RECORD OF DECISION
Operable Unit Five
Olean Well Field Superfund Site
City of Olean, Cattaraugus County, New York
/y _
LGA
iSSl*
United States Environmental Protection Agency
Region 2
New York, New York
September 2023
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DECLARATION
SITE NAME AND LOCATION
Olean Well Field Superfund Site
City of Olean, Cattaraugus County, New York
Superfund Site Identification Number: NYD980528657
Operable Unit: 05
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's (EPA's)
selection of a remedy for Operable Unit 5 (OU5) at the Olean Well Field Superfund site (Site), in
Cattaraugus County, New York. This remedy is being chosen in accordance with the requirements of
the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended
(CERCLA), 42 U.S.C. Sections 9601-9675, and the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300. This decision document explains the factual and legal
basis for selecting the OU5 remedy for 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 on the
proposed remedy in accordance with CERCLA Section 121(f), 42 U.S.C. Section 9621(f), and it
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 actions selected in this OU5 ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The response action in this OU5 ROD actively addresses soil contamination at a discrete area of the
property located at 1695 Seneca Avenue, Olean, New York (AVX Property). This discrete area has
been designated by EPA as OU5. OU5 includes contaminated soil that is located beneath and near
the footprint of a former manufacturing building located in the northern portion of the Historical
Source Area1 at the AVX Property. In prior EPA decision documents AVX is sometimes referred to
as AVX Corporation (AVX)2.
1 A September 1996 ROD for Operable Unit 2 (OU2 ROD) addressed the four known sources of the contamination in the
groundwater, including the AVX Property. A September 2015 amendment to the OU2 ROD (OU2 AVX ROD Amendment) that
modified the AVX component of this remedy, defined the Historical Source Area as generally consisting of soil and groundwater
contamination in a shallow groundwater unit known as the Downgradient Till Unit beneath the former AVX manufacturing building
and the land at the southeast corner of the building immediately proximate thereto, including the shallow north-south trending
drainage swale that begins to the south of the building. The OU2 AVX ROD Amendment provides further details regarding geologic
and hydrogeologic conditions at the Site.
2 In 2020, AVX Corporation became a wholly owned subsidiary of Kyocera Corporation. In 2021, AVX's name changed to Kyocera
AVX Components Corporation or KAVX. The owner of record of the property is still listed as AVX.
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The 0U2 AVX ROD Amendment selected an interim remedy to address soil and groundwater at the
AVX Property. An interim remedy was selected because a final remedy, requiring restoration of the
City Aquifer, would not be possible until the soil under the active AVX manufacturing building
became accessible and additional soil characterization and testing could be conducted. The OU2 AVX
ROD Amendment specified that in the event there was a change in use of the manufacturing building,
a feasibility study would need to be performed to evaluate whether further action in the form of source
control and/or restoration actions was necessary to achieve the OU2 ROD goal of aquifer restoration.
Therefore, a feasibility study to determine a final remedy could not be completed until the AVX
property was no longer operating as an active manufacturing facility. In April 2018, AVX ceased
operations at the facility and in 2020 the building was demolished. This allowed for additional
characterization and the performance of a feasibility study for contaminated soil located beneath and
near the footprint of the former manufacturing building. EPA has designated this portion of the
Historical Source Area as OU5 at the Site.
The major components of the interim remedy selected by the OU2 AVX ROD Amendment included:
maintenance of existing exposure barriers (the building and paved areas) in the northern portion of
the Historical Source Area and the vegetative cover in the drainage swale area (to address soil
contamination); construction and operation of a hydraulic trench containment system to address
groundwater in the Downgradient Till Unit; hydraulic pumping to contain groundwater in the City
Aquifer; implementation of institutional controls; implementation of a long-term groundwater
monitoring program; and development of a Site Management Plan (SMP) to provide for the proper
management of the interim remedy post-construction. Refer to the OU2 AVX ROD Amendment for
a detailed description of the interim remedy.
The major components of the selected remedy for OU5 of the Site include the following:
• Demolition and removal of the existing concrete slab floor and foundation supports;
• Excavation of contaminated unsaturated soil located beneath and near the footprint of the former
manufacturing building in the northern portion of the Historical Source Area;
• Off-Site transportation and disposal of excavated material; and
• Restoration with imported clean fill material.
As part of the remedial design, further evaluations will be conducted to define the depth of the water
table and resulting excavation. If determined practicable, additional limited active remediation will
be performed below the water table to address saturated soil in an effort to improve remediation
timeframes for groundwater. During the remedial design, additional soil sampling will also be
conducted to further evaluate the extent of contamination, including 1,4-dioxane.
The selected OU5 remedy to address contaminated soil located beneath and near the footprint of the
former manufacturing building, in conjunction with the OU2 AVX ROD Amendment, constitutes the
final remedy for the AVX Property.
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The institutional controls to restrict use of the property to industrial uses, as selected in the OU2 AVX
ROD Amendment, continue to apply to the AVX Property and as such apply to this selected remedy
as well.
The environmental benefits of the selected remedy may be enhanced by employing design
technologies and practices that are sustainable in accordance with EPA Region 2's Clean and Green
Energy Policy.3 During the remedial design, green remediation concepts, including the use of low-
sulfur vehicles and the proximity to the landfill that receives the excavated soil in an effort to reduce
the impacts associated with truck trips, will be considered.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy satisfies the statutory requirements for remedial actions set forth in Section 121
of CERCLA, 42 U.S.C. § 9621, as follows: 1) it is protective of human health and the environment;
2) it meets a level or standard of control of the hazardous substances, pollutants, and contaminants
that at least attains the legally applicable or relevant and appropriate requirements under federal and
state laws unless a statutory waiver is justified; 3) it is cost-effective; and 4) it utilizes permanent
solutions and alternative treatment or resource recovery technologies to the maximum extent
practicable. In addition, Section 121 of CERCLA, 42 U.S.C. § 9621, includes a preference for
remedies that employ treatment that permanently and significantly reduces the volume, toxicity, or
mobility of hazardous substances as a principal element. Although it is not currently anticipated, if
necessary, in order to meet the requirements of the disposal facilities, contaminated material will be
treated prior to land disposal; only under such circumstances would the selected remedy partially
satisfy the preference for treatment.
The OU5 selected remedy, in combination with the OU2 AVX ROD Amendment, will result in
hazardous substances, pollutants, or contaminants remaining in and around the drainage swale
area at the AVX Property above levels that would otherwise allow for unlimited use and
unrestricted exposure. As a result, in accordance with Section 121(c) of CERCLA, statutory
reviews will be conducted no less often than once every five years to ensure that the remedy
remains protective of human health and the environment.
ROD DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this OU5 ROD.
Additional information can be found in the Administrative Record for this Site.
- A discussion of the current nature and extent of soil and groundwater contamination is
included in Section 5;
- Chemicals of concern and their respective concentrations may be found in Section 7
"Summary of Site Risks" and Table 1 in Appendix II;
- Potential adverse effects associated with exposure to Site contaminants may be found in
Section 7, "Summary of Site Risks;"
3 http://www.epa.gov/greenercleanups/epa-region-2-clean-andgreen-policy and also
http://www.dec.ny.gov/docs/remediation_hudson_pdf/der31 .pdf.
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- A discussion of cleanup levels for chemicals of concern may be found in Section 8 "Remedial
Action Objectives" and in Table 9 in Appendix II;
- Current and reasonably-anticipated future land use assumptions are discussed in Section 6
"Current and Potential Future Land and Resource Uses;"
- Estimated capital, annual operation and maintenance, and total present-worth costs are
discussed in Section 9 "Summary of Remedial Alternatives;" and
- Key Factors in the detailed analyses of remedial alternatives (e.g., how the selected remedy
provides the best balance of tradeoffs with respect to the balancing and modifying criteria)
may be found in Section 10 "Comparative Analysis of Alternatives" and Section 13
"Statutory Determinations."
AUTHORIZING SIGNATURE
Evangelista
Pat
Digitally signed by Pat
Evangelista
Date: 2023.09.27
23:26:59 -04OT
September 27, 2023
Pat Evangelista, Director
Superfund & Emergency Management Division
Date
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Table of Contents
1. SITE NAME, LOCATION, AND DESCRIPTION 1
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
3. COMMUNITY PARTICIPATION 3
4. SCOPE AND ROLL 01 RESPONSE ACTION 3
5. SUMMARY 01 SITE CI IARAC ITRISTICS 5
5.1. Site Geology/Hydrogeology 5
5.2. 0U5 Investigation Summary 6
6. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 9
6.1. Land Use 9
6.2. Ground water Use 10
7. SUMMARY OF SITE RISKS 10
7.1. Human Health Risk Assessment 11
7.1.1. Hazard Identification 11
7.1.2. Exposure Assessment 12
7.1.3. Toxicity Assessment 12
7.1.4. Risk Characterization 13
7.1.5. Uncertainties 15
7.2. Ecological Risk Assessment 15
7.3. Basis for Taking Action 16
8. REMEDIAL ACTION OBJECTIVES 16
9. DESCRIPTION OF REMEDIAL ALTERNATIVES 16
9.1. Description of Common Elements Among Remedial Alternatives 17
9.2. Description of Remedial Alternatives 17
10. COMPARATIVE ANALYSIS OF ALTERNATIVES 20
10.1. Overall Protection of Human Health and the Environment 21
10.2. Compliance with ARARs 22
10.3. Long-Term Effectiveness and Permanence 22
10.4. Reduction of Toxicity, Mobility or Volume 23
10.5. Short-Term Effectiveness 23
10.6. Implementability 24
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10.7. Cost 24
10.8. State/Support Agency Acceptance 24
10.9. Community Acceptance 24
11. PRINCIPAL THREAT WASTES 25
12. THE SELECTED REMEDY 25
12.1. Summary of the Rationale for the Selected Remedy 25
12.2. Description of the Selected Remedy 26
12.3. Summary of Estimated Remedy Costs 27
12.4. Expected Outcomes of the Selected Remedy 27
13. STATUTORY DETERMINATIONS 27
13.1. Protection of Human Health and the Environment 27
13.2. Compliance with ARARs 27
13.3. Cost Effectiveness 28
13.4. Utilization of Permanent Solutions and Alternative Treatment (or Resource
Recovery) Technologies to Maximum Extent Practicable 28
13.5. Preference for Treatment as a Principal Element 28
13.6. Five-Year Review Requirements 28
14. DOCUMENTATION OF SIGNIFICANT CHANGES 29
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APPENDICES
LIST OF APPENDICES
APPENDIX I
FIGURES
Figure 1
Site Location and Operable Unit Map
Figure 2
Alternative 3 Excavation Area
APPENDIX H
TABLES
Table 1
Summary of Chemicals of Concern & Medium-Specific Exposure Point
Concentrations
Table 2
Selection of Exposure Pathways
Table 3
Noncancer Toxicity Data Summary
Table 4
Cancer Toxicity Data Summary
Table 5
Risk Characterization Summary - Carcinogens and Noncarcinogens
Table 6
Chemical-Specific ARARs, TBCs, and Other Guidelines
Table 7
Location-Specific ARARs, TBCs, and Other Guidelines
Table 8
Action-Specific ARARs, TBCs, and Other Guidelines
Table 9
Cleanup levels for Chemicals of Concern
Table 10
Cost Estimate Summary for the Selected Remedy
APPENDIX III
ADMINISTRATIVE RECORD INDEX
APPENDIX IV
NEW YORK STATE CONCURRENCE LETTER
APPENDIX V
RESPONSIVENESS SUMMARY
Attachment 1
Proposed Plan
Attachment 2
Public Notice - Commencement of Public Comment Period
Attachment 3
August 8, 2023 Public Meeting Transcript
Attachment 4
Written Comments Submitted During Public Comment Period
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DECISION SUMMARY
1. SITE NAME, LOCATION, AND DESCRIPTION
The Olean Well Field Superfund site (Site) is located in the eastern portion of the City of Olean
and western and northwestern portions of the towns of Olean and Portville in Cattaraugus County,
New York. The Site is characterized by volatile organic compound (VOC)-contaminated
groundwater underlying the City of Olean, the Town of Olean, and the Town of Portville, and by
VOC-contaminated soil at certain locations in the City and Town of Olean. The Site is
approximately 65 miles southeast of Buffalo, New York, and seven miles north of the New
York/Pennsylvania border. The Allegheny River, a principal tributary of the Ohio River, and two of
its tributaries, the Olean and Haskell Creeks, flow west-northwest through the southern portion of
the Site. A Site location map is provided as Figure 1 in Appendix I.
EPA has divided the Site into separate phases, or operable units, for remediation purposes. Operable
Unit 1 (OU1) addresses the drinking water supply for the City and Town of Olean. OU2 addresses
the sources of VOC contamination to groundwater. Investigations conducted to date identified four
source areas of VOC contamination to groundwater at the Site: Alcas Cutlery Corporation (Alcas)
(currently owned and operated by Cutco Corporation and located at 1116 East State Street, Olean,
New York); Loohn's Dry Cleaners and Launderers (Loohn's) (currently a vacant lot located at 1713
East State Street, Olean, New York); McGraw-Edison Company (McGraw) (currently owned and
operated by Eaton-Cooper Power Systems, Inc. and located at 1648 Dugan Road, Olean, New York);
and AVX Corporation (AVX) (located at 1695 Seneca Avenue, Olean, New York; AVX
Corporation is currently named Kyocera AVX Components Corporation (KAVX)). OU3 addresses
groundwater contamination at an area south of the Alcas facility referred to as Parcel B. OU4
addresses VOC contamination in groundwater located at certain residential and commercial
properties downgradient of the AVX Property and south of the Conrail railroad tracks. The AVX
Property includes 18.5 acres of real property, which is still listed as being owned by the AVX
Corporation.
This Record of Decision (ROD) for OU5 (OU5 ROD) addresses contaminated soil that is located
beneath and near the footprint of a former manufacturing building located in the northern portion of
the Historical Source Area at the AVX Property.
2. SITE HISTORY AND ENFORCEMENT ACTIVITIES
Site History
Beginning in the 1980s, several separate federal-, state- and Potentially Responsible Party (PRP)-
led investigations were conducted to identify the sources of contamination to the municipal water
supply wells and evaluate the nature and extent of groundwater contamination at the Site. The Site
was included on the National Interim Priorities List, by publication in the Federal Register on
October 23, 1981, and was included on the first National Priorities List on September 9, 1983. For
more details regarding the results of the various investigations and subsequent actions taken to
address Site-related contamination refer to the OU2 ROD, the OU2 AVX ROD Amendment and the
OU4 ROD.
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The following provides a summary of activities at the AVX Property, a source of groundwater
contamination at the Site.
As mentioned previously, the remedy selected in the 1996 OU2 ROD addressed multiple sources of
VOC contamination to groundwater at the Site. The major components of the selected remedy for
AVX, one of the four sources targeted, included the following: excavation and removal of
contaminated soil; off-Site low temperature desorption of soil contaminants, if necessary; upgradient
and downgradient groundwater monitoring; implementation of groundwater treatment, if excavation
and removal of the contaminated soil did not adequately improve the quality of the City Aquifer and
if the property continued to affect the groundwater entering the municipal wells; and implementation
of groundwater use restrictions.
AVX initiated the excavation of contaminated soil at its property in July 2000. Approximately 5,055
tons of contaminated soil was excavated to a depth of approximately 10 feet below ground surface
(bgs) and transported off-Site for disposal before work was halted. AVX could not excavate all of
the contaminated soil because the material extended beyond the area identified as contaminated in
the OU2 ROD to beneath the southeast corner of the manufacturing building, which was fully
occupied with AVX's manufacturing operations. Further excavation had the potential to impact the
structural integrity of the occupied building. As a result, the excavation area was backfilled pending
further study. Further evaluations revealed significant unknown contamination extending under the
building and that additional excavation and removal of all contaminated soil would result in
significant disruption to and/or shutdown of the on-going operations.
Following the backfilling at the AVX Property, EPA directed AVX to conduct soil and groundwater
sampling activities at the AVX Property and properties to the south as part of a multi-phase
investigation to assess the conditions at these properties. Results from these studies indicated that
significant previously unknown VOC contamination is present in both soil and groundwater.
As indicated previously, on September 30, 2015, EPA issued a ROD Amendment for OU2 relating
to the AVX Property that addressed soil and groundwater contamination in the Historical Source
Area, and groundwater contamination in the Downgradient Till Unit and City Aquifer (refer to the
Site Geology and Hydrogeology section in the OU2 AVX ROD Amendment for additional detail
regarding geological and hydrogeologic conditions at the Site). The Downgradient Till Unit
component of the selected remedy involves the construction and operation of a hydraulic trench
containment system involving a gravel trench coupled with active groundwater recovery and
treatment to prevent migration of groundwater downgradient of the AVX Property. Construction of
this component of the selected remedy was completed in January 2023. The City Aquifer component
of the selected remedy involves hydraulic pumping containment utilizing and maintaining an
existing AVX Property production well (PW-1) as an active groundwater recovery system at a
pumping rate that prevents further migration of contaminated groundwater within the City Aquifer.
The AVX production well, in operation since 1959, continues to operate as part of the
implementation of the OU2 AVX ROD Amendment selected remedy even though the plant closed
down.
According to EPA's EJScreen tool, there are no demographic indicators for OU5 at the Site that
would indicate a community with environmental justice concerns. Within and immediately near
OU5, the national and State EJ index percentiles for all of the environmental and socioeconomic
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indicators are at or below the 52nd percentile. The proposed remedy is not anticipated to result in
adverse impacts to environmental resources that would affect low income or minority populations
living within the vicinity of OU5.
3. COMMUNITY PARTICIPATION
On July 27, 2023, EPA released the Proposed Plan for the cleanup of OU5 to the public for comment.
EPA assembled supporting documentation, which comprises the administrative record, and has
made it available to the public at the information repositories maintained at the Olean Public Library
located at Second and Laurens Streets, Olean, New York, and the EPA Region 2 Office in New York
City, as well as at www.epa.gov/superfund/olean-wellfield.
Notice of the July 27, 2023, start of the public comment period and the availability of the above-
referenced documents was published in The Olean Times Herald on July 27, 2023. A copy of the
public notice published in The Olean Times Herald can be found in Appendix V. EPA accepted
public comments on the Proposed Plan from July 27, 2023, through August 28, 2023.
On August 8, 2023, EPA held a public meeting at the Jamestown Community College, Cattaraugus
County Campus, in the Mangano Reception Room, located at 305 North Barry Street, Olean, New
York, to inform local officials and interested citizens about the Superfund process, to present the
Proposed Plan for OU5, including the preferred remedial alternative, and to respond to questions and
comments from the attendees. Responses to comments received at the public meeting and in writing
during the public comment period are included in the Responsiveness Summary (See Appendix V).
4. SCOPE AND ROLE OF RESPONSE ACTION
Site remediation activities are sometimes segregated into different phases, or 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 five OUs for the Olean Well
Field Site (refer to Figure 1 in Appendix I).
On September 24, 1985, EPA signed a ROD for OU1, which called for, among other things, the
treatment of the municipal supply well water and the extension of the public water supply to
residents utilizing private wells.
On September 30, 1996, EPA signed a ROD for OU2 to address the sources of the contamination in
the groundwater. The four source areas targeted in the OU2 ROD were AVX, Alcas, Loohn's, and
McGraw. On September 30, 2014, EPA amended the OU2 ROD to modify the selected remedy for
the Alcas component of the OU2 ROD. The Alcas OU2 ROD Amendment addressed soil and
groundwater contamination impacting the underlying aquifers, and also selected a remedy to address
OU3 groundwater contamination. OU3 addresses groundwater contamination at an area south of the
Alcas facility referred to as Parcel B.
On September 30, 2015, EPA amended the OU2 ROD to modify the selected remedy for the AVX
component of the OU2 ROD. The OU2 AVX ROD Amendment selected an interim action to address
soil and groundwater contamination until a final remedy for the AVX Property could be
implemented. The OU2 AVX ROD Amendment indicated that a change in the current use of the
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building in the future would trigger the performance of a feasibility study to evaluate source control
and/or restoration actions, leading to the selection of a final remedy.
The major components of the OU2 AVX ROD Amendment include the following:
• Historical Source Area (Soil and Till Unit Groundwater): Maintenance of an exposure barrier
utilizing existing surface covers (the building and paved areas in the northern portion of the
Historical Source Area and the vegetative cover in the drainage swale area) to minimize
leaching of volatile organic compounds (VOCs) from soil to groundwater and serve as a
direct contact exposure barrier.
• Downgradient Till Unit (Groundwater): Construction and operation of a hydraulic trench
containment system involving a gravel trench coupled with active groundwater recovery and
treatment to prevent migration of groundwater downgradient of the AVX Property.
• City Aquifer (Groundwater): Hydraulic pumping containment utilizing and maintaining an
existing AVX Property production well (PW-1) as an active groundwater recovery system
at a pumping rate that prevents further migration of contaminated groundwater within the
City Aquifer. An air stripper or carbon adsorption system or combination thereof will be
added to the extraction system, as necessary to meet surface water discharge requirements.
• Implementation of institutional controls, including soil and groundwater use restrictions, to
ensure the remedy remains protective.
• Development of a Site Management Plan (SMP) to provide for the proper management of
the interim remedy post-construction, and to include long-term groundwater monitoring,
periodic reviews and certifications. Until a final remedy is selected, the SMP will provide
for the proper management of any contaminated unsaturated soil at the AVX Property and
the evaluation of the potential for vapor intrusion at the existing building on the AVX
Property and/or for any buildings constructed in the future, and mitigation, if necessary, in
compliance with the SMP. The SMP will also provide for the proper implementation,
management and maintenance of institutional controls. A change in the current use of the
building in the future will trigger the performance of a feasibility study to evaluate source
control and/or restoration actions, leading to the selection of a final remedy.
• Implementation of a long-term groundwater monitoring program as part of the SMP to verify
the effectiveness of the interim remedy, and to track and monitor changes in the groundwater
contamination over time at the AVX Property. The long-term groundwater monitoring
program will consist of a comprehensive monitoring network made up of existing monitoring
wells and additional monitoring wells and piezometers on and off the AVX Property, within
not only the City Aquifer but also within the till unit, and also monitoring to further evaluate
geochemical conditions.
The followings RAOs were established in the OU2 AVX ROD Amendment:
• Restore the City Aquifer beneath the AVX Property to its beneficial use as a source of
drinking water by reducing contaminant levels to the more stringent of federal MCLs or New
York State standards;
• Minimize, contain and/or eliminate sources of VOC contaminants already in the shallow
groundwater at the AVX Property; and
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• Minimize and/or eliminate the potential for future human exposure to Site contaminants via
contact with contaminated groundwater and/or inhalation of vapors.
On September 30, 2022, EPA signed a ROD for OU4, which addresses groundwater contamination
at certain residential and commercial properties to the south of the AVX Property.
OU5, which is the subject of this ROD, is the final planned phase of response activities at the AVX
Property. OU5 addresses soil contamination located beneath and near the former AVX
manufacturing building in the northern portion of the Historical Source Area. The OU5 remedy, in
conjunction with the OU2 AVX ROD Amendment, constitutes the final remedy for the AVX
Property.
5. SUMMARY OF SITE CHARACTERISTICS
5.1. Site Geology/Hydrogeology
The Olean Well Field is underlain by approximately 300 feet of unconsolidated glacial deposits.
Previous groundwater investigations in the Olean Well Field have shown that the upper 100 feet of
glacial deposits can be divided into five lithologic units based on color, texture, grain size and mode
of deposition. These lithologic units have been grouped in topographically descending order into four
hydrogeologic units referred to as the upper aquifer, upper aquitard (Till Unit), lower aquifer (City
Aquifer), and lower aquitard.
The upper aquifer is comprised of glaciofluvial coarse sands and sandy gravels, recent fluvial deposits
of fine sands, and silts with some clay. The upper aquifer is not continuous at the Olean Well Field
Site. The thickest portion of the upper aquifer (approximately 41 feet) is found along the Allegheny
River. The upper aquifer thins to the north, pinching out just south of the AVX Property. The upper
aquifer is recharged by the infiltration of precipitation.
During previous investigations, groundwater in the upper aquifer was encountered at depths ranging
from three feet bgs to more than 20 feet bgs and flow is generally toward the Allegheny River. North
of the railroad tracks (on the AVX Property), groundwater flow is in a south to southeast direction in
much of the undeveloped portion of the AVX Property with some components of flow towards the
surface drainage swale that runs toward the unnamed stream. Groundwater and surface water east of
the stream generally flow in a south-southwest direction, while groundwater and surface water to the
west of the stream generally flows in a southeast direction.
The upper aquitard or Till Unit stratigraphically is located above the lower aquifer (referred to as the
City Aquifer). This unit is a low-permeability lodgement till composed of greater than 50 percent silt
and clay. This unit is heterogeneous and can contain some sandier layers that generally have limited
lateral extents. The thickness of the till unit on the AVX Property generally ranges from 20 to over 30
feet. In the northern portion of the Olean Well Field Site this unit is present at the surface and consists
of surficial till.
The City Aquifer consists of glacial outwash deposits of sand, silt, and gravel. The thickness of the
City Aquifer is approximately 70 feet in the northern portion of the Site and thins to approximately 30
feet south of the Allegheny River. The City Aquifer is underlain by the lower aquitard, which has been
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described as silt, clay, and fine to very fine sand, and was likely deposited in a pre-glacial lake
environment. Regional groundwater level data and potentiometric surface maps indicate that lines of
equal elevation for the upper aquifer generally parallel the Allegheny River. This indicates that
groundwater flow is towards the river from both sides of the river valley.
The City Aquifer is the main source of drinking water for the City and Town of Olean. In addition,
several industrial facilities in the area utilize wells completed in the City Aquifer for manufacturing
activities. The regional groundwater flow within the City Aquifer is generally in a west-southwest
direction. Recharge to the City Aquifer is via leakage from the upper aquifer through the upper
aquitard or directly through the Till Unit (upper aquitard) where the upper aquifer is not present. The
magnitude of leakage over the Olean Well Field Site is variable and is dependent on the thickness and
permeability of the upper aquitard (Till Unit) and relative groundwater level differences between the
upper aquifer and upper aquitard units and the City Aquifer. Natural flow conditions in the City
Aquifer within the vicinity of the Site have been altered by the pumping of the municipal wells, in
operation since 1985, and several industrial wells including an AVX production well. The AVX
production well, in operation since 1959, continues to operate as part of the implementation of the
OU2 AVX ROD Amendment selected remedy even though the plant closed down.
5.2. OU5 Investigation Summary
Soil Investigation Results from Previous Investigations at the AVX Property
Results of post-OU2 ROD investigations showed that VOC contamination in soil consists primarily
of trichloroethene (TCE), 1,1,1-trichl or ethane (1,1,1-TCA), tetrachloroethene (PCE), and the
breakdown products cis-l,2-dichloroethene (cis-l,2-DCE), vinyl chloride, and 1,1-dichloroethane
(1,1-DCA) with elevated concentrations of other VOCs, including toluene and xylenes.
As set forth in a January 29, 2013 Feasibility Study Investigation Report (FSIR) performed after work
was halted on the OU2 ROD remedy, high concentrations of VOCs have been observed in soil (up to
1,614 parts per million (ppm) of total VOCs) beneath the southeast corner of the former manufacturing
building by a maintenance shop and a former solvent underground storage tank (both along the eastern
edge of the manufacturing building), and in areas immediately to the south and north of the
manufacturing building. Minimal detections of VOC contamination were found in soil south of the
fenced area of the AVX Property.
Concentrations of VOCs observed in groundwater indicate that a groundwater plume of VOC
contamination in the till unit originates from the Historical Source Area and extends through the
undeveloped area to the southern property boundary and OU4.
OU5 Feasibility Study Investigation Report (FSIR)
While prior investigations have characterized the hydrogeology and the nature and extent of
contaminants in the subsurface throughout much of the AVX Property, the demolition of the former
manufacturing building in 2020 enabled the collection of soil and groundwater samples beneath and
adjacent to the former structure. This additional soil characterization and testing were also necessary
to support the evaluation of remedial alternatives for contaminated soil in and around the footprint of
the former manufacturing building. The investigation activities were designed to:
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• Define the lateral and vertical extent of contaminants in soil located beneath and near the
footprint of the former manufacturing building within and near the northern portion of the
Historical Source Area; and
• Characterize the framework of the hydrogeologic units to better define the potential
contaminant transport pathways within and near the source area.
A portion of the concrete slab of the former building was left in place and is currently acting as an
exposure barrier to contaminated soil.
OU5 Soil Investigation Results
The first step of the OU5 soil characterization program included screening of near-surface soil/fill for
the presence and magnitude of VOCs using a photoionization detector (PID). Information gathered
using a PID is classified as screening level data and does not provide chemical specific information.
Following the initial soil screening and preliminary surveying, whole core soil sampling (WCSS) and
vertical aquifer profile (VAP) sampling was conducted. The locations of WCSS and VAP sampling
were adjusted as needed based on access and the results of soil screening. A summary of the results
of this work is presented below.
