants, LLC (UMC) on behalf of
the Lehigh Valley Railroad Company (LVRR), a potentially responsible party for
the Site. A copy of the comment letter is provided in Attachment D of this
Responsiveness Summary. EPA's responses to this letter refer to the commenter
as LVRR rather than UMC.
Part 1: Comments Received at the Public Meeting
Comment #1: A local resident made a statement that essentially said his home
was not affected by the Site contamination and that it appears that EPA has
spent enough taxpayer money already on this 1970 spill.
EPA Response #1: EPA has a longstanding policy to pursue "enforcement first"
throughout the entire Superfund cleanup process. Under this policy, EPA seeks,
as appropriate, to find potentially responsible parties to perform response actions
before EPA proceeds with an action funded by the Hazardous Substance Trust
Fund (Fund). This policy promotes the "polluter pays" principle and helps to
conserve the scarce resources of the Fund for the cleanup of those sites where
liable and viable responsible parties do not exist. At the LVRR Site, EPA has
successfully employed this policy for most of the investigations and cleanup work
that has been performed since EPA became the lead agency for the Site nearly
25 years ago. While some taxpayer monies have been spent at this Site, EPA
will pursue recovery of such costs from the PRP.
Comment #2: The same resident also questioned EPA's preferred alternative for
the soil and suggested that moving soil from the LVRR Site to another location is
simply moving the problem, since the soil remains contaminated and poses a risk
to wherever it is moved.
EPA Response #2: The excavated, contaminated soil will be transported off-Site
to a facility licensed to receive such materials. The excavated soil will be
managed under a land disposal permit identified for that specific facility where it
will no longer pose a risk to human health or the environment. The details of
where the contaminated soil will ultimately be moved and how it will be managed
will be determined during the remedial design or RD phase of the project.
Comment #3: The same resident also questioned why it took EPA 30 years to
install the waterline and take care of the most immediate danger to the public.
EPA Response #3: Measures have already been implemented to address the
most immediate threats posed by the contamination at the Site. These measures
included a waterline extension to affected homes, which was successfully
2
-------
implemented in 2003. The remedy selected in this ROD, calls for the connection
of new homes constructed over the groundwater plume to the current municipal
water supply system or the provision of a point-of-entry treatment system if
connection to the municipal system is not feasible.
During 1990 and 1991, in response to public health concerns, EPA installed
point-of-entry carbon treatment units on all contaminated private wells. Following
assuming the role as lead agency on the Site in 1998, EPA continued to work
with the State on the waterline. The waterline was finished in 2003 and
connections were completed in all four of the municipalities that were affected by
the TCE plume (Town of Wheatland, Town of Le Roy, and the Town and Village
of Caledonia). The waterline is currently providing potable water to approximately
70 affected residences and businesses in the area.
Comment #4: The same resident also expressed concerns that LVRR will
declare bankruptcy and the taxpayers will ultimately have to pay the $14 million
for the selected remedy.
EPA Response #4: Since 2006, LVRR has been performing work at the Site, with
EPA oversight, under two different enforcement agreements to complete the
RI/FS and implement the soil portion of the remedy. In addition, LVRR has
reimbursed EPA for all costs EPA incurred overseeing the work. EPA expects to
continue to work with LVRR for the implementation of the ROD remedy for the
Site. In the event of bankruptcy, EPA may pursue certain claims against a PRP
through the bankruptcy process. The obligation to perform the ROD remedy
would not be affected by a bankruptcy.
Part 2: Written Comments Received During the Comment Period
This section presents written comments from LVRR, Dolomite Products
Company, and a local resident received during the public comment period and
EPA's responses to those comments. The comments from LVRR are presented
verbatim and identified in italicized print. For ease of reference, the comment
numbering matches the numbering in LVRR's comment letter.
LVRR Comment #1: The cost to implement the USEPA's Preferred Remedy
($14,082,504) is unreasonable when considering the incomplete risk pathways to
human health and the environment after the installation of the waterline, vapor
intrusion mitigation systems, proposed institutional controls (ICs) and monitoring.
EPA Response #1: LVRR's statement that the risk pathways to human health
and the environment are incomplete is incorrect. The baseline risk assessment
summarizes site risks in the absence of any proposed action or institutional
control. The risk assessment for the Site identified existing complete exposure
pathways for human health and the environment in media of concern in both the
current and future scenarios. While the early response actions taken at the Site
have mitigated certain risks, the risk assessment shows that exposure risks
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remain, which will be addressed by implementation of the selected remedy.
Based on the comparison of the overall effectiveness of the remedy to the cost,
the selected remedy meets the statutory requirement that Superfund remedies
be cost effective in that it represents reasonable value for the money to be spent.
LVRR Comment #2.a: The Preferred Surface Water Remedy ($7,305,550)
proposes the implementation of in-situ treatment of contaminated surface water
with streambed cover, ICs, and monitoring. The Site remedial investigations,
conceptual Site model, and feasibility study identify the technical impracticability
challenges with in-situ treatment of surface water with or without a streambed
cover. These challenges include but are not limited to... [that] it is unlikely that
the in-situ treatment can be effectively dispersed or emplaced within the fractured
bedrock media underneath Mud Creek which acts as a continuing source of TCE
to the groundwater and surface water within the Study Area and Mud Creek Area
of Interest. To implement a surface water in-situ technology would require
extensive knowledge of the fracture networks and connectivity of the seep areas,
which has been determined to be technically impractical when evaluating
remedial options for other media. Even with extensive fracture network
knowledge, successful implementation of in-situ technologies may not be
possible or at best may require trial-and-error installations that may inadvertently
cause new contaminated seeps. Regardless, the in-situ technology will not
address the TCE source (bedrock microfractures and pore spaces) to surface
water.
EPA Response to #2.a: When restoration of groundwater to beneficial uses is not
practicable, EPA selects an alternative remedial strategy that is technically
practicable, protective of human health and the environment, and satisfies
statutory and regulatory requirements of CERCLA. Consistent with the National
Contingency Plan (NCP), alternative remedial strategies for Technical
Impracticability (Tl) sites typically address three site concerns: 1) exposure
control; 2) source control; and 3) aqueous plume migration control. Surface water
data collected during the Rl were used to perform a human health risk
assessment for this medium. As demonstrated in the human health risk
assessment, recreational exposure to surface water in Mud Creek resulted in
noncancer hazards above EPA's threshold of 1. Concentrations in surface water
are significantly above the surface water standard of 40 ug/L for TCE as a result
of groundwater contamination migrating from the Spill Zone and daylighting in
Mud Creek. TCE at these levels indicate that the source area groundwater is
migrating. In order to fully address and meet the conditions for a groundwater Tl
waiver, a remedy for surface water is required.
Further, there is sufficient information for EPA to select the surface water
component of the remedy. After thoroughly reviewing all the surface water
alternatives, EPA has determined that the surface water component of the
selected remedy - In-situ Treatment with Streambed Cover Alternative - will
provide protection through both a containment mechanism and a treatment
4
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process and achieve the remediation goal of 40 |jg/L for TCE, while also
satisfying CERCLA's statutory preference for treatment.
The FS, prepared by LVRR and reviewed and approved by EPA, did not evaluate
the technical impracticability of EPA's surface water remedy. Rather, the FS
acknowledged some challenges associated with the surface water alternatives
and anticipated a Preliminary Design Investigation (PDI) as part of each
alternative in order to refine certain assumptions and provide additional data to
aid in the remedy design. PDIs are frequently conducted at Superfund sites to
provide additional information, including additional sampling and treatability
studies, needed to aid in RD. They can include the collection of surface water
data that would be representative of fluctuations in concentrations, evaluation of
appropriate amendments through treatability studies, and refinement of the
location and configuration of potential treatment areas. EPA believes the
challenges referenced by LVRR in its letter will be appropriately addressed
during the development and implementation of the PDI and the RD.
The in-situ treatment approach can be refined in the PDI and the RD. Further
information on the fracture networks and connectivity of the seep areas can be
obtained during the PDI. The statement that knowledge of the fracture networks
and connectivity of the seep areas has been determined to be technically
impracticable is incorrect. Methods exist to refine the location of seeps and gain
the required information to design the in-situ surface water remedy.
LVRR Comment #2.b: Fouling of in-situ treatment points, associated fractures,
and seeps may occur and can result in the inadvertent daylighting of
contaminated groundwater at previously uncontaminated seep locations following
a path of least resistance. Also, the treatments for fouling typically use acidic
solutions to dissolve precipitates. The applications of these fouling treatments
may negatively alter surface water characteristics.
EPA Response to #2.b: The potential for fouling of in-situ treatment points,
associated fractures, and seeps is typically addressed during remedial design.
Additional sampling in the PDI can be used to further understand the
geochemistry of the groundwater and surface water in the area targeted for
treatment and an appropriate treatment approach and routine maintenance plan
can be designed to address these potential challenges.
LVRR Comment #2.c: It will be challenging to achieve remediation goals if the
location, orientation, and hydraulic conductivity of the fractures and other
subsurface flow paths that may be contributing to the flows and seeps are
technically impracticable to identify. Also, it will be challenging to achieve
remediation goals if the water flow is too high/turbulent to allow for appropriate
contact time with media.
EPA Response to #2.c: The location, orientation and hydraulic connectivity of
flows and seeps contributing contaminated groundwater to the surface water
5
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area of interest can be refined with existing technologies. The RD will take into
consideration the fluctuations in stream levels and flow over time.
LVRR Comment #2.6: The routine maintenance and repair of the in-situ
technology beneath or within proximity to the streambed cover could prove
challenging especially during precipitation and/or flooding events that occur in the
vicinity and upgradient/upstream of the Mud Creek Area of Interest.
EPA Response to #2.6: The RD may have some complex components but is
implementable. The remedial design will take into consideration the fluctuations
in stream levels and flow over time to arrive at the most appropriate in-situ
treatment approach. If applicable, water level indicators and automatic shut off
controls can be incorporated into the design to account for high precipitation
events.
LVRR Comment #2.e: The preferred surface water remedy would include the
clearing of vegetation and trees, construction of access roads, installation of in-
situ treatment infrastructure and other support structures within and in the vicinity
of the streambed, excavation of the streambed associated with the in-situ
treatment, establishment of power source and backup power source, etc.
EPA Response to #2.e: The impacts of the various aspects of the surface water
remedy identified in this comment, were considered in the discussion of the
proposed alternative and will be further addressed during the RD and
implementation of the remedy. Furthermore, other alternatives considered in the
FS, including Surface Water Alternative 4, Streambed cover with ICs and
monitoring, as recommended by LVRR (see LVRR Comment #2.g, below),
require the clearing of vegetation and trees, construction of access roads for
transport of materials and equipment, for temporary on-Site storage of equipment
necessary for the installation of this remedial alternative. With respect to the
establishment of power source and backup power source, a temporary portable
generator can be brought to the Site during the construction period, which is a
common practice at construction sites where there is no utility power or
permanent utility power has not been installed.
LVRR Comment #2.f: TCE data from surface water samples that have been
collected at various locations along Mud Creek show a 50% decrease in TCE
concentrations after only flowing 200 feet along the creek bed (Mudcreek-03 to
Mudcreek-02). These data and observations suggest that the surface water
flowing along the streambed of Mud Creek is subjected to natural degradation
processes that likely include aeration, volatilization, and/or dilution. Turbulent
flow along the streambed has been observed due to the presence of rocks in the
streambed that create obstacles to the natural flow of surface water which
promotes volatilization and likely accounts for the significant reduction of TCE in
downstream surface water samples from the Mud Creek Falls to below 40 jjg/L
(remedial goal) at the southern inlet to Mud Creek Pond. The streambed cover
alone could help to enhance the natural process by creating more obstacles for
6
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surface water flow while minimizing changes to the chemistry of Mud Creek and
maintaining a low carbon footprint over time.
EPA Response to #2.f: There is an unacceptable exposure in the Mud Creek
surface water as determined by the risk assessment. The selected remedy
includes treatment of contaminants by the installation of an in-situ treatment
system to mitigate this exposure. Natural degradation, as presented by LVRR in
its comment 2.f., is not a protective remedial approach because it will not reliably
prevent exposure and will not address contaminant migration from the Spill Zone
to Mud Creek.
LVRR Comment #2.g: A pre-remedial design investigation will not change the
fact that it is technically impractical to obtain extensive knowledge of the fracture
networks and connectivity of the seep areas with current technology or to
anticipate precipitation events within the areas contributing to the fluxes of
allogenic water into the Mud Creek area of interest (approximately 484 million
gallons per month).
UMC respectfully requests the USEPA to review the above comments and
consider the Surface Water Alternative 4, Streambed cover with ICs and
monitoring, as the preferred USEPA surface water remedy."
EPA Response to #2g: An exhaustive knowledge of the fracture networks is not
necessary to implement the selected surface water remedy. Technologies exist
to define areas where groundwater is discharging to surface water. The remedial
design will take into consideration the fluctuations in stream levels and flow over
time to arrive at the most appropriate in-situ treatment approach. If applicable,
water level indicators and automatic shut off controls can be incorporated into the
design to account for high precipitation events.
Dolomite Comment: A representative of the Dolomite Products Company
(Dolomite) stated that the company was never permitted to connect to the
waterline or public water supply, which was installed in 2003, despite the
company's proximity to the original spill area.
EPA Response to Dolomite: The waterline was constructed following NYSDEC's
1997 Record of Decision, which EPA concurred upon in 1998. The connection of
affected properties to the waterline was undertaken by NYSDEC and the New
York State Department of Health (NYSDOH). According to NYSDEC, it installed
a new well with a granular activated carbon (GAC) system for Dolomite in 2003
and maintained the system until September 2005, despite Dolomite being located
upgradient of the Site and the associated groundwater contamination. While
NYSDOH determined that the water at Dolomite was safe for consumption,
NYSDEC recommended that the treatment system remain in place in the event
of future contamination from Dolomite itself or from remedial activities associated
with the Site. EPA believes that the remedy selected in the ROD will not
negatively impact the quality of water in the Dolomite well and suggests
7
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contacting the Town of LeRoy for further information on connecting to the public
water supply system if that is desired.
Resident Comment: One resident was concerned about recent soil disturbances
near the original spill location and questioned whether this was the result of any
work that is being undertaken by EPA or NYSDEC.
EPA Response to Resident: Neither EPA, NYSDEC nor any authorized entity
has conducted any work in the Spill Zone in recent months. EPA will investigate
this situation and contact the resident in the near future.
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ATTACHMENT A
PROPOSED PLAN
-------
Superfund Proposed Plan
U.S. Environmental Protection Agency, Region 2
Lehigh Valley Railroad Derailment Superfund Site
LeRoy, New York
August 2023
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan describes remedial alternatives that
the United States Environmental Protection Agency
(EPA) considered to address contamination in the
groundwater, soil, bedrock, soil vapor and surface water
associated with the Lehigh Valley Railroad Derailment
Superfund Site (the Site), including the source of the Site
contamination located in the Town of LcRoy. Genesee
County. New York, as well as groundwater
contamination in Genesee. Monroe, and Livingston
Counties, and also identifies the preferred remedial
alternative for all media along with the rationale for the
preference.
This Proposed Plan describes EPA's preferred
comprehensive remedy for two operable units (OlJs) or
cleanup phases for the Site. The Proposed Plan proposes
an amendment to a portion of the original OU 1 remedy,
associated with contamination in soil and bedrock in
specific areas of the Site. It also proposes a remedy for
OU2 for the four-mile groundw ater plume contaminated
with trichloroethene (TCE) where contaminated
groundwater discharges to surface water and
contaminated soil vapors previously impacted indoor air
as a result of soil vapor intrusion in properties located in
areas of groundwater contamination at the Site.
This Proposed Plan was developed by EPA. the lead
agency for the Site, in consultation with the New York
State Department of Environmental Conservation
(NYSDEC), the support agency. EPA is issuing this
Proposed Plan as part of its public participation
responsibilities under Section 117(a) of the
Comprehensive Environmental Response.
Compensation, and Liability Act of 1980 (CERCLA.
also know n as Superfund). as amended, and Sections
300.430(f) and 300.435(c) of the National Oil and
Hazardous Substances Pollution Contingency Plan
(NCP).
The nature and extent of contamination at the Site and
the remedial alternatives summarized in this Proposed
Plan are further described in the 2014 Remedial
Investigation OU2 (Rl) Report, the 2023 Feasibility
Study (FS) Report and the 2019 Assessment of
Groundwater Restoration Potential and Technical
Impracticability (AGTI) Report, as well as other
documents in the Administrative Record file for the Site.
EPA encourages the public to review these documents to
gain a more comprehensive understanding of the Site, the
Superfund activities that have been conducted there, and
the preferred remedial alternative that is being proposed.
MARK YOUR CALENDAR
Public Comment Period:
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COMMUNITY ROLE IN SELECTION PROCESS
The purpose of this Proposed Plan is to inform the public
of EPA's Preferred Remedial Alternative and to solicit
public comments, pertaining to all the remedial
alternatives evaluated in the FS, including EPA's
Preferred Alternative. EPA's final decision regarding the
selected remedy will be made after EPA has taken into
consideration all public comments.
A public meeting will be held during the public
comment period to present this Proposed Plan and
information regarding the investigations at the Site and
to receive public comment. Some investigative
information, including the conclusions of the various
studies that were performed to assess treatment options,
to elaborate on the reasons for proposing the Preferred
Remedial Alternative and to receive comments from the
public. Information on the public meeting and how to
submit written comments can be found in the above-
noted "Mark Your Calendar" text box.
Comments received at the public meeting, as well as
written comments received during the comment period,
will be addressed and documented in the Responsiveness
Summary section of the forthcoming OU2 Record of
Decision (ROD) and OU1 ROD Amendment. The ROD
is the document that memorializes the alternative that
has been selected as a remedy and the basis for the
selection of the remedy.
SCOPE AND ROLE OF ACTION
Site remediation activities are sometimes segregated into
different phases or operable units (OUs), so that
remediation of different, discrete environmental media
or geographic areas of a site can proceed separately,
whether sequentially or concurrently. EPA has
designated two OUs for the Site. OU1 addresses the
provision of an alternate water supply to area residences
and businesses that have been or have the potential to be
impacted by the LVRR contaminated groundwater
plume, as well as contamination within the Spill Zone,
present in soil and extending into the bedrock. OU2
addresses the approximately four-mile contaminated
groundwater plume, contaminated groundwater
discharging to surface water, as well as contaminated
vapors that may migrate into residences as a result of
soil vapor intrusion.
In March of 1997, prior to the Site being proposed for
listing on the National Priorities List (NPL), NYSDEC
selected a remedy for the Site which included: 1) the
installation of a waterline to provide potable water to
approximately 70 affected residences and businesses near
the Site; 2) the installation of an in-situ bedrock vapor
extraction (BVE) system within a 10-acre dense
nonaqueous phase liquid (DNAPL) zone (Spill Zone); and
3) ex-situ soil vapor extraction (SVE) of approximately
10,000 cubic yards of TCE-contaminated soil. In July of
1999, following the January 1999 final listing of the Site
on the NPL, EPA concurred with the waterline component
of the NYSDEC remedy, and, subsequently, in May 2002,
concurred with the BVE and SVE components of the
NYSDEC remedy.
The waterline component of the selected remedy was
successfully implemented in 2003. However, as explained
in more detail in the Site History section below, the
components of the remedy addressing contaminated soil
and bedrock have not been successfully implemented.
This Proposed Plan contemplates a comprehensive remedy
for the Site through both a ROD amendment for OU 1 and
ROD for OU2, which would comprise the final
comprehensive remedy for the Site.
SITE BACKGROUND
The Site is located in Genesee, Monroe and Livingston
Counties, New York, in a rural setting. The surrounding
area is used for residential, recreational, and commercial
purposes. The Site is generally divided into two areas of
interest, the Spill Zone and Study Area, which are both
shown on Figure 1.
The Spill Zone is approximately 10 acres in size and is
defined as the physical location of the 1970 train
derailment which resulted in contamination of overburden
soils and bedrock with TCE, in the vicinity of the former
LVRR crossing at Gulf Road. The Spill Zone also
includes a former railroad bed, a former quarry material
staging area, and the foundation of a former hotel.
Currently, the 10-acre Spill Zone is mostly undeveloped
industrial, commercial, residential, and passive
recreational land, largely covered with grass, brush, and
wooded areas.
The larger Study Area is roughly bounded by the Oatka
Creek Valley to the north, the Dolomite Quarry and
Hanson Quarry to the west, Route 5 to the south, and
Spring Creek Valley to the east. The Study Area includes
a TCE-impacted groundwater plume emanating from the
Spill Zone which extends eastward approximately four
miles to Spring Creek. Mud Creek, an area of interest, is a
frequently dry stream bed which carries substantial water
2
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flow during flood events and is located approximately
600 feet (ft) to the east of the Site.
According to EPA's EJSCREEN, there are no
demographic indicators for the area that would indicate a
community with environmental justice concerns.
Therefore, it is not anticipated that implementation of
the proposed action will result in adverse impacts to
environmental resources that would affect low income,
minority populations living within the vicinity of, or
using, the Site.
Site History
The Site is the location of a former train derailment that
occurred on December 6, 1970, at the Gulf Road railroad
crossing in the Town of LeRoy. The train, operated by
the potentially responsible party (PRP), Lehigh Valley
Railroad Company, derailed, and two tank cars
containing trichloroethene (TCE) ruptured and spilled
their contents (estimated 30,000 gallons) onto the
ground. This area is referred to as the 10-acre Spill Zone.
TCE is the primary contaminant of concern (COC) and
is a chlorinated volatile organic compound (VOC),
commonly used as a solvent. A third car containing a
crystalline form of cyanide was also reported to have
partially spilled. The cyanide was recovered shortly after
the derailment; however, the TCE infiltrated into the
ground and was not recovered.
In early 1971, residents near the Site complained of TCE
odors in homes and reported contamination of nearby
drinking water wells. The PRP conducted limited
cleanup activities at the spill location in response to the
residents' concerns. Ditches were constructed in the
Spill Zone and were flooded with water to flush the TCE
out of the ground. Carbon filters were installed on
several private wells to remove TCE from drinking
water.
In 1990 and 1991, the New York State Department of
Health (NYSDOH) sampled private water wells east of
the Site and discovered TCE concentrations in more than
35 residential wells above the NYSDOH drinking water
standard of 5 micrograms per liter ((.tg/L). Based on this
information, EPA installed point-of-entry carbon
treatment units on all contaminated private wells. In
November 1991, the Site was added to the New York
State (NYS) Registry of Inactive Hazardous Waste
Disposal Sites.
In 1992, NYSDEC initiated a remedial investigation and
feasibility study (RI/FS) at the Site. NYSDEC completed
the RI Report in 1996, and two FS Reports in early
1997. The NYSDEC RI found TCE concentrations in soil
ranging from 46 to 840,000 micrograms per kilogram
(fig/kg) and that a source of TCE contamination remained
in the unsaturated soil and bedrock in the Study Area, the
nearby surface water, and the groundwater with a plume
extending almost four miles east and southeast of the Spill
Zone.
As noted above, in 1997, prior to the Site being listed on
the NPL, NYSDEC selected a remedy for the Site which
included ex-situ SVE and in-situ BVE as source-control
measures, and a waterline extension to provide a potable
water supply to affected residents and businesses.
On August 7, 1998, NYSDEC requested that EPA approve
its ROD and assume responsibility for the source-control
components of the remedy. At the same time, the State
agreed to continue its work on the waterline component of
the selected remedy.
The waterline component of the remedy was completed by
NYSDEC in 2003. The carbon treatment units installed on
all affected domestic wells were removed and the
properties were connected to the waterline. The waterline
connections were completed in all four of the
municipalities that were affected by the TCE plume
(Town of Wheatland, Town of LeRoy, and the Town and
Village of Caledonia). The waterline is currently
providing potable water to approximately 70 affected
residences and businesses in the area.
In September 2006, EPA signed an Administrative
Settlement Agreement and Order on Consent with LVRR
requiring the company to undertake certain investigations
and design work needed for an SVE system. The
investigations focused on determining the extent of the
groundwater contamination and investigating whether
vapors from the groundwater were affecting homes above
the plume. LVRR was also required to install systems to
vent vapors at the homes if vapor intrusion was found to
be an issue.
WHAT IS M 1.1)1.1) l() MAM. A (OMPI.I. I I. VAPOR
I YI'RI SION PATIIWAV."
In order lor a vapor intrusion pathway to be complete, there
must be volatilization of contaminants from contaminated
groundwater or other subsurface sources through the vadose
/one. i.e.. above the water table, to the soil vapor underneath a
structure (i.e.. sub-slab soil vapor). These contaminants can then
migrate through the sub-slab into indoor air. Contaminant vapors
move from an area of higher concentration to an area of lower
concentration. The vapor intrusion pathway is complete when
Site-related contaminants migrate into indoor air where vapors
may be inhaled.
3
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Starting in 2008, measures were initiated to protect
property owners from exposure to vapors arising from
contamination in groundwater volatilizing into soils and
subsequently into residences, a process known as soil
vapor intrusion. To date, more than 35 properties have
been sampled to determine if contamination has
migrated into indoor air. As a result of the sampling,
sub-slab depressurization systems (SSDSs) were
installed in 12 homes to mitigate potential exposures
associated with soil vapor intrusion (SVI).
On March 21, 2014, EPA issued an Administrative
Order to LVRR for the remediation of soil using SVE.
The in-situ SVE system was installed and became
operational during July 2015. The SVE system operated
continuously in the Spill Zone for two years until it was
shut down in July 2017. Despite removing over 284
pounds of VOCs, the post-SVE data indicated that
cleanup goals had not been achieved. The residual
concentrations above cleanup goals were likely
associated with rock fines present in the overburden
materials that are highly diffused into the rock matrix.
EPA determined that continued SVE cleanup would not
attain cleanup levels or accomplish RAOs.
A BVE pilot study was performed by NYSDEC in 1999.
The NYSDEC's pilot study indicated that, while there
were uncertainties, ex-situ SVE and in-situ BVE should
be effective in achieving the soil cleanup objectives
(SCOs) in the State ROD. LVRR agreed to conduct pre-
remedial design investigations while undertaking the
remedial design of the SVE system and the groundwater
RI/FS. LVRR pursued additional evaluations of the
feasibility of BVE, as documented in reports from 2011
through 2014, a BVE Memorandum in 2018 and a
focused BVE Report in 2019. The potential
effectiveness of BVE, given additional information
gained during the RI/FS process, was discussed at length
throughout this period into 2023. Based upon review of
the results of the pilot study and subsequent evaluations,
EPA has concluded that given the nature of the vadose
zone (bedrock) and the large fluctuations in groundwater
levels found at the Site, as well as the size, migration,
and location of the TCE mass (diffused into the saturated
and unsaturated bedrock), implementation of BVE
would not remove enough mass to result in significant
improvement of contamination in the bedrock or
groundwater. This decision is discussed in further detail
below as it relates to the bedrock vadose zone (BVZ)
alternatives. The BVZ is defined as the portion of
subsurface bedrock media that is the zone above the
water table which fluctuates up to 40 ft seasonally and
may be influenced by pumping from the adjacent quarry
typically from approximately May 1st through January 1st
each year; and that is generally located within the
immediate vicinity of the Spill Zone. Typically, a portion
of the BVZ that is unsaturated exists from 0-25 ft below
ground surface (bgs) with a portion of the BVZ that is
seasonally saturated between 25 - 70 ft bgs.
SITE CHARACTERISTICS
Site Topography, Geology and Hydrogeology
The Site is located in the Allegheny Plateau Physiographic
Province in western New York. The northeastern portion
of the Study Area slopes downward toward the northeast
and Mud Creek. East of the Spill Zone, the topography
slopes generally downward toward Spring Creek along an
undulating surface. North of Gulf Road/Flint Hill Road,
the topography slopes downward to the north toward
Oatka Creek. The southeastern portion of the Spill Zone
slopes downward to the east and southeast to Mud Creek.
The western section of the Spill Zone is generally higher
in elevation and contains piles of quarried rock debris,
remnant of historical quarrying activities in the area.
The major surface drainage feature at the Site includes
Oatka Creek, which generally defines the northern
boundary of the Site. Mud Creek, a seasonal tributary of
Oatka Creek, flows from south to north through the
western portion of the Site and hydraulically
downgradient of the Spill Zone. Other seasonal surface
water features are generally defined by the west-to-east-
oriented NYS Route 5. South to north-flowing Spring
Creek (a tributary of Oatka Creek) generally defines the
eastern-most distal end of the TCE plume with monitoring
wells beyond that define the eastern-most portion of the
Site.
The geology of the Site area generally consists of
unconsolidated overburden material, underlain by glacial
till (matrix of fine to coarse grained gravel and sand and
clayey silt) and glacial fluvial deposits underlain by
sedimentary bedrock dipping gently to the south. In the
eastern portion of the Site, overburden materials are
underlain by weathered limestone bedrock. However,
along Spring Creek, bedrock was encountered at depths,
considerably deeper than in borings advanced west of
Spring Creek. Over most of the Study Area, the Onondaga
Formation is the upper most rock unit, dipping gently to
the south. However, in the northern and eastern portions
of the Study Area, some formations are exposed north and
east of an erosional line resulting in an erosional surface
sloping north and east into the Oatka Creek and Spring
Creek drainages.
4
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Owing to the predominantly carbonate/dolomite nature
of the bedrock, the Study Area is characterized by
karstic features, including sinkholes, swallets, and
sinking streams, as well as numerous springs/seeps along
Oatka Creek, Mud Creek, and Spring Creek. The karstic
nature of the Study Area bedrock has a dramatic effect
on the overall hydrogeology of the area and TCE-
impacted groundwater transport mechanisms, including
documented groundwater elevation fluctuations of up to
50 ft or more over short time periods.
Conceptual Site Model
The conceptual site model or CSM is based on data
collected during Site investigation activities and
remedial activities and integrates information on
geology, hydrogeology, source areas and receptors.
Sources
As discussed earlier, the 1970 train derailment resulted
in approximately 30,000 gallons of TCE and one ton of
cyanide crystals being released into the Spill Zone.
Immediate cleanup of the spill included the removal of
cyanide crystals and the spreading of neutralizers to
counteract the effects of any remaining cyanide that
could not be removed. TCE released by two ruptured
tank cars could not be recovered at the time of the
derailment and ultimately migrated into the ground and
groundwater. Figure 3 illustrates the extent of the TCE
contamination in groundwater.
Since the spill, remedial actions were taken to remove
the TCE contamination from the Site with limited
success. While the extent of the plume boundary is near
steady state, the presence of TCE within the bedrock
continues to be a long-term source of contamination.
The current source for the dissolved-phase TCE is
contamination located in the bedrock matrix porosity,
microfractures and matrix pore spaces above and below
the water table. Even though Site contaminants were
released as DNAPL, it was not observed during the
installation and sampling of groundwater monitoring
wells during the RI.
Nature and Extent of Contamination
TCE is the principal contaminant of concern at this Site.
Many groundwater, surface water, soil and sediment
samples were collected at the Site to characterize the
nature and extent of contamination. The following
summarizes the results of Site investigations conducted
by the NYSDEC in 1990 and LVRR from 2008 through
2015:
• Soil sampling activities were conducted in the
Spill Zone. The sampling included the collection
of approximately 250 soil samples from a total of
174 test borings. Analysis of 28 of the samples
detected TCE at concentrations ranging between
7.6 and 460 milligrams per kilogram (mg/kg),
exceeding NYSDEC Soil Cleanup Objectives.
• Groundwater samples collected from monitoring
wells located in the Spill Zone ((DC-01, DC-02,
DC-05, DC-15, DC-16, LVRR-35 and LVRR-36)
detected TCE at levels ranging from 450 - 4,400
(ig/L, exceeding the drinking water standard of 5
l-ig/L-
• Wells immediately downgradient of the Spill
Zone (DC-03, DC-06, DC-17, LVRR-20, LVRR-
34, and LVRR-37) detected TCE at levels ranging
from 40 - 760 (ig/L.
• Groundwater samples collected from
downgradient monitoring wells located by Spring
Street (DC-13, DC-14, GCM, LVRR-22, and
LVRR-23) detected TCE at levels ranging from
non-detect or ND - 11 (ig/L, slightly exceeding
the drinking water standard of 5 (ig/L.
• Groundwater samples collected from
downgradient monitoring wells located East of
Spring Creek (LVRR-38, LVRR-39, LVRR-40,
LVRR-41, and LVRR-42) detected TCE at an
estimated concentration of 0.27 jj.g/1 in well
LVRR-38C. Analysis of the remaining
groundwater samples collected from wells east of
Spring Creek did not detect TCE in concentrations
exceeding laboratory reporting limits.
Mud Creek, a seasonal tributary of Oatka Creek, flows
from south to north through the western portion of the Site
and hydraulically downgradient of the Spill Zone. TCE
was detected at 320 jj.g/1 in surface water samples
collected at the Mud Creek area, including the waterfall
and downstream of the waterfall at 380 jj.g/1. These TCE
concentrations exceed the NYSDEC Class C surface water
quality standard of 40 j^ig/L. Additionally, natural
volatilization, as well as the rapid rise in the water table
displaces TCE-impacted vapor and pushes it upward. This
phenomenon results in periodic TCE-impacted VI into
residences in down-plume areas.
The DNAPL likely reached a stable position within a
relatively short period after the release occurred and then
began to dissolve into groundwater that was flowing
through fractures in the rock matrix and diffusing into
5
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pore spaces within the rock matrix. The TCE mass is
essentially immobile relative to the flow of groundwater
in the fractures, and back diffusion of contamination
provides a long-term source of contamination to the
groundwater in the fractures.
Dissolved TCE in groundwater moves eastward with the
regional groundwater flow. The groundwater flow also
has a vertical component where deeper geologic
formations are also impacted by TCE. As groundwater
moves eastward it discharges into springs near Oatka
Creek and at Spring Creek which manifest themselves as
ponds or wetlands south of the Oatka Creek channel.
Currently, the majority of the TCE mass is located in the
rock matrix, in micro fractures and in pore spaces above
the saturated zone dissolved into pore space
groundwater, sorbed onto the bedrock, or as vapors. The
diffusion of TCE into and out of the rock matrix occurs
dynamically within the entire plume (present day and
historic) both in the saturated and vadose zones during
times of high water. This process has been documented
in the AGTI report from the Spill Zone approximately 2
miles eastward to Limerock Road. As such, the rock
matrix provides a continuous source of TCE impacts to
groundwater via back diffusion. This occurs when
groundwater in the fractures has TCE concentrations that
are lower than those in the adjacent bedrock matrix. This
is the cause of long-term plume persistence despite the
depletion of DNAPL within the Spill Zone. While
diffusion processes have been beneficial in causing
strong attenuation of the TCE plume and in reducing
mass discharge to surface water, it also presents an
impediment to plume cleanup in a reasonable timeframe.
The AGTI proposed a variety of remedial alternatives
(bedrock vapor extraction, in-situ thermal desorption,
groundwater extraction and treatment and subsurface
barrier or other in situ injection scenario) and concluded
that the restoration of groundwater to its most beneficial
use is not technically practical within a reasonable
timeframe.
In addition to field data and observations, a Discrete
Fracture Network (DFN) model was created, to
understand how the various processes controlling plume
behavior interact to result in the observed (and
interpolated) plume configuration and behavior over
various time and distance scales.
The modeling indicates that even complete removal of
TCE mass from the Spill Zone or from other areas of the
overall plume footprint, will not restore groundwater to
its most beneficial use or eliminate risk to human health
or the environment within any reasonable timeframe.
However, TCE concentrations within the plume and
WHAT IS ROCK MATRIX DIFFUSION?
A highly interconnected fracture network such as the
Onondaga Formation provides a relatively large surface area
for VOCs to sorb onto and then diffuse, or move, into the
pore spaces in the rock itself- a process known as matrix
diffusion. The pore volume of the rock matrix at the site is
nearly two orders of magnitude larger than the fracture
network, allowing it to hold the majority of the contaminant
mass. Once the VOCs diffuse into the rock, they are left
nearly immobile because of the low hydraulic conductivity
of the rock matrix.
In the early stages after a release, diffusion into the matrix
can slow the advance of the dissolved plume through the
fractures. At first, the diffused mass penetrates only a short
distance into the bedrock, but in cases with very large initial
DNAPL releases (as at the L VRR site), matrix diffusion can
drive high VOC concentrations until it fully penetrates the
matrix block. This effect more commonly occurs in source
areas, where aqueous mass concentrations are highest and
the residence time is the longest.
After a significant period of time (e.g., 50 years) in the
fractured bedrock environment, contaminant mass that has
moved into the rock matrix, will be higher in concentration
than the groundwater within the fractures. At this point, the
process of matrix diffusion will reverse, (this is known as
back diffusion), slowly releasing the mass in the rock matrix
pore water back to the fractures. Back diffusion occurs
slowly over a very long period of time (usually in multi-
century timeframe). So while contaminant movement
through a bedrock aquifer can be retarded or slowed down
by diffusion into the rock matrix, this same process is a
major limiting factor in effective remediation due to the
slow back diffusion process.
downgradient discharges to surface water will continue to
decline due to natural processes.
SUMMARY OF SITE RISKS
As part of the RI/FS for the Site, a baseline risk
assessment (BRA) and a supplemental risk evaluation for
soil were conducted to estimate the current and future
effects of contaminants on human health and the
environment. A BRA is an analysis of the potential
adverse human health and ecological effects of releases of
hazardous substances from a site if no actions to mitigate
such releases are taken, under current and future land and
groundwater uses. The BRA includes a human health risk
assessment (HHRA, 2016) and a screening-level
ecological risk assessment (SLERA). In 2021, EPA
conducted a soil risk evaluation that supplemented the
baseline risk assessment for the Site.
6
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In the HHRA, cancer risk and noncancer health hazard
estimates are based on current reasonable maximum
exposure (RME) scenarios and were developed by
taking into account various health protective estimates
about the concentrations, frequency and duration of an
individual's exposure to chemicals selected as
contaminants of potential concerns (COPCs), as well as
the toxicity of these contaminants. The RME is intended
to estimate a conservative exposure scenario that is still
within the range of possible exposures.
A four-step human health risk assessment process was
used for assessing site-related cancer risks and
noncancer health hazards. The four-step process is
comprised of: Hazard Identification of COPCs,
Exposure Assessment, Toxicity Assessment, and Risk
Characterization (see text box titled "What is Risk and
How is it Calculated" for additional explanation of these
terms).
Human Health Risks
The current land use at the Site, including the
approximate 10-acre Spill Zone and the resultant 4.1-
mile plume, designated as the Study Area, is mixed use,
including residential, recreational, agricultural, and
commercial/industrial. Future land use is expected to
remain the same. The identification and selection of
potential receptor populations was based on both current
and potential future land uses of the Site. Media of
concern evaluated in the 2016 HHRA included
groundwater, as well as surface water and sediments in
nearby Mud Creek, Oatka Creek and Spring Creek. As
such, the following receptor populations and pathways
were quantitatively evaluated in the 2016 HHRA:
• Future Resident (Adult/Child)- Ingestion of
groundwater as drinking water, dermal contact
with groundwater while bathing or showering,
and inhalation of VOCs released during bathing
or showering.
• Future Commercial/Industrial Worker- Ingestion
of groundwater as drinking water and dermal
contact while hand washing.
• Current/Future Construction/Utility Worker-
Incidental ingestion of and dermal contact with
shallow groundwater in a trench, and inhalation
of vapor phase chemicals released from
groundwater to a confined space (trench).
• Current/Future Recreational User
(Adult/Adolescent/Child)- incidental ingestion
of and dermal contact with surface water and
sediment while wading or swimming in Mud,
Oatka, and Spring Creeks.
In 2021, to supplement the HHRA, EPA conducted an
additional risk evaluation for residual TCE source in the
Spill Zone soils post-treatment with a SVE system.
Residual TCE contamination in the Spill Zone is present
on land zoned industrial; therefore, the following receptor
populations and pathways were evaluated:
• Current/Future Commercial Worker- incidental
ingestion and inhalation of soil particulates
released from Spill Zone soils; and
• Current/Future Construction Workers - incidental
ingestion and inhalation of soil particulates
released from Spill Zone soils.
Two types of toxic effects were evaluated for each
receptor in the risk assessments: carcinogenic effects and
non-carcinogenic effects. Calculated risk estimates for
each receptor were compared to EPA's target threshold
values for carcinogenic risk of 1 x 10"6 (one-in-one
million) to 1 x 10"4 (one-in-ten thousand) and calculated
hazard index (HI) to a target value of 1.
Summary of HHRA Results
This section provides a summary of the conclusions of the
HHRA documents (both the 2016 HHRA and 2021
supplemental soil risk evaluation) per media. The bolded
values in Tables 1 through 3 highlight the cancer risk and
noncancer hazards estimates that exceed EPA's threshold
criteria for site-related contaminants. Further, media
specific COCs were identified in instances when the
threshold criteria were exceeded. A complete discussion
of the exposure pathways and estimates of risk can be
found in the final 2016 HHRA and 2021 supplemental risk
evaluation which are available in the administrative record
for the Site.
> Groundwater
Risk and hazards were evaluated for current and future
exposure to contaminated groundwater beneath the Site.
The populations of interest included the following
receptors: Future child and adult residents, future
commercial/industrial worker and current/future
construction/excavation worker. As summarized in Table
1 below, the hazard indices for the child resident (12,000),
adult resident (7,000), commercial/industrial worker (19)
and construction/excavation worker (3.1) exceeded EPA's
threshold value of 1. In addition, the combined cancer risk
estimates for the child an adult resident of 3.7 xlO"2 and
that of a commercial/industrial worker of 1.6 xlO"4
exceeded EPA's threshold range of 1 x 10"6 to 1 x 10"4. TCE
in groundwater was the main contaminant driving
unacceptable risk and hazard estimates.
7
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WHAT IS RISK AM) MOW IS ITCAI.Cl I.ATED?
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 releases under current - and anticipated 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 chemicals 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 late 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
identified in the previous step are evaluated. Kxamples of exposure
pathways include incidental ingestion of and dermal contact with
contaminated soil and ingestion of and dermal contact with
contaminated ground water, 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" scenario that portrays the highest level of human
exposure that could reasonably be expected to occur is calculated.
Toxicity Assessment: 111 this step, the types of adverse health effects
associated with chemical exposures and the relationship between
magnitude of exposure and severity of adverse effects 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 (changes in the effectiveness of the immune system). Some
chemicals are capable of causing both cancer and non-cancer health
hazards.
Risk ('liaraclerizalion: This step summarizes and combines outputs
ol'the exposure and toxicity assessments to provide a quantitative
assessment of site risks lor all C( )PCs. 1 ¦ xposures are evaluated based
011 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 1 x 10 'cancer
risk means a "one-in-ten thousand excess cancer risk"; or one
additional cancer may be seen in a population of I ().()()() people as a
result 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 I x 101 to
I x 10". corresponding to a one-in- ten thousand to a one-in-one-
million excess cancer risk, for non-cancer health effects, a "hazard
index" (I II) is calculated. The key concept for a non-cancer 1II is that
a "threshold" (measured as an III of less than or equal to I) exists
below which non-cancer health hazards are not expected to occur.
The goal of protection is I x 10"" for cancer risk and an III of I for a
noncancer health hazard. Chemicals that exceed a I x 10"1 cancer risk
or an III of I are ty pically those that will require remedial action at
the site.
1 Bolded values indicate risk exceedances.
Table 1: Summary of total hazard and risks associated with
groundwater'
RECEPTOR
Hazard
Index
Cancer
Risk
Future Child Resident
12,000
3.7E-02
Future Adult Resident
7,000
Future Commercial/Industrial
Worker
19
1.6E-04
Current/Future
Construction/Excavation Worker
3.1
1.1E-06
The potential for subsurface vapor intrusion (SVI) is
evaluated when Site soils and/or groundwater are known
or suspected to contain chemicals that are volatile. Since
TCE is considered volatile, a comparison of detected
concentrations of TCE found in sitewide groundwater
were compared to EPA's chemical-specific, risk-based
groundwater vapor intrusion screening levels (VISLs).
The VISLs provide groundwater levels associated with an
indoor air concentration that represents a cancer risk
ranging from 1 x 10"4 and 1 x 10"6 or a noncancer hazard
quotient of 1. Concentrations exceeding these
groundwater screening values indicate the potential for
vapor intrusion exists. Results of the screening evaluation
indicate that TCE is present in groundwater at
concentrations well above the chemical specific
groundwater VISL for TCE of 1.19 ug/L. Based on the
results of the screening evaluation, the potential for vapor
intrusion exists at the Site and should continue to be
evaluated in both the current and future timeframes.
> Soil
Risks and hazards were evaluated for future exposure to
residual TCE source within the Spill Zone soil by
current/future commercial and construction workers. For
the commercial worker, surface soil down to 2 ft bgs was
evaluated while for the construction worker, soil down to
10 ft bgs was considered. As summarized in Table 2, the
estimated noncancer hazards for these two receptors
exceeded 1 with estimates of 25 and 91 for the
commercial worker and construction worker, respectively.
The noncancer risk driver was TCE in both instances. The
estimated cancer risks for these receptor populations
evaluated were found to be within EPA's target threshold
range of 1 x 10"6 to lxl O"4
8
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Table 2: Summary of hazard and risks associated with
residual TCE source in soil2
RECEPTOR
Hazard
Index
Cancer Risk
Current/Future
Commercial Worker
25
7.6E-05
Current/Future
Construction
Worker
91
1.1E-05
> Surface Water and Sediments in the Mud Creek
area, Oatka Creek and Spring Creek.