Soil Screening
The VOC contamination detected in soil consists primarily of TCE, 1,1,1-TCA, PCE, and the
breakdown products cis-l,2-DCE, vinyl chloride, 1,1-DCA, 1,2-DCA, with elevated concentrations
of other VOCs, including toluene and xylenes. 114 soil gas screening point locations were selected
and organized in a grid layout approximately 25 feet apart, in and around the source area. For all
locations and depths where soil gas could be drawn, the gas was pumped by and analyzed with a PID
and data were recorded.
The highest concentrations of PID-measured VOCs were observed primarily outside of the footprint
of the original building, which was constructed in 1950, with those elevated concentrations observed
largely within the footprint of the historical Machine Shop/Maintenance area (constructed in 1978 and
used as the building maintenance area), the Receiving Area, and the Chemical Storage area (both
constructed in 2001). These levels ranged from 145-1,436 ppm. Some elevated PID-measured
screening concentrations were also observed beneath adjacent areas within the southeastern corner of
the footprint of the original building. These included one area historically noted as the Powder and
Barrel Storage area but also on other maps noted as being used for waste storage. Some elevated PID-
measured concentrations were also noted farther to the west beneath or near to the historical Tape and
Reel Storage area. Refer to Figure 2 in Appendix I for the layout of the former manufacturing building.
Soil Quality Characterization
Following completion of the soil screening activities, whole core soil samples were collected by
rotosonic drilling methods on a modified approximately 50-foot grid spacing at 40 locations.
Approximately 300 soil samples were analyzed to better characterize the nature and extent of VOCs
in soil, both saturated and unsaturated, within the source area. The results are summarized in Table A
below. The data revealed that the highest mass of VOCs in soil is largely concentrated in areas
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predicted by the soil gas screening data, with some deviations. The highest concentrations were
observed within the former footprint of the Machine Shop/Maintenance area, beneath the former
Receiving area, and extending into the former chemical storage/waste storage area. Other notable areas
of higher concentrations included the head of the drainage swale to the south of the facility fence, and
near the southeastern corner of the former Stage 1 remedial action excavation area.
Table A: Maximum Soil Contaminant
Concentrations
(\>nl;nnin;inl
( i>iicenir;ilk>ii
(ppim
1,1,1-TCA
226 DJ
TCE
1,500 DJ
PCE
723 DJ
c/s-l,2-DCE
93.6 DJ
vinyl chloride
2.05 DJ
1,1-DCA
9.88 D
D = Identifies all compounds identified in the analysis at the secondary dilution factor.
J = The analyte was analyzed for and was positively identified, but the associated numerical
value may not be consistent with the amount actually present in the environmental sample.
The concentrations of contaminants were observed to generally diminish with sample depth, though
not consistently in all locations. Thin and discontinuous stringers of more permeable soil appear to
have acted as pathways for contaminants to reach greater depths in certain locations.
During soil sampling, if retrieved core samples appeared to be both saturated and coarse-grained
enough to produce water, VAP samples were collected. In total, only 13 of 40 borings contained
enough water to facilitate VAP sampling, with only two of the 13 borings containing adequate water
to sample at more than one depth.
VAP sampling results can be found below in Table B. Aside from some VAP groundwater sample
locations with anomalously high COC concentrations, likely due to the presence of stringers
containing more permeable material that can collect water containing high contaminant
concentrations, the concentrations of contaminants in the VAP groundwater samples are relatively
consistent with concentrations reported for groundwater sampled from monitoring wells during the
semi-annual groundwater monitoring events which have been conducted since 2000.
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Table B: Maximum Groundwater
Contaminant Concentrations in VAP Samples
( oncenli';ilk>n
(pph)
1,1,1-TCA
59,000 D
TCE
120,000 D
PCE
4,000
c/s-l,2-DCE
17,000
vinyl chloride
1,800
1,1-DCA
12,000
D = Identifies all compounds identified in the analysis at the secondary dilution factor.
Refer to the OU5 FSIR for additional details regarding the sampling results.
Previous investigations conducted at the AVX Property revealed VOC groundwater contamination as
well as 1,4-dioxane, a semi-VOC, in the till unit beneath the AVX manufacturing building and in the
undeveloped area between the building and the southern property boundary. Investigation results also
showed that the City Aquifer has been affected, but at much lower concentrations than in the shallow
(till) stratigraphic unit.
An assessment of natural attenuation conditions in groundwater was conducted as part of the 2015
OU2 ROD. Overall, the analyses indicated that some level of natural attenuation of Site-related
contaminants is occurring. Groundwater samples revealed an increase in concentration of daughter
products (e.g., cis-l,2-DCE and vinyl chloride) relative to the concentration of the parent compound
(e.g., TCE). Reductive dechlorination is a natural attenuation process that can degrade chlorinated
VOCs by transforming chlorinated compounds such as TCE to other compounds. Other natural
attenuation processes can include dispersion, dilution, sorption, and volatilization. The observed
concentrations of contaminants in soil and groundwater near to the former AVX manufacturing
building suggest that some level of natural attenuation is occurring.
Additionally, ethene and ethane were detected in groundwater monitoring well samples,
demonstrating occurrence of the full sequence of reductive dechlorination. The monitored natural
attenuation (MNA) assessment also included analysis of electron acceptors, which showed moderate
to strongly reducing conditions present.
The OU5 FS Report contains additional details, as does the full MNA Screening Analysis conducted
in 2012. Both documents can be found in the Administrative Record file for the Site.
6. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
6.1. Land Use
The Site includes residential, commercial, and industrial zones in the City of Olean. The AVX
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Property is zoned for manufacturing use, and the areas immediately surrounding the AVX Property
are zoned for industrial, commercial, and residential uses. EPA expects that the land-use pattern at and
surrounding OU5 of the Site will not change in the foreseeable future.
6.2. Groundwater Use
Three municipal water supply wells (18M, 37M and 38M) at the Site provide water for the City and
Town of Olean. These water supply wells draw water from the City Aquifer. An air stripper at
municipal supply well 18M and a separate air stripper at municipal supply wells 37M and 38M treat
the extracted groundwater before distribution to the public. The current total pumping rate for these
municipal wells is approximately 3 million gallons per day. In addition, although the extension of the
City of Olean's water line was completed in 1988, and private well users were connected to the public
water supply in 1989, some residents refused EPA's efforts to connect to the public water supply and
continue to use private wells as a source of potable water.
Surface water from the undeveloped area south of the former AVX manufacturing building flows
toward the stream. Prior to entering the culvert, the stream picks up substantial flow volume due to
release of water from AVX State Pollutant Discharge Elimination System (SPDES) Outfall 004
effluent, which was composed of wastewater used for production cooling when the plant operated.
Although the AVX plant is no longer in operation, pumping well PW-1 continues to operate at a rate
of approximately 300 gallons per minute to provide hydraulic control of the City Aquifer as part of
the OU2 AVX ROD Amendment. The extracted water is discharged to the unnamed stream as part of
the OU2 remedy.
The remedy selected in the OU2 AVX ROD Amendment also involves a hydraulic trench containment
system with active groundwater recovery and treatment on the AVX Property. Construction of this
component of the selected remedy was completed in January 2023. Groundwater that is collected and
treated as part of this remedy is discharged to the City of Olean sewer system.
7. SUMMARY OF SITE RISKS
A baseline Human Health Risk Assessment (HHRA) and a qualitative ecological risk assessment were
conducted as part of the 1996 OU2 ROD to estimate the risks associated with current and future
conditions at the Site, including the AVX facility. A baseline risk assessment is an analysis of the
potential adverse human health and ecological effects caused by hazardous substance exposure in the
absence of any actions to control or mitigate these exposures under current and future land uses. A
qualitative human health risk analysis was subsequently performed as part of the OU2 AVX ROD
Amendment. The qualitative assessment focused on a comparison of contaminant concentrations
identified at the time of the 1996 ROD and the 2015 ROD to evaluate the findings included in the
baseline risk assessment, rather than a quantitative calculation of risk based on receptor exposure
assumptions and toxicity.
The results of the baseline OU2 HHRA identified carcinogenic risk and/or noncarcinogenic hazards
that were above the target carcinogenic risk range of lxlO"6 to lxlO"4 and the noncarcinogenic hazard
index (HI) threshold of 1 for future residential exposure to groundwater. These results were confirmed
in the OU2 AVX ROD Amendment. Carcinogenic risks and noncarcinogenic hazards for construction
worker exposure to soil were also evaluated.
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As discussed in more detail in the following sections, EPA has determined that the results of the
baseline OU2 HHRA and the risk evaluation from the OU2 AVX ROD Amendment have not
substantially changed. Therefore, an additional quantitative HHRA was not performed as part of OU5.
However, since OU5 specifically addresses contaminated soil located beneath the AVX Property, an
updated qualitative analysis concerning the risks associated with elevated VOC concentrations in soil
is provided. Information concerning the baseline OU2 HHRA results for groundwater at the AVX
Property can be found in the OU2 ROD and the OU2 AVX ROD Amendment.
7.1. Human Health Risk Assessment
A four-step process is utilized for assessing site-related human health risks for a reasonable maximum
exposure (RME) scenario:
Hazard Identification - uses the analytical data collected to identify the contaminants of
potential concern at the site for each medium, with consideration of several 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 chemical
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 NCP as an excess lifetime cancer risk greater than 1 x 10"6 to 1 x 10"4 (also commonly
expressed as: 1E-06 to 1E-04), an excess of lifetime cancer risk greater than 1 x 10"6 (i.e., point
of departure) combined with site-specific circumstances, or a noncancer HI 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.
7.1.1. Hazard Identification
The baseline OU2 HHRA found in the OU2 ROD quantitatively evaluated the potential risks and
hazards associated with exposure to soil at the AVX Property. In this step, the chemicals 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 COPC screening conducted at the time of the HHRA identified a variety of VOCs, SVOCs and
inorganics in soil. A comprehensive list of all COPCs evaluated can be found in the HHRA in the
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administrative record. Appendix II, Table 1 includes a comparison of concentrations detected in soil
for the COCs during investigations supporting the OU2 ROD, OU2 AVX ROD Amendment and this
ROD.
7.1.2. Exposure Assessment
Consistent with Superfund policy and guidance, the baseline HHRA assumed no remediation or
institutional controls to mitigate or remove hazardous substance releases. Cancer risks and noncancer
His were calculated based on an estimate of the 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.
Risks associated with exposure to contaminants in surface and subsurface soil were calculated for the
ingestion and inhalation of contaminants by construction workers. A residential exposure scenario for
soil was not calculated because all of the properties studied during the OU2 RI/FS were zoned for
industrial or commercial use. It is anticipated that the AVX Property will continue to be used for
commercial/industrial purposes in the future.
Typically, exposures are evaluated using a statistical estimate of the exposure point concentration
(EPC), which is usually an upper-bound estimate of the average concentration for each contaminant,
but in some cases may be the maximum detected concentration. 95% upper confidence limits were
used to evaluate exposure in the baseline OU2 HHRA and can be found in the Administrative Record.
For the purposes of the qualitative analysis performed for soil, an evaluation of maximum
concentrations was performed. A summary of these concentration ranges is provided in Appendix II,
Table 1. The soil exposure pathways evaluated for the baseline OU2 HHRA are included in Appendix
II, Table 2.
7.1.3. 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 are 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 chemicals are considered separately and were evaluated as such in the HHRA
supporting the OU2 ROD. Consistent with current EPA policy, it was assumed that the toxic effects
of the Site-related chemicals would be additive. Thus, cancer and noncancer risks associated with
exposures to individual COPCs were summed to indicate the potential risks and hazards associated
with mixtures of potential carcinogens and noncarcinogens, respectively.
Toxicity data for the OU2 HHRA were provided by the Integrated Risk Information System (IRIS)
database or other sources that were identified as an appropriate reference for toxicity values consistent
with EPA guidance. This information is presented in Appendix II Table 3 (Noncancer Toxicity Data
Summary) and Table 4 (Cancer Toxicity Data Summary) attached hereto. These tables also include a
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comparison of toxicity data used to evaluate risks in the OU2 ROD versus those currently available
and their expected impact on risk and hazard. Additional toxicity information for all COPCs is
presented in the baseline OU2 HHRA.
7.1.4. Risk Characterization
This step summarizes and combines outputs of the exposure and toxicity assessments to provide a
quantitative assessment of site risks. Exposures are evaluated based on the potential risk of developing
cancer and the potential for noncancer health hazards.
Noncarcinogenic Risks
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 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. The
estimated intake of chemicals identified in environmental media (e.g., the amount of a chemical
ingested from contaminated soil) is 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 chemical (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).
As previously stated, the HI is calculated by summing the HQs for all chemicals for likely exposure
scenarios for a specific population. An HI greater than 1 indicates that the potential exists for
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 chemicals for a specific
population exceeds 1, separate HI values are then calculated for those chemicals which are known to
act on the same target organ. These discrete HI values are then compared to the acceptable limit of 1
to evaluate the potential for noncancer health effects on a specific target organ. The HI provides a
useful reference point for gauging the potential significance of multiple contaminant exposures within
a single medium or across media. A summary of the noncarcinogenic risks associated with these
chemicals for each exposure pathway is contained in Table 5 of Appendix II attached hereto.
Noncarcinogenic hazards for construction worker exposure to soil were below the HI threshold of 1,
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however, data collected to support the OU2 AVX ROD Amendment suggested that these hazards
could be underestimated. This data, along with more recently acquired soil data, is further evaluated
under the Qualitative Analysis section below.
Carcinogenic Risks
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. Current Superfund guidance identify the range for determining whether a remedial action
is necessary as an individual lifetime excess cancer risk of 10"4 to 10"6 (corresponding to a one-in-ten-
thousand to a one-in-a-million excess cancer risk), with 10"6 being the point of departure.
Carcinogenic risks for construction worker exposure to soil were below the upper bound, or lxlO"4,
of the cancer risk range, however, data collected to support the OU2 AVX ROD Amendment
suggested that these risks could be underestimated. This data, along with more recently acquired soil
data, is further evaluated under the Qualitative Analysis section below.
Qualitative Analysis
Although the estimated total risks (5xl0"5) and hazards (HI=0.5) in soil calculated for the construction
worker evaluated under the OU2 ROD were within the risk range and below the noncarcinogenic HI
threshold of 1, data collected at the time of the OU2 AVX ROD Amendment identified higher
concentrations of VOCs in soil compared to those evaluated in the OU2 HHRA. A qualitative
determination was made in the OU2 AVX ROD Amendment that the risks associated with soil in the
OU2 HHRA could be underestimated. It was also determined that contamination in the subsurface soil
could serve as a source of continued groundwater contamination. Additional samples were collected
as part of the 2023 OU5 FSIR. Table 1 in Appendix II provides minimum and maximum VOC
concentrations detected in soil during the OU2 RI and during the post-OU2 ROD investigations at the
AVX Property.
As can be seen in this table, the maximum results of the soil samples collected during the OU5 FSIR
were either higher than those identified during the time of the OU2 ROD and OU2 AVX ROD
Amendment or are within the same order of magnitude. Notably, the maximum concentrations of PCE
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and TCE identified during the 0U5 FSIR were over two times greater than the OU2 RI. Maximum
concentrations for cis-l,2-DCE, vinyl chloride and xylene have also increased. Furthermore, as shown
in Appendix II Tables 3 and 4, updated toxicity data would likely lead to higher hazard estimates for
these chemicals, as well as higher risk estimates for TCE, compared to the time of the OU2 ROD.
Therefore, EPA has determined that the unacceptable risks presented in the OU2 AVX ROD
Amendment remain unacceptable and could be underestimated. Additionally, groundwater on the Site
continues to exceed federal MCLs and New York State standards due to impacts from contaminated
soil, underscoring the need to address soil as a source to groundwater.
7.1.5. Uncertainties
The procedures and inputs used to assess human health 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; and
• toxicological data.
Uncertainty in environmental sampling arises in part from the potentially uneven distribution of
chemicals 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.
Uncertainties in the exposure assessment are related to estimates of how often an individual would
actually come in contact with the COCs, the period of time over which such exposure would occur,
and in the models used to estimate the concentrations of the COCs 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
chemicals. These uncertainties are addressed by making conservative assumptions concerning risk and
exposure parameters throughout the assessment.
7.2. Ecological Risk Assessment
The AVX Property is approximately 18.5 acres in size and currently includes an open area with bare
soil due to the recent removal of the former AVX building. Wetlands and a wooded area are located
south of the former building area, which remains fenced. The fenced portion of the site that formerly
comprised the AVX building does not currently provide habitat that could potentially support
populations of indigenous wildlife receptor species. Therefore, there are no ecological risks currently
recognized within this area. For the area outside of the fence, which includes the wooded area and
wetland area, a qualitative ecological risk assessment was conducted as part of the OU2 ROD to
determine if contamination present at the AVX Property was impacting the wooded or wetland area.
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Given that the potential source of contamination in the wooded and wetland area would be
contaminated groundwater discharging to the sediments, sediment samples were collected from the
wetlands. Analysis of the samples did not reveal any VOC contamination. Several semi-volatile
organic compounds (SVOCs) were detected but were not attributed to the AVX Property. Based on
this evaluation, it was determined that there is not a completed exposure pathway from the AVX
property groundwater to the wooded or wetland areas. Since the levels of contamination in
groundwater at the AVX property have remained similar, or have declined, this assumption is still
considered valid.
7.3. Basis for Taking Action
Based upon the results of the OU5 FSIR, the baseline OU2 ROD HHRA, and the updated qualitative
analysis for OU5, the response action selected in this OU5 ROD is necessary to protect the public
health or welfare or the environment from actual or threatened releases of hazardous substances into
the environment.
8. REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are specific goals to protect human health and the environment.
These objectives are based on available information and standards, such as applicable or relevant and
appropriate requirements (ARARs), to-be-considered (TBC) criteria, other guidance documents, and
site-specific risk-based levels.
The followings RAOs have been established for OU5 of the Site:
- Reduce the migration of VOC contaminants in soil to groundwater.
- Eliminate the potential for human exposure to Site contaminants via contact with soil
concentrations above NYSDEC soil cleanup objectives for commercial properties.
The RAOs established in the OU2 AVX ROD Amendment remain unchanged.
The cleanup levels for soil established for the OU5 COCs are identified in Table 9 in Appendix II
attached hereto. The COCs are the same as those outlined in the 1996 OU2 ROD and the OU2 AVX
ROD Amendment, except 1,4-dioxane. This compound was added to the COC list because of its
presence in groundwater above federal MCLs and New York State standards. If it is discovered in soil
above the cleanup level identified in Table 9, it would become a COC for the Site.
9. DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA § 121(b)(1), 42 U.S.C. §9621(b)(l), mandates that remedial actions be protective of human
health and the environment, cost-effective, comply with ARARs, and utilize permanent solutions and
alternative treatment technologies or resource recovery alternatives to the maximum extent
practicable. Section 121(b)(1) also establishes a preference for remedial actions which employ, as a
principal element, treatment to permanently and significantly reduce the volume, toxicity, or mobility
of the hazardous substances, pollutants and contaminants at a site. CERCLA § 121(d), 42 U.S.C.
§9621(d), further specifies that a remedial action must attain a level or standard of control of the
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hazardous substances, pollutants, and contaminants, which at least attains ARARs under federal and
state laws, unless a waiver can be justified pursuant to CERCLA § 121(d)(4), 42 U.S.C. §9621(d)(4).
Detailed descriptions of the remedial alternatives presented in this ROD can be found in the Feasibility
Study Report, dated July 2023.
The construction time for each remedial 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
performance of the remedy with any PRPs, or procure contracts for design and construction, or
operation and maintenance.
9.1. Description of Common Elements Among Remedial Alternatives
Each of the alternatives address unsaturated contaminated soil located beneath and near the footprint
of the former manufacturing building in the northern portion of the Historical Source Area.
Until a final remedy for the AVX Property is selected, the OU2 AVX ROD Amendment requires
implementation of institutional controls and development of a Site management plan (SMP) to provide
for the proper operation and maintenance (O&M) of the remedy for the AVX Property post-
construction. The SMP includes a long-term groundwater monitoring program to track and monitor
changes in the groundwater contamination over time at the AVX Property. The institutional controls
selected in the OU2 AVX ROD Amendment would continue to apply to the AVX Property and as
such would apply to each of the alternatives evaluated for OU5. Implementation of institutional
controls and the SMP are ongoing.
Additionally, because the final remedy for the AVX Property (the OU5 selected remedy in
combination with the remedy selected in the OU2 AVX ROD Amendment) will result in hazardous
substances, pollutants, or contaminants remaining in and around the drainage swale area at the AVX
Property above levels that would otherwise allow for unlimited use and unrestricted exposure,
pursuant to Section 121(c) of CERCLA, statutory reviews will be conducted no less often than once
every five years to ensure that the remedy remains protective of human health and environment.
9.2. Description of Remedial Alternatives
Alternative 1: No Action
Capital Cost: $0
Periodic Costs: $0
Present-Worth Cost: $0
Construction Time: Not Applicable
The NCP requires that a "No Action" alternative be used as a baseline for comparing other remedial
alternatives. Under this alternative, there would be no remedial actions actively conducted at OU5 to
control or remove groundwater contaminants. This alternative also does not include monitoring or
institutional controls.
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Alternative 2: Long-Term Monitoring
Capital Cost:
Periodic Costs:
Present-Worth Cost:
Construction Time:
$44,000
$567,000
$291,000
1 month
This alternative would rely on long-term monitoring of contaminant concentrations in soil to ensure
concentrations are decreasing. As discussed above, reductions in contaminant concentrations in
groundwater are occurring to a limited extent already from various naturally occurring physical,
chemical, and biological processes. These processes occur naturally, in-situ, and act to decrease the
mass or concentration of contaminants in the subsurface. Only non-augmented natural processes
would be relied upon under this alternative. In addition, existing surface covers (concrete slab floor,
pavement, and vegetative cover) would be maintained to control potential leaching of contaminants in
soil to groundwater and prevent exposure.
For cost-estimating and planning purposes, four new groundwater monitoring wells would be
installed, and periodic monitoring would be conducted to track attenuation of contaminants
immediately beneath and/or downgradient of the unsaturated soil source.
Alternative 3: Excavation
Capital Cost: $2,228,000
Periodic Costs: $450,000
Present-Worth Cost: $2,414,000
Construction Time: 4 months
The major components of the soil excavation alternative are demolition and removal of the existing
concrete slab floor and foundation supports, excavation of impacted unsaturated soil located beneath
and near the footprint of the former manufacturing building, off-Site transportation and disposal of
excavated material, and restoration with imported clean fill material. Figure 2 in Appendix I provides
the approximate areas requiring excavation based on data collected during the FSIR. These areas will
be further refined based on additional sampling.
Excavation areas would be restored with imported clean fill material to match the previously existing
contours and grades. Imported clean fill material would meetNYSDEC DER-10 Technical Guidance
for Site Investigation and Remediation criteria for imported fill or soil at commercial or industrial
properties. Surface restoration details would be developed during the remedial design.
For cost estimating and planning purposes, the conceptual design estimates 5,500 cubic yards (cy) of
soil requiring excavation and off-Site transportation for disposal as non-hazardous waste at a solid
waste landfill. Rainwater/surface water that accumulates in, and is then removed from, any excavation
areas would be temporarily containerized onsite (e.g., in 21,000-gallon tanks). It is anticipated that
any water that accumulates and is removed from the excavation would be treated by the groundwater
treatment system at the AVX Property prior to discharge to the City of Olean sewer system.
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Alternative 4: In-Situ Soil Solidification
Capital Cost: $2,715,000
Periodic Costs: $450,000
Present-Worth Cost: $2,901,000
Construction Time: 3.5 Months
The major components of the In-Situ Soil Solidification (ISS) alternative include the demolition and
removal of the existing concrete slab floor and foundation supports, excavation and removal of the
asphalt paved areas to establish a level working surface for the ISS mixing equipment, construction of
a management area adjacent to the ISS target areas to accommodate bulk soil that would swell as a
result of the soil mixing process and amendment addition.
Solidification refers to a cleanup method that prevents or slows the release of harmful chemicals from
contaminated soil. These methods usually do not destroy the contaminants. Instead, they keep them
from "leaching" above safe levels into the surrounding environment. Solidification binds the waste in
a solid block of material and traps it in place, using a binding agent. This block is also less permeable
to water than the waste.
During the Feasibility Study Investigation, a laboratory bench-scale ISS treatability study was
conducted with soil from the AVX Property to identify the optimal percentage of reagents, dosing
requirements, and effectiveness. This treatability study investigated the ability of Portland Cement
(PC) and blast furnace slag (BFS), as well as zero-valent iron (ZVI), to reduce the leaching potential
of contaminants. Based on the results, for cost-estimating and planning purposes, the conceptual
design estimates approximately 5,500 cy of soil would be mixed with a blend of 2.5% PC and 4.5%
ground-granulated BFS, with a water-to-reagent ratio of 4.5 (grams of water to grams of reagent) to
solidify contaminants in-place, creating a low-permeability monolith.
The conceptual design estimates that a three-foot-thick cover would be designed to maintain the ISS-
treated material below the frost line and to promote stormwater drainage away from the treatment
zone. The protective cover would consist of a non-woven geotextile demarcation fabric, 2.5 to 3 feet
of reuse soil, and approximately six inches of gravel at the surface for erosion protection.
It has been estimated that approximately 3,755 cy of non-impacted soil would be excavated to create
the management area and would be used post-ISS construction for installation of a three-foot-thick
cover over both the ISS treatment and management areas.
Under this alternative, long term monitoring of groundwater would be conducted to evaluate the long-
term effectiveness and permanence of the solidified mass.
Alternative 5: In-situ Thermal Remediation
Capital Cost: $3,395,000
Periodic Costs: $450,000
Present- Worth Cost: $3,5 81,000
Construction Time: 6 months
19
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This remedial alternative combines in-situ thermal remediation (ISTR) with a system to address vapor
management within and around areas with the highest concentration of contaminants.
In-situ thermal treatment methods move or "mobilize" harmful chemicals in soil using heat. The
chemicals move through soil toward wells where they are collected and piped to the ground surface to
be treated using ex-situ cleanup methods. For cost estimating and planning purposes, the conceptual
design assumes an ex-situ approach for vapor management composed of cooling, phase separation, air
stripping, liquid-phase granular-activated carbon (GAC), and vapor-phase GAC following. If some
water is encountered, multi-phase extraction (MPE) would be utilized.
Electrical resistance heating (ERH) and thermal conduction heating (TCH) were determined, based on
their effectiveness for treating lower-permeability till with similar soil electrical properties, to be the
most applicable ISTR technologies for source removal within the lower-permeability till unit at OU5.
For cost estimating purposes, ERH was assumed for the development of this alternative.
Preliminary ERH layouts were developed using a regular 19-foot triangular grid pattern for the
electrodes, with vertical MPE wells and horizontal vapor management wells located at the centroids
between adjacent electrodes. Distributed temperature sensor strings would be used for performance
monitoring. A thermally insulating vapor cap would be constructed to provide a no-flow barrier at the
surface, limit heat losses to ground surface, and minimize the potential for recondensation of vapors
near ground surface.
10. COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy for a site, EPA considers the factors set forth in CERCLA Section 121, 42 U.S.C.
§ 9621, by conducting a detailed analysis of remedial alternatives pursuant to the requirements of the
NCP at 40 C.F.R. § 300.430(e)(9), EPA's Guidance for Conducting Remedial Investigations and
Feasibility Studies, OSWER Directive 9355.3-01, and 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 against each
of the nine evaluation criteria set forth at 40 C.F.R. § 300.430(e)(9)(iii) and a comparative analysis
focusing upon the relative performance of each alternative against those criteria.
The following "threshold" criteria are the most important and must be satisfied by any remedial
alternative in order to be eligible for selection:
1. Overall protection of human health and the environment addresses whether or not 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.
2. Compliance with ARARs addresses whether a remedy would meet all of the applicable or
relevant and appropriate requirements of other federal and state environmental statutes and
regulations or provide grounds for invoking a waiver. Other federal or state advisories, criteria,
20
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or guidance are TBCs. While TBCs are not required to be adhered to by the NCP, the NCP
recognizes that they may be very useful in determining what is protective or how to carry out
certain actions or requirements.
The following "primary balancing" criteria are used to make comparisons and to identify the major
tradeoffs between alternatives:
3. 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 levels 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.
4. 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.
5. 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 of the remedy.
6. Implementability is the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement a particular option.
7. Cost includes estimated capital, O&M, and present-worth costs.
The following "modifying" criteria are used in the final evaluation of the remedial alternatives after
the formal comment period, and they may prompt modification of the preferred remedy that was
presented in the Proposed Plan:
8. State acceptance indicates whether, based on its review of the RI/FS report, HHRA, and
Proposed Plan, the State concurs with, opposes, or has no comments on the proposed remedy.
9. Community acceptance refers to the public's general response to the alternatives described in
the RI/FS report, HHRA, and Proposed Plan.