Risk and hazard were evaluated for current and future
exposure by a child, adolescent and adult recreators who
may be wading or swimming in nearby Mud, Oatka, and
Spring Creeks. Based on the distribution of constituent
concentrations in these surface waters, two exposure unit
(EU) were designated for use in the HHRA. Mud Creek
located adjacent and hydraulically downgradient from
the Spill Zone comprises the first EU. Hydraulically
downgradient from Mud Creek is Oatka Creek and
Spring Creek which were designated as EU 2. The
results of the risk assessment are summarized per media
and EU in Table 3 below.
Table 3: Summary of total hazard and risks associated
with surface water and sediment3
RECEPTOR
Hazard
Index
Cancer Risk
Exposure Media: Surface Water in Mud Creek (EU 1)
Current/Future Child
Recreator
14
6.1E-05
Current/Future Adult
Recreator
6.2
Current/Future
Adolescent Recreator
7.9
NC
Exposure Media: Sediment in Mud Creek (EU 1)
Current/Future Child
Recreator
1.5*
2.1E-06
Current/Future Adult
Recreator
0.14
Current/Future
Adolescent Recreator
0.73
NC
Exposure Media: Surface Water in Oatka & Spring Creek
(EU2)
Current/Future Child
Recreator
0.14
1.7E-05
2 Bolded values indicate risk exceedances.
Current/Future Adult
0.036
Recreator
Current/Future
Adolescent Recreator
0.055
NC
Exposure Media: Sediment in Oatka & Spring Creek
(EU2)
Current/Future Child
2.6*
Recreator
8.3E-06
Current/Future Adult
0.24
Recreator
Current/Future
0.44
NC
Adolescent Recreator
Footnotes:
NC= not calculated
* Hazard exceedance due to thallium, which is not related to the
train derailment.
As indicated in Table 3, hazard indices for the child
recreator (14), adolescent recreator (7.9) as well as the
adult recreators (6.2) visiting Mud Creek exceeded EPA's
threshold value of 1. TCE in surface water was the main
COC driving the hazards for these recreators. Cancer risk
estimates did not exceed EPA's threshold of 1 x 10"6 to
1 x 10"4 for any media evaluated. Exposure to sediments in
Mud Creek resulted in a total hazard slightly above unity
(1.5), however, this exceedance was due to thallium in
sediments which is not a Site-related constituent.
Similarly, exposure to sediments in EU2 (Oatka and
Spring Creek) resulted in a slight hazard exceedance with
hazard estimates equal to 2.6; however, this exceedance
was due to presence of non-Site related thallium in
sediments. The presence of TCE in surface water of Mud
Creek drove the unacceptable hazard estimates for
recreators.
In summary, the result of the 2016 HHRA and the 2021
supplemental soil evaluation indicated that TCE in soil,
groundwater and surface water of Mud Creek were
associated with cancer and/or noncancer risk estimates
that exceeded EPA's threshold criteria. The presence of
TCE in groundwater was also found at levels that could be
of concern for the vapor intrusion pathway.
Ecological Risk Assessment
A Screening Level Ecological Risk Assessment (SLERA)
was prepared to determine whether potential adverse
ecological effects are occurring or may occur based on
constituents of potential ecological concern concentrations
in sediment and surface water. Ecological exposure was
3 Bolded values indicate risk exceedances.
9
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first evaluated using an exposure evaluation approach
that quantified potential risk based on the most
conservative exposure scenarios. The results indicated
that maximum concentrations of some constituents in
surface water and sediment exceeded conservative
screening criteria. However, the potential for impacts to
populations from exposure to those constituents is low
when evaluated using refined benchmarks that indicate
the risk of real effects to specific receptors. The findings
of the exposure estimate and risk characterization
support the following conclusions for the exposure area:
1) The low detected concentration of cyanide in
surface water at one location in Mud Creek does
not pose unacceptable risks for fish communities
because the pathway for exposure is incomplete
since Mud Creek upstream of Gorge Pond runs dry
portions of the year and, therefore, is unable to
support fish communities.
2) Acetone is not related to the train derailment and
is not a Site-related constituent. It is unlikely to
adsorb to sediment and was found in similar
concentrations within and outside the historical
plume. The lack of sediment quality criteria and
ecotoxicity data suggest that this analyte is
unlikely to adversely impact macroinvertebrates.
Therefore, the presence of this constituent in
sediment samples is not considered Site-related
and does not pose a significant risk to benthic
invertebrate populations.
A Supplemental Ecological Risk Evaluation was
completed to estimate the potential for adverse effects to
ecological receptors exposed to contaminated soils on
the Site (USEPA, 2021b). Analytical data used in the
Supplemental Risk Evaluation included TCE
concentrations measured in post-SVE soil boring
samples collected in August 2017 from 0.5 to 2.5 ft bgs.
The risk was evaluated for surface soils because
exposure pathways to terrestrial ecological receptors are
only complete in surface soil. Exposure point
concentrations (EPC) calculated by EPA were compared
to the 2 mg/kg value for protection of ecological
receptors established by the NYSDEC. This NYSDEC
value assumes that the soil-to-earthworm-to-small
mammal exposure pathway is the most sensitive wildlife
ingestion pathway. In calculating the 2 mg/kg value,
NYSDEC assumed an exposure scenario where short-
tailed shrews (Blarina brevicauda) consume 100 percent
of their diet in earthworms and the TCE bioaccumulation
from soil to earthworm tissue is based on general
bioaccumulation models for organic compounds based
on octanol-water partitioning coefficients. Based on this
comparison, USEPA calculated a hazard quotient (HQ)
for the Spill Zone of 230 based on an EPC of 460.2
mg/kg. Under current conditions, placement of a stone
cover as part of the SVE system prevents the
establishment of habitat to support a forage base (e.g.,
earthworms, vegetation, etc.) for ecological receptors and
minimizes incidental soil ingestion. However, if the
existing cover is removed, there is a potential for future
habitat to be present for ecological receptors.
Summary of Human Health and Ecological Risks
EPA concluded that remaining TCE in Site soil poses an
unacceptable noncancer risk to human health and the need
to take remedial action remains valid. The inhalation
pathway was the exposure pathway of concern. Surface
water exposure from Mud Creek, containing TCE, poses
an unacceptable noncancer risk to human health, and the
need to take remedial action remains valid. Ingestion of
and dermal contact with contaminated surface water while
swimming were the exposure pathways of concern.
Exposure to groundwater beneath the Site via ingestion,
inhalation and dermal contact drove unacceptable cancer
and noncancer hazard for human health receptors.
Additionally, TCE is present in groundwater at
concentrations that could be of concern for the VI
pathway. A streamlined ecological risk evaluation for the
soil in the Spill Zone concluded that there is a potential for
adverse impact to ecological receptors from exposure to
soil if the existing stone cover is removed.
Based on the results of the human health and ecological
risk assessments, a remedial action is necessary to protect
human health and the environment from actual or
threatened releases of hazardous substances.
It is EPA's judgment that the implementation of preferred
alternatives, summarized in this Proposed Plan, is
necessary to protect human health and the environment
from actual of threatened releases of hazardous substances
into the environment.
PRINCIPAL THREAT WASTE
Principal threat waste is defined in the box below. TCE
released from the train derailment has diffused into the
bedrock matrix and continues to be an ongoing source of
groundwater contamination. Bedrock and contaminated
groundwater at the Site, however, are not considered
source materials and, therefore, are not principal threat
wastes. Soil is not considered principal threat waste
because it does not act as a significant source of
contamination to groundwater.
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WHAT IS A "PRINCIPAL TI IKI-'AT'".'
The Natioiuil Oil and Hazardous Substances Pollution Contingency
Plan (NCI5) establishes an expectation that 1! 15A will use treatment
to address the principal threats posed by a site wherever practicable
(NCP Section 3()().43()(a)( I )(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 migration of contamination to ground water,
surface w ater. or air. or acts as a source for direct exposure.
Contaminated ground water generally is not considered to be a
source material: however. Non-Aqueous Phase Liquids (NAPl.s) in
groundwater may be viewed as source material. Principal threat
wastes are those source materials considered to be highly toxic or
highly mobile that generally cannot be reliably contained or would
present a significant risk to human health or the environment should
exposure occur. The decision to treat these wastes is made on a site-
specilic basis through a detailed analysis of the alternatives using
the nine remedy selection criteria. This analysis provides a basis for
making a statutory finding that the remedy employs treatment as a
principal element.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are specific goals
identified to protect human health and the environment.
These objectives are based on available information and
standards, such as applicable or relevant and appropriate
requirements (ARARs), to-be-considered (TBC)
guidance, and, if applicable, site-specific risk-based
levels.
The RAOs identified in the 1997 NYSDEC ROD were:
• Provide for attainment of Standards, Criteria and
Guidance (SCGs) for groundwater quality and
surface water quality at the limits of the area of
concern, to the extent practicable.
• Prevent, to the extent possible, migration of
contaminants in groundwater and reduce the
impacts of contaminated groundwater to the
environment.
• Reduce, control, or eliminate, to the extent
practicable, the soil and bedrock contamination
present at the derailment Site.
• Eliminate the potential for human and wildlife
exposure to soil containing Site-related
contaminants.
• Contain, treat and/or dispose of contaminated soil
in a manner consistent with applicable state and
federal regulations and guidance.
EPA is amending and supplementing these RAOs with
the RAOs detailed below which are organized by media.
In developing RAOs for groundwater, EPA expects to
return usable groundwater to its beneficial uses (in this
case, use as drinking water) wherever practicable, within a
timeframe that is reasonable given the characteristics of the
site. EPA also acknowledges, however, that groundwater
restoration is not always achievable due to limitations in
remedial technologies and other site-specific factors.
These factors may include technology limitations,
contaminant phase contaminant depth, complexity of
geological setting, and hydraulic regime.
As discussed above, after evaluating the nature and extent
of groundwater contamination and the available remedial
alternatives for groundwater, EPA has concluded that the
available technologies cannot achieve restoration of the
contaminated groundwater to drinking water standards.
EPA is recommending a waiver of ARARs due to
technical impracticability (TI) for groundwater at the Site.
The PRP documented its evaluation of the potential for
groundwater restoration in the 2019 AGTI report and
identified a zone where ARARs are expected to be
exceeded for the foreseeable future. EPA acknowledged
that this evaluation satisfied the requirements for a TI
waiver.
The proposed TI decision applies only to the chemical-
specific groundwater standards being waived in the area
in which ARARs or other cleanup standards cannot be
reached (hereinafter, TI Zone). For the LVRR Site, the TI
Zone includes the portion of the groundwater in the Spill
Zone and the plume downgradient to Spring Creek.
The horizontal and vertical extent of the TI Zone is
illustrated on Figure 4, which shows the TI Zone (items 1
and 2 below) and an area around the TI Zone as follows:
1. Red: depicts an area encompassing the approximately
3.1 million square foot Spill Zone and extending
vertically to the upper Camillus Formation (a depth
corresponding to approximately 120 ft bgs), resulting in
a volume of approximately 213 million cubic feet where
groundwater TCE concentrations generally exceed
1,000 (ig/L;
2. Yellow: depicts an area encompassing approximately
102 million square feet outside of the Spill Zone area
extending vertically to the base of the Camillus
Formation (ranging from approximately 120 ft bgs in
the western extent of the Study Area to outcrops
occasionally near Spring Creek, and Oatka Creek),
resulting in a volume of approximately 7,821 million
cubic feet where groundwater TCE concentrations
generally range from 5 |ig/L to 1,000 |ig/L. The TI
boundary at the distal end of the TCE plume was
established to include the entire Spring Creek Fault
Zone that extends just east of Spring Creek.
11
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3. Gray (Monitoring Zone): depicts an area that
encompasses an approximately 39 million square foot
area extending vertically to the base of the Camillus
Formation (ranging from approximately 120 ft bgs in
the western extent of the Study Area to outcrops
occasionally near Spring Creek, and Oatka Creek)
resulting in a volume of approximately 2,990 million
cubic feet where TCE concentrations in groundwater
generally range from non-detect to 5 |ig/L. Outside of
the TI Zone (gray area), the preliminary remediation
goals (discussed below) will be used to verify
compliance with the TI waiver.
When restoration of groundwater to beneficial uses is not
practicable, EPA selects an alternative remedial strategy
that is technically practicable, protective of human health
and the environment, and satisfies statutory and
regulatory requirements of CERCLA. Consistent with the
NCP, alternative remedial strategies for TI sites typically
address three site concerns: 1) exposure control; 2)
source control; and 3) aqueous plume migration. The
RAOs outlined below for groundwater, soil vapor,
bedrock, surface water and soil address these concerns.
Groundwater RAOs:
• Prevent current and future human exposure (via
ingestion, inhalation and dermal contact) to Site-
related contaminants in groundwater that exceed
federal or state maximum contaminant levels
(MCLs);
• Prevent further migration of Site-related
contaminants in groundwater at levels exceeding
MCLs beyond the delineated areal extent of the
groundwater contamination (TI Zone); and,
• Prevent the migration of Site-related
contaminants in groundwater to surface water
that would result in exceeding applicable surface
water quality standards.
Soil Vapor Intrusion (SVI) RAOs:
• Mitigate potential current and future
unacceptable risks from subsurface SVI into
indoor air.
Soil RAOs:
• Prevent human exposure to contaminated Spill
Zone soil (/'. e., contaminated overburden fill
material/debris/soil) via incidental ingestion and
inhalation above levels that pose an unacceptable
risk for commercial use.
Surface Water RAO:
• Prevent unacceptable risk to human receptors
from incidental ingestion and dermal contact
exposure to contaminated surface and seep water
in the Mud Creek area by reducing contaminant
levels to the more stringent federal or state
standards.
Preliminary Remediation Goals
Preliminary remediation goals (PRGs) are media- and
contaminant-specific numerical or qualitative federal and
state standards that can be compared directly to RAOs and
will be used for developing use restrictions and other
actions to prevent exposure and for assessing the extent of
the aqueous plume. To evaluate remedial alternatives and
support the RAOs, PRGs for the Site were developed for
soil, groundwater and surface water. PRGs are related to
RAOs and are based on state and federal standards and
will be used for developing the final cleanup levels in the
ROD, use restrictions and other actions to prevent
exposure. PRGs will not be used for achieving restoration
of groundwater within the TI zone to the numerical goals
but will be used for assessing the extent of the aqueous
plume.
As there are no promulgated chemical-specific ARARs for
SVI, PRGs were not specifically developed for vapor
intrusion. However, applicable TBC criteria includes EPA
Vapor Intrusion Screening Levels (VISLs) and NYSDOH
Final Guidance for Evaluating Soil Vapor Intrusion in the
State of New York. The most current EPA VISLs and
NYSDOH criteria will be used in the evaluation of the
SVI pathway at the Site.
In the 1997 NYSDEC OU1 ROD established the
groundwater and surface water PRGs as follows:
Groundwater - 5 j^ig/L TCE
Surface water - 11 (ig/L TCE
Bedrock RAOs:
• Mitigate, to the extent practicable, the Bedrock
Vadose Zone (BVZ) as an ongoing source of
groundwater contamination;
• Accelerate long-term improvement to the
groundwater in a reasonable time frame; and,
• Support further risk reduction for the Site as a
whole.
For the surface soil, PRGs were as follows:
TCE - 7 mg/kg
1,2-dichloroethene - 3 mg/kg
12
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EPA is proposing to replace the above PRGs with the
following:
Table 4: EPA's PRGs
MI-DIA
CONTAMINANT OK
( OMT.KN
PKC
i ni is
Trichloroethene (TCE)
5
Hg/L
cis-1,2-dichloroethene
5
Hg/L
Groundwater1
trans-1,2-dichloroethene
5
Hg/L
1,1- dichloroethene
5
Hg/L
Vinyl Chloride
2
Hg/L
Surface Water2
Trichloroethene (TCE)
40
Hg/L
Soil3
Trichloroethene (TCE)
200
mg/kg
Footnotes:
1 Lower of the NYSDEC Class GA Drinking Water Standards and NY state
and federal Maximum Contaminant Levels (MCL) were selected as PRGs.
These PRGs are the ARARs being waived in the TI Zone.
2 NYSDEC - Part 703: Surface Water Quality Standards for Class C (based
on designation of Mud Creek).
36 NYCRR Part 375, Table 375-6.8(b) Commercial use Soil Cleanup
Objective. The protection of groundwater SCO was evaluated in the feasibility
study, but was not applied because groundwater restoration is not possible.
As reflected in the PRG table above, the primary
groundwater COCs include TCE and its breakdown
daughter products: cis- and trans- 1,2 dichloroethene,
1,1,- dichloroethene and vinyl chloride.
The OU2 RI and AGTI Reports conclude that a
substantial quantity of TCE, released from the original
spill, has diffused into the rock matrix. As such,
remediation of the bedrock matrix would be difficult as a
result of the formation of the bedrock geology, as well as
the size, migration, and location of the TCE mass.
Currently, there are no published ARARs, TBCs, or
other Guidance specific to the BVZ. Therefore, PRGs
have not been identified for the BVZ. The AGTI report
concludes that the restoration of groundwater, within the
Study Area, to its most beneficial use is not technically
practical within a reasonable timeframe. Therefore, BVZ
RAOs are based on source reduction and exposure
control.
SUMMARY OF REMEDIAL ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. § 9621(b)(1),
mandates that remedial actions must be protective of
human health and the environment, cost-effective,
comply with ARARs, and utilize permanent solutions,
alternative treatment technologies, and resource recovery
alternatives to the maximum extent practicable. Section
121(b)(1) of CERCLA also establishes a preference for
remedial actions that employ, as a principal element,
treatment to reduce, permanently and significantly, the
volume, toxicity, or mobility of the hazardous substances,
pollutants, and contaminants at a site. Section 121(d) of
CERCLA, 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
that, at least, attains ARARs under federal and state laws,
unless a waiver can be justified pursuant to Section
121(d)(4) of CERCLA, 42 U.S.C. § 9621(d)(4).
The alternatives for addressing contamination at the Site are
organized by media and summarized below. Detailed
descriptions of the remedial alternatives for addressing the
contamination found at the Site are provided in the 2023 FS
Report.
The construction time for each alternative reflects only the
time required to construct or implement the remedy and
does not include the time required to design the remedy,
negotiate the remedy performance with any potentially
responsible parties or procure contracts for design and
construction.
Common Elements of the Alternatives
The proposed alternatives described below, with the
exception of the 'No Action' alternative, include major
common elements which are implementable and do not
change significantly in scope from one alternative to
another as follows:
1. Common Elements:
a. ) Institutional Controls in the form of
governmental controls (see Appendix C of FS
Report); proprietary controls (e.g., easements on
Spill Zone parcels); and informational devices
relating to groundwater, soil vapor, and the Spill
Zone (e.g., notices, publications) to limit
exposure to contaminated groundwater and soil
vapor;
b. Monitoring, which includes sampling, of
groundwater, surface water, soil vapor and
indoor air;
i. A long-term groundwater monitoring
program would be implemented to track and
to monitor changes in the groundwater
contamination to ensure the RAOs are
attained.
ii. The groundwater data results would be used
to evaluate any contaminant migration and
changes in VOC contaminants over time.
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c. Maintenance of existing SSDSs and
installation of new systems, as needed, for
impacted properties; and
d. Connection of new homes constructed over
the groundwater plume to the current
municipal water supply system or the
provision of a point-of-entry treatment
system if connection to the municipal system
is not feasible.
Institutional Controls were evaluated as part of EPA's
nine criteria analysis as discussed in more detail below.
Bedrock Vadose Zone (BVZ) Remedial Alternatives
BVZ Alternative 1: No Action
The NCP requires that a "No Action" alternative be
developed and considered as a baseline for comparing
other remedial alternatives. Under this alternative, no
additional action would be implemented.
Capital Cost:
O&M Costs:
Present-Worth Cost:
$0
$0
$0
BVZ Alternative 2: Monitoring and ICs
No active remedial actions would be implemented in the
BVZ under Alternative 2. An operations and
maintenance (O&M) plan would be prepared to protect
workers from TCE exposure by outlining methods and
procedures for any on-Site work activities. Additionally,
ICs (consisting of deed notices and informational
devices) and monitoring (groundwater sampling) would
be established to prevent the potential use and exposure
of impacted materials, as well as to monitor the
groundwater quality through sampling overtime.
Capital Cost:
O&M Costs:
Common Elements Costs:
Present-Worth Cost:
Construction time:
$0
$0
$137,250
$137,250
Not Applicable
BVZ Alternative 3a (original OU1 bedrock remedy):
BVE in a 10-acre portion of the BVZ, Monitoring
and ICs
Under this alternative, which was also part of the
selected remedy in the OU1 ROD, a BVE system would
be installed within the Spill Zone to address the TCE
mass that remains within the unsaturated BVZ in the 10-
acre area. This would consist of a network of vapor
extraction wells, vacuum extraction pumps, and a
treatment system to mitigate the extracted vapors. The
extent of the proposed area is based on bedrock TCE
vapor with the outer most limits containing concentrations
of approximately 10,000 (ig/m3. TCE within the
seasonally saturated BVZ would not be addressed by this
alternative as it would not be effective.
Capital Cost:
O&M Costs:
Common Elements Costs:
Present-Worth Cost:
Construction time:
$8.36 million
$1.00 million
$0.14 million
$9.50 million
8 months
BVZ Alternative 3b: BVE in a 2-acre portion of the
BVZ, Monitoring and ICs
Under this alternative, a BVE system would be installed
within the Spill Zone to address the TCE mass that
remains within the unsaturated BVZ in a two-acre area.
This consists of a network of vapor extraction wells,
vacuum extraction pumps, and a treatment system to
mitigate the extracted vapors. The extent of the proposed
area is based on bedrock TCE vapor data with the outer
most limits containing concentrations of approximately
1,000,000 (ig/m3. TCE within the seasonally saturated
BVZ would not be addressed by this alternative as it
would not be effective.
Capital Cost:
O&M Costs:
Common Elements Costs:
Present-Worth Cost:
Construction time:
$2.73 million
$0.85 million
$0.14 million
$3.72 million
4 months
Surface Water (SW) Remedial Alternatives
SW Alternative 1: No Action
The NCP requires that a "No Action" alternative be
developed and considered as a baseline for comparing
other remedial alternatives. This alternative would not
reach remedial action objectives in a reasonable time
frame.
Capital Cost:
O&M Costs:
Present-Worth Cost:
$0
$0
$0
SW Alternative 2: ICs and Monitoring
No active surface water remedial action would be
implemented as part of this alternative. Improvements in
14
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surface water quality would be through natural
degradation of TCE by dispersion, dilution,
volatilization, biodegradation, and abiotic processes.
Monitoring would determine if the surface water quality
improved over time.
Capital Cost:
O&M Costs:
Common Elements Costs:
Present-Worth Cost:
Construction time:
$1.76 million
$0
$0.08 million
$1.84 million
Not Applicable
SW Alternative 3: Hydraulic Containment of
Contaminated Groundwater with ICs and
Monitoring
This alternative would involve the installation and
operation of several groundwater extraction wells (and
associated treatment and discharge of extracted
groundwater) to prevent contaminated groundwater
discharges to surface water and active seeps and flows
within the Mud Creek area. A Preliminary Design
Investigation (PDI) would be undertaken and include
collection of seasonal data in the Mud Creek area for
flow conditions, groundwater elevations, surface water
quality, and identification of fractured rock or karst
subsurface flow pathways. Wells and piezometers would
be installed, and pump tests would be completed to
obtain data on groundwater level fluctuations and flow
directions, seep flow rates, changes in COC
concentrations, and hydraulic conductivity. Monitoring
would determine if the surface water quality improves
overtime.
Capital Cost:
O&M Costs:
Common Elements Costs:
Present-Worth Cost:
Construction time:
$5.43 million
$5.09 million
$0.08 million
$10.60 million
1 year
SW Alternative 4: Streambed Cover with ICs and
Monitoring
This alternative consists of covering the active Mud
Creek stream segments and seeps that are impacted by
TCE with stones sourced from nearby quarries. The
stones would be placed such that the stream would be
well below the top of the streambed cover, thereby
preventing direct human contact with TCE-impacted
media. Monitoring would determine if the surface water
quality improves overtime.
Capital Cost:
O&M Costs:
Common Elements Costs:
Present-Worth Cost:
Construction time:
$2.07 million
$0.53 million
$0.08 million
$2.69 million
3 months
SW Alternative 5: In situ Treatment of Contaminated
Surface Water, Streambed Cover with ICs, and
Monitoring
This alternative includes the streambed cover from
Alternative 4 and adds the installation of one or more
permeable treatment barriers (PTBs) to create treatment
zones as an engineered in situ treatment process. The
PTBs would also prevent any potential human contact
with TCE-impacted surface water. Once a PDI has been
completed for the Mud Creek area, the design, the number
of treatment zones, their specific location, configuration,
and the process or media to be used within the treatment
zones will be determined. The PDI would collect seasonal
data for flow conditions, groundwater elevations, surface
water quality samples, and identification of fractured rock
or karst subsurface flow pathways. Additional
geochemical sampling and pilot scale installation of one or
more of the PTBs in potential treatment zones would be
conducted to determine performance and maintenance
requirements of the PTBs. Monitoring would determine if
the surface water quality improves over time.
Capital Cost: $4.12 million
O&M Costs: $3.10 million
Common Elements Costs: $ 0.08 million
Present-Worth Cost: $7.31 million
Construction time: 3 months
Soil Remedial Alternatives
Soil Alternative 1: No Action
The NCP requires that a "No Action" alternative be
developed and considered as a baseline for comparing
other remedial alternatives. Under this alternative, no
additional action would be implemented beyond what was
accomplished under the OU1 ROD.
Capital Cost:
O&M Costs:
Present-Worth Cost:
Time frame:
$0
$0
$0
Not Applicable
15
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Soil Alternative 2: Solidification/Stabilization (SIS) or
Cover System using Commercial Land-Use Based
PRG
Under this alternative, the Spill Zone overburden soils
would be remediated using ex situ solidification/
stabilization. Overburden materials exceeding the
commercial land-use PRG of 200 mg/kg for TCE in soil
to depths ranging up to 10.5 ft bgs would be excavated,
mixed with Portland cement (or other material) to
immobilize the contamination, and returned to the
excavation area underlain by a demarcation layer. Post-
excavation samples would be completed to ensure all
impacted overburden soil exceeding the commercial land
use PRG of 200 mg/kg for TCE has been removed. In
addition, placement of topsoil and seed to provide for
one foot of clean soil cover will extend to any areas of
the Spill Zone where surface soil exceeds 2 mg/kg,
which is the NYS value for the protection of ecological
receptors. Community air monitoring and dust control
measures would be performed to ensure that VOCs are
not volatilizing into the air.
On-Site ex-situ treatment of TCE-impacted overburden
in a temporary treatment unit and placing the solidified
material in the excavation area would need to comply
with Resource Conservation and Recovery Act (RCRA)
corrective action management unit (CAMU)
performance standards including requirements for a
liner, leachate collection system, cap, and groundwater
monitoring.
surface soil exceeds the 2 mg/kg value for the protection
of ecological receptors. Community air monitoring and
dust control measures would be performed to verify
volatilization of VOCs into the air is not occurring.
Capital Cost: $3.02 million
O&MCosts: $0.06 million
Common Elements Costs: $0.12 million
Present-Worth Cost: $3.20 million
Construction time: 6 months
Soil Alternative 4: Low-Temperature Thermal
Desorption (LTTD) using Commercial Land-Use
Based PRG
Under this alternative, the Spill Zone overburden material
exceeding the commercial land use PRG of 200 mg/kg
would be remediated ex-situ using LTTD to depths of up
to 10.5 ft bgs. An estimated total of 1,150 yd3 (1,840 tons)
of overburden would be removed, treated via LTTD.
Post-excavation samples would be completed to ensure all
impacted overburden material exceeding the PRG of 200
mg/kg for TCE has been removed. The area would then be
backfilled using clean, imported soil and/or stone
underlain by a demarcation layer. In addition, placement
of topsoil and seed to provide for one foot of clean soil
cover would extend to areas of the Spill Zone where
surface soil exceeds 2 mg/kg value for the protection of
ecological receptors. Community air monitoring and dust
control measures will be performed to verify volatilization
of VOCs into the air is not occurring.
Capital Cost:
O&M Costs:
Common Elements Costs:
Present-Worth Cost:
Construction time:
$1.37 million
$0.71 million
$0.12 million
$2.20 million
20 months
Soil Alternative 3: Excavation/Disposal using
Commercial Land-Use Based PRG
Under this alternative, the Spill Zone overburden
material exceeding the commercial land use PRG for
TCE of 200 mg/kg would be excavated to depths of up
to 10.5 ft bgs. An estimated total of 1,150 cubic yards
(yd3) (1,840 tons) of overburden would be removed and
disposed off-Site at an approved disposal facility. Post-
excavation samples would be completed to ensure all
impacted overburden material exceeding the PRG of 200
mg/kg for TCE has been removed. The area would then
be backfilled using clean, imported soil and/or stone
underlain by a demarcation layer. In addition, placement
of topsoil and seed to provide for one foot of clean soil
cover would extend to areas of the Spill Zone where
On-Site treatment of TCE-impacted overburden by ex situ
in a temporary treatment unit and placing the treated
material in the excavation area would need to comply with
the RCRA CAMU performance standards. If LTTD
treatment achieves 90% reduction of TCE or reaches 10
times the universal treatment standard (60 mg/kg), the
CAMU would not have to comply with the requirements
for a liner, leachate collection system, cap, and
groundwater monitoring.
Capital Cost:
O&M Costs:
Common Elements Costs:
Present-Worth Cost:
Construction time:
$1.82 million
$0.06 million
$0.12 million
$2.00 million
16 months
EVALUATION OF ALTERNATIVES
In evaluating the remedial alternatives, each alternative is
assessed against the nine evaluation criteria set forth in the
NCP, namely the following: overall protection of human
health and the environment; compliance with ARARs;
16
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long-term effectiveness and permanence; reduction of
toxicity, mobility, or volume through treatment; short-
term effectiveness; implementability; cost; and State and
community acceptance. Refer to the text box for a more
detailed description of these evaluation criteria.
This section of the Proposed Plan evaluates the relative
performance of each alternative, including the Common
Elements, particularly ICs, against the nine criteria,
noting how each compare to the other options under
consideration. A detailed analysis of alternatives can be
found in EPA's FS Report supporting this decision,
dated July 2023.
BEDROCK ALTERNATIVES
Overall Protection of Human Health and the
Environment
BVZ Alternative 1 (No Action) would not meet the
RAOs and would not be protective of human health and
the environment because no action would be taken. BVZ
Alternatives 2, 3a and 3b would address risk mitigation
through the ICs. Although the active remedial BVZ
alternatives (3a and 3b) would provide for a marginal
reduction in TCE mass within the BVZ, the beneficial
impact with respect to protection of human health would
be negligible given that the majority of the TCE mass
would be retained within the bedrock matrix micro pore
spaces. None of the alternatives presented would have a
beneficial impact to groundwater quality as a result of
the matrix diffusion mechanisms that occur between the
bedrock matrix porewater and the groundwater media,
which would be expected to continue for a significant
period of time into the future.
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)
There are no current federal and/or state ARARs that are
applicable for the bedrock source material. None of the
bedrock alternatives presented would be sufficient to
meet the groundwater ARAR of 5 (ig/L across the
entirety of the TCE-impacted groundwater plume or to
reduce risk, in general, with regards to exposure to TCE-
impacted groundwater media.
Long-Term Effectiveness and Permanence
BVZ Alternative 1 would not have any long-term
effectiveness and permanence because no action would
be taken. BVZ Alternative 2, which involves the
implementation of comment elements and ICs, would
provide for a permanent and effective means of
mitigating potential exposure to TCE-impacted bedrock
media and to Site groundwater that is impacted by the
TCE present within the bedrock media. BVZ Alternatives
3a and 3b would not be expected to provide any benefit
with respect to: i) reducing TCE mass to any practical
extent within the BVZ; and ii) reducing TCE
concentrations (and associated exposure risk) within the
TCE-impacted groundwater media, based on an analysis
of the Site data collected through various investigations
and modeling efforts.
EVALUATION CRITERIA FOR SUPERFUND
REMEDIAL ALTERNATIVES
Overall Protectiveness of Human Health and the
Environment considers whether and how an alternative
eliminates, reduces, or controls threats to public health and the
environment through institutional controls, engineering controls,
or treatment.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) considers whether the alternative meets
federal and state environmental statutes, regulations, and other
requirements that pertain to the Site, or whether a waiver is
justified.
Long-term Effectiveness and Permanence considers the ability
of an alternative to maintain protection of human health and the
environment over time.
Reduction of Toxicity, Mobility, or Volume (TMV) of
Contaminants through Treatment considers an alternative's
use of treatment to reduce the harmful effects of principal
contaminants, their ability to move in the environment, and the
amount of contamination present.
Short-term Effectiveness considers the length of time needed to
implement an alternative and the risks the alternative poses to
workers, the community, and the environment during
implementation.
Implementability considers the technical and administrative
feasibility of implementing the alternative, including factors such
as the relative availability of goods and services.
Cost considers estimated capital and annual operations and
maintenance costs, as well as present worth cost. 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.
State/Support Agency Acceptance considers whether the State
agrees with EPA's analyses and recommendations, as described
in the RI/FS and Proposed Plan.
Community Acceptance considers whether the local community
agrees with EPA's analyses and preferred alternative. Comments
received on the Proposed Plan are an important indicator of
community acceptance.
Reduction of Toxicity, Mobility, or Volume Through
Treatment
BVZ Alternative 1, No Action, would not address the
contamination through treatment, so there would be no
reduction in toxicity, mobility, or volume of the
contaminants, and the alternative does not include long-
term monitoring of groundwater conditions. As a result of
the limitations associated with the matrix diffusion
processes within bedrock media, the unpredictable nature
17
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associated with the application of BVE in a fractured
bedrock media and the generally inconclusive results of
the BVE Pilot Study, any implementation of active
remediation through BVE (BVZ Alternatives 3a and 3b),
would be expected to recover a very small fraction of the
TCE mass that lies within the BVZ. Consequently, only
a marginal reduction of toxicity, mobility and volume
would be expected within the bedrock media when
compared to the BVZ Alternatives 1 and 2.
Short-Term Impact and Effectiveness
BVZ Alternative 1 would not have short-term adverse
impacts, because no action would be implemented. The
activities associated with the BVE system installation
phase for BVZ Alternatives 3a and 3b would present a
moderate to high degree of risk to on-Site workers, and
little to no risk to the community. The elevated risk
associated with the installation of the BVE system could
be mitigated through the appropriate training of on-Site
personnel, and implementation of rigorous safety
protocols. Once a BVE system is operational, routine
sampling and O&M activities would present a moderate
degree of risk to on-Site workers, and little to no risk to
the community. In contrast, implementation of either
BVZ Alternatives 1 or 2 would not present any increased
risk to on-Site workers or the public, in general.
Implementability
BVZ Alternative 1, No Action, would be the easiest of
all the alternatives to implement because there would be
no remedy to implement. The implementability of the
BVZ remedial alternatives (3a and 3b) would be
challenging since a large number of extraction wells
would be required, uncertainties with regards to their
placement, and system operational challenges associated
with: i) a highly variable water table and ii) matrix
diffusion processes within the bedrock media (both of
which would limit that amount of TCE mass that could
be recovered by the BVE process). Additionally, the
application of BVE would not address the TCE-
impacted bedrock that is present below the water table,
thus further impacting its implementability and
effectiveness. In contrast, there are no technical or
administrative implementability issues associated with
the BVZ Alternatives 1 and 2.
Cost
BVZ Alternative 1 (No Action) has no cost because no
activities would be implemented. Costs associated with
the Common Elements alternative (BVZ Alternative 2),
which include ICs, are estimated to be approximately
$137,250. BVZ Alternatives 3a and 3b have capital
worth costs of approximately $8.36 and $2.67 million,
and present worth costs for O&M of $1.01 million and
$0.85 million, respectively (assuming a three-year system
operation time frame). These costs are significant in
comparison to the costs associated with the alternative
which contains only Common Elements, with little to no
benefit achieved through implementation of the active
treatment alternatives. The estimated capital cost, O&M,
and present worth cost of the various Alternatives are
discussed in detail in the 2023 FS Report. For cost
estimating and planning purposes, a 30-year time frame
was used for O&M.
State Acceptance
NYSDEC is currently evaluating EPA's preferred
remedial alternatives as stated in this Proposed Plan.
Community Acceptance
Community acceptance of the preferred alternative will be
evaluated after the public comment period ends and all
comments are reviewed. Comments received during the
public comment period will be addressed in the
Responsiveness Summary section of the upcoming ROD.
SURFACE WATER ALTERNATIVES
Overall Protection of Human Health and the
Environment
SW Alternative 1 (No Action) would not meet the RAOs
and would not be protective of human health and the
environment because no action would be taken. The PDI
and Common Elements alternative (SW Alternative 2)
could provide for some degree of protection of human
health through proprietary ICs. Lastly, if the results of the
PDI investigations are favorable, SW Alternatives 3, 4,
and 5 could potentially be implemented to the extent that
they would provide for the protection of human health
from TCE-impacted surface water. The Hydraulic
Containment (SW Alternative 3) and Streambed Cover
(SW Alternative 4) alternatives would provide protection
through the containment of the TCE-impacted surface
water, whereas the In-situ Treatment with Streambed
Cover alternative (SW Alternative 5) would provide
protection through both a containment mechanism, and a
treatment process. Although Alternative 3 includes a
treatment component, the media that it addresses via
treatment is groundwater rather than surface water. In
reality, SW Alternative 3 would be capturing groundwater
prior to daylighting as surface water in Mud Creek and
treating for subsequent discharge. As previously
discussed, a thorough PDI would need to be conducted in
order to obtain specific data, such as seasonal surface
water flows, TCE concentrations, and pilot scale data to
18
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assist in the implementation of key design elements for
each remedial alternative.
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)
The No Action alternative would not comply with NYS
standards for surface water TCE concentration within a
"Class C" stream (i.e., 40 |ig/L). SW Alternative 2
would not comply with ARARs. Implementation of
Hydraulic Containment (SW Alternative 3) or the
Streambed Cover (SW Alternative 4) would not provide
for a reduction in TCE concentrations that would meet
the PRG. In-Situ Treatment with Streambed Cover (SW
Alternative 5) would achieve the PRG for TCE.
Long-Term Effectiveness and Permanence
The long-term effectiveness under the No Action and the
ICs and Monitoring alternatives (SW Alternatives 1 and
2) would not be achieved, as these two alternatives do
not provide for a method to address surface water TCE
concentrations that exceed the PRG. Assuming
favorable results are obtained from the PDI, SW
Alternatives 3, 4, and 5 could all provide for an effective
long-term solution with regards to surface water TCE-
impacts in the Mud Creek area. In addition to favorable
results from the PDI, the implementation of routine
O&M procedures would be another key component with
regards to the long-term effectiveness of SW
Alternatives 3, 4, and 5.
Reduction of Toxicity, Mobility, or Volume Through
Treatment
SW Alternative 1, No Action, would not address the
contamination through treatment so there would be no
reduction in toxicity, mobility, or volume of the
contaminants. The No Action alternative does not
include long-term monitoring of the ongoing
groundwater conditions. The No Action and the
Common Elements alternatives (SW Alternatives 1 and
2) do not provide for any reduction of toxicity, mobility
or volume of TCE impacts. Since SW Alternatives 3 and
5 all provide for a method of containment for
contaminated groundwater discharging to surface water,
the two alternatives would then provide for a reduction
in the toxicity, mobility and volume of TCE with regards
to the surface water pathway. SW Alternative 5 also
provides for an additional mechanism that may result in
the reduction of toxicity, mobility and volume of TCE in
surface water through a treatment process.
Short-Term Impact and Effectiveness
SW Alternative 1 (No Action) would not have short-term
adverse impacts because no action would be implemented.
The system installation activities associated with SW
Alternatives 3, 4 and 5 would present a moderate to high
degree of risk to on-Site workers, and little to no risk to
the community. A significant component of this risk is the
result of construction activities that would need to be
conducted in largely wooded and uneven terrain. The
elevated risk associated with the installation of these
remedial systems could be mitigated through the
appropriate training of on-Site personnel, use of proper
construction equipment, and implementation of safety
protocols. Routine sampling and O&M activities
associated with the proposed remedial systems would
present a moderate degree of risk to on-Site workers and
little to no risk to the community. In contrast,
implementation of either the No Action or the Common
Elements alternatives would not present any increased risk
to on-Site workers or the public in general.
Implementability
SW Alternative 1 (No Action) would be the easiest of all
the alternatives to implement because there would be no
remedy to implement. No technical implementability
issues are associated the No Action and Common
Elements alternatives. SW Alternatives 3, 4 and 5 would
all require a PDI to be conducted initially in order to
determine the design parameters associated with their
implementation. Depending on the results of the PDI, each
of these three alternatives would require a significant
amount of construction activities to be conducted within a
heavily wooded area, as well as the Mud Creek streambed
itself. Access roads would need to be constructed for
construction equipment and on-Site workers to access the
various locations where system infrastructure needs to be
installed. SW Alternatives 3 and 5 would require an
installation phase that may take half-a-year or more to
complete. Additionally, SW Alternative 3 would require a
significant footprint to house all the necessary equipment
necessary for its implementation. SW Alternatives 3 and 5
would require extensive routine O&M activities associated
with their long-term operation. This could include
servicing of pumps, motors and treatment equipment,
replacement of treatment media, and/or waste disposal. In
contrast, the long-term O&M activities associated with
SW Alternative 4 would be simple and straightforward,
and significantly easier to manage over the long-term.
19
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Cost
The estimated capital cost, O&M, and present worth cost
of the various alternatives are discussed in detail in the
2023 FS Report. For cost estimating and planning
purposes, a 30-year time frame was used for O&M. The
cost estimates are based on the available information.
SW Alternative 1 (No Action) has no cost because no
activities would be implemented. Costs associated with
the ICs and Monitoring alternative (SW Alternative 2)
are estimated to be approximately $81,750. Capital costs
associated with implementation of the proposed PDI are
$2.12 million. Capital costs for Hydraulic Control &
Common Elements (SW Alternatives 3), Streambed
Cover & Common Elements (SW Alternative 4), and In-
situ Treatment, Streambed Cover & Common Elements
(SW Alternative 5) are estimated to be approximately
$5.43 million, $2.07 million and $4.12 million,
respectively. Note that these costs also include the
implementation of the proposed PDI. Present worth costs
for O&M for these three alternatives are estimated to be
approximately $5.09 million, $534,000 and $3.10
million, respectively (assuming a 30-year O&M period).
Present worth costs are calculated based on a 7%
discount rate for each year of system O&M. The
corresponding total costs for these three alternatives are
estimated to be approximately $10.6 million, $2.69
million and $7.31 million, respectively. The costs for
SW Alternatives 3 and 5 are significant in comparison to
the other alternatives presented, as they will incur more
upfront capital expenditures and higher O&M costs over
the course of their operation.
State Acceptance
NYSDEC is currently evaluating EPA's preferred
alternatives, as stated in this Proposed Plan.
Community Acceptance
Community acceptance of the preferred alternative will
be evaluated after the public comment period ends and
all comments are reviewed. Comments received during
the public comment period will be addressed in the
Responsiveness Summary section of the upcoming
ROD.
Soil Remedial Alternatives
Overall Protection of Human Health and the
Environment
Soil Alternative 1 (No Action) would not meet the
RAOs and would not be protective of human health and
the environment because no action would be taken. Except
for the No Action Alternative, all alternatives are
protective of human health and the environment. Soil
Alternatives 3 and 4 reduce TCE concentrations on-Site
through physical removal. Although Soil Alternative 2
does not reduce TCE concentrations, solidification would
mitigate wind/surface water erosion and incidental
ingestion/inhalation and placement within a lined/capped
CAMU would make these alternatives equally as
protective.
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)
EPA has identified NYSDEC's soil cleanup objectives
(SCOs) (6 NYCRR § 375-6.5) as an ARAR, a "to-be
considered," or other guidance to address contaminated
soil at the Site. Refer to soil PRG in the table above. The
No Action Alternative does not achieve the soil PRGs.
Since all alternatives involve removal of soil and any
treatment options would be expected to meet the soil
PRGs for the soil placed back on the ground, post-
excavation soil samples would verify attainment of the
PRGs. Imported soil for backfill under Soil Alternative 3
would be tested to verify conformance with the allowable
constituent levels for imported fill soil. Since Soil
Alternative 2 (solidification) would not achieve any
reduction in soil TCE concentrations, the CAMU would
need to comply with the requirements for a liner, leachate
collection, cap, and groundwater monitoring.
Long-Term Effectiveness and Permanence
The No Action Alternative provides no long-term
effectiveness toward achieving the RAOs. All alternatives
prevent direct contact with residual impacts. Soil
Alternative 3 provides the greatest long-term effectiveness
and permanence since the TCE-impacted soil media is
removed from the Site. If proven effective through pilot
testing, Soil Alternative 4 (LTTD) will permanently
reduce TCE concentrations on-Site.
Reduction of Toxicity, Mobility, or Volume Through
Treatment
Soil Alternative 1, (No Action), would not address the
contamination through treatment, so there would be no
reduction in toxicity, mobility, or volume of the
contaminants, and the alternative does not include long-
term monitoring of groundwater conditions. Soil
Alternative 2 (solidification) would reduce the mobility
but not the toxicity or volume of TCE impacted soil
media. Soil Alternative 3 (off-Site disposal) would reduce
the toxicity, mobility, and volume on-Site; however, the
off-Site reduction in toxicity and/or volume depends on
20
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the form of treatment/disposal at the Treatment, Storage
and Disposal Facility (TSDF). Soil Alternative 4
(LTTD) would reduce the volume of TCE in the soil
media but the overall reduction in volume and toxicity
depends on the form of emissions control employed.