A comparative analysis of the remedial alternatives considered in this OU5 ROD, based upon the
evaluation criteria noted above, follows.
10.1. Overall Protection of Human Health and the Environment
All of the alternatives except Alternative 1 (No Action) would provide adequate protection of human
health and the environment by eliminating, reducing, or controlling risk through off-site disposal, in-
situ treatment, engineering controls, and/or institutional controls. Alternative 2 (Long-Term
Monitoring) would provide some protection from future exposure to contaminated soil through the
maintenance of the existing cover material (concrete slab floor, pavement, and vegetative cover), and
through institutional controls such as land-use restrictions. However, contaminated soil would remain
in place above the cleanup levels.
21
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Alternative 3 (Excavation) would permanently remove unsaturated soil with VOCs above the cleanup
levels for off-Site disposal while Alternative 5 (In-Situ Thermal Remediation) would remove VOCs
through in-situ treatment and ex-situ recovery for on-Site treatment. Under Alternative 4 (In-Situ Soil
Solidification) contaminated soil would not be destroyed, but rather would be treated in-situ to bind
the contaminants to the material and prevent or slow the release of contaminants from soil.
Alternatives 2, 3, 4, and 5 would achieve the RAOs. Alternative 1 (No Action) would not achieve the
RAOs.
10.2. Compliance with ARARs
EPA has identified NYSDEC's soil cleanup objectives for the protection of groundwater (6 NYCRR
§ 375-6.5) as an ARAR, a "to-be considered," or other guidance to address contaminated soil at the
Site. Refer to Table 9 for the cleanup levels for soil.
Under Alternatives 2 through 5, ARARs would be achieved. Although soil sampling results indicate
that biodegradation of VOC contaminants may be occurring at the AVX Property, given the elevated
concentrations of contaminants in soil, achievement of the cleanup levels under Alternative 2 may not
be reached for many years. Under Alternative 2, elevated concentrations of contaminants in soil would
result in the prolonged presence of contamination in the unsaturated soil, which would continue to act
as a source to groundwater contamination and likely prevent or extend the attainment of the cleanup
levels established in the OU2 AVX ROD Amendment.
Alternatives 2 through 4 would comply with location-specific ARARs, such as the Clean Water Act,
to mitigate adverse impacts on protected wetlands. Alternatives 2 through 4 would comply with action-
specific ARARs, such as hazardous waste management regulations that manage remediation derived
waste. Alternative 1 would not comply with ARARs.
Chemical-, location-, and action-specific ARARs are identified in Appendix II, Tables 6, 7, and 8,
respectively.
10.3. Long-Term Effectiveness and Permanence
Alternative 2 relies on naturally occurring in-situ processes to decrease the concentrations of
contaminants over time. While degradation has been shown to occur in soil and groundwater at the
AVX Property, given the elevated concentrations of contaminants present the timeframe to achieve
the cleanup levels resulting in long-term protectiveness is not anticipated to occur in a reasonable
timeframe. Alternatives 3 through 5 are all effective alternatives in the long-term because they would
remove or solidify the contaminants in unsaturated soil located beneath and near the footprint of the
former manufacturing building, through physical methods (excavation, Alternative 3), solidification
(Alternative 4), and volatilization via thermal treatment followed by soil vapor extraction (Alternative
5). Alternatives 2 through 5 would permanently reduce accessible contaminant concentrations over
time, while Alternatives 3, 4, and 5 would achieve permanent contaminant concentration reduction or
immobilization more quickly. Alternative 1 would not achieve long-term effectiveness or permanence.
22
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Potential Site impacts from climate change have been assessed, and the future performance of the
remedy is currently not at risk due to the expected effects of climate change in the region and near the
Site.
10.4. Reduction of Toxicity, Mobility or Volume
Alternative 2 would reduce the toxicity and volume of contaminants in soil over time, however, the
timeframe to achieve the cleanup levels and long-term protectiveness may not be reached for many
years. Under Alternative 3, the mobility, volume, and exposure to contaminants would be reduced
through the removal and disposal of the soil at an approved off-Site facility. Furthermore, although
currently not anticipated, off-site treatment, if required, would reduce the toxicity of the contaminated
soil prior to disposal. Alternatives 4 and 5 provide active in-situ treatment of contaminants in soil that
would greatly reduce the mobility of these contaminants. Alternative 5 would also reduce the volume
and toxicity of contaminants because it destroys the contaminants rather than solidifying them in-
place. Alternative 1 would not reduce the toxicity, mobility, or volume of contaminants.
10.5. Short-Term Effectiveness
Alternatives 2 through 5 may have short-term impacts to remediation workers, the public, and the
environment during implementation. Alternative 2 could have minimal adverse short-term impacts
since work is limited to the installation of four additional groundwater monitoring wells associated
with the groundwater sampling program. Occupational health and safety controls would be
implemented to mitigate exposure risks. Alternative 2 has an estimated implementation timeframe of
30 years, although it is unclear whether RAOs would be reached within 30 years. Alternative 1 would
not have any short-term impacts as no implementation would be necessary.
Under Alternative 3, the potential risks to workers, the public, or the environment would increase
relative to Alternative 2 due to substantial soil disturbance and offsite transportation of soil, although
these activities would be managed through engineering controls, health and safety procedures, and
worker training. The implementation timeframe for Alternative 3 is estimated to be approximately 4
months.
Under Alternative 4, the potential risks to workers, the public, or the environment would increase
relative to Alternative 2, due to implementation of ISS although these activities would be managed
through engineering controls, health and safety procedures, and worker training. The implementation
timeframe for Alternative 4 is estimated to be approximately 3.5 months.
Installation of the electrodes and associated SVE and MPE wells for Alternative 5 may result in short-
term exposure risks to workers, the public, or the environment, but these potential risks are likely
lower than those from Alternatives 2, 3, and 4 because there will be less physical disturbance and
movement of soil. These potential risks would be managed through engineering controls, vapor
monitoring and mitigation, health and safety procedures, and worker training. The implementation
timeframe for Alternative 5 is estimated to be approximately 6 months.
Based on the information contained above, Alternative 2 presents the least short-term impacts.
Alternative 5, while presenting more short-term impacts than Alternative 2, has less short-term impacts
as compared to Alternatives 3 and 4.
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10.6.
Implementability
All technologies under active Alternatives 3, 4, and 5 are established technologies with commercially
available equipment and are implementable.
Alternative 5 would be the most difficult to implement, as it requires the most specialized equipment
with the installation of electrodes, wells for vapor management, and MPE wells (as necessary),
temperature monitoring points, a power delivery system, and waste stream controls. However, the
equipment is conventional and readily available.
Alternatives 3 and 4 would be easier to implement than Alternative 5, but more difficult than
Alternative 2, as Alternative 2 is not an active remedy.
10.7. Cost
"Cost" includes estimated capital and annual operation 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. This is a standard
assumption in accordance with EPA guidance.
The estimated capital, O&M, and present worth costs are discussed in detail in the FS Report. The
cost estimates are based on the best available information. Alternative 1: No Action has no cost
because no activities are implemented. The highest present worth cost alternative is Alternative 5, at
$3.58 million. The total present worth costs, using a discount rate of 7%, for Alternatives 2 through 5
are as follows:
Allernalive
Capital
Cost
O&M Costs
Total
Present
Worth
2. Long-Term Monitoring
$44,000
$567,000
$291,000
3. Excavation
$2,228,000
$450,000
$2,414,000
4. In-Situ Soil Solidification
$2,715,000
$450,000
$2,901,000
5. In-Situ Thermal Remediation
$3,395,000
$450,000
$3,581,000
10.8. State/Support Agency Acceptance
NYSDEC has consulted with NYSDOH and concurs with the selected remedy. A letter of concurrence
is attached in Appendix IV attached hereto.
10.9. Community Acceptance
"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.
EPA solicited input from the community on the remedial alternatives proposed for OU5 at the Site.
Oral comments received from community members at the August 8, 2023 public meeting generally
24
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related to the details of historical site operations and the negative impact of these operations, the
schedule for remediation of OU5 of the Site, and public health concerns. During the public comment
period from July 27, 2023, through August 28, 2023, one written comment was received via e-mail,
which can be found in Appendix V. Responses to the questions and comments received at the public
meeting and in writing during the public comment period are included in the Responsiveness Summary
(See Appendix V).
11. PRINCIPAL THREAT WASTES
The NCP establishes an expectation that EPA will use treatment to address the principal threats posed
by a site whenever practicable (NCP Section 300.430(a)(l)(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 would present a significant risk to human health
or the environment in the event exposure should occur. The decision to treat these wastes is made on
a site-specific basis through a detailed analysis of alternatives, using the remedy selection criteria
which are described above. The manner in which principal threat wastes are addressed provides a basis
for making a statutory finding that the remedy employs treatment as a principal element.
Varying concentrations of VOCs were detected in soil samples collected during previous
investigations from borings installed within the main manufacturing building at the AVX Property.
Results from previous investigations showed concentrations of 1,1,1-TCA as high as 990 ppm and
TCE as high as 650 ppm in subsurface soil, indicative of the presence of DNAPL in the soil zone at
approximate depths of 16 feet and 6 feet, respectively, below the foundation of the main building.
During the FSIR, concentrations of 1,1,1-TCA and TCE as high as 226 ppm and 1,500 ppm,
respectively, in subsurface soil were revealed. The FSIR results are indicative of the presence of
DNAPL in the soil zone at an approximate depth of five feet below the foundation of the main building.
These findings show the presence of "principal threat" wastes at the AVX Property. The selected
remedy for OU5 discussed in more detail below is expected to remove this contamination through
excavation and off-Site disposal.
12. THE SELECTED REMEDY
Based upon the requirements of CERCLA, the results of OU5 investigations, the detailed analysis of
the alternatives, and public comments, EPA has determined that Alternative 3 (Excavation) best
satisfies the requirements of CERCLA Section 121, 42 U.S.C. §9621, and provides the best balance
of tradeoffs among the remedial alternatives with respect to the NCP's nine evaluation criteria, 40
CFR §300.430(e)(9).
12.1. Summary of the Rationale for the Selected Remedy
While Alternatives 3: Excavation, 4: In-Situ Soil Solidification and 5: In-Situ Thermal Remediation
all use proven technologies to actively treat VOC-contaminated soil in OU5, Alternative 3 would
permanently remove the contaminated soil located beneath and near the footprint of the former
25
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manufacturing building in a relatively short implementation timeframe. Alternative 3 is also
comparatively easier to implement than Alternatives 4 and 5 and uses conventional construction
equipment.
Based upon the information currently available, the selected remedy (Alternative 3: Excavation) meets
the threshold criteria and provides the best balance of tradeoffs compared to the other alternatives with
respect to the balancing criteria. The selected remedy satisfies the following statutory requirements of
Section 121(b) of CERCLA: 1) the selected remedy is protective of human health and the environment;
2) it complies with ARARs; 3) it is cost effective; and 4) it utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable.
Although it is not currently anticipated, if necessary, in order to meet the requirements of the disposal
facilities, contaminated material would be treated prior to land disposal and only under such
circumstances would the selected alternative partially satisfy the preference for treatment.
12.2. Description of the Selected Remedy
The major components of the selected remedy for OU5 include the following:
• Demolition and removal of existing concrete slab floor and foundation supports;
• Excavation of contaminated unsaturated soil located beneath and near the footprint of the
former manufacturing building in the northern portion of the Historical Source Area;
• Off-Site transportation and disposal of excavated material; and
• Restoration with imported clean fill material.
As part of the remedial design, further evaluations will be conducted to define the depth of the water
table and resulting excavation. If determined practicable, additional limited active remediation will be
performed below the water table to address saturated soil in an effort to improve remediation
timeframes for groundwater. During the remedial design, additional soil sampling will also be
conducted to further evaluate the extent of contamination, including 1,4-dioxane.
The selected OU5 remedy to address contaminated soil located beneath and near the footprint of the
former manufacturing building, in conjunction with the OU2 AVX ROD Amendment, constitutes the
final remedy for the AVX Property.
The institutional controls to restrict use of the use of the property to industrial uses, as selected in the
OU2 AVX ROD Amendment, continue to apply to the AVX Property and as such apply to this selected
remedy as well.
The environmental benefits of the selected remedy may be enhanced by employing design
technologies and practices that are sustainable in accordance with EPA Region 2's Clean and Green
Energy Policy. During the remedial design, green remediation concepts, including the use of low-
sulfur vehicles and the proximity to the landfill that would receive the excavated soil in an effort to
reduce the impacts associated with truck trips, will be considered.
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12.3.
Summary of Estimated Remedy Costs
The estimated capital, O&M, and total present-worth costs for the selected remedy are $2,228,000,
$450,000, and $2,414,000, respectively. The costs estimates are based on available information and
are order-of-magnitude engineering cost estimates that are expected to be between +50 to -30 percent
of the actual project cost. Changes to the cost estimate can occur as a result of new information and
data collected during the design of the remedy.
A cost estimate summary for the selected remedy is presented in Appendix II, Table 10 attached hereto.
12.4. Expected Outcomes of the Selected Remedy
The selected remedy actively addresses areas of VOC contaminated soil located beneath and near the
footprint of the former manufacturing building at the AVX Property, identified as OU5 of the Site.
The results of the risk assessment indicate that the contaminated soil at OU5 presents an unacceptable
exposure risk. The response action selected in this ROD will eliminate risks associated with exposure
to contaminated soil. In addition, the removal of contaminated soil is expected to facilitate and
expedite the restoration of the City Aquifer. The selected remedy for OU5, in conjunction with the
OU2 AVX ROD Amendment, constitutes the final remedy for the AVX Property.
13. STATUTORY DETERMINATIONS
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. These provisions require the selection
of remedies that are protective of human health and the environment, comply with ARARs (or justify
a waiver from such requirements), are cost effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable. In
addition, CERCLA includes a preference for remedies that employ treatment that permanently and
significantly reduces the toxicity, mobility, or volume of hazardous substances as a principal element
(or justifies not satisfying the preference). The following sections discuss how the selected remedy
meets these statutory requirements.
13.1. Protection of Human Health and the Environment
The selected remedy will protect human health and the environment because it will permanently
remove unsaturated soil with VOCs above the cleanup levels for off-Site disposal.
13.2. Compliance with ARARs
EPA has identified NYSDEC's soil cleanup objectives for the protection of groundwater (6 NYCRR
§ 375-6.5) as an ARAR, a "to-be considered," or other guidance to address contaminated soil at the
Site. The selected remedy is expected to achieve cleanup levels for COCs in soil. The COCs and the
relevant cleanup levels are provided in Table 9, which can be found in Appendix II attached hereto. A
full list of the ARARs, TBCs, and other guidance related to implementation of the selected remedy is
presented in Tables 6, 7, and 8 which also can be found in Appendix II.
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13.3. Cost Effectiveness
A cost-effective remedy is one whose costs are proportional to its overall effectiveness (40 C.F.R. §
300.430(f)(l)(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. 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.
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 each alternative. The total estimated
present worth cost for implementing the selected remedy is $2,414,000.
Based on the comparison of overall effectiveness to cost, the selected remedy meets the statutory
requirement that Superfund remedies be cost effective (40 C.F.R. § 300.430(f)(l)(ii)(D)) in that it
represents reasonable value for the money to be spent and is thus cost effective. A four-month
timeframe was used for planning and estimating purposes to remediate soil, although remediation
timeframes could exceed this estimate.
13.4. Utilization of Permanent Solutions and Alternative Treatment (or Resource
Recovery) Technologies to Maximum Extent Practicable
The selected remedy complies with the statutory mandate to utilize permanent solutions, alternative
treatment technologies, and resource recovery alternatives to the maximum extent practicable because
removing the contaminated soil is a permanent solution and, if necessary for disposal, treatment will
be utilized.
13.5. Preference for Treatment as a Principal Element
CERCLA includes a preference for remedies that employ treatment that permanently and significantly
reduce the volume, toxicity, or mobility of hazardous substances as a principal element (or justifies
not satisfying the preference). Based on the sampling performed to date, the contaminated soil is not
expected to require treatment to meet the requirements of off-site disposal facilities. While the selected
remedy does not meet the statutory preference for treatment, it nonetheless reduces toxicity, mobility
or volume through excavation and off-Site disposal and on balance is the alternative that best satisfies
all of the NCP criteria.
13.6. Five-Year Review Requirements
The OU5 selected remedy, in combination with the OU2 AYX ROD Amendment, will result in
hazardous substances, pollutants, or contaminants remaining in and around the drainage swale
area at the AYX Property above levels that would otherwise allow for unlimited use and
unrestricted exposure. As a result, in accordance with Section 121(c) of CERCLA, statutory
reviews will be conducted no less often than once every five years to ensure that the remedy
remains protective of human health and the environment.
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14. DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for OU5 was released on July 27, 2023. The Proposed Plan identified Alternative
3 as the preferred alternative for remediating the OU5 contaminated soil.
EPA considered all written and oral comments (including electronic formats such as e-mail) submitted
during the public comment period and has determined that no significant changes to the remedy as
originally identified in the Proposed Plan are necessary or appropriate.
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APPENDIX I
FIGURES
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[pJ2P%W§
£002 Micas.
t9U3 ,-Wlca*s"tRarcel
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APPENDIX II
TABLES
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TABLE 1
Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations
Scenario Timeframe: Current/Future
Medium: AVX Surface and Subsurface Soil
Exposure Medium: Surface and Subsurface Soil
Exposure Point
Chemical of
Concern
Maximum Concentration
Detected OU2 ROD (mg/kg)
Maximum Concentration Detected
2015 OU2 ROD Amendment (mg/kg)
Maximum Concentration
Detected 2023 FSIR
Surface and
Subsurface Soil
1,1,1 -trichloroethane
1,300
990
226 DJ
T etrachloroethene
270
270
723 DJ
T richloroethene
500
650
1500 DJ
Cis-1,2-
dichloroethene
65
93.6 DJ
Trans-1,2-
dichloroethene
ND
0.04
Vinyl chloride
0.6
2.1 DJ
T oluene
16
460
339 DJ
1,2-dichloroethane
0.047
ND
0.083
Xylene
4
315
320.5 DJ
ND - Indicates chemical was not detected
D - Indicates compounds identified in the secondary dilution factor
J - Estimated value
Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations
This table presents the maximum detected concentrations of the chemicals of concern (COCs) detected in surface/subsurface soil across
investigations supporting the 1996 OU2 ROD, OU2 AVX ROD Amendment and this 2023 OU5 ROD.
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TABLE 2
Selection of Exposure Pathways
Scenario
Timeframe
Medium
Exposure
Medium
Exposure Point
Receptor
Population
Receptor
Age
Exposure Route
Type of
Analysis
Rationale for Selection or
Exclusion of Exposure
Pathway
Current/Future
Soil
Surface and
Subsurface Soil
On-site soil
(AVX)
Construction
Worker
Adult
Ingestion/Dermal
/Inhalation
Quant/Qual
Current or future adult
construction workers could be
exposed to on-property soil.
Quant/Qual = Quantitative and qualitative risk analysis performed.
Summary of Selection of Exposure Pathways
This table describes the exposure pathways associated with soil that were evaluated for the risk assessment, to support the OU2 ROD, OU2 AVX ROD Amendment,
and this 2023 OU5 ROD in addition to the rationale for the inclusion of each pathway. Exposure media, exposure points, and characteristics of receptor populations are
included. Exposure to groundwater to future child and adult residents was also evaluated as presented in the OU2 ROD and 2015 AVX ROD Amendment.
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TABLE 3
Noncancer Toxicity Data Summary
Pathway: Oral/Dermal
Chemical of Concern
Oral RfD
(OU2 ROD)
Units
Oral RfD
(Current)
Units
Estimated
Hazard
Higher/Lower
1,1,1 -trichloroethane
9.0E-01
mg/kg-day
2.0E+00
mg/kg-day
Lower
1,2-dichloroethane
6.0E-03
mg/kg-day
Higher
T etrachloroethene
1.0E-01
mg/kg-day
6.0E-03
mg/kg-day
Higher
Trichloroethene
5.0E-04
mg/kg-day
Higher
Cis-1,2-dichloroethene
1.0E-02
mg/kg-day
2.0E-03
mg/kg-day
Higher
Trans-1,2-dichloroethene
1.7E-02
mg/kg-day
2.0E-02
mg/kg-day
Lower
Vinyl chloride
3.0E-03
mg/kg-day
Higher
Toluene
2.0E+00
mg/kg-day
8.0E-02
mg/kg-day
Higher
Xylene
4.0E+00
mg/kg-day
2.0E-01
mg/kg-day
Higher
Pathway: Inhalation
Chemical of Concern
Inhalation RfC
(OU2 ROD)
Units
Inhalation RfC
(Current)
Units
Estimated
Hazard
Higher/Lower
1,1,1 -trichloroethane
5.0E+00
mg/m3
Higher
1,2-dichloroethane
7.0E-03
mg/m3
Higher
T etrachloroethene
4.0E-02
mg/m3
Higher
Trichloroethene
2.0E-03
mg/m3
Higher
Cis-1,2-dichloroethene
4.0E-02
mg/m3
Higher
Trans-1,2-dichloroethene
4.0E-02
mg/m3
Higher
Vinyl chloride
1.0E-01
mg/m3
Higher
Toluene
2.0E+00
mg/m3
5.0E+00
mg/m3
Lower
Xylene
1.0E-01
mg/m3
Higher
Summary of Toxicity Assessment
This table provides non-carcinogenic hazard information which is relevant to the contaminants of concern in soil. The
last column identifies if the hazard index would be higher (increased hazard) or lower (decreased hazard) if the hazards
identified in the OU2 ROD were recalculated.
-------
TABLE 4
Cancer Toxicity Data Summary
Pathway: Oral/Dermal
Oral Cancer
Oral Cancer
Risk Estimate
Higher/Lower
Chemical of Concern
Slope Factor
(OU2 ROD)
Units
Slope Factor
(Current)
Units
1,1,1 -trichloroethane
1,2-dichloroethane
9.1E-02
mg/kg-day
9.1E-02
mg/kg-day
Same
T etrachloroethene
5.32E-02
mg/kg-day
2.1E-03
mg/kg-day
Lower
Trichloroethene
1.1E-02
mg/kg-day
4.6E-02
mg/kg-day
Higher
Cis-1,2-dichloroethene
Trans-1,2-dichloroethene
Vinyl chloride
1.9E+00
mg/kg-day
7.2E-01
mg/kg-day
Lower
Toluene
Xylene
Pathway: Inhalation
Chemical of Concern
Unit Risk
(OU2 ROD)
Units
Unit Risk
(Current)
Units
Risk Estimate
Higher/Lower
1,1,1 -trichloroethane
1,2-dichloroethane
2.6E-05
ug/m3
2.6E-05
ug/m3
Same
T etrachloroethene
5.7E-07
/ 3
ug/m
2.6E-07
/ 3
ug/m
Lower
Trichloroethene
1.7E-06
/ 3
ug/m
4.1E-06
/ 3
ug/m
Higher
Cis-1,2-dichloroethene
Trans-1,2-dichloroethene
Vinyl chloride
8.4E-05
ug/m3
4.4E-06
ug/m3
Lower
Toluene
Xylene
Summary of Toxicity Assessment
This table provides carcinogenic risk information which is relevant to the contaminants of concern in soil. Toxicity data
are provided for both the oral and inhalation routes of exposure. The last column identifies if the risk would be higher
(increased risk) or lower (decreased risk) if the risks identified in the OU2 ROD were recalculated.
-------
TABLE 5
Risk Characterization Summary - Carcinogens and Noncarcinogens
Scenario Timeframe: Current/Future
Medium: Surface and subsurface soil
Receptor
Carcinogenic Risk
Ingestion
Dermal
Inhalation
Cancer Risk
Total
Non-Carcinogenic Hazard
Ingestion
Dermal
Inhalation
Hazard
Index Total
Adult
Construction
Worker
4.97E-05
2.32E-08
4.97E-05
0.502
0.0512
0.507
Summary of Risk Characterization - Carcinogens and Non-Carcinogens
This table presents the cancer risks and non-cancer hazards for the construction worker exposed to soil, which was presented
in the OU2 ROD. As stated in the National Contingency Plan, the point of departure is 10-6 and the acceptable risk range for site
related exposure is 10-6 to 10-4. The NCP also indicates that the acceptable non-cancer hazard index is 1. Concentrations detected in
surface/subsurface soil on the AVX property during investigations supporting the OU2 AVX ROD Amendment as well as this OU5
ROD are largely higher than the concentrations reported in the OU2 ROD. Thus, a qualitative evaluation found that the risks and
hazards identified in the OU2 ROD were underestimated and would likely be greater than those presented in the OU2 ROD.
Regardless, the contaminants in soil continue to act as a source to elevated concentrations in groundwater exceeding Maximum
Contaminant Levels and a remedial action is warranted.
-------
Table 6
Chemical-Specific ARARs, TBCs, and Other Guidelines
Olean Well Field OU5 Superfund Site
Olean, New York
Media/Authority
Requirement
Requirement Synopsis
New York Remedial Program Soil Cleanup
Objectives (6 NYCRR Subpart 375-6.4, 6.5,
6.8), pursuant to the New York Environmental
Conservation Law
Applies to the development and implementation
of remedial programs for soil. Establishes
numeric soil cleanup objectives both for
unrestricted use and for restricted use for the
protection of human health, the protection of
ecological resources, and the protection of
groundwater.
State Criteria,
Advisories, and
Guidance
NYSDEC Commissioner Policy - Soil Cleanup
Guidance (CP-51), October 2010
This policy provides the framework and
procedures for the selection of soil cleanup
levels appropriate for each of the remedial
programs in the NYSDEC Division of
Environmental Remediation.
Sampling, Analysis, and Assessment of
Polyfluoroalkyl Substances (PFAS) Under
NYSDEC's Part 375 Remedial Programs, April
2023
This document summarizes currently accepted
procedures and updates previous NYSDEC
Division of Environmental Remediation technical
guidance pertaining to PFAS to ensure
consistency in sampling, analysis, reporting, and
assessment of PFAS.
Federal Criteria,
Advisories, and
Guidance
USEPA RSLs for Chemical Contaminants at
Superfund Sites (USEPA May 2023 and periodic
updates)
Provides non-enforceable, generic, risk-based
contaminant concentrations to be used for site
"screening."
Notes:
ARAR = applicable or relevant and appropriate requirement
NYCRR = New York Codes, Rules, and Regulations
NYSDEC = New York State Department of Environmental Conservation
PFAS = per- and polyfluoroalkyl Substances
PFOA = perfiuorooctanoic acid
PFOS = perfluorooctanesulfonic acid
ppb = parts per billion
RSL= Regional Screening Level
TBC = To Be Considered
USEPA = United States Environmental Protection Agency
Table 3-1 - Chemical-Specific ARARs Criteria Advisories and Guidance
1/1
-------
Table 7
Location-Specific ARARs, TBCs, and Other Guidelines
Olean Well Field OU5 Superfund Site
Olean, New York
Site Feature/Authority
Requirement
Requirement Synopsis I
Wetlands and Floodplains
State Criteria, Advisories,
and Guidance
New York Regulations concerning Freshwater
Wetlands (6 NYCRR Parts 663 and 665),
pursuant to the New York Environmental
Conservation Law
Regulations to ensure the preservation of New
York regulated freshwater wetlands. Regulates
activities that may adversely affect wetlands.
Federal Regulatory
Requirements
Section 404(b)(1) of the Clean Water Act, 33
U.S.C. §1344 (Permits for Dredged or Fill
Material); Guidelines for Specification of
Disposal Sites for Dredged or Fill Material (40
CFR Part 230); and Section 404(c)
Procedures (40 CFR Part 231)
Under these requirements, no activity that
adversely affects a CWA Section 404 wetland
shall be permitted if a practicable alternative
with lesser effects is available. Controls
discharges of dredged or fill material to protect
aquatic ecosystems.
40 CFR Part 6, Appendix A - Statement of
Procedures on Floodplain Management and
Wetlands Protection (44 FR 64177, Nov. 6,
1976, as amended at 50 FR 26323, June 25,
1985)
Action to avoid, whenever possible, the long-
and short-term impacts on wetlands and to
preserve and enhance wetlands. Plans for
action in federal wetlands must be submitted for
public review.
Action to avoid, whenever possible, the long-
and short-term impacts associated with the
occupancy and modifications of floodplains
development, wherever there is a practical
alternative. Promotes the preservation and
restoration of floodplains so that their natural
and beneficial value can be realized.
Fish and Wildlife Coordination Act
(16 U.S.C. 661-668ee)
Any modification of a body of water that triggers
a federal approval requires consultation with the
U.S. Fish and Wildlife Service and the
appropriate state wildlife agency to develop
measures to prevent, mitigate, or compensate
for losses of fish and wildlife. This requirement
is addressed under CWA Section 404
requirements.