Short-Term Impact and Effectiveness
Soil Alternative 1 would not have short-term adverse
impacts because no action would be implemented. All
other soil alternatives would result in noise, dust, and
vapor impacts; however, these are considered minimal
and controllable through proper construction techniques.
Evaluation of additional emissions controls for crushing
that might be required under Soil Alternative 2
(solidification) would be considered during pilot-testing.
Except for Soil Alternative 2, the work would be
sequenced to minimize the time the excavation will
remain open and safety measures would be in place.
Construction of a CAMU for Soil Alternative 2 would
require an open excavation for a significant period to
install the liner and leachate collection system. Soil
Alternative 4 would require significant fuel for the
LTTD reactor and, since natural gas is not available near
the Site, propane or heating oil tanks would need to be
kept on-Site resulting in short-term risk to both human
health and the environment.
Implementability
Soil Alternative 1 (No Action) would be the easiest of all
the alternatives to implement because there would be no
remedy to implement. Soil Alternative 2 (solidification)
would have significant technical and administrative
implementability issues surrounding construction of a
CAMU in the Spill Zone. Since ex-situ solidification and
stabilization of the soil media does not result in a TCE
concentration reduction, the CAMU would have to
comply with the requirements for a liner, leachate
collection system, cap, and groundwater monitoring.
Administrative issues include require agency approval of
the CAMU design. The impacted soil media would need
to be excavated and stockpiled or placed in roll off
containers pending CAMU construction. The impacted
material would need to be covered to prevent erosion.
Design and construction of a CAMU would extend the
time for these remedial alternatives by approximately 12
months. Other implementability issues include
determining the type and amount of binding agent that
will effectively solidify the impacted soil media and
securing the appropriate equipment. The footprint of the
CAMU would need to be larger than the excavation area
to manage the grade change due to volume increases
through the addition of the solidification agent.
Soil Alternative 3 (off-Site disposal) would require
traffic coordination for off-Site transport to the TSDF,
securing a disposal contract with out-of-State TSDF, and
locating a borrow source for backfill material. Soil
Alternative 4 requires a pilot test to verify effectiveness,
securing specialized equipment for LTTD, and emissions
control. Soil Alternative 4 is estimated to take up to 18
months to implement.
Cost
A comparative summary of the cost estimates for each
alternative is presented in Table 5.
State Acceptance
NYSDEC is currently evaluating EPA's preferred
alternatives as stated in this Proposed Plan.
Community Acceptance
Community acceptance of the preferred alternative will be
evaluated after the public comment period ends and all
comments are reviewed. Comments received during the
public comment period will be addressed in a
responsiveness summary section of the upcoming ROD.
PREFERRED ALTERNATIVES
Climate resiliency was evaluated in reviewing the
alternatives. Potential Site impacts from climate change
have been assessed and EPA's preferred alternative would
be not at risk as a result of the expected effects of climate
change in the region and near the Site.
After a thorough review of the proposed remedial
alternatives, EPA recommends the following preferred
remedy for the various media:
1. Groundwater: For the approximately four-mile
TCE plume, EPA proposes a combination of
monitoring and ICs while invoking a TI waiver for
chemical-specific groundwater ARARs in the TI
Zone because groundwater cannot be restored in a
reasonable timeframe. Outside of the TI Zone, the
ARARs will remain as the final cleanup goal.
Long-term monitoring and groundwater use
restrictions would be required.
2. Bedrock Vadose Zone - BYZ Alternative 2: ICs
and Groundwater Monitoring. The BVZ and the
groundwater in the Spill Zone is included in the
extent of the TI zone (Figure 4).
3. Soil - Alternative 3: Excavation and off-Site
disposal.
21
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4. Surface Water - Alternative 5: In-situ treatment
of contaminated surface water with streambed
cover, ICs, and monitoring.
5. Common Elements:
a. Institutional Controls in the form of
governmental controls (see Appendix C of FS
Report); proprietary controls (e.g., easements on
Spill Zone parcels); and informational devices
relating to groundwater, soil vapor, and the Spill
Zone (e.g., notices, publications) to limit
exposure to contaminated groundwater and soil
vapor;
b. Monitoring, which includes sampling, of
groundwater, surface water, soil vapor and
indoor air as follows:
i. A long-term groundwater monitoring
program would be implemented to track and
to monitor changes in the groundwater
contamination to ensure the RAOs are
attained.
ii. The groundwater data results would be used
to evaluate any contaminant migration and
changes in VOC contaminants over time.
c. Maintenance of existing SSDSs and
installation of new systems, as needed, for
impacted properties; and
d. Connection of new homes constructed over
the groundwater plume to the current municipal
water supply system or the provision of a point-
of-entry treatment system if connection to the
municipal system is not feasible.
With this comprehensive remedy for OU1 and OU2, this
Proposed Plan also proposes the following changes to
the OU1 ROD:
1. Eliminating the BVE source control measure;
2. Eliminating ex-situ SVE;
3. Updating the surface water standard for TCE
from the original cleanup goal of 11 (.ig/L to the
current NYSDEC standard of 40 (ig/L;
4. Addressing soil contamination beneath Gulf
Road by implementing ICs to restrict access and
to require proper soil management if the roadbed
is disturbed in the future; and
5. Updating the RAOs as discussed above.
A Site Management Plan (SMP) would also be
developed for long-term O&M to provide for:
a) reviews of the effectiveness of the engineering
and institutional controls;
b) proper management of the Site remedy post-
construction;
c) long-term groundwater monitoring and health and
safety requirements;
d) maintenance of existing vapor mitigation systems;
e) inspection of the plume area for new home
construction and associated installation of new
vapor mitigation systems; and
f) new connections to the public waterline or the
provision of a point-of-entry treatment system if
connection to the municipal system is not feasible.
Because this preferred alternative would result in
contaminants remaining on-Site above levels that allow
for unlimited use and unrestricted exposure, CERCLA
requires that the Site remedy be reviewed at least once
every five years. Also, provisions would be made for
periodic reviews and certifications of the institutional and
engineering controls. If justified by these reviews,
additional remedial action may be implemented at the
Site.
Green remediation techniques may be implemented as part
of the preferred alternative to minimized environmental
impacts consistent with EPA Region 2's Clean and Green
Policy4 and NYSDEC's Green Remediation Program
Policy-DER-31.5
The total, estimated, present worth cost for the proposed
remedy is $14,082,504 (see Table 5). Further details of the
overall cost are presented in the FS Report.
Basis for the Remedy Preference
The preferred alternative for groundwater involves a TI
waiver of chemical-specific ARARs based on the
following factors: (1) the limited options available to
successfully treat contamination in fractured bedrock with
extensive evidence of matrix diffusion into the rock over a
wide area; (2) the expected limited ability of the
groundwater contamination to expand beyond its current
extent; and, (3) the limited potential for treatment or
containment of contamination remaining in the Spill Zone
to result in a measurable improvement in groundwater
quality anywhere in the aquifer within a reasonable time
period. It also includes monitoring and institutional
controls, mentioned as common elements.
4 https://www.epa.gov/greenercleanups/epa-region-2-clean-and-
green-policv
5 http://www.dec.ny.gov/docs/remediation_hudson_pdf/der31 .pdf.
22
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The preferred alternative for Bedrock Vadose Zone -
BVZ Alternative 2: ICs and Groundwater Monitoring
was selected over BVZ Alternatives 3a and 3b. As
demonstrated in the FS, the source reduction RAOs
cannot be met because of matrix diffusion, complexity
of the fracture network, and the groundwater elevation
fluctuations in the BVZ. The active remedial BVZ
alternatives (3a and 3b) would not achieve any
appreciable reduction of TCE mass in the long term due
to the matrix diffusion mechanisms that occur between
the bedrock matrix porewater and the groundwater
media, which would be expected to continue for a
significant period of time into the future. This is also the
basis for EPA proposing a TI waiver as to restoration of
groundwater. The implementation of long-term
groundwater monitoring and ICs would provide for an
effective means of mitigating potential exposure to TCE-
impacted bedrock media, and to Site groundwater that is
impacted by the TCE that is present within the bedrock
media.
The preferred Soil alternative (Soil Alternative 3 -
excavation and off-Site disposal) was selected over other
alternatives because it is expected to achieve the greatest
degree of long-term effectiveness and permanence by
removing impacted soils. Excavation Soil Alternative 3
is technically feasible, is a proven technology and more
reliable than the soil treatment presented in Soil
Alternatives 4 and 5. It is expected that this alternative
could be substantially implemented within five to six
months at a cost comparable to the other alternatives and
provide for long-term reliability of the remedy.
The preferred Surface Water - SW Alternative 5: in-situ
treatment of contaminated surface water with streambed
cover, ICs and monitoring, was selected over other
alternatives because it is expected to achieve substantial
and long-term risk reduction through treatment of
contaminants, and the use of engineering and
institutional controls. The preferred SW Alternative
reduces the risk within a reasonable time frame, at a cost
comparable to other alternatives, and provides for long-
term reliability of the remedy. A PDI would be
undertaken and include collection of seasonal data in the
Mud Creek area for flow conditions, groundwater
elevations, surface water quality, and identification of
fractured rock or karst subsurface flow pathways.
Based upon the information currently available, EPA
believes that the preferred alternatives meet the threshold
criteria and provide the best balance of trade-offs among
the other alternatives with respect to the balancing
criteria.
As discussed above, EPA is proposing an ARAR waiver
for the federal and state drinking water and groundwater
standards at the Site because of the technical
impracticability of achieving ARARs in the TI Zone.
EPA expects the preferred remedy to satisfy the following
statutory requirements of Section 121(b) of CERCLA: (1)
the proposed remedy is protective of human health and the
environment; (2) it complies with ARARs for all media
except for where ARARs are waived; (3) it is cost
effective; (4) it utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable; and (5) it
satisfies the preference for treatment.
FOR FURTHER INFORMATION
The Administrative Record file, which contains copies of the
Proposed Plan and technical supporting documentation, is
available at the following information repositories:
USEPA-Region H
Superfimd Records Center
290 Broadway, 18th Floor
New York, New York 10007-1866
(212)637-4325
Hours: Monday - Friday: 9:00 am to 4:30 pm
In addition, the Administrative Record file is available on-line
on the Site Profile Page:
https://www.epa.gov/superfund/lehigh-vallev-rr
For general information or questions about EPA's
Superfimd program, please contact the EPA Regional Public
Liaison: George Zachos, zachos.george(S?epa.gov or (732)
321-6621 or toll free at (888) 283-7626.
23
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Table 5: Costs for the Proposed Remedy
Media
Description
Capital Cost
OdtM Cost
Institutional
Controls Costs
Present-Worth
Cost
Groundwater
TI waiver (includes
monitoring)
$0
$2,253,200
$524,000
$2,778,000
Soil Vapor
Intrusion
Indoor air
$0
$659,704
$0
$659,704
Bedrock
Vadose Zone
Alternative BVZ - 2:
ICs and Groundwater
Monitoring
$0
$0
$137,250
$137,250
Soil
Alternative 3 -
excavation and off-Site
disposal
$3,017,897
$62,000
$121,750
$3,202,000
Surface Water
Alternative SW-5: In-
situ treatment of
contaminated surface
water with streambed
cover, ICs and
monitoring
$4,121,550
$3,102,250
$81,750
$7,305,550
Total
SI 4,082,504
Note: The soil alternative includes one foot of clean soil cover
in areas of the Spill Zone where surface soil exceeds 2 mg/kg,
which is the SCO value for the protection of ecological
receptors.
24
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Unicorn Management
.Consultants, IXC
52 Feaera *oaa
Sutt 2C
Danoury. CT
06810
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-------
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Consultant*, I.T.C
52 Federal Road
Suite 2C
~anbury. CT
06810
w™ LBh*h v*!,cy R"'r:>ad
Project Name. Stpecfund S*
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Project #:
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LVRR Work Area
OW-11
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:w-02
Legend
LVRR Wells
~ Spill Area
Existing DEC Well Clusters
© Observation Wells
Extraction Wells
.yMajor Transmission Line
v* Streams
Railroad
ISB Roads
SPILL AREA
Figure 2
26
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*
*
Legend
BtgCprtng
U3c*jy Cprrg
AfpTMmMSpflArM
TCE PUT*- way 2017
ivw Monitomg vmw OuK«f
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-------
Tl Zone 1
(Red Area)
NOTES:
- Original Figure 7 from UMC Report
(Draft FS Tech Memo "Feb-2015").
- Some wells within Tl Zones 1 and 2
(Red and Yellow Areas, i.e.. LVRR-34)
may also be part of the long term monitoring plan.
1,500 3,000
LVRR-25
\
Tl Zone 2
(Yellow Area)
Monitoring Zone
(Gray Area)
6,000
9,000
TFeet
12,000
LVRR TCE Groundwater Concentration Zones
I
Unicom Management
Consultants, LLC
52 Federal Road
Suite 2C
Danbury, CT
06810
(203) 205-9000
Lehigh Valley Railroad
Derailment Superfund Site
Figure 2-1
Feasibility Study Report
Author: CRW/RTM
Project#: 2032
Scale: 1in:2,250ft
Created: 2/18/15
Revised: 8/1/23
File:
Fig2-1_TCE_Zones
New York State
> = Approximate Site Location
Legend
| Approximate Spill Zone
• Monitoring Well Cluster
Stream
Road
| Groundwater Zone 1: TCE Concentration >1000 ppb
| Groundwater Zone 2: TCE Concentration >5 ppb
~! Groundwater Zone 2: TCE Concentration >1 ppb
Figure 4
28
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ATTACHMENT B
PUBLIC NOTICE
-------
4% Jl United States
Environmental Protection
#m Agency
EPA Invites Public Comment on Proposed Cleanup Plan Addressing Groundwater,
Bedrock, Soil, Soil Vapor and Surface Water at the Lehigh Valley Railroad Derailment
Superfund Site in LeRoy, New York
The U.S. Environmental Protection Agency (EPA) has issued a proposed final cleanup plan for
the Lehigh Valley Railroad Derailment Superfund site in LeRoy, New York.
A 30-day public comment period on EPA's proposed cleanup plan begins on August 18, 2023,
and ends on September 18, 2023. EPA's proposed preferred alternative calls for excavating and
disposing contaminated soil off-site, monitoring and maintaining the current vapor mitigation
systems and installing new systems when required, plus connecting newly constructed homes
over the groundwater plume to the municipal water supply system. Contaminated surface water
will be addressed through in-situ (in place) treatment with a streambed cover. The contamination
in the groundwater and bedrock zone above the water table will continue to be monitored. EPA
also calls for utilizing institutional controls in the form of governmental controls, proprietary
controls (e.g., easements) and informational devices and monitoring as components of the
cleanup plan.
EPA will hold an in-person public meeting at 6:00 p.m. on August 29, 2023, at the Caledonia
Mumford High School, 99 North Street, Caledonia, New York, for public input to the proposed
cleanup plan.
The proposed cleanup plan is available at: https://www.epa.gov/superfund/lehigh-valley-rr
You may also find the plan at the site's two local repositories; Caledonia Public Library, 3108
Main Street, Caledonia, NY and the Woodward Memorial Library, Wolcott Street, LeRoy, NY;
or at the EPA Records Center, 290 Broadway, 18th floor, New York, New York.
Written comments regarding EPA's preferred cleanup plan must be submitted by September 19,
2023, to Maria Jon, Remedial Project Manager, EPA Region 2, 290 Broadway, 19th floor, New
York, New York 10007-1866, or preferably via email: ion.maria@epa.gov.
You may contact Michael Basile, EPA Community Involvement Coordinator at
basile.michael@epa. gov with any questions.
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ATTACHMENT C
PUBLIC MEETING TRANSCRIPT
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND
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PUBLIC MEETING
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Tuesday, August 29, 2023 - 6:00 p.m.
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Caledonia-Mumford High School, Caledonia, New
York
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
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1 (Beginning of Audio Recording.)
2 MR. BASILE: Can I have your attention,
3 please? I think we're going to start this
4 6:00 meeting at 6:04. No, I'm very punctual.
5 I'm sorry, but my feeling is we invited you to
6 a 6:00 meeting, and we're going to start on
7 time, and there's no need to waste in waiting.
8 My name is Mike Basile. On behalf of
9 the United States Environmental Protection
10 Agency, let me welcome you to the Lehigh
11 Valley Railroad Derailment Superfund Site
12 meeting here in Caledonia.
13 I work out of the field office up in
14 Buffalo, handle 38 community relations sites
15 like this one, and have been involved with the
16 Lehigh Valley for almost two and a half
17 decades.
18 We're going to have -- pretty simple.
19 You can see the agenda that you picked up at
20 the sign-in table. We're going to have about
21 three speakers. I'm going to just kind of
22 facilitate the beginning and the end with
23 questions and answers. We are having this
24 preceding tonight videotaped so that I ask you
25 to please let our speakers make their
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1 presentations, and then they will -- we'll do
2 questions and answers.
3 I will be coming into the audience to
4 ask you to raise your hand. When you're
5 identified and I bring the microphone to you,
6 I'll ask you to spell and state your name and
7 spell and state the street and your mailing
8 address just for the record. Okay. Because
9 it's important that we have that information.
10 We have a variety of different speakers
11 from EPA. From Region 2, Region 2 we cover
12 New York, New Jersey, the Virgin Islands, and
13 Puerto Rico. And this evening we have a bunch
14 of speakers that are members of the team that
15 I serve on from our 2 90 Broadway headquarters
16 in downtown New York.
17 One of the representatives will not be
18 on the agenda, but I'd like to introduce him
19 and just recognize him. Damian Duda, our
20 Superfund remedial section branch chief. He's
21 down front here. He'll probably be available
22 to answer some questions later on.
23 From the New York State Department of
24 Environmental Conservation, who are partners
25 with us, Jeff Dyber. Jeff.
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1 From the New York State Department of
2 Health, Chris Budd and Chris Nicastro. And
3 from Livingston County, Mark Rove. Mark,
4 where are you? Mark's over here. And is Star
5 O'Neil here from Monroe County? Star is not
6 here. Okay.
7 We are here tonight to listen to a
8 presentation as we roll out the proposed plan
9 for the Lehigh Valley Railroad Derailment
10 Site. We are in a -- are currently in a 30-
11 day public comment period that ends on
12 September the 18th. If this evening you don't
13 have any questions, but you think of something
14 while you're driving home over the holiday
15 weekend, just keep the agenda, and you have
16 the information there on how you can send your
17 comments in to us that have to be postmarked
18 no later than September the 18th. Okay?
19 At this time, I'd like to go into the
2 0 agenda and call upon let's see, where's the
21 clicker? Right here. The mouse. Okay.
22 There we go. There we go. Okay, I'm going to
23 call upon the remedial project manager was
24 going to give you an overview for the site,
25 and that is Maria Jon. Maria?
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MS. WIEDER: I'll do the history.
MR. BASILE: Oh, you're going to do the
3 history. Okay. Maria Wieder, the site
4 attorney, is going to do the history first.
5 Okay.
6
MS. WIEDER: Thank you, Mike. So
7 you've all seen the agenda. We're going to
8 talk a little bit about the site history, talk
9 a little bit about the remedial
10 investigations, the risk assessment results,
11 the remedial action objectives that we chose
12 for the site, the remedial alternatives that
13 we have debated and discussed in terms of the
14 feasibility study, the preferred remedy, which
15 will be -- is embodied in the proposed plan.
16 And then we'll have a little time for some
17 questions and answers.
18 So a lot of you, I'm sure, are familiar
19 with the site already, so I'm not going to go
20 into a lot of detail. But the site is located
21 in Genesee, Monroe, and Livingston counties.
22 And as you know, this was the site of the
23 1970s train derailment.
24 So over 50 years ago, the Lehigh Valley
25 Railroad, two cars ruptured, spilled over with
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1 with TCE. It was about 30,000 gallons. And
2 TCE is also called Trichloroethane. And this
3 is the primary contaminant of concern at the
4 site. It's a volatile, organic compound and
5 it's quite common on a lot of our sites.
6 So the area where it spilled, this is
7 called the spill zone so as not to confuse
8 anybody, and it's about a ten-acre site. So
9 when we talk more about the alternatives,
10 Maria will be referencing what we plan on
11 doing in that area.
12 So unfortunately, the TCE was flushed
13 with water and it seeped into the ground and
14 formed the four-mile plume that we have here
15 today. Early in the '90s, New York State had
16 undertaken some sampling, and they had found a
17 number of homes exceeded the drinking water
18 standards in the area. EPA came in with the
19 removal program and installed groundwater
20 filters to protect people from the TCE and the
21 groundwater.
22 Then DEC went into a process of study,
23 so they went into their remedial investigation
24 and feasibility study. Eventually in 19 --
25 unbelievable -- 1997, they released their
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1 record of decision for the site, which is
2 their decision document. And this was
3 released under state law. So this wasn't
4 under the federal superfund program, and this
5 was to address the TCE that was in the soil,
6 the bedrock, as well as provide clean drinking
7 water for people.
8 So in about 1998 was when DEC requested
9 that EPA come on board and take over
10 responsibility for the site. EPA included the
11 site on the national priorities list, which
12 enables us to use superfund money to do the
13 work. So that freed up a lot of funding for
14 us to be able to undertake the work on
15 installing the water line with our partners at
16 DEC.
17 So in 1999, we formally concurred on
18 DEC'S water line portion of the remedy.
19 Later, a few years later, we concurred on the
2 0 source control part of their remedy and that
21 was the soil and the bedrock components. But
22 we also decided that we needed to go a little
23 further, and we felt a further remedial
24 investigation and feasibility study would be
25 necessary to look at the rest of the
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1 groundwater plume in the area.
2 So by 2003, the water line was
3 constructed, and that's currently providing
4 about 70 affected residents with clean water.
5 Now, this is just a little chart to show you
6 about the Superfund remedy process. So we
7 took it over. We took responsibility over
8 from DEC, and most of our time has been spent
9 here in the remedial investigation, risk
10 assessment, and feasibility study squares,
11 which we'll talk about.
12 So in order to get the work implemented
13 and to get our remedial investigation and
14 feasibility study underway, EPA negotiated
15 with the potentially responsible party, who is
16 the Lehigh Valley Railroad Company, to perform
17 the work.
18 And during the Rl/FS process, the
19 railroad investigated the nature and extent of
20 the contamination at the site, and that
21 includes the groundwater, soil, bedrock,
22 surface water, and also the vapors that were
23 coming into homes that were located over the
24 plume.
25 EPA then worked with Lehigh Valley
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1 Railroad, and we issued them what we call a
2 friendly order for them to initiate the work
3 on the soil. So we were all in agreement on
4 trying a certain technology called soil vapor
5 extraction in the source area, which we tried
6 for about two years with some moderate
7 success, but we knew it wasn't going to meet
8 the final cleanup standards. So we stopped
9 that process in 2017.
10 So while all this was going on, Lehigh
11 Valley also initiated a pretty extensive vapor
12 intrusion study in the area. And afterwards,
13 after all the dust settled on all the
14 sampling. About 12 homes do have vapor
15 mitigation systems, and that's really to
16 protect the residents in those homes from
17 inhaling any of the TCE vapor.
18 We did finally get to the point where
19 the remedial investigation under EPA's
20 jurisdiction was finalized at the end of 2014.
21 And after that, there was a lot of discussion
22 on is there any way that we can really restore
23 groundwater here, and what are we going to do
24 with the TCE contamination in the bedrock?
25 We have a very complicated site, hydro-
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1 geologically speaking. So these were
2 extensive and difficult and a lot of dialog
3 with all of the stakeholders involved in this.
4 By June of 2019, the railroad did
5 submit a draft feasibility study, and that was
6 to evaluate the different remedial
7 alternatives for the site. A final FS was
8 just approved this summer, and so this is
9 where we're then going to talk about our
10 remedial project manager, Maria Jon, is going
11 to come up and talk about what we found during
12 the remedial investigation and then go into
13 the feasibility study, the alternatives we
14 looked at, and then what we feel is the
15 appropriate remedy for the site. And so,
16 Maria.
17 MS. JON: Thank you, Maria. Hi. So
18 based on the results of the remedial
19 investigation, TCE was detected in
20 groundwater, soil vapor, soil in the spill
21 zone, in the bedrock, and in section of Mud
22 Creek surface water.
23 This figure illustrates the study area,
24 which includes the ten-acre portion of the
25 spill zone. And the plume of groundwater
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1 contamination emanating from the spill area
2 to -- from the spill area, which is this this
3 section here, emanating contamination and
4 moving eastward down to Spring Creek.
5 So the remedial investigation
6 conclusions. The area we found an area
7 impacted by TCE in the groundwater. We also
8 found evidence of TCE contamination within the
9 primary pore spaces of the bedrock. This is
10 referred to as the matrix diffusion.
11 The TCE mass is in the bed - is in the
12 rock pore spaces and in microfractures
13 throughout the footprint of the plume. We
14 also found TCE vapors from the contaminated
15 groundwater that had affected homes above the
16 plume.
17 Furthermore, TCE was detected in
18 surface water in Mud Creek, located -- which
19 is located hydraulically downgradient from the
20 spill zone, including the waterfall and
21 downstream of the waterfall at up to 440
22 micrograms per liter, which exceeds the New
23 York State DEC class C surface water quality
24 standard of 40 micrograms per liter.
25 We also found soil contamination in the
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1 spill zone area a concentrations of up to 460
2 micrograms per kilogram exceeding the New York
3 State DEC soil cleanup objectives.
4 Contamination remains in the unsaturated soil
5 in the spill zone in the bedrock in nearby
6 surface water and the groundwater.
7 Site clean-ups may be divided into
8 phases or operable units to prioritize and
9 accelerate the selection of a remedy. For the
10 Lehigh Valley site, EPA designated two
11 operable units.
12 Operable Unit 1 includes alternate
13 water supply for homes impacted by the
14 groundwater contamination. This component of
15 OU1 was -- has been completed. The OU1 plan
16 also includes soil treatment within the spill
17 zone, which also has been completed, and the
18 bedrock source area treatment, which has not
19 been implemented.
2 0 Operable Unit 2 includes the
21 groundwater, the four-mile plume contaminated
22 with TCE, soil vapor intrusion into homes,
23 soil which are remaining in the spill zone
24 after treatment which has not successfully
25 removed most of the TCE in the soil, as well
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1 as contaminated groundwater discharging to
2 surface water.
3 Baseline risk assessment. Ula is going
4 to talk about the risk assessment.
5 MS. KINAHAN: All right. So a baseline
6 risk assessment is the analysis of the
7 potential adverse human health and ecological
8 effects of releases of hazardous substances
9 from a site if no actions to mitigate such
10 releases are taken under both current and
11 future land and groundwater uses.
12 A baseline risk assessment is conducted
13 during the remedial investigation phase of the
14 site, and it consists of a human health risk
15 assessment and an ecological screening level
16 ecological risk assessment. It provides the
17 basis for taking an action and identifies the
18 contaminants and exposure pathways that need
19 to be addressed by the remedial action.
20 This slide summarizes the conclusions
21 of the baseline risk assessment per media. On
22 top is the human health risk assessment
23 conclusions, and on the bottom is the
24 screening level ecological risk assessment
25 conclusions. All media at the site, including
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1 groundwater, soil, sediment, and surface
2 water, were evaluated for both human health
3 and ecological risk. Both cancer and non-
4 cancer effects were evaluated. And this slide
5 only presents the risks that exceeded EPA's
6 benchmark values.
7 So for the human health risk
8 assessment, exposure to TCE contaminated
9 groundwater via potable uses resulted in
10 unacceptable cancer risk and non-cancer
11 hazard. Exposure to TCE and soil poses an
12 unacceptable non-cancer hazard. Further
13 exposure via swimming in Mud Creek poses an
14 unacceptable non-cancer hazard.
15 Furthermore, the vapor intrusion
16 pathway was evaluated in the risk assessment,
17 and it was concluded that the potential for
18 subsurface vapor intrusion into indoor air
19 exists.
20 The screening level ecological risk
21 assessment conclusions were that there is
22 potential for risk to ecological receptors if
23 the stone cover that is part of the soil vapor
24 extraction system is removed. So currently
25 there is a soil vapor extraction system that
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1 is still in place, and it provides a barrier
2 to the contamination below the cap. And next
3 I will give it back to Maria for the remedial
4 action objectives.
5 MS. JON: Thank you. Remedial action
6 objectives, RAOs, by media. RAOs are remedial
7 action objectives that are the specific goals
8 identified during the base risk assessment to
9 protect human health and the environment. The
10 RAOs for groundwater is -- well, in this case,
11 in this particular case for the site, EPA
12 recognizes that it may not be possible to
13 restore groundwater to its designated
14 beneficial -- beneficial use in some cases.
15 In situations where from an engineering
16 perspective, it is not possible to restore all
17 or part of the groundwater plume, EPA may
18 waive the applicable or relevant and
19 appropriate requirements, ARARs, and establish
20 alternative protective remedial strategies.
21 The RAOs from the groundwater are
2 2 prevent current and human exposure via
23 ingestion, inhalation, and dermal contact to
24 site related contaminants in groundwater that
25 exceeds the federal MCLs and the state
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1 groundwater standards.
2 Prevent -- prevent further migration of
3 site-related contaminants in groundwater
4 levels exceeding the maximum contaminant
5 levels beyond the delineated area extent of
6 the groundwater and contamination of the
7 groundwater contamination, and to prevent the
8 the migration of site-related contaminants in
9 groundwater to surface water that would result
10 in exceeding applicable surface water quality
11 standards.
12 For soil vapor intrusion to mitigate
13 potential current and future unacceptable
14 risks from subsurface soil vapor intrusion
15 into indoor air.
16 Remedial action objectives for the
17 bedrock vadose zone is to mitigate, to the
18 extent practicable, the bedrock vadose zone as
19 an ongoing source of groundwater
20 contamination, accelerate long-term
21 improvement to the groundwater in a reasonable
22 time frame, and to support further risk
23 reduction for the site as a whole.
24 For soil to prevent human exposure to
25 contaminated spill zone soil via incidental
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1 ingestion and inhalation above levels that
2 pose an unacceptable risk for commercial
3 commercial use.
4 RAOs for surface waters is to prevent
5 unacceptable risk to human receptors from
6 incidental ingestion and dermal contact
7 exposure to contaminated surface and seep
8 water in Mud Creek area by reducing
9 contaminant levels to the most stringent
10 federal and state standards.
11 Based on these RAOs, EPA developed
12 cleanup levels for various media, which are
13 referred to as preliminary remediation goals
14 or PRGs.
15 Clean-up options that were evaluated in
16 the -- in the FS for each environmental media.
17 And we also develop common elements for each
18 of the alternatives except for the no-action
19 alternative.
20 Common elements include institutional
21 controls, monitoring of the groundwater,
22 surface water, soil vapor and indoor air,
23 maintenance of existing soil vapor, intrusion
24 mitigation systems, and installation of new
25 systems as needed for impacted properties, and
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1 connection of new homes constructed over the
2 groundwater plume to the municipal water
3 supply system, or the provision of a point of
4 entry treatment system if connection to the
5 municipal system is not feasible.
6 Alternative for groundwater and soil.
7 For groundwater, EPA has determined that
8 restoration of groundwater to beneficial uses
9 is technically impracticable. Therefore, EPA
10 proposes a technical impracticability waiver
11 for the federal and state drinking water and
12 groundwater standards.
13 EPA remedial strategy, which however,
14 will address exposure control, source control,
15 and aqueous plume migration control.
16 For soil vapor, the existing sub-slab
17 depressurization systems will be inspected,
18 maintained, and new system will be installed
19 on new homes as needed.
20 The cost for the institutional
21 controls, for the groundwater, as well as for
22 the soil vapor monitoring and maintenance are
23 presented on this table, and the costs are
24 estimated for a 30-year operational and
25 maintenance period.
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1 Alternatives for bedrock vadose zone.
2 The NCP requires that a no-action alternative
3 be developed and considered as a baseline for
4 comparing other remedial alternatives. For
5 the no-action alternative, contamination will
6 remain in place and there is no cost
7 associated with the no-action alternative.
8 So for the bedrock vadose Zone,
9 alternatives -- four alternatives were
10 evaluated in the feasibility study. Number
11 one, no action. Number two, monitoring and
12 institutional controls with the groundwater
13 TI waiver. The third alternative for vapor
14 bedrock vadose zone is vapor extraction in a
15 ten-acre portion of the bedrock vapor zone
16 with institutional controls and monitoring,
17 which is -- this is the remedial, the cleanup
18 that -- that was established in the New York
19 State DEC OU1 record of decision.
20 Alternative 3B, which is vapor
21 extraction in a two-acre portion of the vapor
22 vadose zone with institutional controls and
23 monitoring. The column on the right-hand side
24 are the costs associated for each of these
25 remedial alternatives presented in the FS for
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1 the bedrock vadose zone.
2 For these media, EPA prefers
3 alternative number two, which is monitoring
4 and institutional controls. The preferred
5 alternative is highlighted here in green.
6 Thank you.
7 Alternative for soil. The FS evaluate
8 four alternatives to address the contaminated
9 soil. One, the no-action. Number two, ex
10 situation solidification/stabilization.
11 Number three, excavation and offsite disposal.
12 Number four, ex situation ow temperature
13 thermal desorption treatment.
14 So for the soil remedies, EPA preferred
15 alternative is number three, excavation and
16 offsite disposal. And the costs associated
17 for each of these alternatives are presented
18 on the right-hand side right here. These are
19 the total costs for each of the remedial
20 alternatives for the soil remedies.
21 Alternative for surface water. The FS
22 evaluated five alternatives to address
23 contamination in surface water. No action.
24 Number two, institutional controls and
25 monitoring. Number three, hydraulic
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1 containment of groundwater to prevent
2 discharges to surface water with institutional
3 controls and monitoring. Number four, stream
4 cover with institutional controls and
5 monitoring. And number five, in situ
6 treatment of contaminated groundwater prior to
7 discharge to surface water with a stream bed
8 cover, institutional controls and monitoring.
9 EPA's preferred alternative is
10 Alternative five, in situ treatment of
11 contaminated groundwater prior to discharge to
12 Surface water with stream bed cover,
13 institutional controls and monitoring with the
14 estimated cost of $7.3 million.
15 EPA is also proposing to amend the OU1
16 record of decision by eliminating the bedrock
17 surface area treatment -- source area
18 treatment excuse me, eliminating the soil
19 treatment in the spill zone, updating the TCE
20 surface water standard from the original
21 cleanup goal of 11 micrograms per liter to the
22 current New York State standard of 40
23 micrograms per liter.
24 Also addressing the soil contamination
25 beneath Gulf Road by implementing
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1 institutional controls to restrict access and
2 to require proper soil management management
3 if the road bed is disturbed in the future.
4 We are also proposing to update the
5 remedial action objectives by media to
6 recognize the proposed waiver for the federal
7 and state drinking water and groundwater
8 standards at the site because the technical
9 impracticability of achieving the standards.
10 EPA uses nine criteria for the analysis
11 of alternatives. They are overall protection
12 of human health; compliance with applicable or
13 relevant and appropriate requirements, ARARs;
14 long-term effectiveness and permanence;
15 reduction of toxicity, mobility, or volume of
16 contaminant through treatment; short term
17 effectiveness; implementability; cost; state
18 acceptance of the remedy; and the community
19 acceptance of the remedy or the proposed
2 0 remedy.
21 So this slide presents a summary of
22 EPA's preferred remedy. For the groundwater,
23 the four-mile plume, a combination of
24 monitoring and institutional controls while
25 invoking a technical impracticability waiver
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1 for specific chemicals in -- for the
2 groundwater standards in the TI zone.
3 For bedrock groundwater monitoring and
4 institutional controls. For soil excavation
5 and offsite disposal. For surface water in-
6 situ treatment of contaminated surface water
7 with a stream bed cover, institutional
8 controls, and monitoring .
9 Plus the common elements, which are
10 institutional controls, long term monitoring
11 of groundwater, surface water, soil vapor, and
12 indoor air maintenance of the existing sub-
13 slab, depressurization systems, and
14 installation of new systems are as needed.
15 And connection to the water -- to the
16 municipal water supply for new construction
17 over the groundwater plume or installation of
18 a point of entry treatment systems.
19 All areas that will be impacted by the
20 remedy will be restored to the extent that is
21 applicable or feasible.
22 In summary, this slide presents the
23 components of the EPA, the EPA preferred
24 remedy and the associated costs for each
25 media, and the total estimated cost is for the
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1 entire -- for all the preferred remedies for
2 each environmental media is approximately $14
3 million.
4 EPA's preferred alternative. EPA
5 believes the preferred alternative most
6 effectively meets the nine criteria
7 evaluation -- the nine evaluation criteria.
8 Reduces risk to human health and the
9 environment; complies with applicable,
10 relevant and appropriate requirements for all
11 media except for where ARARs are waived;
12 minimizes impact of remedial activities on the
13 community; uses permanent solutions; satisfy
14 the preference for treatment; and is cost
15 effective.
16 So we are current here in the proposed
17 plan stage of the superfund remedial process.
18 And this concludes my presentation. So any
19 questions, please?
20 MR. BASILE: Thank you, Maria, Maria,
21 and Ula. We'll now go into the question and
22 answer period. If you have a question, please
23 raise your hand. And again, I remind you,
24 I'll come forth with a portable microphone.
25 Just ask you to state your name and address
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1 and spell it for the record. Are there any
2 questions?
3 MR. MOWRY: My name is William Mowry.
4 I live at 9290 York Road in Leroy. M-O-W-R-Y.
5 And my personal opinion, this has been going
6 on since 1970. I don't know of anybody that
7 has been deathly struck and ill with anything
8 from this spill.
9 We have a well that is in this aquifer
10 that is affected by this. We've had the water
11 tested, and there's no sign of TCE in the
12 water. And I think this is an absolute waste
13 of money, taxpayers' money. And I just can't
14 believe that people would go to this extent
15 for something that's been there for 55 years
16 or 53 years now and has had no effects on the
17 people.
18 And I'd hate to think of how many
19 million dollars they've already spent trying
2 0 to remedy this, and apparently have gotten
21 nowhere because they're going back to doing
22 this.
23 So I think it's just creating work for
24 some people. And -- and I don't understand
25 one other part of this. When you're going to
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Meeting on 08/29/2023 Page 26
1 remove the soil from the contaminated zone and
2 take it off site, aren't you just moving it to
3 another site? If it's contaminated, it's
4 going to stay contaminated and pose risk to
5 wherever you're moving this.
6 MR. BASILE: Thank you, sir.
7 MS. WIEDER: Maybe the team should kind
8 of come up here and your your questions and
9 comments were good. Just trying to make sure
10 we cover all of them. You had a few mixed in
11 there.
12 First of all, I'm glad that you don't
13 have any exposure scenarios going on where you
14 live. That, first of all, is really
15 important. And what I think was really
16 important for this site was when we came on
17 and when DEC came on and DOH came on, you
18 know, our first -- the first thing that we
19 have to do is look around for exposure and
20 figure out how we can mitigate that.
21 And so, you know, first it was
22 providing bottled water to people who were
23 affected, and then it was doing a lot of
24 sampling. And then it was also about working
25 with our partners at the state to not only get
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Meeting on 08/29/2023 Page 27
1 the money and get the plans and get the water
2 line implemented so the homes that were
3 affected by the contamination could be hooked
4 up and they wouldn't be exposed anymore.
5 And then there was also a pretty
6 extensive study done for the vapor issue. So
7 some people who were living above the plume --
8 and now it's like about four acres and about
9 how -- I'm sorry, about four miles and about a
10 mile and a half wide. So it's a pretty good
11 sized plume.
12 So we had to make sure that those
13 people weren't breathing in the TCE that
14 vaporized and unfortunately was in their
15 homes. So that's why we do have a series of
16 these mitigation systems that operate in their
17 homes. And I don't know if you either of you
18 want to address a little bit more about the
19 the risk issues.
2 0 MS. KINAHAN: I think you covered it
21 really well. When we first come in, and that
22 includes EPA and the state, the first thing we
23 do is make sure that there is no exposure. So
24 that's why those point of entry systems were
25 put on. People were connected to the public
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Meeting on 08/29/2023 Page 28
1 water supply, People were put on bottled water
2 initially. So that is always the first thing
3 or EPA or DEC do. So I think you spoke about
4 that and that was a good point.
5 For the excavation, once the excavation
6 and offsite disposal to facility that is
7 properly permitted and they have the proper
8 lining, all the things that you need to store
9 that waste. So it is taking it from here and
10 moving it somewhere else. But it's a safer
11 place where it won't be leaking into the
12 ground or, you know, exposure to overlying
13 buildings.
14 MS. WIEDER: Right. Right.
15 MS. JON: So let me -- let me add to a
16 little more about the contaminated soil.
17 MR. MOWRY: (Inaudible).
18 MS. JON: Well, the contaminated soil
19 that will be excavated will be transported to
20 a treatment and disposal facility that have
21 a -- they have the authority to manage and
22 treat the soil before they place the treated
23 soil in the landfill.
24 There are there are commercial
25 facilities out there that can manage the type
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1 of soil that can treat it and can properly
2 dispose of those -- of the treated soil on
3 their own facility.
4
And that1s why we are proposing for the
5 soil to do X -- to excavate and properly
6 dispose of them to a permitted disposal
7 facility.
8
MR. MOWRY: (Inaudible).
9
MS. JON: Well, for VOCs, there are
10 different ways of treating it. They could
11 they could use low -- low temperature thermal
12 treatment unit to reduce the concentrations of
13 TCE, or they could also mix it with Portland
14 cement to solidify the soil and the -- and the
15 TCE and then dispose of it properly.
16 It -- all those options that are out
17 there to dispose and treat the -- the soil
18 will be evaluated once the -- the -- the
19 company, the PRPs, are -- prepares a design
2 0 for the -- for the remedy. That's one of the
21 stages of the -- the superfund process.
22 We select the proposed remedy. So
23 right now we're here on the proposed plan.
24 After we issue a final plan, a final cleanup
25 plan, the responsible party will then prepare
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Meeting on 08/29/2023 Page 30
1 a design document for the remedy. Then they
2 will prepare -- and the design document, they
3 will specify what they are going -- there --
4 how they're going to comply with the remedy,
5 how are they going to build a treatment
6 system, how and what -- what is going to
7 include in the design, what levels they are
8 required to meet, what cleanup standards they
9 are required to meet.
10 Then once the design is approved, then
11 they put together what they call a remedial
12 action plan, which is -- which indicates how
13 they're going to implement the design of the
14 remedy.
15 Once it's completed. Then they go out
16 in the field and start construction of the
17 remedy. And once the construction is
18 completed, then we go into the monitoring
19 maintenance stage of the remedy.
2 0 MR. BASILE: Thank you, Maria. Any
21 other questions? Another question. Any
22 questions?
23 MALE VOICE: (Inaudible).
24 MS. WIEDER: Yeah, that's -- that's an
25 excellent point.
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1 MALE VOICE: Maybe you can make clear
2 who's paying for the remedy. Just to address
3 that gentleman's question.
4 MS. WIEDER: Well, hopefully the
5 responsible party, Lehigh Valley Railroad
6 Company, will be paying for the remedy. But
7 that's something after we actually release the
8 record of decision, we'll be going back to
9 them and continuing our dialogue, and
10 hopefully that's where we'll end up.
11 And -- and, sir, to your point, as
12 well, I mean, I think what I'm hearing you
13 saying, too, is that -- and -- and I think
14 what's reflected in our decision making and
15 our dialogue on all this is it's really a
16 balancing test.
17 I mean, it's clear that, you know,
18 we're not going to be able to get 100 percent
19 of the contamination. And so we have to go
2 0 back and examine the different remedial
21 alternatives for each of the impacted media
22 and see how can we do our best and and it's
23 all a balancing test with the nine criteria
24 that Maria had listed here to see which of
25 these we can put together to really make a --
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Meeting on 08/29/2023 Page 32
1 a remedy that's going to be effective in
2 reaching the remedial goals.
3 MR. BASILE: Are there any other
4 questions from the audience? Are there any
5 other questions? Wait, wait, wait, wait.
6 Coming, coming, coming. No, they can't hear
7 you, sir. Sorry. You think they can hear
8 you, but they can't hear you. Okay.
9 MR. MOWRY: I have a big mouth.
10 MR. BASILE: Last question.
11 MR. MOWRY: You understand that it took
12 you 3 0 years to take care of the drinking
13 water by putting a water line in. That was
14 the most imminent danger to -- to the public.
15 And it was 29 years before public water was
16 offered to these houses.
17 MS. WIEDER: Well, a -- on the water
18 line issue, remember, there was the spill in
19 1970. There was some immediate efforts that
2 0 went into trying to figure out how do we deal
21 with it. And at that time, it was, you know,
22 digging ditches, flushing the contamination.
23 And unfortunately, as we know now, that
24 flushes it into being a groundwater plume. So
25 at the time, there was a lot of -- a lot of
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1 sampling done. People were provided bottled
2 water for a while by EPA. Then people were
3 put on filters for a while.
4 And it wasn't until the state went back
5 in the early 1 90s and did some sampling that
6 they did find those homes that unfortunately
7 by that time, you know, you were seeing levels
8 higher than the recommended drinking water
9 standards.
10 And at that point is when the state
11 started in earnest their study of how do we
12 get a handle on this? And then we went
13 through the process of eventually getting to
14 the water line. And remember, the water line
15 was very expensive. I believe it was -- cost
16 us over $8 million.