-------
Table 7
Location-Specific ARARs, TBCs, and Other Guidelines
Olean Well Field OU5 Superfund Site
Olean, New York
Site Feature/Authority
Requirement
Requirement Synopsis
Endangered Species
Federal Regulatory
Requirements
Endangered Species Act (16 U.S.C. 1531-
1532, 1536, and 1538-1540; 50 CFR Part 402)
Requires actions to ensure the continued
existence of any endangered or threatened
species. Also requires that their habitats will not
be jeopardized by a site action.
State Criteria, Advisories,
and Guidance
6 NYCRR Parts 182.1-182.2, 182.5, 182.8-
182.13, and 182.15-182.16 - Endangered and
Threatened Species of Fish and Wildlife;
Species of Special Concern: Incidental Take
Permits, pursuant to the New York
Environmental Conservation Law
Requires actions to ensure the continued
existence of endangered or threatened species.
Notes:
CFR = Code of Federal Regulations
CWA = Clean Water Act
FR = Federal Register
NYCRR = New York Codes, Rules, and Regulations
TBC = To Be Considered
U.S.C. = United States Code
2/2
-------
Table 8
Action-Specific ARARs, TBCs, and Other Guidelines
Olean Well Field OU5 Superfund Site
Olean, New York
Media/Authority
Requirement
Requirement Synopsis
Air
Federal Regulatory
Requirements
Clean Air Act - National Primary and Secondary Ambient Air
Quality Standards (40 CFR Parts 50.1-50.3 and 50.6) and
National Emission Standards for Hazardous Air Pollutants
(40 CFR Parts 61.01 -61.19)
Establishes air emissions limits for hazardous air pollutants.
State Criteria,
Advisories, and
Guidance
New York Air Pollution Control Regulations: 6 NYCRR Part 200
(General Provisions); 6 NYCRR Part 201 (Permits and
Registrations); 6 NYCRR Part 202 (Emissions Verification); 6
NYCRR Part 211 (General Prohibitions); 6 NYCRR Part 256 (Air
Quality Classifications System); 6 NYCRR Part 257 (Air Quality
Standards); 6 NYCRR Part 263 (Air Quality Regulations for
Cattaraugus County); all pursuant to the New York
Environmental Conservation Law
Prohibits emissions of any contaminant that may become
injurious to human, plant, or animal life. Provides emission
standards. Describes applicable permits.
NYSDOH - Generic Community Air Monitoring Plan (DER-10,
Appendix 1A)
Provides a generic plan for monitoring of air quality during
remedial construction.
Surface Water
Federal Regulatory
Requirements
Federal National Pollutant Discharge Elimination System
Regulations (40 CFR Part 122 and 125)
Federal water quality standards/pollutant effluent discharge
standards.
State Criteria,
Advisories, and
Guidance
State Pollutant Discharge Elimination System Regulations (6
NYCRR Part 750), pursuant to Article 17 of the New York
Environmental Conservation Law (Consolidated Laws of New
York, Chapter 43-B, Article 17), New York State Surface Water
and Groundwater Quality Standards and Groundwater Effluent
Limitations (6 NYCRR Part 703), and New York State Division of
Water Technical and Operational Guidance Series (TOGS)
Ambient Water Quality Standards and Guidance Values and
Groundwater Effluent Limitations (TOGS 1.1.1)
Establishes state water quality standards/pollutant effluent
discharge standards.
Waste
-------
Table 8
Action-Specific ARARs, TBCs, and Other Guidelines
Olean Well Field OU5 Superfund Site
Olean, New York
Media/Authority
Requirement
Requirement Synopsis
Federal Regulatory
Requirements
RCRA 40 CFR Part 261.30-261.31 and 261.170-261.179
(Identification and Listing of Hazardous Waste), 40 CFR Part
262.11, 262.13, 262.18, 262.40, 262.44 and subparts B, C, and
H (Standards Applicable to Generators of Hazardous Waste);
and 40 CFR Part 263.10-263.12, 263.20-263.22 and 263.25
Standards Applicable to Transporters of Hazardous Waste
Defines waste that are subject to regulation as hazardous
waste under 40 CFR Parts 262-264. Defines regulations
applicable to generators and transporters of hazardous
waste.
USDOT Rules for Transportation of
Hazardous Materials
(49 CFR Parts 107, 171, 172, 177, 179)
Outlines procedures for the packaging, labeling,
manifesting, and transporting of hazardous materials.
New York Solid Waste Management Regulations
(6 NYCRR Part 360)
Establishes standards and criteria for solid waste
management operations. Regulations apply to land disposal
of non-hazardous wastes.
State Criteria,
Advisories, and
Guidance
New York Hazardous Waste Management Regulations
(6 NYCRR Parts 370-376)
Establishes criteria for identifying and handling hazardous
waste. Regulations apply to owners and operators of
facilities that treat, store, or dispose hazardous wastes.
New York State Waste Transporter Regulations
(6 NYCRR Part 364)
Establishes permit requirements for transportation of
regulated waste.
New York State Hazardous Waste Manifest System and
Related Standards for Generators, Transporters and Facilities
(6 NYCRR Part 372)
Establishes record keeping requirements and standards
related to the manifest system for hazardous wastes.
General
Federal Criteria,
Advisories, and
Guidance
USEPA Region 2 Clean and Green Policy
Establishes preferences for sustainable technologies and
practices for federal cleanup programs.
State Criteria,
Advisories, and
Guidance
NYSDEC DER Green Remediation (DER-31, January 2011)
Defines "green remediation" and identifies the NYSDEC's
approach to implementing green remediation.
NYSDEC Groundwater Monitoring Well Decommissioning Policy
(CP-43, November 2009)
Provides the procedures for decommissioning groundwater
monitoring wells.
Notes:
CFR = Code of Federal Regulations RCRA = Resource Conservation and Recovery Act
DAR - Division of Air RSL = Regional Screening Level
DER = Division of Environmental Remediation TOGS = Technical and Operational Guidance Series
NYCRR = New York Codes, Rules, and Regulations TBC = To Be Considered
NYSDEC = New York State Department of Environmental Conservation USEPA = United States Environmental Protection Agency
OSWER = Office of Solid Waste and Emergency Response WQC = Water Quality Criteria
2/2
-------
Table 9 - Cleanup Levels for Chemicals of Concern
Chemicals of Concern
NYSDEC Soil Cleanup
Objectives
TCE
0.47
C/s-1,2-DCE
0.25
1,4-dioxane
0.1
Vinyl Chloride
0.02
1,1,1-TCA
0.68
1,2-DCA
0.02
Toluene
0.7
Xylene
1.6
Trans-1,2- DC E
0.19
PCE
1.3
* NYSDEC SCOs [6 NYCRR Section 375-6.5] are based on the protection of groundwater.
-------
Table 10
Cost Estimate Summary for the Selected Remedy
Item Description
Estimated
Quantity
Unit
Unit Price
Cost
Site Preparation
Permits and Notifications
1
Lump Sum
$5,000.00
$5,000
Submittals
1
Lump Sum
$5,000.00
$5,000
Mobilization
1
Lump Sum
$134,000.00
$134,000
Temporary Controls, Facilities, and Project Support
1
Lump Sum
$40,000.00
$40,000
Construction Layout and Surveying
1
Lump Sum
$20,000.00
$20,000
Utility Termination / Utility Protection
1
Lump Sum
$5,000.00
$5,000
Subtotal
S209.000
Implementation
On-Site Construction Wastewater Handling
1
Lump Sum
$ 30,000.00
$30,000
Imported Fill Material Geotechnical Sampling
2
Per Sample
$ 600.00
$1,200
Imported Fill Chemical Sampling
15
Per Sample
$ 1,160.00
$17,400
Concrete Removal
13,000
Square Feet
$ 1.50
$19,500
Soil Excavation - Benching/Sloping
275
Cubic Yard
$ 30.00
$8,250
Excavation Support - Trench Box
1
Lump Sum
$ 25,000.00
$25,000
Soil Excavation
5,500
Cubic Yard
$ 30.00
$165,000
Post-Excavation Soil Sampling
27
Per Sample
$ 55.00
$1,464
Soil Drying Agent
20
Ton
$ 400.00
$8,000
Waste Characterization Sampling
5
Per Sample
$ 600.00
$3,000
Transportation and Disposal - C&D Debris
600
Ton
$ 40.00
$24,000
Transportation and Disposal - Non-Hazardous Soil and Debris
10,000
Ton
$ 65.00
$650,000
Subtotal
$952,814
Site Restoration
General Fill
8,700
Ton
$26.00
$226,200
Type 2 Subbase
1,200
Ton
$80.00
$96,000
Demobilization
1
Lump Sum
$110,000.00
$110,000
Subtotal
S432.200
Management
Engineering Design and Coordination
1
Lump Sum
$ 90,000.00
$90,000
Construction Oversight
1
Lump Sum
$ 225,000.00
$225,000
Subtotal
S315.000
Total
S1.909.014
Construction Contingency (20"'..)
S318.803
CAPITAL COST $2,228,000
TOTAL ANNUAL INSPECTION AND COVER/FENCE MAINTENANCE COSTS $450,000
NET PRESENT VALUE (7% Discount Rate) $2,414,000
-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
07/26/2023 REGION ID: 02
Site Name: OLEAN WELL FIELD
CERCLIS ID: NYD980528657
OUID: 05
SSID: 0216
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Orgariization:
676982
7/26/2023
ADMINISTRATIVE RECORD INDEX FOR OU5 FOR THE
OLEAN WELL FIELD SITE
5
Administrative
Record Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
54611
09/24/1985
Record of Decision - Oiean Well Field Site, Olean,
Cattaragus County, New York, September 24, 1985.
37
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
54635
12/01/1993
Report: Final Risk Assessment, Olean Well Field,
Oiean, New York, prepared for U.S. EPA, Region II,
prepared by Ebasco Services Incorporated, December
1993.
172
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
(EBASCO SERVICES INC)
54888
09/30/1996
Record of Decision - Olean Well Field Site, Olean,
Cattaragus County, New York, September 1996,
327
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
267626
03/18/1998
CONSENT DECREE CIVIL ACTION NO. l:98-CV-00054
UNITED STATES V. AVX CORPORATION FOR THE
OLEAN WELL FIELD SITE
113
Legal Instrument
(US DISTRICT COURT FOR THE WESTERN
DISTRICT OF NEW YORK)
300260
03/01/1999
FINAL REMEDIAL DESIGN / REMEDIAL ACTION WORK
PLAN FOR OU2 FOR THE OLEAN WELL FIELD SITE
59
Work Plan
(AVX CORPORATION)
(BBL ENVIRONMENTAL SERVICES
INCORPORATED)
Page 1 of 5
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
07/26/2023 REGION ID: 02
Site Name: OLEAN WELL FIELD
CERCLIS ID: NYD980528657
OUID: 05
SSID: 0216
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Orgariization:
122681
04/01/2001
STAGE 1 REMEDIAL ACTION REPORT VOLUME 1 FOR
THE OLEAN WELL FIELD SITE
131
Report
(AVX CORPORATION)
(BlASIAND, BOUCK& LEE,
INCORPORATED)
122682
04/01/2001
STAGE 1 REMEDIAL ACTION REPORT VOLUME II FOR
THE OLEAN WELL FIELD SITE
833
Report
(AVX CORPORATION)
(BLASLAND, BOUCK& LEE,
INCORPORATED)
297740
07/20/2012
ARCADIS'S MONITORED NATURAL ATTENUATION
SCREENING ANALYSIS IN RESPONSE TO EPA'S
COMMENT 26 TO THE FEASIBILITY STUDY REPORT
FOR THE AVX CORPORATION PROPERTY FOR THE
OLEAN WELL FIELD SITE
16
Letter
MANNING,PETER (US ENVIRONMENTAL
PROTECTION AGENCY)
HANISH,MARK,B (BBL ENVIRONMENTAL
SERVICES INCORPORATED)
682183
04/16/2013
COMPREHENSIVE ADMINISTRATIVE RECORD INDEX
FOR OU1 FOR THE OLEAN WELL FIELD SITE
2
Administrative
Record Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
687031
07/16/2013
COMPREHENSIVE ADMINISTRATIVE RECORD INDEX
FOR OU2 FOR THE OLEAN WELL FIELD SITE
24
Administrative
Record Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
319291
09/30/2015
ADMINISTRATIVE RECORD INDEX FOR OU2 - AVX ROD
AMENDMENT FOR THE OLEAN WELL FIELD SITE
15
Administrative
Record Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
372868
09/30/2015
RECORD OF DECISION AMENDMENT FOR OU2 - AVX
PROPERTY FOR THE OLEAN WELL FIELD SITE
176
Report
MUGDAN,WALTER,E (US ENVIRONMENTAL
PROTECTION AGENCY)
Page 2 of 5
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
07/26/2023 REGION ID: 02
Site Name: OLEAN WELL FIELD
CERCLIS ID: NYD980528657
OUID: 05
SSID: 0216
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Orgariization:
458774
01/25/2017
AMENDED REMEDIAL DESIGN / REMEDIAL ACTION
CONSENT DECREE OU2 CIVIL ACTION NO, 1:98-CV-
00054 REGARDING AVX CORPORATION FOR THE
OLEAN WELL FIELD SITE
245
Legal Instrument
(UNITED STATES DISTRICT
JUDGE) | CUMMINGS,KURT,P (AVX
CORPORATION) | MUGDAN,WALTER (US
ENVIRONMENTAL PROTECTION AGENCY)
607915
01/01/2018
REMEDIAL DESIGN WORK PLAN AVX PROPERTY FOR
OU2 FOR THE OLEAN WELL FIELD SITE
823
Work Plan
(AVX CORPORATION)
689015
03/20/2018
NOTICE OF CESSATION OF OPERATIONS AT AVX
CORPORATION FOR OU5 FOR THE OLEAN WELL FIELD
SITE
2
Letter
(US DEPARTMENT OF JUSTICE) | (US
ENVIRONMENTAL PROTECTION AGENCY)
(NIXON PEABODY LLP)
607919
09/01/2018
PRE-DESIGN INVESTIGATION REPORT AVX PROPERTY
FOR OU2 FOR THE OLEAN WELL FIELD SITE
161
Report
(AVX CORPORATION)
689017
05/29/2020
AMENDED FEASIBILITY STUDY HEALTH AND SAFETY
PLAN FOR AVX CORPORATION FOR OU2 FOR THE
OLEAN WELL FIELD SITE
174
Work Plan
(ARCADIS)
615296
09/01/2020
FEASIBILITY STUDY WORK PLAN - SOURCE AREA FOR
OU2 FOR THE OLEAN WEEL FIELD SITE
47
Work Pian
(AVX CORPORATION)
(ARCADIS)
Page 3 of 5
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
07/26/2023 REGION ID: 02
Site Name: OLEAN WELL FIELD
CERCLIS ID: NYD980528657
OUID: 05
SSID: 0216
Action:
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Orgariization:
689016
05/29/2021
FEASIBILITY STUDY QUALITY ASSURANCE PROJECT
PLAN FOR AVX CORPORATION FOR OU2 FOR THE
OLEAN WELL FIELD SITE
794
Work Plan
(ARCADIS)
677369
07/09/2021
FINAL 100% REMEDIAL DESIGN REPORT FOR THE AVX
PROPERTY FOR OU2 FOR THE OLEAN WELL FIELD SITE
1841
Report
(ARCADIS)
677370
07/09/2021
TRANSMITTAL OF THE FINAL 100% REMEDIAL DESIGN
REPORT AND RESPONSE TO COMMENTS ON THE 95%
REMEDIAL DESIGN REPORT FOR THE AVX PROPERTY
FOR OU2 FOR THE OLEAN WELL FIELD SITE
5
Letter
MANNING,PIETRO (US ENVIRONMENTAL
PROTECTION AGENCY)
(ARCADIS)
638430
10/19/2021
TRANSMITTAL OF THE REMEDIAL ACTION WORK
PLAN FOR OU2 - AVX PROPERTY FOR THE OLEAN
WELL FIELD SITE
1
Letter
MANNINO.PIETRO (US ENVIRONMENTAL
PROTECTION AGENCY)
HANISH,MARK (ARCADIS)
638431
10/19/2021
REMEDIAL ACTION WORK PLAN FOR OU2 - AVX
PROPERTY FOR THE OLEAN WELL FIELD SITE
100
Work Plan
HANISH,MARK (ARCADIS)
677221
06/30/2022
FEASIBILITY STUDY INVESTIGATION REPORT - SOURCE
AREA FOR OU5 FOR THE OLEAN WELL FIELD SITE
1576
Report
(KYOCERA AVX COMPONENTS
CORPORATION)
(ARCADIS)
630531
09/30/2022
ADMINISTRATIVE RECORD INDEX FOR OU4 FOR THE
OLEAN WELL FIELD SITE
6
Administrative
Record Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
Page 4 of 5
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
07/26/2023 REGION ID: 02
Site Name: OLEAN WELL FIELD
CERCLIS ID: NYD980528657
OUID: 05
SSID: 0216
Action:
DocID:
Doc Date:
Title:
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689014
07/01/2023
FEASIBILITY STUDY REPORT - AVX SOURCE AREA
KYOCERA AVX COMPONENTS CORPORATION FOR
OU5 FOR THE OLEAN WELL FIELD SITE
135
Report
(KYOCERA AVX COMPONENTS
CORPORATION)
(ARCADIS)
652561
7/26/2023
PROPOSED PLAN FOR OU5 FOR THE OLEAN WELL
FIELD SITE
19
Publication
(US ENVIRONMENTAL PROTECTION
AGENCY)
Page 5 of 5
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APPENDIX IV
STATE LETTER OF CONCURRENCE
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
PiviMon of l:nviroimiviiUtl Rinioeit.itkm, Otfit <* of thf Directot
62B Bioudway, 12th Floor, Albany, New York 12233-7011
P: p18) 402-9706 I F; (51B) 40P-9020
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additional soil sampling would also be conducted to further evaluate the extent of
contamination, including 1,4-dioxarie.
The OU5 remedy in conjunction with the OU2 ROD Amendment will constitute the final
remedy for the AVX Property.
The environmental benefits of the remedial alternative may be enhanced by employing
design technologies and practices that are sustainable,
EPA released the Proposed Plan for the cleanup of OU5 to the public for comment on
July 27, 2023. EPA also held a public meeting on August 8, 2023 to present the Proposed
Plan for OU5 to local officials and interested citizens and to solicit input from the
community on the remedial alternatives proposed for OU5. EPA considered all written
and oral comments submitted during the public comment period (July 27, 2023 through
August 28, 2023), which are documented in the Responsiveness Summary section of the
ROD, and determined that no significant changes to the remedy, as originally identified
in the Proposed Plan, were necessary or appropriate. With this understanding, we concur
with the selected remedy for the Olean Well Field OU5 Site.
If you have any questions or need additional information, please contact Mr Sloven
Moeller at (718) 851-7220.
ec: P. Mannino, USFPA, Region 2 (mannino.pietfO@epa.gov)
M. Wurtz, USEPA, Region 2(wurtz.maeve@epa.gov)
C. Bethoney, NYSDOH (charlotte.bethoney@health.ny.gov)
M. Cruden, NYSDEC (michael.cruden@dec.ny.gov)
S. Radon, NYSDEC, Region 9 (stanley.radon@dec.ny.gov)
S. Moeller, NYSDEC, Region 9 (steven.moeller@dec.ny.gov
Sincerely,
Andrew 0. Guglielmi
Director
Division of Environmental Remediation
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APPENDIX V
RESPONSIVENESS SUMMARY
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APPENDIX V
RESPONSIVENESS SUMMARY
Table of Contents
Appendix V:
Appendix V - Attachment 1
Appendix V - Attachment 2
Appendix V - Attachment 3
Appendix V - Attachment 4
Introduction
Summary of Community Relations Activities
Summary of Comments and EPA Responses
Proposed Plan
Public Notice - Commencement of Public Comment Period
August 8, 2023 Public Meeting Transcript
Written Comments Submitted During Public Comment
Period
1
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INTRODUCTION
A responsiveness summary is required by the regulations promulgated under the Superfund statute.
It provides a summary of comments received during the public comment period, as well as the
responses of the U.S. Environmental Protection Agency (EPA) to those comments. All comments
received were considered by EPA in its Record of Decision (ROD) regarding the selection of the
fifth operable unit (OU5) remedy at the Olean Well Field Superfund Site (Site).
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The Proposed Plan for OU5, attached hereto as Attachment 1, was released to the public on July
27, 2023, along with the Feasibility Study Investigation Report (FSIR) and Feasibility Study (FS),
as well as other documents contained in the Administrative Record for the OU5 ROD. EPA's
preferred remedy and the basis for that preference were identified in the Proposed Plan.
These documents, including the Proposed Plan, were made available to the public at information
repositories maintained at the Olean Public Library; the EPA Region 2 Superfund Records Center
in New York, New York; and on EPA's website for the Olean Well Field Superfund Site located
at www.epa.gov/superfund/olean-wellfield.
A notice of the commencement of the public comment period, the public meeting date, a
description of the preferred remedy, EPA contact information, and the availability of the above-
referenced documents, attached hereto as Attachment 2, was published in the Olean Times Herald,
a local newspaper, on July 27, 2023. The public comment period ran from July 27, 2023, to August
28, 2023.
EPA held a public meeting on August 8, 2023, at 6:00 P.M. at the Jamestown Community College
TECH Building, 305 North Barry Street, Olean, New York to discuss the findings of the FSIR and
FS Reports and to answer questions from the public about the remedial alternatives and the
proposed remedy. A copy of the public meeting transcript is attached hereto as Attachment 3.
Responses to the oral questions and comments received at the public meeting and in writing during
the public comment period are included in this Responsiveness Summary.
SUMMARY OF COMMENTS AND EPA RESPONSES
A summary of the comments provided at the public meeting on August 8, 2023, as well as EPA's
responses to those comments, are provided below. One written comment was received via email
during the public comment period from an area resident. A copy of the email received is provided
in Attachment 4 of this Responsiveness Summary.
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Comment Summary
This section summarizes comments received from the public concerning OU5 of the Olean Well
Field Site at the public meeting on August 8, 2023, as well as one comment via email, and EPA's
responses.
Comment #1: An area resident commented that the Olean Tile property may be a source of
contamination. The resident also noted a concern regarding the use of the word oversight in EPA's
July 2023 community update flyer, stating their belief that the release of contamination to the
environment by the PRPs was deliberate and not an oversight.
Response to Comment #1: The former Dai-Tile property (previously Olean Tile) and 13 other
properties were evaluated as potential source areas in the early 1990s. Four of the 14 investigated
source areas were identified as being sources of the groundwater contamination at the Site. While
these previous investigations did not reveal the former Dai-Tile property as a source area, the
former Dai-Tile property was included as part of the recent OU4 investigation due to its proximity
to the AVX Property. While the OU4 investigation confirmed the presence of debris from tile
manufacturing activities, the sampling results did not reveal the former Dai-Tile property as a
source of VOC groundwater contamination.
Regarding the commenter's concern with EPA's reference to oversight in the July 2023
community update flyer, the commenter may have misinterpreted EPA's use of the term. EPA did
not intend to imply that the release of contamination at the Site was not deliberate. Rather, the term
in the flyer describes EPA's oversight of the work performed by PRPs at each of the source areas.
Comment #2: An area resident asked if EPA would notify the public of the issuance of the selected
remedy.
Response to Comment #2: EPA will notify the public of the issuance of the OU5 Record of
Decision (ROD), the document that memorializes the selection of a remedy for this OU.
Comment #3: An area resident asked when EPA would have a decision on the remedy.
Response to Comment #3: EPA typically issues RODs shortly after the close of the public
comment period, which it has done for the OU5 ROD, of which this Responsiveness Summary is
a part.
Comment #4: An area resident asked why no public officials were in attendance at the public
meeting.
Response to Comment #4: Notification of the Proposed Plan's release, including the public
meeting, was sent to Cattaraugus County and New York State officials, as well as the City of Olean
mayor's office on July 27, 2023.
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Comment #5: Two area residents requested sampling of the private well water at their properties.
In addition, one of the residents, located to the northeast of and adjacent to the AVX Property, also
requested sampling of the soil on their property.
Response to Comment #5: Based upon historic and current groundwater sampling results, there
is no indication that the groundwater in the vicinity of these two residences has been impacted by
Site-related contamination and therefore sampling of the two private wells is not warranted for
purposes of the Superfund cleanup. EPA recommends contacting the Cattaraugus County Health
Department or the New York State Department of Environmental Conservation to inquire
regarding testing of potable water at a private property. Robert Ring with Cattaraugus County can
be reached at rwring@cattco.ore or 716-701-3437. Steve Moeller with NYSDEC can be reached
at Steven.moeller@dec.ny.gov or 716-851-7289.
Investigations conducted at the AVX Property have revealed contamination beneath the former
AVX manufacturing building near the southern portion of the building, as well as in the southern
portions of the AVX Property. Monitoring well AVX-8DR, located in the northeastern corner of
the AVX Property, was installed in June 2003. While initial sampling results for this monitoring
well revealed VOC contaminated groundwater, sampling conducted between 2003 and 2006
revealed gradually decreasing levels of VOCs until no concentrations were detected above their
respective maximum contaminant levels for multiple sampling events. As a result, sampling of this
monitoring well was discontinued. In addition, surface soil samples collected and analyzed in 2011
from the northeast portion of the AVX Property did not detect VOC contamination. Given the
sampling results in the northeast corner of the AVX Property, additional off-property soil sampling
is not necessary.
Comment #6: An area resident noted that the city water line was not extended to his property on
Seneca Avenue and asked why it was not extended further.
Response to Comment #6: Pursuant to the 1985 OU1 ROD, work associated with the city water
line extension was broken into four zones. The portion of Seneca Avenue referenced by the
commenter was included as part of zone 3. For zones 1, 2, and 4, the city water line was extended
enabling connections to each of the residents with private wells in those zones. For zone 3,
residences were monitored quarterly until 1998, at which time monitoring was discontinued as no
VOCs had been detected; since no VOCs were detected, it was determined that an extension to
these residences was not warranted.
Comment #7: An area resident asked if stormwater drains near Olean Creek could get cleaned out
to aid in the drainage of water.
Response to Comment #7: The clearing of debris from municipal storm drains to aid in surface
water drainage cannot be addressed using Superfund authority. EPA's responsibilities at the Site
relate to the VOC contaminated groundwater, soil, and the sources of the contamination. EPA
recommends speaking to the local government about this issue.
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Comment #8: An area resident asked about the status of the cleanup on the AVX Property,
specifically the construction of the hydraulic trench.
Response to Comment #8: Construction of the remedy identified in the 2015 OU2 AVX ROD
Amendment, including the hydraulic trench and treatment plant, was completed in January 2023.
The remedy has been operating since construction was completed. EPA is currently reviewing
periodic groundwater monitoring and treated effluent data that has been collected from the AVX
Property to ensure the system is effectively treating the groundwater.
Comment #9: An area resident asked if the former canal located on the Alcas property had been
tested for contamination. The resident stated that the canal is now filled in.
Response to Comment #9: While not related to the OU5 remedy, the following responds to this
comment. Prior investigations of the Alcas Property do not specifically refer to a former canal.
However, based on further details provided by the commenter after the public meeting ended, it is
EPA's understanding that a former canal was located along the southern edge of the Alcas Property
and that the main building there was built on a portion of the filled-in canal. The highest
concentrations of contaminants detected on the Alcas Property were below the foundation of the
main building and around the southeast corner of the main building. In addition, in September
2014, EPA issued a ROD for several parcels of land to the south of the Alcas Property and the
former canal, that were determined to be impacted by contaminated groundwater from the Alcas
Property, referred to as Parcel B. Implementation of the selected remedies addressing the
contamination at the Alcas Property and Parcel B both began in 2020 and are ongoing. Refer to
the 2014 OU2 Alcas ROD Amendment and OU3 Parcel B ROD for more information regarding
these remedies.
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ATTACHMENT A
PROPOSED PLAN
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Superfund Proposed Plan U.S. Environmental Protection Agency, Region 2
Olean Well Field Superfund Site
Operable Unit 5
Cattaraugus County, New York My 2023
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan describes the remedial alternatives
considered to address soil contamination at a discrete area
of the property located at 1695 Seneca Avenue, Olean.
New York (AVX Property), which has been designated
by EPA as Operable Unit (OU) 5 of the Olean Well Field
Superfund Site (Site) in Cattaraugus County. New York
and identifies the preferred remedial alternative with
the rationale for this preference. For the purposes of this
Proposed Plan. OU5 includes contaminated soil that is
located beneath and near the footprint of a former
manufacturing building located in the northern portion of
the Historical Source Area1 at the AVX Property. The
AVX Property is one of four source areas at the Site. In
prior EPA decision documents AVX is sometimes
referred to as AVX Corporation.2 A Site location map is
provided as Figure 1.