17 So it was very important that when the
18 state came to EPA to see if the site would
19 possibly list on our national priorities list,
20 and if it would, that would give us the option
21 of making the superfund money available to
2 2 fund this.
23 And one of the tenets of our program
24 is, you know, it's about cleaning up the site
25 first and then going after a responsible party
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1 for cost recovery second.
2 So it was our priority to, you know,
3 get the site listed, get the money available,
4 get the design going. Unfortunately, it
5 doesn't happen overnight. Everybody's like,
6 well, you throw in a water line. It's a
7 little more complicated than that. But
8 everybody was moving as fast as they could to
9 get to design and construction.
10 So, you know, that's kind of the long
11 and the short of it. But, you know, I
12 understand what you're saying, but that was
13 the process to get us to the 2003 water line.
14 MR. BASILE: Any other questions? Are
15 there any other questions from anyone in the
16 audience?
17 MS. WIEDER: I think he has some more.
18 Oh.
19 MR. MOWRY: (Inaudible) file bankruptcy
20 (inaudible).
21 MS. WIEDER: Well, that's a good point.
22 They filed bankruptcy many years ago.
23 MR. MOWRY: It'll all come back --
24 it'll all come back onto the taxpayers. And
25 the superfund money isn't money that falls out
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1 of the sky.
2 MS. WIEDER: It is not. That's true.
3 MR. MOWRY: So I happen to own a
4 business, and I pay substantial taxes. So I
5 like my tax money spent properly. And I don't
6 consider this, 53 years later, the proper use
7 of $14 million when they've -- they aren't
8 going to get it. They understand they aren't
9 going to get any money back because the
10 company is bankrupt.
11 MS. WIEDER: Well -- well, here's --
12 here's the thing. And I can tell you this
13 because I'm the attorney on the site. Lehigh
14 Valley Railroad, There has been two different
15 bankruptcies. I believe it was in -- you
16 know, I can't remember the dates exactly, but
17 there was the Rail Reorganization Act and then
18 there was also a bankruptcy by Lehigh Valley
19 Railroad.
2 0 And EPA, you know, based upon federal
21 law, you know, we can pursue claims against
22 the responsible party even through bankruptcy
23 in certain cases. And this was the case here.
24 So that's why we are at the table with
25 Lehigh Valley Railroad. That's why they've
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Meeting on 08/29/2023 Page 36
1 been involved in the site and under two
2 different orders with us. And hopefully they
3 will cooperate going forward and work with us
4 to implement it.
5 And there's also a cost recovery
6 component, too, because, you know, for EPA,
7 you know, the main thing is to prevent
8 exposure to people and to clean up the site.
9 And our second priority is to get the money
10 back. Exactly. The taxpayer money back from
11 the people who are responsible for the
12 contamination.
13 And that's what we've done here. We've
14 moved forward with our money when we needed
15 to, when we needed to get things going with
16 the water line. But we do have a tab going,
17 let's say, with Lehigh Valley Railroad, and
18 they have been doing a lot of this work for
19 the last since EPA's been involved with it and
2 0 the EPA has been involved, you know, as
21 essentially lead agency for the last 25 years.
22 They've been working with us. They
23 have done a lot of work and study. And we're
24 hopeful going forward that we're going to
25 reach an agreement with them for them to
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Meeting on 08/29/2023 Page 37
1 implement the work on their dime and then to
2 reimburse EPA for its oversight costs so that
3 the taxpayers, like yourself and everybody
4 here, including me, are not paying for this.
5 MR. BASILE: Any other questions? Are
6 there any other questions? If there aren't
7 any other questions, I, on behalf of EPA and
8 the state, would like to thank you for
9 attending.
10 And again, a reminder that we do have
11 two repositories set up in your community --
12 the Woodward Memorial Library and the
13 Caledonia Public Library. And once again,
14 September 18th is the deadline for comments.
15 So if you think of something after you leave
16 here, please feel free to use the agenda to
17 email your comments to EPA by September 18th.
18 And I thank you for your interest in
19 coming this evening. Hope you have a
2 0 wonderful holiday weekend, and enjoy the rest
21 of your summer. Thank you very much. We'll
22 be here for a while to answer any questions.
23 Thank you.
24 (End of Audio Recording.)
25
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Meeting on 08/29/2023 Page 38
2
3
4
5
6
7
8
9
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
CERTIFICATE
I, Wendy Sawyer, do hereby certify that I was
authorized to and transcribed the foregoing recorded
proceedings, and that the transcript is a true record, to
the best of my ability.
DATED this 14th day of September, 2 023
/
,r
„p j, -
10 M v
V-'#
WENDY SAWYER, CDLT
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: $14..alternate
$14 24:2
35 : 7
$7.3 21:14
$8 33:16
I 12:12
100 31:18
II 21:21
12 9:14
14th 38:8
18th 4:12,
18 37 : 14,
17
19 6:24
1970 25:6
32 : 19
1970s 5:23
1997 6:25
1998 7:8
1999 7:17
2 3:11
12 : 20
2003 8:2
34 : 13
2014 9:20
2017 9:9
2019 10:4
2023 38:8
25 36:21
29 32:15
290 3:15
30 32:12
30,000 6:1
30- 4:10
3 0-year
18 : 24
38 2:14
3B 19:20
40 11:24
21:22
440 11:21
460 12:1
50 5:24
53 2 5:16
35 : 6
55 25:15
6:00 2:4,6
6:04 2:4
70 8:4
90s 6:15
33 : 5
9290 25:4
ability 3 8:5
absolute
25 : 12
accelerate
12 : 9 16:20
acceptance
22 : 18,19
access 22:1
achieving
22 : 9
acres 2 7:8
Act 3 5:17
action 5:11
13:17,19
15 :4,5,7
16 : 16
19 : 11
20 : 23 22:5
30 : 12
actions 13 : 9
activities
24 : 12
add 2 8:15
address 3 : 8
7:5 18 : 14
20:8,22
24 : 25
27 : 18 31:2
addressed
13 : 19
addressing
21 : 24
adverse 13:7
affected 8 : 4
11 : 15
25 : 10
26:23 27:3
agency 2:10
36:21
agenda 2:19
3:18 4:15,
20 5:7
37 : 16
agreement
9:3 36:25
air 14:18
16 : 15
17 : 22
23 : 12
alternate
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: alternative..branch
12 : 12
alternative
15 : 20
17:19 18:6
19:2,5,7,
13 ,20
20:3,5,7,
15, 21
21:9,10
24 :4, 5
alternatives
5:12 6:9
10:7,13
17 : 18
19:1,4,9,
25 20:8,
17,20,22
22 : 11
31:21
amend 21:15
analysis
13 : 6 22:10
answers 2:23
3:2 5:17
anymore 2 7:4
apparently
25 : 20
applicable
15 : 18
16 : 10
22 : 12
23 : 21 24:9
approved
10:8 30:10
approximately
24 : 2
aqueous
18 : 15
aquifer 25:9
ARARS 15:19
22 : 13
24 : 11
area 6:6,
11,18 8:1
9:5,12
10 : 23
11:1,2,6
12:1,18
16:5 17:8
21 : 17
areas 23:19
assessment
5:10 8:10
13:3,4,6,
12,15,16,
21,22,24
14:8,16,21
15 : 8
attending
37 : 9
attention
2 : 2
attorney 5 : 4
35 : 13
audience 3 : 3
32:4 34:16
Audio 2 : 1
37 : 24
authority
28 : 21
authorized
38:3
B
back 15:3
25 : 21
31:8,20
33 : 4
34:23,24
35:9 36:10
balancing
31 : 16,23
bankrupt
35 : 10
bankruptcies
35 : 15
bankruptcy
34 : 19,22
35 : 18,22
barrier 15 : 1
base 15:8
based 10:18
17 : 11
35 : 20
baseline
13:3,5,12,
21 19:3
Basile 2:2,8
5:2 24 : 20
26:6 30:20
32:3,10
34 : 14 37:5
basis 13:17
bed 11:11
21 : 7,12
22:3 23 : 7
bedrock 7:6,
21 8:21
9 : 24 10:21
11:9 12:5,
18 16:17,
18 19:1,8,
14,15 20:1
21 : 16 23 :3
beginning
2:1,22
behalf 2 : 8
37 : 7
believes
24 : 5
benchmark
14 : 6
beneath
21 : 25
beneficial
15:14 18:8
big 32:9
bit 5:8,9
27 : 18
board 7 : 9
bottled
26 : 22 28:1
33 : 1
bottom 13:23
branch 3:20
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: breathing.xonstruction
breathing
27 : 13
bring 3 : 5
Broadway
3 : 15
Budd 4 : 2
Buffalo 2 : 14
build 3 0:5
buildings
28 : 13
bunch 3:13
business
35:4
C
Caledonia
2 : 12 37:13
call 4:20,
23 9:1
30:11
called 6:2,7
9:4
cancer 14:3,
4,10
cap 15:2
care 3 2:12
cars 5:25
case 15:10,
11 35:23
cases 15:14
35 : 23
CDLT 3 8:12
cement 2 9:14
CERTIFICATE
38 : 1
certify 3 8:2
chart 8 : 5
chemicals
23 : 1
chief 3:20
chose 5:11
Chris 4 : 2
claims 3 5:21
class 11:23
clean 7 : 6
8:4 36:8
Clean-up
17 : 15
clean-ups
12 : 7
cleaning
33 : 24
cleanup 9 : 8
12:3 17:12
19 : 17
21:21
29:24 30:8
clear 31:1,
17
clicker 4:21
column 19:23
combination
22 : 23
comment 4:11
comments
4:17 26:9
37 : 14,17
commercial
17:2,3
28 : 24
common 6 : 5
17:17,20
23 : 9
community
2 : 14 22:18
24 : 13
37 : 11
company 8:16
29:19 31:6
35 : 10
comparing
19:4
completed
12 : 15,17
30 : 15,18
compliance
22 : 12
complicated
9:25 34:7
complies
24 : 9
comply 3 0:4
component
12 : 14 36:6
components
7:21 23:23
compound 6 : 4
concentrations
12 : 1 29:12
concern 6 : 3
concluded
14 : 17
concludes
24 : 18
conclusions
11 : 6
13 : 20,23 ,
25 14:21
concurred
7:17,19
conducted
13 : 12
confuse 6 : 7
connected
27 : 25
connection
18:1,4
23 : 15
Conservation
3 : 24
considered
19:3
consists
13 : 14
constructed
8:3 18:1
construction
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: contact..determined
23 : 16
30:16,17
34 : 9
contact
15:23 17:6
containment
21 : 1
contaminant
6:3 16:4
17:9 22:16
contaminants
13 : 18
15 : 24
16 :3, 8
contaminated
11 : 14
12 : 21 13 : 1
14 : 8 16:25
17:7 20:8
21:6,11
23 : 6 26:1,
3,4 28:16,
18
contamination
8:20 9:24
11:1,3,8,
25 12:4,14
15:2 16:6,
7,20 19:5
20 : 23
21:24 27:3
31:19
32 : 22
36 : 12
continuing
31 : 9
control 7:20
18:14,15
controls
17 : 21
18 : 21
19:12,16,
22 20:4,24
21:3,4,8,
13 22:1,24
23:4,8,10
cooperate
36:3
cost 18:20
19:6 21:14
22 : 17
23 : 25
24 : 14
33 : 15 34:1
36 : 5
costs 18:23
19 : 24
20:16,19
23:24 37:2
counties
5:21
County 4:3,5
cover 3:11
14 : 23
21:4,8,12
23:7 26:10
covered
27:20
creating
25 : 23
Creek 10:22
11:4,18
14:13 17:8
criteria
22 : 10
24:6,7
31 : 23
current
13 : 10
15 : 22
16 : 13
21 : 22
24 : 16
D
Damian 3:19
danger 3 2:14
DATED 3 8:8
dates 35:16
day 4:11
38 : 8
deadline
37 : 14
deal 3 2:20
deathly 25:7
debated 5:13
DEC 6:22
7:8,16 8:8
11:23 12:3
19 : 19
26:17 28:3
DEC 1s 7:18
decades 2:17
decided 7:22
decision
7:1,2
19 : 19
21 : 16
31 : 8,14
delineated
16 : 5
Department
3 : 23 4:1
depressurizati
on 18:17
23 : 13
derailment
2:11 4:9
5 : 23
dermal 15:23
17 : 6
design 2 9:19
30:1,2,7,
10, 13
34:4,9
designated
12 : 10
15 : 13
desorption
20 : 13
detail 5:20
detected
10 : 19
11 : 17
determined
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: develop..established
18 : 7
develop
17 : 17
developed
17:11 19:3
dialog 10:2
dialogue
31 : 9,15
difficult
10 : 2
diffusion
11 : 10
digging
32 : 22
dime 3 7:1
discharge
21:7,11
discharges
21 : 2
discharging
13 : 1
discussed
5 : 13
discussion
9 : 21
disposal
20 : 11,16
23 : 5 28:6,
20 29:6
dispose
29:2,6,15,
17
disturbed
22:3
ditches
32 : 22
divided 12:7
document 7 : 2
30:1,2
DOH 2 6:17
dollars
25 : 19
downgradient
11 : 19
downstream
11 : 21
downtown
3 :16
draft 10:5
drinking
6:17 7:6
18:11 22:7
32 : 12 33:8
driving 4:14
Duda 3:19
dust 9:13
Dyber 3:25
E
early 6:15
33 : 5
earnest
33 : 11
eastward
11:4
ecological
13:7,15,
16, 24
14:3,20,22
effective
24 : 15 32:1
effectively
24 : 6
effectiveness
22 : 14,17
effects 13 : 8
14 : 4 25:16
efforts
32 : 19
elements
17:17,20
23 : 9
eliminating
21 : 16,18
email 3 7:17
emanating
11:1,3
embodied
5 : 15
enables 7:12
end 2:22
9:20 31:10
37 : 24
ends 4:11
engineering
15 : 15
en j oy 3 7:20
entire 24 : 1
entry 18:4
23 : 18
27 : 24
environment
15:9 24 : 9
environmental
2:9 3:24
17 : 16 24 : 2
EPA 3:11
6:18 7:9,
10 8:14,25
12 : 10
15:11,17
17 : 11
18:7,9,13
20:2,14
21 : 15
22 : 10
23:23 24:4
27 :22 28:3
33:2,18
35 : 20
36:6,20
37:2,7,17
EPA1s 9:19
14 : 5 21:9
22:22 24:4
36 : 19
essentially
36:21
establish
15 : 19
established
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
Meeting on 08/29/2023
PUBLIC MEETING
Index: estimated..found
19 : 18
estimated
18 : 24
21 : 14
23 : 25
evaluate
10:6 20:7
evaluated
14: 2 , 4 ,16
17 : 15
19 : 10
20:22
29 : 18
evaluation
24 : 7
evening 3:13
4:12 37:19
eventually
6:24 33:13
Everybody1s
34 : 5
evidence
11 : 8
examine
31:20
excavate
29 : 5
excavated
28 : 19
excavation
20:11,15
23:4 28:5
exceeded
6:17 14 : 5
exceeding
12:2 16:4,
10
exceeds
11 : 22
15 : 25
excellent
30:25
excuse 21:18
existing
17 : 23
18 : 16
23 : 12
exists 14:19
expensive
33 : 15
exposed 2 7:4
exposure
13 : 18
14:8,11,13
15 : 22
16:24 17:7
18 : 14
26 : 13,19
27 : 23
28:12 36:8
extensive
9:11 10:2
27 : 6
extent 8:19
16:5,18
23 : 20
25 : 14
extraction
9:5 14:24,
25 19:14,
21
facilitate
2 : 22
facilities
28 : 25
facility
28:6,20
29:3,7
falls 34:25
familiar
5 : 18
fast 34:8
feasibility
5:14 6 : 24
7:24 8:10,
14 10:5,13
19 : 10
feasible
18:5 23:21
federal 7 : 4
15 : 25
17 : 10
18:11 22:6
35 : 20
feel 10:14
37 : 16
feeling 2 : 5
felt 7:23
field 2:13
30 : 16
figure 10:23
26 : 20
32 : 20
file 34:19
filed 34:22
filters 6:20
33 : 3
final 9 : 8
10:7 29:24
finalized
9 : 20
finally 9:18
find 33:6
flushed 6:12
flushes
32 : 24
flushing
32 : 22
footprint
11 : 13
foregoing
38:3
formally
7 : 17
formed 6:14
forward
36 :3,14,24
found 6:16
10 : 11
11:6,8,14,
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: four-mile..impacted
25
good 2 6:9
33 : 12
18:1,19
four-mile
27:10 28:4
happen 3 4:5
27:2,15,17
6:14 12:21
34 : 21
35:3
33 : 6
22 : 23
green 2 0:5
hate 25:18
hooked 2 7:3
frame 16:22
ground 6:13
hazard
Hope 3 7:19
free 3 7:16
28 : 12
14:11,12,
hopeful
freed 7 : 13
groundwater
14
36 : 24
friendly 9 : 2
front 3:21
6:19,21
hazardous
houses 3 2:16
8:1,21
9:23
13 : 8
human 13:7,
FS 10:7
17 : 16
19 : 25
10:20,25
He'll 3:21
14, 22
11:7,15
12:6,14,21
headquarters
3 : 15
14 : 2,7
15:9,22
13:1,11
16:24 17:5
20:7,21
14:1,9
health 4 : 2
22:12 24 : 8
fund 3 3:22
15:10,13,
13:7,14,22
14 :2, 7
hydraulic
funding 7:13
17,21,24
15:9 22:12
20 : 25
future 13:11
16:1,3,6,
24 : 8
hydraulically
7,9,19,21
16:13 22:3
17 : 21
hear 3 2:6,
11 : 19
18:2,6,7,
7 , 8
hydro- 9:25
G
8,12,21
hearing
gallons 6 : 1
19 : 12
31 : 12
I
21:1,6,11
higher 33:8
Genesee 5:21
22:7,22
identified
gentleman1s
23:2,3,11,
highlighted
3:5 15 : 8
31:3
17 32 : 24
20 : 5
identifies
geologically
Gulf 21:25
history 5:1,
13 : 17
10 : 1
3,4,8
ill 25:7
give 4:24
H
holiday 4:14
illustrates
15:3 33 :20
half 2:16
37:20
10 : 23
glad 2 6:12
27:10
home 4:14
imminent
goal 21:21
hand 3 : 4
homes 6:17
32 : 14
goals 15:7
24 : 23
8:23 9:14,
16 11:15
impact 24:12
17 : 13 32:2
handle 2:14
12 : 13,22
impacted
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
Meeting on 08/29/2023
PUBLIC MEETING
Index: implement..knew
11:7 12:13
17 : 25
23 : 19
31:21
implement
30:13 36:4
37 : 1
implementabili
ty 2 2:17
implemented
8:12 12 : 19
27 : 2
implementing
21 : 25
important
3:9 26 : 15,
16 33 : 17
impracticabili
ty 18:10
22:9,25
impracticable
18 : 9
improvement
16 : 21
in- 23:5
inaudible
28:17 29:8
30 : 23
34 : 19,20
incidental
16:25 17:6
include
17:20 30:7
included
7 :10
includes
8:21 10 :24
12:12,16,
20 27:22
including
11 : 20
13 :25 37:4
indoor 14:18
16 : 15
17 : 22
23 : 12
information
3:9 4:16
ingestion
15 : 23
17:1,6
inhalation
15:23 17:1
inhaling
9 :17
initially
28 : 2
initiate 9 : 2
initiated
9 :11
inspected
18 : 17
installation
17 : 24
23:14,17
installed
6:19 18:18
installing
7 : 15
institutional
17 : 20
18 : 20
19:12,16,
22 20:4,24
21:2,4,8,
13 22:1,24
23:4,7,10
interest
37 : 18
introduce
3 : 18
intrusion
9:12 12:22
14:15,18
16 : 12,14
17 : 23
investigated
8 : 19
investigation
6:23 7:24
8:9,13
9 : 19
10 : 12,19
11:5 13 : 13
investigations
5 : 10
invited 2 : 5
invoking
22 : 25
involved
2 : 15 10:3
36:1,19,20
Islands 3:12
issue 2 7:6
29 : 24
32 : 18
issued 9 : 1
issues 2 7:19
Jeff 3:25
Jersey 3:12
Jon 4:25
10 : 10,17
15 : 5
28 : 15,18
29 : 9
June 10:4
jurisdiction
9 : 20
K
kilogram
12 : 2
KINAHAN 13:5
27 : 20
kind 2:21
26:7 34:10
knew 9 : 7
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
Meeting on 08/29/2023
PUBLIC MEETING
Index: land..miles
land 13:11
landfill
28 : 23
law 7 : 3
35 : 21
lead 3 6:21
leaking
28 : 11
leave 3 7:15
Lehigh 2:10,
16 4:9
5:24 8:16,
25 9:10
12 : 10 31:5
35 : 13,18,
25 36:17
Leroy 2 5:4
level 13:15,
24 14:20
levels 16:4,
5 17:1,9,
12 30:7
33 : 7
Library
37:12,13
lining 2 8:8
list 7:11
33 : 19
listed 31:24
34:3
listen 4 : 7
liter 11:22,
24 21:21,
23
live 2 5:4
26 : 14
living 2 7:7
Livingston
4:3 5:21
located 5:20
8:23
11:18,19
long 23:10
34 : 10
long-term
16 : 20
22 : 14
looked 10:14
lot 5:18,20
6:5 7 : 13
9:21 10:2
26 : 23
32 : 25
36 : 18,23
low 2 9:11
M
M-O-W-R-Y
25:4
mailing 3 : 7
main 3 6:7
maintained
18 : 18
maintenance
17 : 23
18 :22,25
23 : 12
30:19
make 2:25
26 : 9
27 : 12,23
31:1,25
making 31:14
33 : 21
MALE 3 0:23
31 : 1
manage
28 : 21,25
management
22 : 2
manager 4:23
10 : 10
Maria 4:25
6 : 10
10 : 10,16
15:3 24:20
30:20
31 : 24
Mark 4 : 3
Mark1s 4:4
Maria 5 : 3
10 : 17
24 : 20
mass 11:11
matrix 11:10
maximum 16:4
MCLS 15:25
media 13 : 21,
25 15:6
17 : 12,16
20:2 22:5
23 : 25
24 : 2,11
31:21
meet 9 : 7
30:8,9
meeting 2:4,
6, 12
meets 24:6
members 3:14
Memorial
37 : 12
microfractures
11 : 12
micrograms
11 :22,24
12 : 2
21 : 21,23
microphone
3:5 24:24
migration
16:2,8
18 : 15
Mike 2 : 8
5 : 6
mile 2 7:10
miles 2 7:9
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: million..part
million
21:14 24:3
25 : 19
33:16 35:7
minimizes
24 : 12
mitigate
13 : 9
16:12,17
26 : 20
mitigation
9:15 17 : 24
27 : 16
mix 2 9:13
mixed 2 6:10
mobility
22 : 15
moderate 9 : 6
money 7:12
25 : 13 27:1
33 : 21
34:3,25
35:5,9
36 : 9,10,14
monitoring
17 : 21
18 : 22
19:11,16,
23 20:3,25
21:3,5,8,
13 22:24
23:3,8,10
30:18
Monroe 4 : 5
5:21
mouse 4:21
mouth 3 2:9
moved 3 6:14
moving 11:4
26:2,5
28:10 34:8
Mowry 2 5:3
28:17 29:8
32:9,11
34:19,23
35:3
Mud 10:21
11 : 18
14:13 17:8
municipal
18:2,5
23 : 16
N
national
7:11 33:19
nature 8:19
NCP 19:2
nearby 12:5
needed 7:22
17 : 25
18 : 19
23 : 14
36:14,15
negotiated
8 :14
Nicastro 4 : 2
no-action
17 : 18
19:2,5,7
20 : 9
non- 14:3
non-cancer
14:10,12,
14
number 6:17
19 : 10,11