The OU2 Record of Decision (ROD) was amended in
2015 as it related to AVX. The OU2 AVX ROD
Amendment selected an interim remedy to address soil
and groundwater at the AVX Property. An interim
remedy was selected because a final remedy, requiring
restoration of the City Aquifer, would not be possible
until the soil under the active AVX manufacturing
building became accessible and additional soil
characterization and testing could be conducted. The OU2
AVX ROD Amendment specified, that in the event there
was a change in use of the manufacturing building, a
feasibility study would need to be performed to evaluate
whether further action in the form of source control and/or
restoration actions was necessary to achieve the OU2
ROD goal of aquifer restoration. Therefore, a feasibility
study to determine a final remedy could not be completed
until the AVX property was no longer operating as an
1 The remedy selected in a September 2015 Amendment to the
Operable Unit Two Record of Decision (OU2 ROD
Amendment) defined the Historical Source Area as generally
consisting of soil and groundwater contamination in a shallow
groundwater unit known as the Downgradient Till Unit
beneath the former manufacturing building and the land at the
southeast corner of the building immediately proximate
thereto, including the shallow north-south trending drainage
active manufacturing facility. In April 2018, AVX ceased
operations at the facility and in 2020 the building was
demolished. This allowed for additional characterization
and the performance of a feasibility study for
contaminated soil located beneath and near the footprint
of the former manufacturing building. EPA has
designated this portion of the Historical Source Area as
OU5 at the Site.
The major components of the interim remedy selected by
the OU2 ROD Amendment included: maintenance of
existing exposure barriers (the building and paved areas)
in the northern portion of the Historical Source Area and
the vegetative cover in the drainage swale area (to address
soil contamination); construction and operation of a
hydraulic trench containment system to address
groundwater in the Downgradient Till Unit; hydraulic
pumping to contain groundwater in the City Aquifer;
implementation of institutional controls; implementation
of a long-term groundwater monitoring program; and
development of a Site Management Plan (SMP) to
provide for the proper management of the interim remedy
post-construction. Refer to the OU2 ROD Amendment for
a detailed description of the interim remedy.
The preferred remedy for OU5 includes the excavation of
impacted soil located beneath and near the footprint of the
former manufacturing building. In addition to identifying
the preferred remedy to address contaminated soil located
beneath and near the footprint of the former
manufacturing building, once selected, the OU5 remedy
in conjunction with the OU2 ROD Amendment will
constitute the final remedy for the AVX Property.
swale that begins to the south of the building. The OU2 ROD
Amendment provides further details regarding geologic and
hvdrogeologic conditions at the Site.
2 In 2020, AVX Corporation (AVX) became a wholly owned
subsidiary of K.YOCERA Corporation. In 2021, AVX's name
changed to KYOCERA AVX Components Corporation or
KAVX. The owner of record of the property is still AVX.
Iliilliillililllilliilillliillilllillil
652561
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This Proposed Plan was developed by the U.S.
Environmental Protection Agency (EPA), the lead agency
for the Site, in consultation with the New York State
Department of Environmental Conservation (NYSDEC).
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 known 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 for OU5 at the Site and the remedial
alternatives summarized in this Proposed Plan are more
fully described in the Feasibility Study Investigation
Report (FSIR), dated June 2022, and the Feasibility Study
(FS) Report, dated July 2023, as well as other documents
in the Administrative Record file for this remedy. EPA
encourages the public to review these documents to gain
a more comprehensive understanding of the Site, the
Superfund activities that have been conducted, and the
remedial alternative that is being proposed.
The purpose of this Proposed Plan is to inform the public
of EPA's preferred remedy and to solicit public
comments pertaining to all of the remedial
alternatives evaluated for OU5, including the preferred
remedy.
Changes to the preferred remedy, or a change from the
preferred remedy to another remedial alternative
described in this Proposed Plan, may be made if public
comments or additional data indicate that such a change
will result in a more appropriate remedial action. The
final decision regarding the selected remedy will be made
after EPA has taken into consideration all public
comments. For this reason, EPA is soliciting public
comments on all of the alternatives considered in the
Proposed Plan and on the detailed analysis section of
the FS Report because EPA may select an alternative
other than the preferred alternative.
MARK YOUR CALENDAR
PUBLIC COMMENT PERIOD:
July 27, 2023 to August 28, 2023
EPA will accept written comments on the Proposed
Plan during the public comment period.
IN PERSON PUBLIC MEETING:
August 8, 2023 at 6:00 pm
TECH Building, Mangano Reception Room, near the
Cutco Theater, 305 North Barry Street, Cattaraugus
County Campus of Jamestown Community College,
Olean, New York
COMMUNITY ROLE IN SELECTION PROCESS
EPA relies on public input to ensure that the concerns of
the community are considered in selecting an effective
remedy for each Superfund site. To this end, this
Proposed Plan has been made available to the public for
a public comment period which begins on July 27, 2023
and concludes on August 28, 2023.
A public meeting will be held on August 8, 2023 to
present the conclusions of the studies performed, to
elaborate further on the reasons for recommending the
preferred alternative, and to receive public comments.
Comments received at the public meeting, as well as
written comments, will be documented in the
Responsiveness Summary Section of the Record of
Decision (ROD), the document which formalizes the
selection of the remedy.
Written comments on the Proposed Plan should be
addressed to:
Maeve Wurtz
Western New York Remediation Section
U.S. Environmental Protection Agency
290 Broadway, 19th Floor
New York, New York 10007-1866
Telephone: (212)637-4230
E-mail: wurtz.maeve@epa.gov
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INFORMATION REPOSITORIES
Copies of the Proposed Plan and supporting
documentation are available at the following
information repositories.
Olean Public Library, located at Second and Laurens
Streets Olean, New York
(716) 372-0200
Hours: Monday - Thursday, 9:00 AM - 9:00 PM
Friday and Saturday, 9:00 AM - 5:00 PM
USEPA - Region II
Superfund Records Center
th
290 Broadway, 18 Floor
New York, New York 10007
(212) 637-4308
EPA's website for the Olean Well Field Site:
www.epa.gov/superfund/olean-wellfield
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 five
OUs for the Olean Well Field Site (refer to Figure 2) to
address soil and groundwater contaminated with volatile
organic compounds (VOCs).
On September 24, 1985, EPA signed a ROD for OU1,
which called for, among other things, the treatment of the
municipal supply well water and the extension of the
public water supply to residents utilizing private wells.
On September 30,1996, EPA signed a ROD for OU2. The
four source areas targeted in the OU2 ROD were as
follows: AVX Corporation (AVX) (currently owned by
KYOCERA AVX Components Corporation (""KAVX")
located at 1695 Seneca Avenue, Olean, New York); Alcas
Cutlery Corporation (Alcas) (currently owned and
operated by Cutco Corporation and located at 1116 East
State Street, Olean, New York); Loohn's Dry Cleaners
and Launderers (Loohns) (currently a vacant lot located
at 1713 East State Street, Olean, New York); and
McGraw-Edison Company (McGraw) (currently operated
by Cooper Power Systems, LLC, owned by Cooper Power
Systems, Inc., and located at 1648 Dugan Road, Olean,
New York).
On September 30, 2014, EPA amended the OU2 ROD to
modify the selected remedy for the Alcas component of
the OU2 ROD. The Alcas OU2 ROD Amendment
addressed soil and groundwater contamination impacting
the underlying aquifers, and also selected a remedy to
address OU3 groundwater contamination. OU3 addresses
groundwater contamination at an area south of the Alcas
facility referred to as Parcel B.
On September 30, 2015, EPA again amended the OU2
ROD to modify the selected remedy for the AVX
component of the OU2 ROD. The AVX OU2 ROD
Amendment selected an interim action to address soil and
groundwater contamination impacting the underlying
aquifers until a final remedy for the AVX Property is
implemented. The AVX OU2 ROD Amendment
indicated that a change in the current use of the building
in the future would trigger the performance of a feasibility
study to evaluate source control and/or restoration
actions, leading to the selection of a final remedy. In April
2018, AVX informed EPA that it intended to cease
operations at its Olean Manufacturing facility.
On September 30, 2022 EPA signed a ROD for OU4. The
OU4 ROD addressed VOCs in groundwater located at
certain residential and commercial properties
downgradient of the AVX Property and south of the
Conrail railroad tracks.
This Proposed Plan concerns OU5, the final planned
phase of response activities at the AVX Property, and
addresses soil contamination located beneath and near to
the former AVX manufacturing building in the northern
portion of the Historical Source Area. Once selected, the
OU5 remedy in conjunction with the OU2 ROD
Amendment will constitute the final remedy for the AVX
Property.
SITE BACKGROUND
The Site is located in the eastern portion of the City of
Olean and western and northwestern portions of the towns
of Olean and Portville in Cattaraugus County, New York.
The Site is characterized by VOC-contaminated
groundwater underlying the City of Olean, the Town of
Olean and the Town of Portville, and by VOC-
contaminated soil at certain locations in the City and
Town of Olean. The Site is approximately 65 miles
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southeast of Buffalo, New York, and seven miles north of
the New York/Pennsylvania border.
The AVX Property is currently zoned for manufacturing
use, and the areas immediately surrounding the Property
are zoned for industrial, commercial, and residential uses.
EPA expects that the land-use pattern at and surrounding
OU5 of the Site will not change in the foreseeable future.
Beginning in the 1980s, several separate federal-, state-
and Potentially Responsible Party (PRP)-led
investigations were conducted to identify the sources of
contamination to the municipal water supply wells and
evaluate the nature and extent of groundwater
contamination at the Site. The Site was included on the
National Interim Priorities List, by publication in the
Federal Register on October 23, 1981, and was included
on the first National Priorities List on September 9, 1983.
For more details regarding the results of the various
investigations and subsequent actions taken to address
Site-related contamination refer to the OU4 ROD.
According to EPA's EJScreen tool, there are no
demographic indicators for OU5 at the Site that would
indicate a community with environmental justice
concerns. Within and immediately near OU5, the national
and State EJ index percentiles for all of the environmental
and socioeconomic indicators are at or below the 52nd
percentile. The proposed remedy is not anticipated to
result in adverse impacts to environmental resources that
would affect low income or minority populations living
within the vicinity of OU5.
The following provides a summary of activities at the
AVX Property, a source of groundwater contamination at
the Site.
As mentioned previously, the remedy selected in the 1996
OU2 ROD addressed multiple sources of VOC
contamination to groundwater at the Site. The major
components of the selected remedy for AVX, one of the
four sources targeted, included the following: excavation
and removal of contaminated soil; off-Site low
temperature desorption of soil contaminants, if necessary;
upgradient and downgradient groundwater monitoring;
implementation of groundwater treatment, if excavation
and removal of the contaminated soil did not adequately
improve the quality of the City Aquifer and if the property
continued to affect the groundwater entering the
municipal wells; and implementation of groundwater use
restrictions.
AVX initiated the excavation of contaminated soil at its
property in July 2000. Approximately 5,055 tons of
contaminated soil was excavated to a depth of
approximately 10 feet below ground surface (bgs) and
transported off-Site for disposal before work was halted.
AVX could not excavate all of the contaminated soil
because the material extended beyond the area identified
as contaminated in the OU2 ROD to beneath the southeast
corner of the manufacturing building, which was fully
occupied with AVX's manufacturing operations. Further
excavation had the potential to impact the structural
integrity of the occupied building. As a result, the
excavation area was backfilled pending further study.
Further evaluations revealed significant unknown
contamination extending under the building and that
additional excavation and removal of all contaminated
soil would result in significant disruption to and/or
shutdown of the on-going operations.
Following the backfilling at the AVX Property, EPA
directed AVX to conduct soil and groundwater sampling
activities at the AVX Property and properties to the south
as part of a multi-phase investigation to assess the
conditions at these properties. Results from these studies
indicated that significant previously unknown VOC
contamination is present in both soil and groundwater.
As indicated previously, on September 30, 2015, EPA
issued a ROD Amendment for OU2 relating to the AVX
Property that addressed soil and groundwater
contamination in the Historical Source Area, and
groundwater contamination in the Downgradient Till Unit
and City Aquifer (refer to the Site Geology and
Hydrogeology section in the OU2 ROD Amendment for
additional detail regarding geological and hydrogeologic
conditions at the Site).
The Downgradient Till Unit component of the selected
remedy involves the construction and operation of a
hydraulic trench containment system involving a gravel
trench coupled with active groundwater recovery and
treatment to prevent migration of groundwater
downgradient of the AVX Property. Construction of this
component of the selected remedy was completed in
January 2023.
The City Aquifer component of the selected remedy
involves hydraulic pumping containment utilizing and
maintaining an existing AVX Property production well
(PW-1) as an active groundwater recovery system at a
pumping rate that prevents further migration of
contaminated groundwater within the City Aquifer. The
AVX production well, in operation since 1959, continues
to operate as part of the implementation of the AVX OU2
ROD Amendment selected remedy even though the plant
closed down.
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Soil Investigation Results from Previous
Investigations at the AVX Property
Results of post-OU2 ROD investigations showed that
VOC contamination in soil consists primarily of
trichloroethene (TCE), 1,1,1-trichlorethane (1,1,1-TCA),
tetrachloroethene (PCE), and the breakdown products cis-
1,2-dichloroethene (cis-l,2-DCE), vinyl chloride, and
1,1-dichloroethane (1,1-DCA) with elevated
concentrations of other VOCs, including toluene and
xylenes.
As set forth in a January 29, 2013 FSIR performed after
work was halted on the OU2 ROD remedy, high
concentrations of VOCs have been observed in soil (up to
1,614 parts per million (ppm) of total VOCs) beneath the
southeast corner of the former manufacturing building by
a maintenance shop and a former solvent underground
storage tank (both along the eastern edge of the
manufacturing building), and in areas immediately to the
south and north of the manufacturing building. Minimal
detections of VOC contamination were found in soil south
of the fenced area of the AVX Property.
Concentrations of VOCs observed in groundwater
indicate that a groundwater plume of VOC contamination
in the till unit originates from the Historical Source Area
and extends through the undeveloped area to the southern
property boundary and OU4.
OU5 Feasibility Study Investigation Report (FSIR)
While prior investigations have characterized the
hydrogeology and the nature and extent of contaminants
in the subsurface throughout much of the AVX Property,
the demolition of the former manufacturing building in
2020, enabled the collection of soil and groundwater
samples beneath and adjacent to the former structure. This
additional soil characterization and testing were also
necessary to support the evaluation of remedial
alternatives for contaminated soil in and around the
footprint of the former manufacturing building. The
investigation activities were designed to:
• Define the lateral and vertical extent of
contaminants in soil located beneath and near the
footprint of the former manufacturing building
within and near the northern portion of the
Historical Source Area; and
• Characterize the hydrostratigraphic framework to
better define the potential contaminant transport
pathways within and near the source area.
A portion of the concrete slab of the former building was
left in place and is currently acting as an exposure barrier
to contaminated soil.
OU5 Soil Investigation Results
The first step of the soil characterization program
included screening of near-surface soil/fill for the
presence and magnitude of VOCs using a photoionization
detector (PID). Information gathered using a PID is
classified as screening level data and does not provide
chemical specific information. Following the initial soil
screening and preliminary surveying, whole core soil
sampling (WCSS) and vertical aquifer profile (VAP)
sampling was conducted. The locations of WCSS and
VAP sampling were adjusted as needed based on access
and the results of soil screening. A summary of the results
of this work is presented in the following sections.
Soil Screening
The VOC contamination detected in soil consists
primarily of TCE, 1,1,1-trichlorethane (1,1,1-TCA), PCE,
and the breakdown products cis-l,2-DCE, vinyl chloride,
1,1-DCA, with elevated concentrations of other VOCs,
including toluene and xylenes. 114 soil gas screening
point locations were selected and organized in a grid
layout approximately 25 feet apart, in and around the
source area. For all locations and depths where soil gas
could be drawn, the gas was pumped by and analyzed with
a PID and data were recorded.
The highest concentrations of PID-measured VOCs were
observed primarily outside of the footprint of the original
building, which was constructed in 1950, with those
elevated concentrations observed largely within the
footprint of the historical Machine Shop/Maintenance
area (constructed in 1978 and used as the building
maintenance area), the Receiving Area, and the Chemical
Storage area (both constructed in 2001). These levels
ranged from 145 - 1,436 ppm. Some elevated PID-
measured screening concentrations were also observed
beneath adjacent areas within the southeastern corner of
the footprint of the original building. These included one
area historically noted as the Powder and Barrel Storage
area but also on other maps noted as being used for waste
storage. Some elevated PID-measured concentrations
were also noted farther to the west beneath or near to the
historical Tape and Reel Storage area. Refer to Appendix
A in the 2023 FS Report for the layout of the former
manufacturing building.
5
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Soil Quality Characterization
Following completion of the soil screening activities,
WCSS were collected by rotosonic drilling methods on a
modified approximately 50-foot grid spacing at 40
locations. Approximately 300 soil samples were analyzed
to better characterize the nature and extent of VOCs in
soil, both saturated and unsaturated, within the source
area. The results are summarized in Table 1 below. The
data revealed that the highest mass of VOCs in soil is
largely concentrated in areas predicted by the soil gas
screening data, with some deviations. The highest
concentrations were observed within the former footprint
of the Machine Shop/Maintenance area, beneath the
former Receiving area, and extending into the former
chemical storage/waste storage area. Other notable areas
of higher concentrations included the head of the drainage
swale to the south of the facility fence, and near the
southeastern corner of the former Stage 1 remedial action
excavation area.
Table 1: Maximum Soil Contaminant
Concentrations
( onl;iinin;inl
( onceninilion
(ppim
1,1,1-TCA
226 DJ
TCE
1,500 DJ
PCE
723 DJ
c/s-l,2-DCE
93.6 DJ
vinyl chloride
2.05 DJ
1,1-DCA
9.88 D
D = Identifies all compounds identified in the analysis at the secondary
dilution factor.
J = The analyte was analyzed for and was positively identified, but the
associated numerical value may not be consistent with the amount
actually present in the environmental sample.
The concentrations of contaminants were observed to
generally diminish with sample depth, though not
consistently in all locations. Thin and discontinuous
stringers of more permeable soil appear to have acted as
pathways for contaminants to reach greater depths in
certain locations.
Groundwater
During soil sampling, if retrieved core samples appeared
to be both saturated and coarse-grained enough to produce
water, VAP samples were collected. In total, only 13 of
40 borings contained enough water to facilitate VAP
sampling, with only two of the 13 borings containing
adequate water to sample at more than one depth.
Aside from some VAP groundwater sample locations
with anomalously high COC concentrations, likely due to
the presence of stringers containing more permeable
material that can collect water containing high
contaminant concentrations, the concentrations of
contaminants in the VAP groundwater samples are
relatively consistent with concentrations reported for
groundwater sampled from monitoring wells during the
semi-annual groundwater monitoring events which have
been conducted since 2000.
Table 2: Maximum Groundwater
Contaminant Concentrations
(ppim
1,1,1-TCA
59 D
TCE
120 D
PCE
4
c/s-l,2-DCE
17
vinyl chloride
1.8
1,1-DCA
12
D = Identifies all compounds identified in the analysis at the secondary
dilution factor.
Refer to the OU5 Feasibility Study Investigation Report
for additional details regarding the sampling results.
An assessment of natural attenuation conditions in
groundwater was conducted as part of the 2015 OU2
ROD. Overall, the analyses indicated that some level of
natural attenuation of Site-related contaminants is
occurring. Groundwater samples revealed an increase in
concentration of daughter products (e.g., cis-l,2-DCE and
vinyl chloride) relative to the concentration of the parent
compound (e.g., TCE). Reductive dechlorination is a
natural attenuation process that can degrade chlorinated
VOCs by transforming chlorinated compounds such as
TCE to other compounds. Other natural attenuation
processes can include dispersion, dilution, sorption,
volatilization. The observed concentrations of
contaminants in soil and groundwater near to the former
AVX manufacturing building suggest that some level of
natural attenuation is occurring.
Additionally, ethene and ethane were detected in
groundwater monitoring well samples, demonstrating
occurrence of the full sequence of reductive
dechlorination. The monitored natural attenuation (MNA)
assessment also included analysis of electron acceptors,
-------
which showed moderate to strongly reducing conditions
present.
The OU5 FS Report contains additional details, as does
the full MNA Screening Analysis conducted in 2012.
Both documents can be found in the Administrative
Record file for the Site.
Principal Threat Waste
Principal threat wastes are considered source materials,
i.e., materials that include or contain hazardous
substances, pollutants or contaminants, such as DNAPL
in soil, that act as a reservoir for migration of
contamination to groundwater, surface water, or 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 would present a significant risk to human health or the
environment in the event exposure should occur. The
decision to treat these wastes is made on a site-specific
basis through a detailed analysis of alternatives, using the
remedy selection criteria which are described below. The
manner in which principal threat wastes are addressed
provides a basis for making a statutory finding that the
remedy employs treatment as a principal element.
Varying concentrations of VOCs were detected in soil
samples collected during previous investigations from
borings installed within the main manufacturing building
at the AVX Property. Results from previous
investigations showed concentrations of 1,1,1-TCA as
high as 990 ppm and TCE as high as 650 ppm in
subsurface soil, indicative of the presence of DNAPL in
the soil zone at approximate depths of 16 feet and 6 feet,
respectively, below the foundation of the main building.
WHAT IS A "PRINCIPAL THREAT"?
The National Oil and Hazardous Substances Pollution
Contingency Plan (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)(l)(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 water 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 (NAPLs) in ground water 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-specific 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.
During the FSIR, concentrations of 1,1,1-TCA and TCE
as high as 226 ppm and 1,500 ppm, respectively in
subsurface soil were revealed. The FSIR results are
indicative of the presence of DNAPL in the soil zone at
an approximate depth of five feet below the foundation of
the main building. These findings show the presence of
"principal threat" wastes at the AVX Property. The
proposed alternative for OU5 discussed in more detail
below is expected to remove this contamination through
excavation and off-Site disposal. Please refer to the text
box entitled, "What is a Principal Threat" for more
information on the principal threat concept.
RISK SUMMARY
As part of the 1996 OU2 ROD, a baseline human health
risk assessment (HHRA) and a qualitative ecological risk
assessment were conducted to estimate the risks and
hazards associated with the current and future effects of
contaminants on human health and the environment. A
baseline risk assessment is an analysis of the potential
adverse human health and ecological effects caused by
hazardous substance exposure in the absence of any
actions to control or mitigate these exposures under
current and future site uses.
In the HHRA, cancer risk and noncancer health hazard
estimates were based on reasonable maximum exposure
(RME) scenarios. The estimates 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 chemicals
of potential concerns (COPCs), as well as the toxicity of
these contaminants.
Human Health Risk Assessment
A four-step human health risk assessment (HHRA)
process was used for assessing site-related cancer risks
and noncancer health hazards related to soil at the AVX
Property during the OU2 ROD (see box on next page
"What is Risk and How is it Calculated"). The HHRA
evaluated the potential health effects which would result
from exposure to groundwater contamination through
ingestion, dermal contact and inhalation of volatilized
contaminants during showering. Risks associated with
exposure to contaminants in surface and subsurface soil
were calculated for the ingestion and inhalation of
contaminants by construction workers. A residential
exposure scenario for soil was not calculated because all
of the properties studied during the OU2 RI/FS are zoned
for industrial or commercial use. It is expected that the
7
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AVX Property will continue to be used for
commercial/industrial purposes in the future.
The results of the OU2 HHRA identified carcinogenic
risk and/or noncarcinogenic hazards that were above the
acceptable carcinogenic risk range of lxlO"6 to lxlO"4 and
the noncarcinogenic hazard index (HI) of 1 for future
exposure to groundwater. Carcinogenic risks and
noncarcinogenic hazards for construction worker
exposure to soil were within the risk range and below the
noncarcinogenic HI threshold of 1. However, data
collected at the time of 2015 ROD Amendment identified
higher concentrations of VOCs in soil compared to those
evaluated in the OU2 HHRA. Therefore, a qualitative
determination was made in the 2015 ROD Amendment
that the risks associated with soil in the OU2 HHRA could
be underestimated. As discussed in more detail in the
following sections, EPA has determined that the results of
the OU2 HHRA and the risk evaluation from the 2015
ROD Amendment have not substantially changed.
Therefore, an additional HHRA was not performed as part
of OU5. Nevertheless, an updated qualitative analysis of
the data to evaluate the risks associated with the elevated
VOC concentrations detected in soil at the AVX Property
is provided below.
Soil
The estimated total risks (5xl0 5) and hazards (HI=0.5) in
soil included in the OU2 ROD Amendment for the AVX
Property were primarily due to VOCs in the subsurface
soil below the concrete slab floor of the building. It was
also determined that contamination in the subsurface soil
could serve as a source of continued groundwater
contamination. Additional samples were collected as part
of the OU5 FS. A comparison of the results for the
primary contaminants is included in Table 3 below.
WHAT IS HUMAN HEALTH RISK AND HOW IS IT
CALCULATED
Human Health Risk Assessment: 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 fate and
transport of the contaminants in the environment, concentrations
of the contaminants in specific media, mobility, persistence, and
bioaccumulation.
Exposure Assessment: In this step, the different exposure
pathways through which people might be exposed to the
contaminants in air, water, soil, etc. that were identified in the
previous step are evaluated. Examples of exposure pathways
include incidental ingestion of and dermal contact with
contaminated soil and ingestion of and dermal contact with
contaminated groundwater. Factors relating to the exposure
assessment include, but are not limited to, the concentrations in
specific media that people might be exposed to and the
frequency and duration of that exposure. Using these factors, a
"reasonable maximum exposure" scenario, which portrays the
highest level of human exposure that could reasonably be
expected to occur, is calculated.
Toxicity Assessment: In this step, the types of adverse health
effects associated with chemical exposures, and the relationship
between magnitude of exposure 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 noncancer health hazards, such as changes in the normal
functions of organs within the body (e.g., changes in the
effectiveness of the immune system). Some chemicals are
capable of causing both cancer and noncancer health hazards.
Risk Characterization: This step summarizes and combines
outputs of the exposure and toxicity assessments to provide a
quantitative assessment of site risks for all COPCs. Exposures
are evaluated based on the potential risk of developing cancer
and the potential for noncancer health hazards. The likelihood
of an individual developing cancer is expressed as a probability.
For example, a 10~4 cancer risk means a "one-in-ten-thousand
excess cancer risk"; or one additional cancer may be seen in a
population of 10,000 people 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 f0~4 to
fO6, corresponding to a one-in-ten-thousand to a one-in-a-
million excess cancer risk. For noncancer health effects, a
"hazard index" (HI) is calculated. The key concept for a
noncancer HI is that a "threshold" (measured as an HI of less
than or equal to 1) exists below which noncancer health hazards
are not expected to occur. The goal of protection is f0~6 for
cancer risk and an Ht of f for a noncancer health hazard.
Chemicals that exceed a f0~4 cancer risk or an Ht of f are
typically those that will require remedial action at a site and are
referred to as chemicals of concern, or COCs, in the final
remedial decision document or Record of Decision.
8
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Table 3. Primary contaminant results in subsurface
soil at the AVX Property.
ND - Non-Detect
D - Indicates compounds identified in the secondary dilution factor
J - Estimated value
The maximum results of the soil samples collected during
the OU5 FS were either higher than those identified in the
OU2 RI or are within the same order of magnitude (i.e.,
1,1,1-TCA). Notably, the maximum concentrations of
PCE and TCE during the OU5 FFS were over two times
greater than the OU2 RI. Therefore, EPA has determined
that the risk conclusions presented in the OU2 ROD
Amendment have not substantially changed and could be
underestimated. Additionally, groundwater on the Site
continues to exceed drinking water standards from
impacts from contaminated soil.
Ecological Risk Assessment
The AVX Property is approximately 18.5 acres in size and
currently includes an open area with bare soil due to the
recent removal of the former AVX building. Wetlands
and a wooded area are located south of the former
building area, which remains fenced. The fenced portion
of the site that formerly comprised the AVX building does
not currently provide habitat that could potentially
support populations of indigenous wildlife receptor
species. Therefore, there are no ecological risks currently
recognized within this area. For the area outside of the
fence, which includes the wooded area and wetland area,
a qualitative ecological risk assessment was conducted as
part of the OU2 ROD to determine if contamination
present at the AVX Property was impacting the wooded
or wetland area. Given that the potential source of
contamination in the wooded and wetland area would be
contaminated groundwater discharging to the sediments,
sediment samples were collected from the wetlands.
Analysis of the samples did not reveal any VOC
contamination. Several semi-volatile organic compounds
(SVOCs) were detected but were not attributed to the
AVX Property. Based on this evaluation, it was
determined that there is not a completed exposure
pathway from the AVX property to the wooded or
wetland areas. Since the levels of contamination in
groundwater at the AVX property have remained similar,
or have declined, this assumption is still considered valid.
Based on the results of the data collected to support the
OU5 FFS, it is EPA's current judgment that the Preferred
Alternative identified in this Proposed Plan is necessary
to protect public health, welfare and the environment from
actual or threatened releases of hazardous substances.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are specific goals to
protect human health and the environment. 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 followings RAOs have been established for OU5 of
the Site:
• Reduce the migration of VOC contaminants in
soil to groundwater.
• Eliminate the potential for human exposure to
Site contaminants via contact with soil
concentrations above NYSDEC soil cleanup
objectives for commercial properties.
The RAOs established in the OU2 ROD Amendment for
groundwater and the drainage swale remain the same.
The soil preliminary remediation goals established for
OU5 COPCs are identified in Table 4.
Table 4: Preliminary Remediation Goals for Soil
( 'hcmic;ils ill
Soil
l\ik'iili;il ('oiii_vni
Remedi;ilK>n
(COPCs)
(io;ils (ppmr
TCE
.47
cis- 1,2-DCE
.25
vinyl chloride
.02
1,1,1-TCA
.68
1,2-DCA
0.02
Trans-1,2-
.19
dichloroethene
PCE
1.3
Toluene
0.7
Xylene
1.6
1,4-dioxane
0.1
* NYSDEC SCOs [6 NYCRR Section 375-6.5] are based on the
protection of groundwater.
9
( heniicals
oi: ri
< ppni
()l 5 I S
(ppm)
1,1,1-TCA
990
226 DJ
PCE
270
723 DJ
TCE
650
1,500 DJ
cis-1,2 DCE
65
93.6 DJ
Vinyl Chloride
ND
2.05 DJ
-------
These PRGs are based on the protection of groundwater
and are lower than the NYSDEC soil cleanup objectives
for commercial properties. These PRGs would therefore
be protective of commercial workers.
SUMMARY OF REMEDIAL ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. §9621(b)(l),
mandates that remedial actions must be protective of
human health and the environment, cost-effective,
comply with ARARs, and utilize permanent solutions
and alternative treatment technologies or resource
recovery alternatives to the maximum extent practicable.
Section 121(b)(1) also establishes a preference for
remedial actions that employ, as a principal element,
treatment to reduce permanently and significantly the
volume, toxicity, or mobility of the hazardous substances,
pollutants, and contaminants at a site. Section 121(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).
Since principal threat wastes are associated with OU5,
treatment of the contaminated soil was considered as a
principal element of some of the alternatives developed
for OU5.
Detailed descriptions of the remedial alternatives for
addressing the contamination associated with OU5 of the
Site can be found in the OU5 FS Report, dated July 2023.
For cost-estimating and planning purposes, the FS made
certain assumptions regarding the depth of the water table
to distinguish between saturated and unsaturated soil and
estimated an elevation of 1,430 ft above mean sea level
(amsl) as the depth to the water table. While the FS
assumed that unsaturated contaminated soils would be
addressed under the active remedial alternatives, as part
of the remedial design, further evaluation would be
conducted to refine the depth of active remediation.
Additional active remediation may be performed below
the water table to address saturated soil with elevated
concentrations of COPCs, which would have the
incidental effect of improving remediation timeframes for
groundwater. Additional soil sampling would also be
conducted during the design, to further refine the extent
of contamination. During the performance of the FSIR,
analysis of soil samples did not include 1,4-dioxane.
Given the presence of elevated concentrations of 1,4-
dioxane in groundwater, additional soil sampling would
be performed for 1,4-dioxane analysis during the remedial
design.
The construction time for each alternative reflects only
the actual time required to construct or implement the
action and does not include the time required to design
the remedy, negotiate the performance of the remedy
with any potentially responsible parties, or procure
contracts for design and construction.
Common Elements
Each of the alternatives address unsaturated contaminated
soil located beneath and near the footprint of the former
manufacturing building in the northern portion of the
Historical Source Area.
Until a final remedy for the AVX Property is selected, the
OU2 Amended Remedy requires implementation of
institutional controls and development of a Site
management plan (SMP) to provide for the proper
operation and maintenance (O&M) of the remedy for the
AVX Property post-construction. The ICs selected by the
OU2 Amended ROD would continue to apply to the AVX
Property and as such would apply to each of the
alternatives evaluated for OU5. Implementation of ICs
and the SMP are ongoing.
Additionally, because the OU2 amended remedy will
result in hazardous substances, pollutants, or
contaminants remaining in and around the drainage swale
area at the AVX Property above levels that would
otherwise allow for unlimited use and unrestricted
exposure, pursuant to Section 121(c) of CERCLA,
statutory reviews will be conducted no less often than
once every five years to ensure that the remedy remains
protective of human health and environment.
Alternative 1: No Action
The NCP requires that a "No Action" alternative be used
as a baseline for comparing other remedial alternatives.
Under this alternative, there would be no remedial actions
actively conducted at OU5 to control or remove soil
contaminants. This alternative also does not include
monitoring or institutional controls.
Capital Cost:
Periodic Costs:
Present-Worth Cost:
Construction Time:
$0
$0
$0
Not Applicable
10
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Alternative 2: Long-Term Monitoring
This alternative would rely on long-term monitoring of
contaminant concentrations in soil to ensure
concentrations are decreasing. As discussed above,
reductions in contaminant concentrations in groundwater
are occuring to limited extent already from various
naturally occurring physical, chemical, and biological
processes. These processes occur naturally, in-situ, and
act to decrease the mass or concentration of contaminants
in the subsurface. Only non-augmented natural processes
would be relied upon under this alternative. In addition,
existing surface covers (concrete slab floor, pavement,
and vegetative cover) would be maintained to control
potential leaching of contaminants in soil to groundwater
and prevent exposure.
For cost-estimating and planning purposes, periodic
monitoring of four newly installed groundwater
monitoring wells would be conducted to track attenuation
of contaminants immediately beneath and/or
downgradient of the unsaturated soil source.
the groundwater treatment system at the AVX Property
prior to discharge to the City of Olean sewer system.
Capital Cost:
Periodic Costs:
Present-Worth Cost:
Construction Time:
Alternative 3: Excavation
$44,000
$567,000
$291,000
1 month
The major components of the soil excavation alternative
are demolition and removal of the existing concrete slab
floor and foundation supports, excavation of impacted
unsaturated soil located beneath and near the footprint of
the former manufacturing building, off-Site transportation
and disposal of excavated material, and restoration with
imported clean fill material.
Excavation areas would be restored with imported clean
fill material to match the previously existing contours and
grades. Imported clean fill material would meetNYSDEC
DER-10 Technical Guidance for Site Investigation and
Remediation for imported fill or soil at commercial or
industrial properties. Surface restoration details would be
developed during the remedial design.
For cost estimating and planning purposes, the conceptual
design estimates 5,500 cubic yards (cy) of soil requiring
excavation and off-Site transportation for disposal as non-
hazardous waste at a solid waste landfill.
Rainwater/surface water that accumulates in, and is then
removed from, any excavation areas would be
temporarily containerized onsite (e.g., in 21,000-gallon
tanks). It is anticipated that any water that accumulates
and is removed from the excavation would be treated by
Capital Cost:
Periodic Costs:
Present-Worth Cost:
Construction Time:
52,228,000
5450,000
52,414,000
4 months
Alternative 4: In-Situ Soil Solidification
The major components of the In-Situ Soil Solidification
(ISS) alternative include the demolition and removal of
the existing concrete slab floor and foundation supports,
excavation and removal of the asphalt paved areas to
establish a level working surface for the ISS mixing
equipment, construction of a management area adjacent
to the ISS target areas to accommodate bulk soil that
would swell as a result of the soil mixing process and
amendment addition.
Solidification refers to a cleanup method that prevents or
slows the release of harmful chemicals from
contaminated soil. These methods usually do not destroy
the contaminants. Instead, they keep them from
"leaching" above safe levels into the surrounding
environment. Solidification binds the waste in a solid
block of material and traps it in place, using a binding
agent. This block is also less permeable to water than the
waste.
During the FSIR, a laboratory bench-scale ISS treatability
study was conducted with soil from the AVX Property to
identify the optimal percentage of reagents, dosing
requirements, and effectiveness. This treatability study
investigated the ability of (Portland Cement) (PC) and
blast furnace slag (BFS), as well as zero-valent iron
(ZVI), to reduce the leaching potential of contaminants.
Based on the results, for cost-estimating and planning
purposes, the conceptual design estimates approximately
5,500 cy of soil would be mixed with a blend of 2.5% PC
and 4.5% ground-granulated BFS, with a water-to-reagent
ratio of 4.5 (grams of water to grams of reagent) to
solidify contaminants in-place, creating a low-
permeability monolith.
The conceptual design estimates that a three-foot-thick
cover would be designed to maintain the ISS-treated
material below the frost line and to promote stormwater
drainage away from the treatment zone. The protective
cover would consist of a non-woven geotextile
demarcation fabric, 2.5 to 3 feet of reuse soil, and
approximately six inches of gravel at the surface for
erosion protection.
11
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It has been estimated that approximately 3,755 cy of non-
impacted soil would be excavated to create the
management area and would be used post-ISS
construction for installation of a three-foot-thick cover
over both the ISS treatment and management areas.
Under this alternative, long term monitoring would be
conducted to evaluate the long-term effectiveness and
permanence of the solidified mass.
Capital Cost:
Periodic Costs:
Present-Worth Cost:
Construction Time:
53,395,000
5450,000
53,581,000
6 months
Capital Cost:
Periodic Costs:
Present-Worth Cost:
Construction Time:
52,715,000
5450,000
52,901,000
3.5 months
Alternative 5: In-Situ Thermal Remediation
This remedial alternative combines in-situ thermal
remediation (ISTR) with a system to address vapor
management within and around areas with the highest
concentration of contaminants.
In-situ thermal treatment methods move or "mobilize"
harmful chemicals in soil using heat. The chemicals move
through soil toward wells where they are collected and
piped to the ground surface to be treated using ex-situ
cleanup methods. For cost estimating and planning
purposes, the conceptual design assumes an ex-situ
approach for vapor management composed of cooling,
phase separation, air stripping, liquid-phase GAC, and
vapor-phase granular-activated carbon following. If some
water is encountered, multi-phase extraction (MPE)
would be utilized.
Electrical resistance heating (ERH) and thermal
conduction heating (TCH) were determined, based on
their effectiveness for treating lower-permeability till
with similar soil electrical properties, to be the most
applicable ISTR technologies for source removal within
the lower-permeability till unit at OU5. For cost
estimating purposes, ERH was assumed for the
development of this alternative.
Preliminary ERH layouts were developed using a regular
19-foot triangular grid pattern for the electrodes, with
vertical MPE wells and horizontal vapor management
wells located at the centroids between adjacent electrodes.
Distributed temperature sensor strings would be used for
performance monitoring. A thermally insulating vapor
cap would be constructed to provide a no-flow barrier at
the surface, limit heat losses to ground surface, and
minimize the potential for recondensation of vapors near
ground surface.
EVALUATION OF ALTERNATIVES
In evaluating the remedial alternatives, each alternative
is assessed against nine evaluation criteria set forth in the
NCP namely, overall protection of human health and
the environment, compliance with ARARs, 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 table below for a
more detailed description of the evaluation criteria.
This section of the Proposed Plan summarizes the
evaluation of the relative performance of each alternative
against the nine criteria, noting how each compare to the
others under consideration. The detailed analysis of
alternatives can be found in the FS Report.
Overall Protection of Human Health and the
Environment
All of the alternatives except Alternative 1 (No Action)
would provide adequate protection of human health and
the environment by eliminating, reducing, or controlling
risk through off-site disposal, in-situ treatment,
engineering controls, and/or institutional controls.
Alternative 2 (Long-Term Monitoring) would provide
some protection from future exposure to contaminated
soil through the maintenance of the existing cover
material (concrete slab floor, pavement, and vegetative
cover), and through institutional controls such as land-use
restrictions. However, contaminated soil would remain in
place above the cleanup goals.
Alternative 3 (Excavation) would permanently remove
unsaturated soil with VOCs above the PRGs for off-Site
disposal while Alternative 5 (In-Situ Thermal
Remediation) would remove VOCs through in-situ
treatment and ex-situ recovery for on-Site treatment.
Under Alternative 4 (In-Situ Soil Solidification)
contaminated soil would not be destroyed, but rather
would be treated in-situ to bind the contaminants to the
material and prevent or slow the release of contaminants
from soil.
Alternatives 2, 3, 4, and 5 would achieve the RAOs.
Alternative 1 (No Action) would not achieve the RAOs.
Because Alternative 1 is not protective of human health
12
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and the environment, it is not further discussed under the
remaining evaluation criteria.
Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)
EPA has identified NYSDEC's soil cleanup objectives for
the protection of groundwater (6 NYCRR § 375-6.5) as
an ARAR, a "to-be considered," or other guidance to
address contaminated soil at the Site. Refer to Table 4 for
the preliminary remediation goals for soil.
Under Alternatives 2 through 5, it is intended that ARARs
would be achieved. Although soil sampling results
indicate that biodegradation of VOC contaminants may
be occurring at the AVX Property, given the elevated
concentrations of contaminants in soil, achievement of the
preliminary remediation goals under Alternative 2 may
not be reached for many years. Under Alternative 2,
elevated concentrations of contaminants in soil, would
result in the prolonged presence of contamination in the
unsaturated soil which would continue to act as a source
to groundwater contamination and likely prevent or
extend the attainment of the remediation goals established
in the OU2 ROD Amendment.
Alternatives 2 through 4 would comply with location-
specific ARARs, such as the Clean Water Act to mitigate
adverse impacts on protected wetlands. Alternatives 2
through 4 would comply with action-specific ARARs,
such as hazardous waste management regulations that
manage remediation derived waste.
Chemical-, location-, and action-specific ARARs are
identified in the July 2023 FS Report, Tables 3-1, 3-2
and 3-3.
EVALUATION CRITERIA FOR SUPERFUND
REMEDIAL ALTERNATIVES
Overall Protectiveness of Human Health and the
Environment evaluates 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) evaluates
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
overtime.
Reduction of Toxicity, Mobility, or Volume
(TMV) of Contaminants through Treatment
evaluates 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 includes 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.
13
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Long-Term Effectiveness and Permanence
Alternative 2 relies on naturally occurring in-situ
processes to decrease the concentrations of contaminants
over time. While degradation has been shown to occur in
soil and groundwater at the AVX Property, given the
elevated concentrations of contaminants present, the
timeframe to achieve the cleanup levels, long-term
protectiveness is not anticipated to occur in a reasonable
timeframe. Alternatives 3 through 5 are all effective
alternatives in the long-term because they would remove
or solidify the contaminants in unsaturated soil located
beneath and near the footprint of the former
manufacturing building, through physical methods
(excavation, Alternative 3), solidification (Alternative 4),
and volatilization via thermal treatment followed by soil
vapor extraction (Alternative 5). Alternatives 2 through 5
would permanently reduce accessible contaminant
concentrations over time, while Alternatives 3, 4, and 5
would achieve permanent contaminant concentration
reduction or immobilization more quickly.
Potential Site impacts from climate change have been
assessed, and the future performance of the remedy is
currently not at risk due to the expected effects of climate
change in the region and near the Site.
Reduction of Toxicity, Mobility, or Volume
Alternatives 3 and 5 reduce toxicity and volume of
contaminants in soil located beneath and near the
footprint of the former manufacturing building.
Alternative 4 substantially reduces the mobility of
contaminants in soil by solidifying them in a solid block
of material. Alternative 2 would reduce the toxicity and
volume of contaminants in soil over time, however, the
timeframe to achieve the cleanup levels and long-term
protectiveness may not be reached for many years.
Under Alternative 3, the mobility, volume, and exposure
to contaminants would be reduced through the removal
and disposal of the soil at an approved off-Site facility.
Furthermore, although currently not anticipated, off-site
treatment, if required, would reduce the toxicity of the
contaminated soil prior to disposal. Alternatives 4 and 5
provide active in-situ treatment of contaminants in soil
that would greatly reduce the mobility of these
contaminants. Alternative 5 would also reduce the
volume and toxicity of contaminants because it destroys
the contaminants rather than solidifying them in-place.
Short-Term Effectiveness
Alternatives 2 through 5 may have short-term impacts to
remediation workers, the public, and the environment
during implementation. Alternative 2 could have minimal
adverse short-term impacts since work is limited to the
installation of four additional groundwater monitoring
wells associated with the groundwater sampling program.
Occupational health and safety controls would be
implemented to mitigate exposure risks. Alternative 2 has
an estimated implementation timeframe of 30 years,
although it is unclear whether RAOs would be reached
within 30 years.
Under Alternative 3, the potential risks to workers, the
public, or the environment would increase relative to
Alternative 2 due to substantial soil disturbance and
offsite transportation of soil, although these activities
would be managed through engineering controls, health
and safety procedures, and worker training. The
implementation timeframe for Alternative 3 is estimated
to be approximately 4 months.
Under Alternative 4, the potential risks to workers, the
public, or the environment would increase relative to
Alternative 2, due to implementation of ISS although
these activities would be managed through engineering
controls, health and safety procedures, and worker
training. The implementation timeframe for Alternative 4
is estimated to be approximately 3.5 months.
Installation of the electrodes and associated SVE and
MPE wells for Alternative 5 may result in short-term
exposure risks to workers, the public, or the environment,
but these potential risks are likely lower than those from
Alternatives 3 and 4 because there will be less physical
disturbance and movement of soil. These potential risks
would be managed through engineering controls, vapor
monitoring and mitigation, health and safety procedures,
and worker training. The implementation timeframe for
Alternative 5 is estimated to be approximately 6 months.
Based on the information contained above, Alternative 2
presents the least short-term impacts. Alternative 5, while
presenting more short-term impacts than Alternative 2,
has less short-term impacts as compared to Alternatives 3
and 4.
Implementability
All technologies under active Alternatives 3, 4, and 5 are
established technologies with commercially available
equipment and are implementable.
Alternative 5 would be the most difficult to implement, as
it requires the most specialized equipment with the
installation of electrodes, wells for vapor management,
and MPE wells (as necessary), temperature monitoring
14
-------
points, a power delivery system, and waste stream
controls. However, the equipment is conventional and
readily available.
Alternatives 3 and 4 would be easier to implement than
Alternative 5, but more difficult than Alternative 2, as
Alternative 2 is not an active remedy.
Cost
The estimated capital, O&M, and present worth costs are
presented in Table 5 below and discussed in detail in the
FS Report. The cost estimates are based on the best
available information. Alternative 1: No Action has no
cost because no activities are implemented. The highest
present worth cost alternative is Alternative 5, at $3.58
million.
* 30-year present worth calculations are based on a 7% discount rate.
State/Support Agency Acceptance
NYSDEC has consulted with NYSDOH and concurs with
the preferred alternative.
Community Acceptance
Community acceptance of the preferred alternative will
be evaluated after the public comment period ends and
will be described in the Responsiveness Summary
section of the Record of Decision for OU5.
PREFERRED REMEDY AND BASIS FOR
PREFERENCE
Based upon an evaluation of the remedial alternatives,
EPA, in consultation with NYSDEC, proposes
Alternative 3, Excavation, as the preferred remedy for
OU5.
The preferred alternative has as its key components: 1)
demolition and removal of the existing concrete slab floor
and foundation supports; 2) excavation of contaminated
3 See http://www.epa.gov/greenercleanups/epa-region-2-
clean-andgreen-policy and
unsaturated soil located beneath and near the footprint of
the former manufacturing building in the northern portion
of the Historical Source Area; 3) off-Site transportation
and disposal of excavated material; and 4) restoration
with imported clean fill material. Refer to Figure 3 for the
conceptual design depicting the estimated excavation area
based on the results of the FSIR.
As part of the remedial design, further evaluations would
be conducted to define the depth of the water table and
resulting excavation. If determined practicable, additional
limited active remediation could be performed below the
water table to address saturated soil in an effort to
improve remediation timeframes for groundwater. During
the remedial design, additional soil sampling would also
be conducted to further evaluate the extent of
contamination, including 1,4-dioxane.
The environmental benefits of the preferred remedy may
be enhanced by employing design technologies and
practices that are sustainable in accordance with EPA
Region 2's Clean and Green Energy Policy.3 During the
remedial design, green remediation concepts, including
the use of low-sulfur vehicles and the location of the
landfill that would receive the excavated soil in an effort
to reduce truck trips, would be considered.
The total estimated present-worth cost for the preferred
alternative is $2,414,000. This is an engineering cost
estimate that is expected to be within the range of plus 50
percent to minus 30 percent of the actual project cost.
Further detail on the cost is presented in Appendix C of
the FS Report.
This proposed OU5 remedy addressing contaminated soil
located beneath and near the footprint of the former
manufacturing building, along with the remedy selected
in the OU2 ROD Amendment addressing soil in the
drainage swale area and groundwater, would constitute
the final remedy for the AVX Property.
The ICs selected in the OU2 Amended ROD continue to
apply to the AVX Property and as such would apply to the
preferred remedy. Because the OU2 amended remedy will
result in hazardous substances, pollutants, or
contaminants remaining in and around the drainage swale
area at the AVX Property above levels that would
otherwise allow for unlimited use and unrestricted
exposure, pursuant to Section 121(c) of CERCLA,
statutory reviews will be conducted no less often than
http://www.dec.ny.gov/docs/remediation_hudson_pdf/der3
l.pdf
15
Table 5: Summary of Costs
Ciipiliil
Cosl
(>& M
Cnsls
I'lYSCIII
Worlh •
Alternative 2
$44,000
$567,000
$291,000
Alternative 3
$2,228,000
$450,000
$2,414,000
Alternative 4
$2,715,000
$450,000
$2,901,000
Alternative 5
$3,395,000
$450,000
$3,581,000
-------
once every five years to ensure that the remedy remains
protective of human health and environment.
Basis for the Remedy Preference
While Alternatives 3: Excavation, Alternative 4: In-Situ
Soil Solidification and Alternative 5: In-Situ Thermal
Remediation all use proven technologies to actively treat
VOC-contaminated soil in OU5, Alternative 3 would
permanently remove the contaminated soil located
beneath and near the footprint of the former
manufacturing building in a relatively short
implementation timeframe. Alternative 3 is also
comparatively easier to implement than Alternatives 4
and 5 and uses conventional construction equipment.
Based upon the information currently available, the
preferred alternative (Alternative 3, Excavation) meets
the threshold criteria and provides the best balance of
tradeoffs compared to the other alternatives with respect
to the balancing criteria. The EPA expects the preferred
alternative 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; 3) it is cost effective; and 4) it
utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable. Although it is not currently
anticipated, if necessary, in order to meet the
requirements of the disposal facilities, contaminated
material would be treated prior to land disposal and only
under such circumstances would the preferred alternative
partially satisfy the preference for treatment. With respect
to the two modifying criteria of the comparative analysis,
state acceptance and community acceptance, NYSDEC
concurs with the preferred alternative, and community
acceptance will be evaluated upon the close of the public
comment period.
16
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Figure 1: Site Location Map
HA/MLTONAVE
GENESEE ST
Imanville
PROSPECT AVE
Weston
Mills
park ave-
COOOHILH AVI
[brook ST 1
Olean Well Field Location
'•Mi,,, i—i-s—r
AVX Property
City of Olean
Pumping Wells
Seneca
Heights
^iermstr
Executive
Airport
Savage
Hollow
" vVestons Mills
Mt Herman
REFERENCE: BASE MAP USGS 7.5 MIN. TOPO. QUAD . OLEAN. NEW YORK. 2016.
0 2000'
NEWYORK
KYOCERA AVX COMPONENTS CORPORATION
OLEAN WELL FIELD SUPERFUND SITE
OLEAN, NEWYORK
FEASIBILITY STUDY INVESTIGATION REPORT
KAVX PROPERTY AND OLEAN WELL FIELD
LOCATION MAP
^ARCADIS
17
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Figure 2: Operable Units
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L ¦ .1 Approximate OU1 Boundary |_J Approximate OU4 Boundary
I I Approximate OU2 Boundary |_J Approximate OU5 Boundary
Approximate 0U3 Boundary
18
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Figure 3: Alternative 3 -Excavation
KOfCSt
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STAGE I REMEDIAL ACTON EXCAVATION flPEA |2DDDt
VERTICAL AQUIFER PROFILE SAMPLING LOCATION
C3JZJ) • WHERE TWO CCLCFS ARE PRESENTED. THE
INNER CCLC® REPRESENTS THE DEEPEP SAMDLE
APPPCKIKWTE EXTENT OF E*CAVATICW
AVX CORPORATION
OLEAN. NEW YORK
FEASIBILITY STUDY
PROPOSED EXCAVATION AREA
^ARCADIS
19
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ATTACHMENT B
PUBLIC NOTICE
-------
EPA Invites Public Comment on a Proposed Cleanup Plan
Addressing Contamination near the
Olean Wellfield Superfund Site in Olean, New York July 2023
The U.S. Environmental Protection Agency (EPA) has issued a proposed cleanup plan to address
contaminated soils located beneath and near the former manufacturing building previously known
as AVX Corporation.
A 30-day public comment period on the plan, which identifies EPA's cleanup alternatives, begins
on July 27, 2023 and ends on August 28, 2023. EPA's proposed alternative involves soil
excavation and removal of the existing concrete slab floor, removal of the impacted soil, off-site
disposal and restoration with imported clean fill material. The former AVX Corporation is now
owned by KYOCERA AVX Components Corporation (KAVX).
EPA will hold a public meeting at 6:00 pm on August 8, 2023 in the Magnano Reception Room
near the Cutco Theater, 305 North Barry Street at the Cattaraugus County Campus of Jamestown
Community College in Olean, to get public reaction and input to the proposed cleanup plan.
The proposed cleanup plan is available at: http://www.epa.gov/superfund/olean-wellfield
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ATTACHMENT C
PUBLIC MEETING TRANSCRIPT
-------
OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023
1
OLEAN WELL FIELD SUPERFUND SITE:
2
3
OPERABLE UNIT 5
4
In Re:
5
Proposed Plan Public Meeting
6
7
8
Q
HELD ON: August 8, 2023
<7
10
11
HELD AT: Jamestown Community College
Cattaraugus County Campus
12
305 North Barry Street
Olean, New York
13
14
15
BEFORE: CARMEN A. NASCA
16
Court Reporter
17
APPEARANCES:
18
MICHAEL BASILE, USEPA Region 2 Community
Involvement Coordinator
19
MAEVE WURTZ, EPA Remedial Project Manager
BOB RING, Cattaraugus County Health Department
20
PETE MANNINO, Branch Chief
21
22
23
24
25
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023
Page 2
1 MICHAEL BASILE: Good evening. My
2 name is Mike Basile. I'm the
3 community-involving coordinator at EPA.
4 I want to welcome you to our proposed
5 plan rollout for the Olean well field
6 site here in Olean, New York. Thank you
7 for taking the time to come out. We
8 have a simple agenda tonight. You have
9 the agenda in front of you. Thank you
10 for signing in. When you sign in, you
11 automatically go on our mailing list.
12 I'm going to give the opportunity of our
13 remedial project manager, Maeve Wurtz.
14 She'll have a PowerPoint presentation to
15 explain the proposed plan for this phase
16 of the clean up that we're recommending.
17 We're in the 30-day public commentary.
18 She'll be explaining all of that to you.
19 Give her an opportunity to make the
20 presentation and then we'll do questions
21 and answers after. We have a
22 stenographer that's here. We're going
23 to ask you to stand, state your name,
24 spell your name and your address for the
25 stenographer at that time. At this
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023
Page 3
1 time, I want to introduce a few folks
2 that will not be making presentations
3 but are here: Mr. Bob Ring from the
4 Cattaraugus County Health Department and
5 with our team at EPA at 290 Broadway,
6 Pete Mannino, a branch chief right here,
7 Maeve Wurtz, our remedial project
8 manager. Maeve?
9 MAEVE WURTZ: Hi, everyone. Thanks
10 for coming out tonight. So Mike just
11 introduced everyone who's here tonight.
12 Also on the site team, we have Nick
13 Mazziotta who's a health risk assessor
14 and Sharon Kivowitz who is our site
15 attorney, as well as Steve Moeller and
16 Eamonn O'Neill with New York State. So
17 tonight, I'm going to be talking about
18 the Superfund process in general and
19 then get into the site background and
20 the site investigations that have been
21 conducted thus far then we'll get into
22 EPA's cleanup options, and our preferred
23 alternative and then, at the end, we'll
24 have time for any questions and we can
25 go back to any slide. So just a little
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023
Page 4
1 bit about the Superfund process in
2 general. It starts off with the
3 preliminary assessment, which is an
4 initial investigation into the type of
5 contaminant at the site and if that
6 determination is above a certain level,
7 then the site gets elevated to the
8 national priority list. Once the site
9 is ranked on the national priority list,
10 the remedial investigation can start and
11 this is a more in-depth investigation
12 into the type and extent of
13 contamination at the site. After the
14 remedial investigation is done, the
15 feasibility study can be conducted and
16 this is when the EPA looks at the
17 different types of technology available
18 to us to address the contamination at
19 the site. After that, we're in the
20 proposed planning and record of decision
21 phase, which is where we're at right now
22 with OU5. This is when EPA releases the
23 proposed plan for the cleanup and that
24 opens up a 30-day public comment period
25 where we are open to the receiving of
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023
Page 5
1 any comments, questions from the
2 community and after that comment period
3 is closed, we finalize the alternative
4 and take into account and record any
5 comments or questions that were received
6 during the public comment period. Then,
7 the remedial design and remedial action
8 phase is conducted. This is when the
9 chosen remedy is constructed as -- and
10 designed before constructed and once the
11 remedy is constructed, EPA operates and
12 maintains the remedy until the
13 contaminants are at low enough levels
14 that it is no longer needed. Throughout
15 this whole process, community
16 involvement is really important so I
17 want to thank all of you for coming out
18 tonight and hearing what we have to say.