20:3,9,11,
12,15,24,
25 21:3,5
0
01 NEIL 4:5
objectives
5:11 12 :3
15:4,6,7
16:16 22:5
offered
32 : 16
office 2 : 13
offsite
20 : 11,16
23 : 5 28:6
ongoing
16 : 19
operable
12:8,11,
12, 20
operate
27 : 16
operational
18 : 24
opinion 25:5
option 33:20
options
17 : 15
29 : 16
order 8:12
9 : 2
orders 3 6:2
organic 6 : 4
original
21 : 20
OU1 12:15
19 : 19
21 : 15
overlying
28 : 12
overnight
34 : 5
oversight
37 : 2
overview
4 : 24
ow 2 0:12
P
part 7:20
14 : 23
15 : 17
25 : 25
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE
Meeting on 08/29/2023
PUBLIC MEETING
Index: partners..prior
partners
3:24 7 : 15
26 : 25
party 8:15
29:25 31:5
33 : 25
35 : 22
pathway
14 : 16
pathways
13 : 18
pay 3 5:4
paying 31:2,
6 37:4
people 6:20
7:7 25 : 14,
17, 24
26 : 22
27:7,13,25
28:1 33:1,
2 36:8,11
percent
31 : 18
perform 8:16
period 4:11
18 : 25
24 : 22
permanence
22 : 14
permanent
24 : 13
permitted
28:7 29:6
personal
25 : 5
perspective
15 : 16
phase 13:13
phases 12:8
picked 2:19
place 15:1
19 : 6
28:11,22
plan 4 : 8
5 :15 6:10
12 : 15
24 : 17
29:23,24,
25 30:12
plans 2 7:1
plume 6:14
8:1,24
10:25
11 : 13,16
12 : 21
15 : 17
18:2,15
22 : 23
23 : 17
27:7,11
32 : 24
point 9:18
18:3 23:18
27:24 28:4
30:25
31 : 11
33 : 10
34 : 21
pore 11:9,
12
portable
24 : 24
portion 7:18
10 : 24
19 : 15,21
Portland
29 : 13
pose 17:2
26:4
poses 14:11,
13
possibly
33 : 19
postmarked
4 : 17
potable 14 : 9
potential
13 : 7
14:17,22
16 : 13
potentially
8 : 15
practicable
16 : 18
preceding
2 : 24
preference
24 : 14
preferred
5 : 14 20:4,
14 21:9
22 : 22
23 : 23
24 : 1,4, 5
prefers 2 0:2
preliminary
17 : 13
prepare
29:25 30:2
prepares
29 : 19
presentation
4:8 24:18
presentations
3 : 1
presented
18 : 23
19 : 25
20 : 17
presents
14 : 5 22:21
23 : 22
pretty 2:18
9:11 27:5,
10
prevent
15 : 22
16:2,7,24
17:4 21:1
36 : 7
PRGS 17:14
primary 6 : 3
11 : 9
prior 21:6,
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: priorities..reflected
11
21 : 15 22:4
16 : 10
16 : 21
priorities
29:4
question
receptors
7:11 33:19
protect 6:20
24 : 21,22
14:22 17:5
prioritize
9:16 15:9
30:21 31:3
recognize
12 : 8
protection
32 : 10
3:19 22:6
priority
2:9 22:11
questions
recognizes
34:2 36:9
protective
2:23 3:2,
15 : 12
proceedings
15:20
22 4 : 13
5:17 24:19
recommended
38:4
provide 7 : 6
25:2 26:8
33 : 8
process 6:22
provided
30:21,22
record 3 : 8
8:6,18 9:9
33 : 1
32:4,5
7:1 19:19
24 : 17
providing
34 : 14,15
21:16 25:1
29:21
8:3 26:22
3 7:5,6,7,
31:8 38:4
33:13
22
provision
recorded
34 : 13
38:3
18:3
D
program 6:19
K
Recording
2:1 37:24
7:4 33 :23
PRPS 29:19
Rail 3 5:17
project 4:23
public 4:11
railroad
2:11 4:9
10 : 10
27:25
32 : 14,15
recovery
34:1 36:5
proper 22:2
37 : 13
5:25 8:16,
reduce 2 9:12
28:7 35:6
19 9:1
Puerto 3:13
10:4 31:5
Reduces 24:8
properly
28:7 29:1,
punctual 2 : 4
35 : 14,19,
reducing
5,15 35:5
pursue 3 5:21
25 36:17
17 : 8
properties
put 27:25
raise 3 : 4
reduction
17 : 25
28:1 30:11
24 : 23
16 : 23
proposed 4 : 8
31:25 33 :3
RAOS 15:6,
22 : 15
5:15 22:6,
putting
10,21
referencing
19 24:16
32 : 13
17:4,11
6 : 10
29:22,23
reach 3 6:25
referred
proposes
Q
reaching
11 : 10
18 : 10
32 : 2
17 : 13
quality
reflected
31 : 14
proposing
11 : 23
reasonable
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: Region..ruptured
Region 3:11
reimburse
37 : 2
related
15 : 24
relations
2 : 14
release 31:7
released
6:25 7:3
releases
13:8,10
relevant
15 : 18
22 : 13
24 : 10
remain 19:6
remaining
12 : 23
remains 12:4
remedial
3:20 4:23
5:9,11,12
6:23 7:23
8:9,13
9:19 10:6,
10,12,18
11 : 5
13:13,19
15:3,5,6,
20 16:16
18 : 13
19:4,17,25
20:19 22:5
24:12,17
30:11
31:20 32:2
remediation
17 : 13
remedies
20:14,20
24 : 1
remedy 5:14
7:18,20
8:6 10:15
12 : 9
22:18,19,
20,22
23:20,24
25 : 20
29:20,22
30 : 1,4,14,
17, 19
31:2,6
32 : 1
remember
32 : 18
33 : 14
35 : 16
remind 24:23
reminder
37:10
removal 6:19
remove 2 6:1
removed
12 : 25
14 : 24
Reorganization
35 : 17
repositories
37 : 11
representative
s 3:17
requested
7 : 8
require 2 2:2
required
30:8,9
requirements
15 : 19
22 : 13
24 : 10
requires
19 : 2
residents
8:4 9:16
responsibility
7:10 8:7
responsible
8:15 29:25
31:5 33:25
35 : 22
36 : 11
rest 7:25
37:20
restoration
18 : 8
restore 9:22
15 : 13,16
restored
23 : 20
restrict
22 : 1
result 16:9
resulted
14 : 9
results 5:10
10 : 18
RI/FS 8:18
Rico 3:13
right-hand
19 : 23
20 : 18
risk 5:10
8:9 13:3,
4,6,12,14,
16,21,22,
24 14:3,7,
10,16,20,
22 15:8
16 : 22
17:2,5
24 : 8 26:4
27 : 19
risks 14:5
16 : 14
road 21:25
22:3 25:4
rock 11:12
roll 4 : 8
Rove 4 : 3
ruptured
5 : 25
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: safer..squares
S
safer 2 8:10
sampling
6:16 9:14
26 : 24
33:1,5
satisfy
24 : 13
Sawyer 3 8:2,
12
scenarios
26 : 13
screening
13:15,24
14 : 20
section 3:20
10:21 11 :3
sediment
14 : 1
seep 17:7
seeped 6:13
select 2 9:22
selection
12 : 9
send 4:16
September
4:12,18
37:14,17
38 : 8
series 2 7:15
serve 3:15
set 3 7:11
settled 9 :13
short 22:16
34 : 11
show 8 : 5
side 19:23
20 : 18
sign 25:11
sign-in 2:20
simple 2:18
sir 2 6:6
31:11 32:7
site 2:11
4 :10,24
5:3,8,12,
19,20,22
6:4,8 7:1,
10,11 8:20
9:25 10:7,
15 12:7,10
13:9,14,25
15:11,24
16:23 22:8
26:2,3,16
33:18,24
34:3 35 : 13
36:1,8
site-related
16:3,8
sites 2 : 14
6:5
s i tu 21:5,
10 23 : 6
situation
20 : 10,12
situations
15 : 15
sized 27:11
sky 3 5:1
slab 23:13
slide 13:20
14 :4 22 :21
23 : 22
soil 7:5,21
8:21 9:3,4
10 : 20
11 : 25
12:3,4,16,
22,23,25
14:1,11,
23 , 25
16:12,14,
24, 25
17 :22,23
18:6,16,22
20:7,9,14,
20 21:18,
24 22:2
23 :4,11
26 : 1
28:16,18,
22, 23
29:1,2,5,
14 , 17
solidification
/stabilization
20:10
solidify
29 : 14
solutions
24 : 13
source 7:20
9:5 12:18
16 : 19
18 : 14
21 : 17
spaces 11:9,
12
speakers
2:21,25
3:10,14
speaking
10 : 1
specific
15 : 7 23 : 1
spell 3:6,7
25 : 1
spent 8 : 8
25:19 35:5
spill 6 : 7
10 : 20,25
11:1,2,20
12:1,5,16,
23 16:25
21:19 25:8
32 : 18
spilled 5:25
6 : 6
spoke 2 8:3
Spring 11:4
squares 8:10
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: stage..TCE
stage 24:17
37 : 8
subsurface
swimming
30:19
States 2 : 9
14 : 18
14 : 13
stages 2 9:21
stay 2 6:4
16 : 14
system
stakeholders
stone 14:23
success 9 : 7
14 : 24,25
18:3,4,5,
10:3
successfully
stopped 9 : 8
12:24
18 30:6
standard
11 : 24
store 2 8:8
summarizes
systems 9:15
21 : 20,22
strategies
13 : 20
17 : 24,25
18:17
standards
15:20
summary
23 :13,14,
6:18 9:8
strategy
22 : 21
18 27:16,
16:1,11
18 : 13
23 : 22
24
17 : 10
stream 21:3,
summer 10:8
18 : 12
7,12 23 : 7
37:21
T
22:8,9
23 : 2 30:8
street 3 : 7
superfund
tab 3 6:16
33 : 9
stringent
2:11 3:20
7:4,12 8:6
table 2:20
Star 4:4,5
17:9
24 : 17
18 : 23
start 2:3,6
struck 25:7
29:21
35 : 24
30:16
study 5:14
33 : 21
taking 13:17
started
6:22,24
34 : 25
28 : 9
33 : 11
7:24 8:10,
supply 12:13
talk 5 : 8
state 3:6,7,
23 4:1
14 9:12
10:5,13,23
18:3 23 : 16
28 : 1
6:9 8:11
10:9,11
19:10 27:6
13 : 4
6:15 7:3
33 : 11
support
11:23 12:3
36 : 23
16 : 22
tax 3 5:5
15 : 25
17 : 10
sub- 23:12
surface 8:22
10 : 22
taxes 3 5:4
18 : 11
sub-slab
11 : 18,23
taxpayer
19 : 19
18 : 16
12 : 6 13 : 2
36 : 10
21 : 22
submit 10:5
14:1 16:9,
taxpayers
22:7,17
10 17:4,7,
34 :24 37:3
24:25
substances
26 : 25
27 : 22
13 : 8
22 20:21,
taxpayers 1
substantial
23 21:2,7,
12,17,20
25 : 13
33:4,10,18
35:4
23:5,6,11
TCE 6:1,2,
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: team..vapor
12,20 7:5
9:17,24
10 : 19
11:7,8,11,
14 , 17
12:22,25
14:8,11
21 : 19
25 : 11
27 : 13
29 : 13,15
team 3:14
26 : 7
technical
18 : 10
22:8,25
technically
18 : 9
technology
9:4
temperature
20 : 12
29 : 11
ten-acre 6 : 8
10 : 24
19 : 15
tenets 33:23
term 2 2:16
23 : 10
terms 5:13
test 31:16,
23
tested 25:11
thermal
20 : 13
29 : 11
thing 2 6:18
27:22 28:2
35:12 36:7
things 2 8:8
36 : 15
throw 3 4:6
TI 19:13
23 : 2
time 2 : 7
4:19 5:16
8:8 16:22
32:21,25
33 : 7
today 6:15
tonight 2:24
4 : 7
top 13:22
total 2 0:19
23 : 25
toxicity
22 : 15
train 5:23
transcribed
38:3
transcript
38:4
transported
28:19
treat 2 8:22
29:1,17
treated
28:22 29:2
treating
29:10
treatment
12:16,18,
24 18:4
20 : 13
21:6,10,
17,18,19
22 : 16
23:6,18
24 : 14
28 : 20
29:12 30:5
Trichloroethan
e 6:2
true 3 5:2
38:4
two-acre
19 : 21
type 2 8:25
U
Ula 13:3
24 : 21
unacceptable
14:10,12,
14 16:13
17 :2, 5
unbelievable
6 : 25
understand
25 : 24
32 : 11
34 : 12 35:8
undertake
7 : 14
undertaken
6 : 16
underway
8 : 14
unit 12:12,
20 29:12
United 2 : 9
units 12:8,
11
unsaturated
12 : 4
update 2 2:4
updating
21 : 19
V
vadose
16 : 17,18
19:1,8,14,
22 20:1
Valley 2:11,
16 4:9
5:24 8:16,
25 9:11
12 : 10 31:5
35 : 14,18,
25 36:17
values 14:6
vapor 9:4,
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LEHIGH VALLEY RAILROAD DERAILMENT SUPERFUND SITE PUBLIC MEETING
Meeting on 08/29/2023 Index: vaporized..zone
11,14,17
10 : 20
12 : 22
14:15,18,
23 , 25
16:12,14
17:22,23
18:16,22
19:13,14,
15,20,21
23:11 27:6
vaporized
27 : 14
vapors 8:22
11 : 14
variety 3:10
Virgin 3 : 12
VOCS 2 9:9
VOICE 30:23
31 : 1
volatile 6 : 4
volume 22:15
W
wait 3 2:5
waiting 2 : 7
waive 15:18
waived 24:11
waiver 18:10
19 : 13
22:6,25
waste 2 : 7
25:12 28:9
water
17
18
22
11 :
12 :
13 :
16 :
17 :
18 :
20 :
21 :
20
23 :
15,
25 :
26 :
28 :
32 :
17
14
36 :
6 : 13 ,
7:7,15,
8:2,4,
10 : 22
18, 23
6, 13
2 14 : 2
9,10
8,22
2, 11
21, 23
2,7,12,
22 : 7
5,6,11,
16
10, 12
22 27:1
1
13,15,
33:2,8,
34:6,13
16
waterfall
11:20,21
waters 17:4
ways 2 9:10
weekend 4:15
37:20
Wendy 3 8:2,
12
wide 2 7:10
Wieder 5:1,
3,6 26:7
28 : 14
30:24 31:4
32 : 17
34:17,21
35 :2,11
William 2 5:3
wonderful
37:20
Woodward
37 : 12
work 2:13
7:13,14
8:12,17
9:2 25:23
36 :3,18,23
37 : 1
worked 8:25
working
26 : 24
36:22
years 5:24
7:19 9:6
25:15,16
32:12,15
34:22 35:6
36:21
York 3:12,
16,23 4:1
6:15 11:23
12:2 19:18
21:22 25:4
zone 6 : 7
10 : 21,25
11 : 20
12:1,5,17,
23 16:17,
18, 25
19:1,8,14,
15,22 20:1
21:19 23 : 2
26 : 1
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ATTACHMENT D
WRITTEN COMMENTS
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Unicorn Management
ConsuItaufs, IXC
Memorandum
Date 9-12-2023
T« M. Hill, Esq.
From! F. Trejo and A. Leonard
RE: Timely submittal of c»niments, during the public comment period that ends on
September 18,2023, for the Superfund Proposed Plan for the Lehigh Valley
Railroad Derailment Superfund Site, located In LeRoy, New York
Unicom Management Consultants, LLC (UMC), on betel of the Lehigh Valley Railroad
Company (LVRR). has carefully reviewed and considered the United Stated Environmental
Protection Agency's (USEPA) Superfund Proposed Plan for tie Lehigh Valley Railroad
Derailment Superfund Site, located in LeRoy, New York (Proposed Plan). In general, UMC is
in agreement with the USEPA Proposed Plan; however, UMC respectfully requests the
USEPA to consider the following questions and comments related to the General Proposed
Plan and Preferred Surface Water Remedy.
1. The cost to implement the USEPA's Preferred Remedy ($14,082,504) is
unreasonable when considering the incomplete risk pathways to human health and
the environment after the installation of the waterline, vapor intrusion mitigation
systems, proposed institutional controls (ICs) and monitoring.
2. The Preferred Surface Water Remedy ($7,305,550) proposes the implementation of
irt-siu treatment of contaminated surface water with streambed cover, ICs, and
monitoring. The Site remedial investigations, conceptual Site model, and feasibility
study identify the technical impracticability challenges with ir»-situ treatment of
surface water with or without a streambed cover. These challenges include but are
not limited to:
a. It is unlikely that the irv-situ treatment can be effectively dispersed or
emplaced within the fractured bedrock media underneath Mud Creek which
acts as a continuing source of ICE to the groundwater and surface water
within the Study Area and Mud Creek Area of Interest. To implement a
surface water in-situ technology would require extensive knowledge of the
fracture networks and connectivity of the seep areas which has been
determined to be technically impractical when evaluating remedial options
for other media. Even with extensive fracture network knowledge,
successful implementation of in-situ technologies may not be possible or at
best may require friat-and-error installations that may inadvertently cause
new contaminated seeps. Regardless, the irv-situ technology will not
address the ICE source (bedrock microfractures and pore spaces) to
surface water.
b. Fouling of in-situ treatment points, associated fractures, and seeps may
occur and can result in the inadvertent daylighting of contaminated
groundwater at previously uncontaminated seep locations following a path
Page 1 of 2
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Memorandum
of least resistance. Also, the treatments for fouling typically use acidic
solutions to dissolve precipitates. The applications of these fouling
treatments may negatively alter surface water characteristics.
c. It will be challenging to achieve remediation goals if the location, orientation,
and hydraulic conductivity of the fractures and other subsurface flow paths
that may be contributing to the flows and seeps are technically impracticable
to identify. Also, it will be challenging to achieve remediation goals if the
water flow is too high/turbulent to allow for appropriate contact time with
media.
d. The routine maintenance and repair of the in-situ technology beneath or
within proximity to the streambed cover could prove challenging especially
during precipitation and/or flooding events that occur in the vicinity and
upgradient/upstream of the Mud Creek Area of Interest.
e. The preferred surface water remedy would include the clearing of vegetation
and trees, construction of access roads, installation of in-situ treatment
infrastructure and other support structures within and in the vicinity of the
streambed, excavation of the streambed associated with the in-situ
treatment, establishment of power source and backup power source, etc.
f. TCE data from surface water samples that have been collected at various
locations along Mud Creek show a 50% decrease in TCE concentrations
after only flowing 200 feet along the creek bed (Mudcreek-03 to Mudcreek-
02). These data and observations suggest that the surface water flowing
along the streambed of Mud Creek is subjected to natural degradation
processes that likely include aeration, volatilization, and/or dilution.
Turbulent flow along the streambed has been observed due to the presence
of rocks in the streambed that create obstacles to the natural flow of surface
water which promotes volatilization and likely accounts for the significant
reduction of TCE in downstream surface water samples from the Mud
Creek Falls to below 40 |jg/L (remedial goal) at the southern inlet to Mud
Creek Pond. The streambed cover alone could help to enhance the natural
process by creating more obstacles for surface water flow while minimizing
changes to the chemistry of Mud Creek and maintaining a low carbon
footprint overtime.
g. A pre-remedial design investigation will not change the fact that it is
technically impractical to obtain extensive knowledge of the fracture
networks and connectivity of the seep areas with current technology or to
anticipate precipitation events within the areas contributing to the fluxes of
allogenic water into the Mud Creek area of interest (approximately 484
million gallons per month).
UMC respectfully requests the USEPA to review the above comments and consider the
Surface Water Alternative 4, Streambed cover with ICs and monitoring, as the preferred
USEPA surface water remedy.
Page 2 of 2
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From:
To:
Subject:
Date:
Basile. Michael
Duda. Damian: Wieder. Maria: Jon. Maria
Fwd: Lehigh Valley Railroad Derailment Superfund Site
Tuesday, August 29, 2023 5:08:34 PM
FYI
Thanks Mike
Begin forwarded message:
From: "Swierkos, John (The Dolomite Group)"
Date: August 29, 2023 at 3:10:24 PM EDT
To: "Basile, Michael"
Cc: "Haley, Thomas P (DEC) (thomas.haley@dec.ny.gov)"
, jeffrey slade
Subject: Lehigh Valley Railroad Derailment Superfund Site
Good afternoon Mr. Basile,
I just found out about the public meeting and I'm unable to attend. I wanted to bring it
to your attention that Dolomite Products Company Inc. was never allowed the
opportunity to connect to the water line the DEC installed in 2003. We are the second
closest to the spill site and yet have no potable water. Question would be why did the
connection not happen? I'm still reviewing the proposal plan, I may forward other
comments if any. Thank you for your attention to this detail.
Regards,
John Swierkos Jr. PG
Geologist & Environmental Coordinator
The Dolomite Group
A CRH Company
800 Parker Hill Drive, Suite 400
Rochester, NY 14625
0+1(585) 381-7010
C+l(585) 749-2371
E iswierkosir@olomitegroup.com
www.dolomitegroyD.com
-------
From:
To: Jpb,,Mm
Subject; Gulf road/TCE clean up
Date; Tuesday, August 29, 2023 12:56:35 PM
Good i
1 grew up a|IB||BHHj||||||uid 1 am familiar with the spill, and migration of TCE over the years (And played in
the creek' etc, but that was prior to any known high concentrations 70*s and 80 s). I was just reading the
announcement about the town meeting and the importance of proper soil management. My mother is still on|
HHjnd recently noticed tlial dirt next to the spill is being disturbed She is concerned that the person who lives
across from the site is moving dirt to his property. .Vie you or someone from your team able to investigate, or is this
part of the EPA/NYS DEC plans? We could like our names to be kept private in case of an investigation of a
neighbor. I am unfortunately unable to go to the town meeting tonight, but I did start perusing the larger document
online.
Thank you for your time.
Sincerely,
Sent from my iPhone
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