19 So EPA breaks larger or more
20 complex Superfund sites into different
21 operable units. This is so we can
22 address different types of contamination
23 or different geographic sections of
24 contamination so that we can conduct the
25 cleanup in the most efficient and
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023
Page 6
1 fastest way possible. Olean has five
2 different operable units. They are OU1,
3 which is ground water, OU2, which is the
4 four source areas, which are Alcas, AVX,
5 Loohn's, and McGraw Edison. OU3 is
6 Alcas parcel B, OU4 is the area south of
7 the AVX property and OU5 are the source
8 area soils at the AVX property.
9 This is a figure of the entire
10 Superfund site. So over here, we have
11 the Alcas facility. Alcas is currently
12 owned by the cutlery corporation, Cut
13 Co. Corporation, so we have OU2 in green
14 above and OU3 below in orange. In the
15 middle, we have the AVX facility. AVX
16 is currently owned by Kyocera AVX
17 Components Corporation or KAVX. We have
18 OU2 in green above OU4 in red and OU5 in
19 blue. Right below there is Loohn's Dry
20 Cleaners and over to the right, we have
21 McGraw Edison, which is currently owned
22 by Cooper Power Systems. Just zooming
23 in on the AVX site, OU5, which we're
24 talking about tonight, is the
25 contaminated soil located beneath and
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023
Page 7
1 near the footprint of the former
2 reconstruction building on AVX property.
3 So again, that's in blue.
4 A little bit about the site
5 investigation history. The
6 contamination was first discovered in
7 1981 when contamination was found in the
8 three municipal supply wells and nearby
9 private residential wells. So as a
10 result of this discovery, the wells were
11 shut down and service water treatment
12 facility operations were started in
13 order to get clean water to residents.
14 In 1985, the first Record of
15 Decision for the decision was published
16 and this called for the installation of
17 air-strippers on the Municipal wells, as
18 well as the extension of the City of
19 Olean waterline into the Town of Olean
20 in order to connect residents to the
21 public water supply who were using
22 private wells. The ROD also called for
23 institutional controls to limit or
24 restrict groundwater use and since then,
25 the air-stripping devices have been
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1 working effectively and the water that's
2 pumped from the city Aquifer has been
3 meeting all federal and state standards.
4 In 1996, we issued the OU2 ROD and
5 this identified four source areas for
6 the site. As I said before, they were
7 Alcas, AVX, McGraw Edison, and Loohn's
8 so this Record of Decision required four
9 different cleanup methods for each
10 different source area. All of those are
11 still in progress. All four of those
12 source areas were also considered
13 sources of contamination to the City
14 Aquifer at one point in their - when
15 they were running. So the four source
16 areas were McGraw Edison, the remedy is
17 pump and treat; there's Loohn's; that
18 was excavation, Alcas was vacuum
19 enhanced recovery and AVX was also
20 excavation. In 2014, the Alcas rod
21 amendment was issued. This is because
22 while work was going on in Alcas, based
23 on additional studies, it was found that
24 the remedy that was previously selected
25 would no longer -- would not be
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1 successful so a new remedy of in-situ
2 chemical oxidation was selected.
3 There's also more contamination than
4 previously thought in 1996 so a new
5 operable unit, OU3, was designated at
6 the Alcas site and that remedy that was
7 selected in the 2014 ROD was Enhanced
8 Anaerobic Bioremediation.
9 Similarly, at the AVX site during
10 excavation, more contamination was
11 discovered than was previously known
12 about, specifically underneath a
13 manufacturing building in the
14 undeveloped wooded area to the south of
15 the AVX manufacturing building and
16 across the AVX property boundary to the
17 south. The remedy picked in the OU2 ROD
18 was an exposure barrier, a containment
19 trench, and a hydraulic pumping
20 containment system.
21 At the time of the 2015 recorded
22 decision, the contamination underneath
23 the manufacturing building was not
24 accessible because the building was
25 still an active manufacturing plant. So
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1 at this time, the 2015 remedy was
2 considered an interim remedy until a
3 time where the contamination under the
4 building was successful. In 2018, AVX
5 ceased operations at their manufacturing
6 facility so this -- following demolition
7 in 2020, this started the feasibility
8 study process in order to test and get a
9 handle on the contamination under the
10 building and look into possible cleanup
11 options.
12 In 2022, we published the OU4
13 Record of Decision. Some of you were
14 here last summer for that meeting,
15 proposed plan meeting. The remedy
16 selected for that was in-situ chemical
17 oxidation and that brings us to 2023,
18 OU5.
19 So a little bit about the history
20 of AVX manufacturing. The Olean
21 facility was opened in 1950 and they
22 produced ceramic capacitors and
23 resistors. TCE was used until the early
24 1970s, where after that they switched to
25 PCE, and then shortly after that, 1,1,
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1 TCA and that was used until the late
2 1980s.
3 Just a few locations that - of the
4 AVX manufacturing building that will
5 come up later until the presentation.
6 So down in the southeast corner, there
7 was the former machine shop maintenance
8 area and also the receiving and chemical
9 storage area and then, a little above
10 them are the tape and reel storage areas
11 and the powder and barrel storage area.
12 So as I said before, in 2018, AVX
13 ceased operations at the manufacturing
14 building and in 2020, the building was
15 demolished. The concrete slab was left
16 behind that is acting as a barrier to
17 the elevated concentrations of
18 contaminations in the soil. From 2020
19 to 2022, the feasibility study
20 investigation and treatability study
21 were conducted by KAVX. In 2022 to
22 2023, the feasibility was conducted also
23 by KAVX and in 2023, we are releasing
24 our proposed plan for cleanup of the
25 contamination.
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1 So the investigation activities at
2 OU5 were designed to define the location
3 and extent of contaminants beneath and
4 near the former manufacturing building
5 and also to characterize the
6 hydrogeology in order to define any
7 potential pathways of contaminant
8 transport. The sampling methods used
9 during the OU5 investigations were photo
10 ionization detector screening, soil gas
11 screening, whole core soil sampling and
12 vertical Aquifer profile sampling.
13 This is a figure of the soil, gas
14 screening locations. Just to orient you
15 all, this highlighted yellow is the edge
16 of the manufacturing building, so
17 anything to the north of that is the
18 manufacturing building or former
19 manufacturing building. This blue
20 outline is the source area as defined in
21 the 2015 Record of Decision and all of
22 the points are different soil, gas
23 screening locations.
24 This legend is hard to see. The
25 pink and red dots are the highest areas
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1 of contamination. So there are 114 soil
2 and gas screening locations. This is
3 where the highest levels popped up so
4 you can see, if you remember the
5 locations from the previous slide, over
6 here is the general area of the machine
7 shop and maintenance area and over here
8 is the general area of the receiving
9 area and chemical storage area. The
10 highest levels range from 145 to 1,436
11 parts per million.
12 This is a figure of the whole core
13 soil samples. Similarly, this is the
14 outline of the building. Anything north
15 of that is the former manufacturing
16 building and the blue is the outline of
17 the source area as defined by the 2015
18 Record of Decision.
19 There were 40 different locations
20 for the core sampling. There were 300
21 soil samples that were analyzed and
22 similarly, we found the highest levels
23 of contamination in similar places so
24 down near the machine shop and
25 maintenance area, as well as the
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1 receiving area and chemical storage
2 areas. Another notable area was the
3 southeast corner of the area that was
4 formerly excavated as part of the 2015
5 remedy, which the former excavation is
6 this, outlined in grey.
7 Vertical Aquifer profile samples
8 were also collected during the whole
9 core sampling. If there is enough water
10 in the samples to sample. So only 13
11 out of 40 borings contained enough water
12 to sample and the samples - the
13 concentration of contaminants in the
14 samples were relatively consistent with
15 the semi -- annual groundwater sampling
16 that has been conducted since 2000.
17 The chemicals of potential concern
18 at the site are TCE, PCE, CIS, 1, 2,
19 DCE, 1,1,1 TCA, 1,2, DCA, trans 1, 2,
20 dichloroethene, toluene, xylene, vinyl
21 chloride, and 1,4-dioxane. To the left,
22 we have a table with the maximum soil
23 contaminant concentrations so they range
24 from about 2 parts per million for vinyl
25 chloride, up to 1500 parts per million
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1 for TCE. And then, to - on the table
2 to the right, we have the soil
3 remediation goals and these are the
4 levels to which we are aiming to
5 remediate down to. So they are a lot
6 lower than the table on the left.
7 Using site-sampling results, EPA
8 conducts risk assessments, which are
9 used to determine the potential risks
10 from coming into contact with
11 contaminated soil. There was a risk
12 assessment performed as part of the
13 original 1996 OU2 ROD, as well as a risk
14 evaluation performed as part of the
15 2015 ROD amendment.
16 EPA has determined that the results
17 of both the assessment and evaluation
18 have not substantially changed. The
19 risk assessment was driven by high
20 levels of contaminants in the soil,
21 underneath the concrete slab at the
22 former manufacturing building and the
23 risks were associated with exposure to
24 contaminants and soil and they were
25 calculated for the ingestion and
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1 inhalation of contaminants by
2 construction workers since it is an
3 industrial area.
4 An ecological risk assessment was
5 also conducted and it was found that
6 exposures to -- ecological exposures to
7 soil or sediment at OU5 were considered
8 unlikely to pose risk. Remedial action
9 objectives are goals to protect human
10 and health--human health and the
11 environment. They are site-specific.
12 The following RAOs have been established
13 forOU5. They are to reduce the
14 migration of VOC contaminants in soil
15 and groundwater and to eliminate the
16 potential for human exposure to site
17 contaminants via contact with soil
18 concentrations above New York State DEC
19 soil cleanup objectives for commercial
20 properties.
21 So getting into our potential
22 alternatives, Alternative 1 is
23 no-action. Superfund regulations
24 require that a no-action alternative be
25 used as a baseline for comparing other
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1 alternatives. Under this alternative,
2 there would be no remediation - no
3 active remediation activities to control
4 or remove soil contaminants.
5 Alternative 2 is long-term monitoring.
6 This would involve monitoring
7 concentrations of contaminants in the
8 soil that are reduced by naturally
9 occurring processes. It would also
10 involve installing four additional
11 monitoring wells and coming up with a
12 monitoring program. The long-term
13 monitoring alternative would cost
14 $291,000.
15 Alternative 3 is excavation. This
16 would involve the demolition and removal
17 of the existing concrete slab floor and
18 foundation supports, excavation of
19 contaminated, unsaturated soil, off-site
20 transportation, disposal of excavated
21 material and restoration with clean,
22 imported fill material. This is a
23 figure of the proposed excavation area.
24 So we have our outline of the building
25 in yellow and in pink, the proposed
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1 excavation areas. So you can see they
2 are in the areas of the highest
3 contamination as found by testing.
4 Alternative 3 would cost $2,414,000.
5 Alternative 4 is in-situ soil
6 solidification. This would involve
7 contaminants being solidified into a
8 solid block using a binding agent and
9 this would trap the chemicals and not
10 allow them to move or migrate. It would
11 also involve a cover designed to keep
12 the treated block underneath the frost
13 line to protect it and to promote storm
14 water drainage away from the treatment
15 zone. Alternative 4 would cost
16 $2,901,000.
17 Alternative 5 is in-situ thermal
18 radiation. This would involve using
19 heat to move and mobilize the
20 contaminants in the soil. So this would
21 - the heat would cause the contaminants
22 to move through the soil towards
23 installed wells where they'll be
24 collected and piped to the surface to be
25 treated and at the surface, they will be
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1 treated using cooling phase separation,
2 air-stripping, and activated carbon.
3 Alternative 5 would cost $3,581,000.
4 EPA uses seven balancing criteria
5 when comparing the alternatives to each
6 other, as well as state and community
7 acceptance. So the seven balancing
8 criteria are the overall protection of
9 human health and the environment,
10 compliance with applicable or relevant
11 and appropriate requirements, long-term
12 effectiveness and permanence, reduction
13 in toxicity, mobility or volume of
14 contaminants through treatment,
15 short-term effectiveness,
16 implementability and cost.
17 EPA's preferred alternative is
18 Alternative 3, excavation. And again,
19 that would involve the demolition and
20 removal of the existing concrete slab
21 floor and foundation supports, the
22 excavation of contaminated, unsaturated
23 soil, off-site transportation of that
24 soil, disposal of the excavated material
25 and restoration with a clean fill.
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1 So our basis for the selection of
2 excavation is that it permanently
3 removes the contaminated soil. It's a
4 relatively short remediation timeframe
5 and it provides the best balance of
6 tradeoffs compared to the other
7 alternatives with respect to the
8 balancing criteria. Again, Alternative
9 3 would cost $2,414,000.
10 So our next steps are - we are
11 accepting any written comments on this
12 proposed plan through August 28th and
13 after that, EPA will prepare a Record of
14 Decision, which formalizes the selection
15 of the remedy and takes and records any
16 comments received through the public
17 comment period, as well as any verbal
18 comments we may receive tonight.
19 You can address any written
20 comments to this address here. I'll
21 leave it up on the screen in case anyone
22 wants to write it down at the end. You
23 can also email me at this address. All
24 of this presentation and all of the site
25 documents can be found online on the
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1 site's webpage or they are available at
2 the Olean Public Library or the EPA
3 record center. Now we have time for any
4 questions.
5 MICHAEL BASILE: Thank you very
6 much, Maeve. At this time, we will
7 entertain questions and once again, I
8 was just going to call upon you. I
9 would just ask you to identify yourself,
10 spell your name, your first and last
11 name, and give your address so we can
12 have the stenographer, Carmen, put that
13 into public record. Any questions at
14 this time about the presentation? Yes,
15 sir?
16 RICHARD WEB! R; I've got three
17 questions.
18 MICHAE L BASILE: Okay.
19 RICIIARD WEBER: Richard Paul Weber,
20 ¦¦¦^¦loiean, New York. My
21 questions are: There's two sites.
22 You've got to talking about this site,
23 but they also tore the building down on
24 the corner of Seneca and Line Street,
25 which also had chemicals underneath it,
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1 but that has just weeded over. They
2 left it there, left the fence up.
3 That's not being touched and AVX, per
4 se, is in the Town of Olean, not Olean.
5 You're addressing everything to Olean,
6 New York and there ain't nobody here
7 from Olean, not a mayor, not an
8 alderman, not a town supervisor, not a
9 legislator. There's nobody here but
10 neighbors and the AVX and the county and
11 you people from the EPA and the
12 stenographer. There's nobody here
13 higher than us three here. Olean Tile
14 was another one that was part of this
15 deal, but never - they never slapped
16 their hands. They did the same thing.
17 They were using the same chemicals we
18 were at AVX.
19 And the third question is: Will we
20 be told which alternative you're going
21 to do? Will they tell us prior to doing
22 it or will they just tear the building
23 down or tear the ground up and not tell
24 anybody? Are they going to notify us?
25 The other thing is: On this one second
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1 page, it said it was an oversight in
2 1981 and 1983. I was there in 1981 and
3 '83. I seen them pour the chemicals
4 down in the ground underneath the box
5 crusher in the back of the plant. They
6 did it for 20 years. They put the PCE
7 in the ground, but they couldn't get rid
8 of it. Now it leaked into the Aquifer
9 and this second page, it makes no sense.
10 You're saying it's contaminated from the
11 Haskell Creek, to the Olean Creek to the
12 Allegany River. Well, hell bell. My
13 house is on the corner of Clark and
14 Seneca. Are you telling me that if I
15 want to sell my house, I'm going to have
16 to tell somebody that my ground
17 underneath is contaminated, the water is
18 contaminated under my house? I just
19 don't understand this second page. I
20 really don't understand it and if
21 somebody can explain it to me, go ahead.
22 I mean, it doesn't - an oversight?
23 There was no such thing as an oversight.
24 They did it on purpose and there's a lot
25 of people dying right now. I've got
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1 cancer. I've had cancer, but there's a
2 lot of people that I know personally
3 from AVX that are dying daily from
4 cancer. I hate to tell you where that
5 came from. TCE is the worst
6 carcinogenic in the world. So those are
7 my questions. I don't understand that
8 second page.
9 MICHAEL BASILE: Well, I can answer
10 your question about the elected
11 officials. At every one of our
12 Superfund sites including this site, we
13 have an elected officials listing. We
14 send everything electronically to the
15 mayor, supervisor. We send it out to
16 the state representatives, including the
17 state assemblymen, the state senator, as
18 well as our federal counterparts,
19 Senator Schumer and Senator Gillibrand's
20 office. At many of our meetings, they
21 do send representatives to the meetings.
22 This meeting, just like the one that we
23 held last year, they receive and they
24 receive complimentary information about
25 this meeting, the agenda, as well as the
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1 community update so they're well aware
2 of the meeting, okay?
3 RICHARD WEBER: Okay. I just don't
4 understand. Believe me, I'm going to
5 confront every one of them. I know them
6 all.
7 MAEVEWURTZ: To address one of
8 your other comments, so, this is our
9 community notification of our proposed
10 cleanup plan, which is the excavation.
11 So everyone has 30 days, starting when
12 we released this plan last week, to
13 review the plan, have any comments, tell
14 us how we can do it better from your
15 point of view and then, on August 28th,
16 that public comment period closes and
17 after that, we review everything that
18 we've gotten and finalize the decision
19 and at that point, when the recorded
20 decision is published, that is our
21 notification of what our plan is to do
22 with the cleanup.
23 RICHARD WEBER: Okay. Thank you.
24 PETEMANNINO: I'm sorry. There
25 were - I believe there were a couple
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1 more points to your questions and
2 comments. On the oversight piece, I
3 believe, unless there was an error, the
4 oversight pertains to EPA's overseeing
5 the work that the responsible parties
6 did at the three source areas. The
7 fourth source area, Loohn's, was done
8 under - by the federal government and
9 so the federal government wouldn't
10 oversee itself, but at the former KAVX
11 at Alcas and at McGraw, work that was
12 done by the what we call, "potentially
13 responsible parties," PRPs, was overseen
14 by the federal government so I believe
15 that's the context of oversight there.
16 With respect to your point about
17 Olean Tile and the other location, I
18 believe Olean Tile was one of the -- it
19 predates me - it goes back to the early
20 '80s - but of the original 13 or 15
21 potential source areas that were
22 evaluated either by New York State DEC
23 or EPA. And of those facilities, we
24 identified the four that Maeve described
25 earlier as being sources of the
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1 groundwater contamination at the site.
2 So I believe it was one of our -- not
3 the last public meeting, but maybe with
4 respect to the OU2 amended ROD where
5 some community members identified other
6 potential source areas where chemicals
7 were used and we were not able to find
8 any records of disposal or releases at
9 those locations. So please, if you are
10 aware of disposal or other potential
11 known source areas, provide us the
12 information. We will continue to follow
13 up because, you know, this is the data
14 as we know it as a snapshot today, but
15 there's been a long history of looking
16 at other potential--
17 RICHARD WEBER: They did. They
18 buried tile and chemicals and everything
19 in the back of their lot where they're
20 building Tim Horton's right now.
21 PETE MANNINO: So keep in mind,
22 ceramic tile typically wouldn't be a
23 hazardous waste. Some of the adhesives
24 and glues that are associated with the
25 tile industry could potentially have
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1 hazardous substances to it, but how
2 ceramic tile itself would not likely
3 generate health hazards when --
4 RICHARD WEBER: Where they're going
5 to dig and where they're going to take
6 out in the back of that plant, going
7 towards Cooper from that direction,
8 there was a city dump -
9 PETEMANNINO: Yes.
10 RICHARD WEBER: - in there for 34
11 years. They dumped everything but the
12 kitchen sink in there and-
13 PETEMANNINO: Yes, so - but --
14 RICHARD WEBER: - and it burnt for
15 years. It got on fire and never - they
16 could never put it out. It took them
17 years to get the thing to go out so
18 that's another thing. When you start
19 digging, are you going to draw some of
20 that crap from down there?
21 PETEMANNINO: So two points. One:
22 The names of the various dumps in that
23 area, I can't remember off the top of my
24 head, but I believe there was at least
25 two that were previously looked at so
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1 that is something that was looked at in
2 the past. We didn't find -- based on
3 the groundwater data, soil data that was
4 collected, we didn't find any evidence
5 of hazardous waste contamination at
6 those locations.
7 Again, if you're aware of specific
8 disposal activities, please share that
9 and we will, to the extent that we can,
10 follow up. Work continues. By no means
11 is today the end of EPA's or New York
12 State's investigation of the Olean
13 well-field Superfund site. With respect
14 to digging, this is a soil excavation
15 that we'd be doing at the KAVX property,
16 right? I believe the excavation would
17 go down to, basically, the water table,
18 which I -- we have an elevation. I
19 think it's probably just, like, 10 to
20 12, 13 feet. Somewhere thereabout 18,
21 just throwing a ballpark up -- or out.
22 Yes, go ahead.
23 NORM DEGROFF: Where I am, I'm
24 almost the same level as AVX. I just
25 had a well put in five or six years ago.
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1 PETEMANNINO: Okay.
2 NORM DEGROFF: And he found water
3 at 50 feet. So he - yeah.
4 PETEMANNINO: Okay. 50 feet--
5 NORM DEGROFF: 50 feet-yeah.
6 PETEMANNINO: Okay.
7 NORM DEGROFF: So that's the water
8 table.
9 PETEMANNINO: At - where we are
10 for the KAVX property, water table is
11 not at 50 feet.
12 NORM DEGROFF: They're a tad lower,
13 but you know, just the same.
14 PETEMANNINO: Right. We had a lot
15 of soil borings that have been done, a
16 lot of groundwater monitoring wells that
17 have been done. We have - there's some
18 fluctuations within a couple of feet,
19 but not to the order of magnitude of,
20 you know, 10, 20, 30 feet so -- for
21 where we are at the KAVX property. So
22 that scope of work, you know, wouldn't
23 draw in water from the city Aquifer or,
24 you know, from any kind of significant
25 distances. So any water that comes into
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1 the hole would be managed. I think the
2 current conceptual design would be that
3 that water would be captured, it would
4 be sent through the existing treatment
5 plant that was constructed at the KAVX
6 property, I believe that work was
7 completed around last year, and then
8 discharged to the City of Olean's
9 treatment work system. So it's
10 periodically sampled to make sure that
11 it meets all the discharge requirements.
12 So there again, the EPA doing
13 oversight, if the PRP is performing the
14 work and ensuring that all the standards
15 are being met, we would have air
16 monitoring to ensure that dust does not
17 pose a hazard to the nearby residents
18 and safety measures for all the workers,
19 trucks entering, leaving. All of the
20 best management practices will be in
21 place and that all gets flushed out once
22 we're in the remedial design phase.
23 After the Record of Decision, we'll get
24 into design. We develop the
25 specifications of exactly how the work
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1 is going to be done, and then there's
2 the actual performance of the work.
3 NORM DEGROFF: I did request that
4 my soil got tested, because on the
5 screen - if you want to bring that one
6 back up where it shows the worst two
7 spots in pink. I'm going to get up.
8 Now where's the building? The yellow?
9 MAEVEWURTZ: Yep.
10 NORM DEGROFF: I'm right here.
11 That's why I want to check. I'm
12 probably 200 feet, not even, from the
13 fence. Probably 100 feet so that's why
14 I want that done. Can we do it?
15 MAEVEWURTZ: Yeah, we would
16 recommend contacting your local health
17 department to see if they could do the
18 testing.
19 NORM DEGROFF: You would do it or
20 me?
21 MAEVEWURTZ: The health
22 department.
23 NORM DEGROFF: Who would contact
24 them?
25 MAEVE WURTZ: Yeah, you can reach
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1 out to them to see if they can do it.
2 If they can't do it, they'll either be
3 in contact with us or let you know that.
4 You can always give me a call or
5 email -
6 NORM DEGROFF: I'll remind you.
7 MAEVEWURTZ: - if nothing's
8 happening yet if you are looking to get
9 things done and things aren't getting
10 done.
11 NORM DEGROFF: I have a feeling if
12 I call them they'll just say I've got to
13 refer to you.
14 PETEMANNINO: We'll work together.
15 We'll make sure that you're not
16 ping-ponged back and forth. The county
17 representative is here, but if you don't
18 mind for a second, I just want to get
19 clarification: Are you looking to have
20 your groundwater or soil tested?
21 NORM DEGROFF: I'd like both.
22 Well, well water.
23 PETEMANNINO: Right. That's what
24 I meant.
25 NORM DEGROFF: That's probably
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1 down, like I said, at least at
2 50-something feet they found water, but
3 it was too sandy and they kept going.
4 BOB RING: Do you mind if I say
5 something?
6 PETE MANNINO: Yeah, go right ahead
7 and then I have something I'd like to
8 add about groundwater quality and
9 groundwater flow direction just to
10 address the point entirely.
11 BOB RING: That was going to be my
12 question. Bob Ring, I'm the
13 environmental health director with
14 Cattaraugus County. So I think the
15 difference between the water that
16 they're encountering at, like, 9 or 10
17 feet deep, it's - you know, a lot of
18 that comes from the surface and the
19 surface water that's getting down in.
20 You know, when the well driller --
21 they're looking for clean water,
22 drinking water and we consider Aquifer
23 to have 50-foot graders. There's no
24 influence from the surface water because
25 there's so many layers of clay and other
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1 things so - if the minimums of casing
2 and depth for a well nowadays, but going
3 to 50 is a really good idea. We figure
4 your drinking water is not under the
5 influence of anything that's at the
6 surface. Feel free to reach out to me
7 with regards to well testing, but as far
8 as the drinking water we'll get involved
9 and make any recommendations if needed.
10 NORM DEGROFF: So you're the county
11 health director?
12 BOB RING: Yes.
13 NORM DEGROFF: What's your name?
14 BOB RING: Bob Ring.
15 NORM DEGROFF: Ring.
16 PETE MANNINO: I would just like to
17 add, the city Aquifer, which is
18 typically what is called the Aquifer
19 where producing water for the drinking
20 water supply wells. That is
21 contaminated and that is why, back in
22 the '80s, the three supply wells in the
23 area, treatment was added to them. The
24 18M -- it's been a while - 17 and it's
25 another well there. So just because
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1 you're in the city Aquifer does not mean
2 that there are impacts from the site.
3 When it comes to KAVX, groundwater
4 flow in this area is generally from
5 north to south, right? So from where
6 the KAVX property is down towards the
7 river. You are what we would call
8 upgradient of KAVX so you can't expect
9 to see influences from KAVX groundwater
10 on your property across the street.
11 However, there are other sources of
12 groundwater contamination at the site
13 and, you know, I would suggest sampling
14 your well and coordinating with the
15 county to have that done.
16 NORM DEGROFF: Because it said
17 somewhere in the literature that the
18 groundwater and the ground was all
19 contaminated in that area. I'm assuming
20 it would go towards me even though I'm a
21 tad higher.
22 PETE MANNINO: Yeah, so
23 groundwater - I mean -
24 NORM DEGROFF: Contamination, it
25 said, is in the soil under all the -- it
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1 said under residences.
2 PETE MANNINO: No, because soil
3 contamination on the KAVX property is
4 really, generally to the south, right?
5 So the AVX manufacturing plant, when it
6 was expanded - and I forget the
7 timeframes. So the area that we're
8 addressing now, at one point, the
9 structure was enlarged and covered up
10 part of the area that needed to be
11 addressed. So the original estimation
12 that was done that's shown in the shaded
13 area, that began in the late '90s, I
14 believe it was, and they couldn't go
15 further to the north because the
16 building was there, right? Most of the
17 contamination is in that southerly
18 direction and goes all the way down to,
19 you know, the - we've sampled all the
20 way down to the railroad tracks and then
21 sampling done as part of the Operable
22 Unit 4 on the southern side of the
23 railroad tracks didn't show any soil
24 contamination.
25 NORMDEGROFF: It did or did not?
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1 PETEMANNINO: It did not in the
2 unsaturated zone. In the saturated
3 zone, within the water table, there were
4 some points. Let me correct myself. I
5 believe there may have been one or two
6 samples in the unsaturated zone that
7 showed some contamination, but --
8 RICHARD WEBER: I got --1 was told
9 there's a real thing here. The TCE that
10 we're talking about --
11 PETEMANNINO: Yes.
12 RICHARD WEBER: - was used at
13 Cooper.
14 PETEMANNINO: Yes.
15 RICHARD WEBER: It was used at
16 Loohn's.
17 PETEMANNINO: Yes.
18 RICHARD WEBER: It was used at
19 Alcas.
20 PETEMANNINO: Yes.
21 RICHARD WEBER: It was used at AVX
22 and it was used at the tile plant. They
23 all dumped it out their backdoors. They
24 didn't know what to do with it. AVX out
25 it in the ground. Okay, it leaked. Now
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1 it's in everything. Now, if you're
2 saying that AVX is the only place to get
3 theTCE-
4 PETE MANNINO: No, I did not say
5 that.
6 RICHARD WEBER: - that's wrong
7 because now you're saying the
8 contamination - because this says right
9 here, "The contamination is from the
10 Haskell Road to the Olean Creek to the
11 Allegany River." That means the ground
12 underneath my house may have TCE in it
13 because not only AVX, it could be from
14 Alcas, it could be from the tile plant,
15 it could be from Cooper, it could be
16 from Loohn's. So the entire area is
17 contaminated. That's probably why the
18 city doesn't even want to come here
19 because they don't know what to do
20 either.
21 PETE MANNINO: So just so we're
22 clear, that statement in that community
23 update, that flyer, pertains to
24 groundwater contamination and not soil,
25 okay? What I was saying before, with
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1 respect to soil contamination, right?
2 I'm just going to go up here for a
3 second. When you look at all the data
4 that's been collected, and over the
5 years there's been a significant amount
6 of data, when dealing with soil
7 contamination related to the KAVX
8 property, that soil contamination is to
9 the south, right? There isn't going to
10 be a need for a clean up on the northern
11 side of the property, right? And so
12 with respect to your specific comment
13 regarding soil contamination, right, we
14 didn't see it to the north of the
15 property and it's unlikely to be on your
16 property, right?
17 NORM DEGROFF: It would be nice to
18 know, though.
19 PETEMANNINO: I'm sorry?
20 RICHARD WEBER: It would be good to
21 know.
22 PETE MANNINO: I understand and I
23 recognize the comment, and I just -- I'm
24 not in a position to say yes or no that
25 we would sample your - collect a soil
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1 sample. I just--1 want to make sure
2 you understand or recognize the current
3 conditions at the KAVX property, right?
4 The soil digging is in the back in the
5 rear and not in the front, okay? That's
6 just -- based on all the data that's
7 been collected, the contamination is
8 down here, not in the front, okay?
9 RICHARD WEBER: I understand.
10 PETE MANNINO: And again, you make
11 a valid point. You still would feel
12 more comfortable knowing specifically
13 based on a soil sample collected on your
14 property. I recognize that.
15 NORM DEGROFF: He's talking about
16 Loohn's. That got cleaned out, didn't
17 it?
18 PETE MANNINO: Loohn's in--
19 NORM DEGROFF: They dug that out.
20 PETE MANNINO: - in the
21 timeframe -
22 NORM DEGROFF: 30 years ago?
23 PETE MANNINO: It's been a while.
24 I believe it was in the '90s, late '90s.
25 EPA used federal funds with a 10 percent
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1 contribution from New York State and we
2 performed a soil excavation and we
3 continued to monitor the groundwater
4 quality in that area and we are still
5 seeing exceedances of certain VOCs in
6 certain groundwater-monitored wells in
7 that property and I believe the next
8 sampling of that is going to be
9 happening sometime this month for the
10 Loohn's property. And the city Aquifer,
11 which we were talking about earlier,
12 gets sampled periodically by the PRP
13 groups and we receive that data.
14 Before I forget, I believe there
15 was one more part of your original
16 comment with respect to notifications
17 when you go to sell--if and when you
18 go to sell your property and all I can
19 say about that is when that time comes,
20 you should coordinate with your realtor
21 and understand the New York State laws
22 with respect to notifications so - but
23 again, it's groundwater contamination
24 and not soil contamination on the
25 property.
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1 NORM DEGROFF: One other point ~
2 PETEMANNINO: Yeah.
3 NORM DEGROFF: And maybe you would
4 know, but the waterline of the city
5 would run out Seneca Avenue, but it
6 stopped halfway down, right about
7 eastern end of the AVX property. Why
8 didn't it go further?
9 PETEMANNINO: I don't know the
10 whole history of it as far as the
11 waterline going through the town.
12 NORM DEGROFF: The place where they
13 used to unload the trucks by the road,
14 there were some bikes there they used to
15 come in here to wait and they would
16 punch stuff into the plant. Right
17 roughly there is where that line is. It
18 was just towards the eastern end of the
19 - or whatever it is.
20 PETEMANNINO: Anyway, if you do
21 want to consider expense and -
22 NORM DEGROFF: Actually, it
23 really -
24 PETEMANNINO: - you would talk to
25 your town representative about it to get
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1 the ball rolling.
2 NORM DEGROFF: What was that?
3 BOB RING: Talk to your town
4 representative. You know, they would
5 have the initiation, you know in sense
6 to the water district, we can certainly
7 help, you know, there might be State
8 funding available for property if that's
9 something that you wanted. You also
10 have the ability to fund it yourself if
11 you're 200 feet away.
12 NORM DEGROFF: I'm about - my
13 property is probably about 100 to 150
14 feet from the AVX property. That's why
15 I'm concerned about it. I can look
16 straight up to where the plant was.
17 BOB RING: If we can get a copy of
18 this presentation, they listed, you
19 know, all the chemicals that would be -
20 you know, that you would want to test
21 for so that might be a better place to
22 start.
23 NORM DEGROFF: I just want the
24 ground tested and the water tested,
25 basically.
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1 BOB RING: I don't know if the
2 state will fund the testing, but there
3 are plenty of labs in the area that will
4 sample.
5 RICHARD WEBER: How about him? How
6 about Stan and I? We live inside of the
7 city. We are -
8 BOB RING: So the city -
9 RICHARD WEBER: We're all on the
10 same waterline.
11 BOB RING: So they're required to
12 do regular testing that's all available
13 in their annual water quality report.
14 RICHARD WEBER: The water testing,
15 would we have to pay for that?
16 PETE MANNINO: No. If you are on
17 city water, then the water that you
18 receive from the tap is required to meet
19 all federal and state standards and the
20 water distributor has their periodic
21 sampling, whether it's quarterly,
22 semi-annual or annually that can be made
23 available to show you what is being
24 distributed.
25 NORM DEGROFF: I'll just wait to
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1 see what the water in the we!! tests out
2 to be and we'll go from there. If it
3 shows it's okay, then we'll just leave
4 it. I just put that in. It cost me
5 quite a bit of money. At one time, in
6 the 90s, we had a lot of rain. I could
7 see rainbows in the water in the
8 backyard. You know what I'm talking
9 about?
10 PETE MANNINO: Yeah, that could
11 just -- and again, not knowing the
12 composition, that could just be organic
13 material from your yard and not related
14 to anything else.
15 NORM DEGROFF: Just saying.
16 PETE MANNINO: Yeah, no, yeah.
17 STANLEY WESLEY: My name is Stanley
18 Wesley, I live Olean, New York.
19 You're talking about
20 groundwater and along the railroad
21 tracks and that, there's two little --
22 there's a creek that follows down and
23 dumps in and goes under. Is there any 24
chance of getting those cleaned out so 25 the
water moves faster? And -- do you
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1 know what I'm saying? Because -
2 PETE MANNINO: Yeah, so that you
3 would have to speak to your local
4 representatives, local government to see
5 what they can do and maybe they can
6 solve that, but that is outside of our
7 purview. We wouldn't clean out creeks
8 or water bodies.
9 STANLEY WESLEY: And I was curious;
10 you put the big ditch back in by the
11 tracks, have you been --1 take it you
12 would want the body of water, has that
13 made any difference since you put it in
14 for your sampling or that? Is the
15 sampling improving?
16 PETE MANNINO: So are you talking
17 about the ditch in the back where the
18 fields - from the water from the former
19 operations at the plant gets discharged
20 to--
21 STANLEY WESLEY: Yeah. No, I put
22 the trench in across that, following the
23 railroad tracks, basically, and that. I
24 believe you were going to fill it with
25 organic and I think there was some kind
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1 of mud you would use.
2 PETE MANNINO: Oh, my apologies.
3 So you're talking about the hydraulic
4 trench that was installed along the KAVX
5 properties as part of what we call the
6 OU2 Record of Decision. Yes, so the
7 hydraulic trench was installed. I
8 believe that work was completed in the
9 -- about a year ago. We are receiving
10 data from KAVX with respect to the
11 treated water after it gets pulled out,
12 it goes to the treatment plant and then
13 it gets discharged. So where, you know,
14 construction is complete, we're
15 monitoring the data that's collected and
16 that's going to be a system that
17 operates for quite some time.
18 STANLEY WESLEY: I was just
19 wondering if you had any facts, you
20 know, or figures saying, "Oh, it was
21 here and now it's down here. It's
22 actually doing it's job," or anything?
23 PETE MANNINO: So I don't have any
24 data off the top of my head that I can
25 share with you.
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1 STANLEY WESLEY: That's fine.
2 PETE MANNINO: What we typically do
3 is after a system like that is
4 constructed, we monitor the data for a
5 year, monitor the operation and then
6 make a decision of whether or not the
7 system is operating and functioning as
8 it was intended, and then it goes to the
9 next phase of work, which is basically,
10 you know, long term operation and
11 maintenance, but that's just us moving
12 the project from, you know, one phase to
13 the next phase.
14 STANLEY WESLEY: I was just
15 wondering.
16 PETE MANNINO: Yeah.
17 STANLEY WESLEY: I was curious. I
18 mean, I walked down there and watched
19 them digging it and it was a deep hole.
20 PETE MANNINO: Yep.
21 STANLEY WESLEY: And I have one
22 other question. It's off of AVX,
23 though. It's not that, but you were
24 doing Alcas and you had that new 03 box
25 underneath it?
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1 PETEMANNINO: Yeah.
2 STANLEY WESLEY: Now, there was a
3 canal that ran in the back of Alcas -
4 it ran back from Alcas and basically,
5 the railroad tracks followed the canal.
6 Now when I was a child, I lived on
7 Grossman Avenue and AVX - or not --
8 excuse me. Alcas dumped all kinds of
9 stuff in that canal. When we were kids,
10 we used to crawl in that stuff looking
11 for knives and that --1 don't know if
12 you guys are thinking of testing there
13 or have tested that canal to see what's
14 in there and if it's worth removing or
15 no.
16 PETE MANNINO: So I am not familiar
17 with the use of the canal when it comes
18 to the Alcas property, but after the
19 meeting, maybe we can pull up a figure
20 and you can kind of show us exactly the
21 area that you're talking about. That
22 would be helpful, but what I can tell
23 you now, you know, as it relates to this
24 meeting is that, you know, there's been
25 extensive sampling done on the Alcas
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1 property. We identified the areas that
2 there was soil contamination and there
3 was some in-situ treatment technologies
4 used to address that contamination.
5 There's some groundwater contamination,
6 not soil, that is still being addressed
7 and some of that is on the Alcas
8 property and some of that is on the
9 adjoining parcels; we can call them
10 Parcel B or Operable Unit 3 and that
11 work there for the in-situ treatment and
12 the groundwater is - either has begun
13 or is scheduled to begin again at some
14 point.
15 MAEVE WURTZ: Yeah, it's scheduled
16 for the next few months.
17 PETE MANNINO: Next few months,
18 yeah. Definitely, I'd like to talk to
19 you offline after this meeting and maybe
20 talk a figure so you'd just kind of
21 point me to the area, and then we can go
22 back and kind of take a closer look at
23 what data, if any, was collected in that
24 area.
25 NORM DEGROFF: The old city map
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1 where the Shawmut Railroad came through
2 there over on the same side as the
3 canal.
4 PETEMANNINO: Okay.
5 STANLEY WESLEY: The canal would be
6 on the southern side. When they built
7 the Reading Railroad, they built it on
8 the side of the canal. I lived on - I
9 live in Grossman Avenue, right in the
10 back of it, basically.
11 NORM DEGROFF: I think that's all
12 filled in now.
13 STANLEY WESLEY: It's all filled
14 in, but I mean, you know, like I said,
15 when we were kids, we used to crawl
16 around in the stuff looking for knives
17 and that and then there's that and, you
18 know, there's a backdoor there and stuff
19 came out and it went in the canal.
20 NORM DEGROFF: It's pretty much
21 behind the building.
22 STANLEY WESLEY: Yes, as a matter
23 of fact, some of their new buildings
24 would be on top of that canal.
25 NORM DEGROFF: Right up to it. I
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1 mean, they kind of built around it
2 earlier at one time on an angle.
3 STANLEY WESLEY: Those are all the
4 questions I have. Thank you.
5 MICHAEL BASILE: Does anyone else
6 have a question?
7 NORM DEGROFF: One more.
8 MICHAEL BASILE: Yes, sir?
9 NORM DEGROFF: On the 28th, you're
10 going to decide how to take care of the
11 AVX; is that what you're saying?
12 PETEMANNINO: No.
13 NORM DEGROFF: Or after the 28th?
14 MAEVEWURTZ: Yes.
15 PETEMANNINO: Yes.
16 MAEVE WURTZ: Yeah, right, that's
17 the end of the public comment period so
18 then we finalize our cleanup plan and
19 release the Record of Decision.
20 NORM DEGROFF: And it's most likely
21 Number 3, right?
22 MAEVEWURTZ: That's EPA's
23 preferred alternative, yes.
24 PETEMANNINO: We have to wait and
25 see - for the public commentaries to
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1 end to see what the totality of the
2 comments are and use that in our
3 decision-making process to see whether
4 or not the selected -- the preferred
5 alternative that Maeve presented will
6 actually be the selected remedy or if
7 there's any modifications based on
8 public comment.
9 RICHARD WEBER: Will there be
10 another meeting before they start this?
11 PETEMANNINO: No.
12 MICHAEL BASILE: Once the comments
13 close, as Pete indicated on August 28th,
14 we will review all the comments and then
15 we'll issue a Record of Decision. That
16 Record of Decision will most likely be
17 signed by the 30th of September and we
18 will have a press-release that will go
19 out that will explain to the public that
20 the Record of Decision has now been
21 signed.
22 RICHARD WEBER: Thank you.
23 PETE MANNINO: We will also place a
24 copy of that Record of Decision on the
25 website that Maeve has there and this is
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1
also on community updates and so you can
2
check there and before any construction
3
starts, we would also announce the start
4
of construction.
5
MICHAEL BASILE: Thank you for
6
taking the time. If you have any other
7
questions, we will be here for a while
8
and we hope you have a great remainder
9
of your summer and remember: The
10
deadline for public comments is August
11
28th. Have a great evening.
12
MAEVE WURTZ: Thanks, everyone.
13
(Proceedings concluded.)
14
15
16
17
18
19
20
21
22
23
24
25
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1
CERTIFICATION:
2
3
I hereby certify that the proceedings and
4
evidence are contained fully and accurately in the
5
notes taken by me on the above cause and that this
6
is a correct transcript of the same to the best of
7
my ability.
8
9
10
11
CARMEN A. NASCA
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: $2,414,000..acceptance
$2,414,000
18:4 20:9
$2,901,000
18 :16
$291,000
17 :14
$3,581,000
19:3
1 14:18,19
16:22
1.1 10:25
1,1,1 14:19
1.2 14:19
1,4-dioxane
14 :21
1,436 13:10
10 29:19
30:20
34 :16
41:25
100 32:13
44 :13
114 13:1
12 29:20
13 14:10
26:20
29:20
1306 46:18
145 13:10
15 26:20
150 44:13
1500 14:25
17 35:24
18 29:20
18M 35:24
1950 10:21
1970s 10:24
1980s 11:2
1981 7:7
23:2
1983 23:2
1985 7:14
1996 8:4
9:4 15:13
2 14:18,19,
24 17:5
20 23:6
30:20
200 32:12
44 :11
2000 14:16
2014 8:20
9:7
2015 9:21
10:1 12:21
13
15
2018
11
2020
11
2022
11
2023
11
28th
25
53
54
290
21
17 14:4
15
10:4
12
10:7
14,18
10 :12
19,21
10 :17
22,23
20 :12
15
9, 13
13
3:5
20
3 17:15
18:4 19:18
20:9 51:10
53:21
30 25:11
30:20
41:22
30-day 2:17
4:24
300 13:20
30th 54:17
34 28:10
4 18:5,15
31:22
40 13:19
14 :11
5 18:17
19:3
50 30:3,4,
5,11 35:3
50-foot
34 :23
50-something
34:2
8
80s 2 6:20
35 :22
83 23:3
9 34:16
90s 37:13
41:24 46:6
ability
44 :10
acceptance
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: accepting..attorney
19:7
accepting
20 :11
accessible
9:24
account 5 : 4
acting 11:16
action 5 : 7
16:8
activated
19:2
active 9:25
17 :3
activities
12:1 17:3
29:8
actual 32:2
add 34:8
35 :17
added 35:23
additional
8:23 17:10
address 2:24
4:18 5:22
20:19,20,
23 21:11
25:7 34:10
51: 4
addressed
37:11 51:6
addressing
22:5 37:8
adhesives
27 :23
adjoining
51:9
agenda 2:8,9
24 :25
agent 18:8
ahead 2 3:21
29:22 34:6
aiming 15:4
air 31:15
air-strippers
7 :17
air-stripping
7:25 19:2
Alcas 6:4,6,
11 8:7,18,
20,22 9:6
26:11
38:19
39:14
49:24
5 0:3,4,8,
18,25 51:7
alderman
22:8
Allegany
23:12
39:11
alternative
3:23 5:3
16:22,24
17:1,5,13,
15 18:4,5,
15, 17
19:3,17,18
20:8 22:20
53:23 54:5
alternatives
16:22 17:1
19:5 20:7
amended 2 7:4
amendment
8:21 15:15
amount 4 0:5
Anaerobic
9:8
analyzed
13:21
angle 53:2
annual 14:15
45 :13
annually
45:22
answers 2:21
apologies
48:2
applicable
19:10
Aquifer 8:2,
14 12:12
14:7 23:8
30:23
34 :22
35:17,18
36:1 42:10
area 6:6,8
8:10 9:14
11:8,9,11
12:20
13:6,7,8,
9,17,25
14:1,2,3
16:3 17:23
26:7 28:23
35:23
36:4,19
37:7,10,13
39:16 42:4
45:3 50:21
51:21,24
areas 6 : 4
8:5,12,16
11:10
12:25 14 :2
18:1,2
26:6,21
27:6,11
51:1
as semblymen
24 :17
assessment
4:3 15:12,
17,19 16:4
assessments
15:8
assessor
3:13
assuming
36:19
attorney
3:15
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: August.xall
August 2 0:12
25 :15
54 :13
automatically
2 :11
Avenue 4 3:5
46:18 50:7
52 : 9
avx 6:4,7,
8,15,16,23
7:2 8:7,19
9:9,15,16
10:4,20
11:4,12
22:3,10,18
24:3 29:24
37 :5
38 :21,24
39:2,13
43:7 44:14
49:22 50:7
53:11
aware 25:1
27:10 29:7
B
back 3:25
23:5 26:19
27:19 28:6
32:6 33:16
35:21 41:4
47:10,17
50:3,4
51:22
52 :10
backdoor
52:18
backdoors
38:23
background
3:19
backyard
46:8
balance 2 0:5
balancing
19:4,7
20:8
ball 4 4:1
ballpark
29:21
barrel 11:11
barrier 9:18
11:16
based 8:22
29:2 41:6,
13 54 :7
baseline
16:25
basically
29:17
44 :25
47 :23 49:9
50:4 52:10
Basile 2:1,2
21:5,18
24:9 53:5,
8 54:12
basis 2 0:1
began 37:13
begin 51:13
begun 51:12
bell 23:12
beneath 6:25
12 :3
big 47:10
bikes 4 3:14
binding 18:8
Bioremediation
9:8
bit 4:1 7:4
10:19 46:5
block 18:8,
12
blue 6:19
7:3 12:19
13:16
Bob 3 : 3
34:4,11,12
35:12,14
44:3,17
45:1,8,11
bodies 4 7:8
body 4 7:12
borings
14 :11
30:15
boundary
9:16
box 23:4
49:24
branch 3 : 6
breaks 5:19
bring 32:5
brings 10:17
Broadway 3 : 5
building 7 : 2
9:13,15,
23,24
10:4,10
11:4,14
12:4,16,
18,19
13:14,16
15:22
17:24
21:23
22:22
27:20 32:8
37 :16
52:21
buildings
52:23
built 52:6,7
53:1
buried 2 7:18
burnt 2 8:14
c
calculated
15:25
call 21:8
26:12
33:4,12
36:7 48:5
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: called..compliance
51: 9
characteri ze
19:25
40:12,23
called 7:16,
12:5
34 :21
42:16
22 35:18
check 32:11
40:10 47:7
53:17 54:8
canal 50:3,
chemical 9 : 2
cleaned
commentaries
5, 9,13,17
10:16 11:8
41:16
53 :25
52:3,5,8,
13:9 14:1
46:24
commentary
19,24
chemicals
Cleaners
2 :17
cancer 2 4:1,
14:17 18:9
6:20
comments
4
21:25
cleanup 3:22
5:1,5
capacitors
22:17 23:3
4:23 5:25
20:11,16,
10:22
27:6,18
8:9 10:10
18,20
44:19
11:24
25:8,13
captured
31:3
chief 3 : 6
16:19
26:2 54:2,
25:10,22
12,14
carbon 19:2
child 50:6
53:18
commercial
carcinogenic
chloride
clear 3 9:22
16:19
24 : 6
14 :21,25
close 54:13
community
care 53:10
chosen 5 : 9
closed 5 : 3
5:2,15
Carmen 21:12
CIS 14:18
19:6 25:1,
closer 51:22
9 27:5
case 2 0:21
ci ty 7:18
8:2,13
closes 25:16
39:22
casing 35:1
28:8 30:23
collect
community-
Cattaraugus
31:8 35:17
40:25
involving
3:4 34:14
36:1 39:18
collected
2 :3
ceased 10:5
42:10 43:4
14:8 18:24
compared
11:13
45:7,8,17
29:4 40:4
20:6
center 21:3
51:25
41: 7,13
comparing
clarification
48 :15
16:25 19:5
ceramic
33:19
51:23
10:22
complete
27:22 28:2
Clark 21:20
23:13
comfortable
41:12
48 :14
chance 4 6:24
clay 34:25
comment 4:24
completed
31:7 48:8
changed
clean 2:16
5:2,6
15:18
20 :17
25:16
complex 5:20
7:13 17 :21
compliance
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Huseby Global Litigation
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: complimentary.xost
19:10
complimentary
24:24
Components
6:17
composition
46:12
concentration
14 :13
concentrations
11:17
14 :23
16:18 17:7
conceptual
31:2
concern
14 :17
concerned
44 :15
concrete
11:15
15:21
17 :17
19:20
conditions
41:3
conduct 5:24
conducted
3:21 4:15
5:8 11:21,
22 14:16
16:5
conducts
15:8
confront
25:5
connect 7:20
considered
8:12 10:2
16:7
consistent
14 :14
constructed
5:9,10,11
31:5 49:4
cons tructi on
16:2 48:14
contact
15:10
16:17
32:23 33:3
contacting
32:16
contained
14 :11
containment
9:18,20
contaminant
4:5 12:7
14 :23
contaminants
5:13 12:3
14 :13
15:20,24
16:1,14,17
17:4,7
18:7,20,21
19:14
con tami na ted
6:25 15:11
17 :19
19:22 20:3
23:10,17,
18 35:21
36:19
39:17
contamination
4:13,18
5:22,24
7:6,7 8:13
9:3,10,22
10:3,9
11:25
13:1,23
18:3 27:1
29:5
36:12,24
37:3,17,24
38:7 39:8,
9,24 40:1,
7,8,13
41: 7
42 :23, 24
51:2,4,5
contaminations
11:18
context
26:15
continue
27 :12
continued
42:3
continues
29:10
contribution
42 :1
control 17:3
controls
7:23
cooling 19:1
Cooper 6:22
28:7 38:13
39:15
coordinate
42:20
coordinating
36:14
coordinator
2:3
copy 4 4:17
54:24
core 12:11
13:12,20
14 : 9
corner 11:6
14:3 21:24
23:13
corporation
6:12,13,17
correct 3 8:4
cost 17:13
18:4,15
19:3,16
2 0:9 46:4
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: counterparts..discharged
counterparts
24 :18
county 3 : 4
22 :10
33:16
34 :14
35:10
36:15
couple 25:25
30:18
cover 18:11
covered 37:9
crap 2 8:20
crawl 50:10
52 :15
creek 23:11
39:10
46:22
creeks 4 7:7
criteria
19:4,8
20:8
crusher 23:5
curious 4 7:9
49:17
current 31:2
41:2
Cut 6:12
cutlery 6:12
daily 2 4:3
data 2 7:13
29:3 40:3,
6 41:6
42 :13
48:10,15,
24 49:4
51:23
days 2 5:11
dca 14:19
dce 14:19
deal 2 2:15
dealing 4 0:6
dec 16:18
26:22
decide 53:10
decision
4:20 7:15
8:8 9:22
10:13
12:21
13:18
20:14
25:18,20
31:23 48:6
49:6 53:19
54 :15,16,
20,24
decision-
making 5 4:3
deep 3 4:17
49:19
define 12:2,
6
defined
12 :20
13 :17
DEGROFF
29:23
30:2,5,7,
12 32:3,
10,19,23
33:6,11,
21,25
35:10,13,
15 36:16,
24 37:25
40 :17
41:15,19,
22 43:1,3,
12, 22
44:2,12,23
45:25
46:15
51:25
52 :11, 20,
25 53:7,9,
13, 20
demolished
11:15
demolition
10:6 17:16
19:19
department
3:4 32:17,
22
depth 35:2
design 5 : 7
31:2,22,24
designated
9:5
designed
5:10 12:2
18 :11
detector
12 :10
determination
4 : 6
determine
15: 9
determined
15:16
develop
31:24
devices 7:25
dichloroethene
14:20
difference
34 :15
47 :13
dig 2 8:5
digging
28:19
29:14 41:4
49:19
direction
28:7 34:9
37 :18
director
34 :13
35:11
discharge
31:11
discharged
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Huseby Global Litigation
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: discovered..excavation
31:8 47:19
48 :13
discovered
7:6 9:11
discovery
7 :10
disposal
17
20
19
24
27
CO
¦>
1—1
o
29
8
distances
30:25
distributed
45:24
distributor
45:20
district
44 : 6
di tch 4 7 : 10,
17
documents
20:25
dots 12:25
drainage
18 :14
draw 2 8:19
30:23
driller
34 :20
drinking
34 :22
35:4,8,19
driven 15:19
Dry 6:19
dug 41:19
dump 2 8:8
dumped 2 8:11
38:23 50:8
dumps 2 8:22
46:23
dust 31:16
dying 2 3:25
24:3
E
Eamonn 3:16
earlier
26:25
42:11 53:2
early 10:23
26:19
eastern
43:7,18
ecological
16:4,6
edge 12:15
Edison 6:5,
21 8:7,16
effectively
8:1
effectiveness
19:12,15
efficient
5:25
elected
24:10,13
electronically
24 :14
elevated 4 : 7
11:17
elevation
29:18
eliminate
16:15
email 2 0:23
33:5
encountering
34 :16
end 3:23
20:22
29:11
43:7,18
53:17 54:1
enhanced
8:19 9:7
enlarged
37 : 9
ensure 31:16
ensuring
31:14
entering
31:19
entertain
21: 7
entire 6 : 9
39:16
environment
16:11 19:9
environmental
34 :13
epa 2:3 3:5
4:16,22
5:11,19
15:7,16
19:4 20:13
21:2 22:11
26:23
31:12
41:25
EPA's 3:22
19:17 26:4
29:11
53:22
error 2 6:3
established
16:12
estimation
37 :11
evaluated
26:22
evaluation
15:14,17
evening 2 : 1
evidence
29:4
excavated
14:4 17:20
19:24
excavation
8:18,20
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Huseby Global Litigation
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE
Public Meeting on 08/08/2023
UNIT 5
Index: exceedances..gas
9:10 14:5
17:15,18,
23 18:1
19:18,22
20:2 25:10
29:14,16
42:2
exceedances
42:5
12:3 29:9
excuse
50 : 8
existing
17 :17
19:20 31:4
expanded
37 : 6
expect 3 6:8
expense
43:21
explain 2:15
23:21
54 :19
explaining
2 :18
exposure
9:18 15:23
16:16
exposures
16:6
extension
7 :18
extensive
50:25
extent 4:12
facilities
26:23
facility
6:11,15
7:12 10:6,
21
fact 52:23
facts 4 8:19
familiar
50:16
faster 4 6:25
fastest 6 :1
feasibility
4:15 10 : 7
11:19,22
federal 8 : 3
24 :18
26:8,9,14
41:25
45:19
feel 35:6
41:11
feeling
33:11
feet 2 9:20
3 0:3,4,5,
11,18,20
32:12,13
34:2,17
44:11,14
fence 22:2
32 :13
field 2 : 5
fields 4 7:18
figure 6 : 9
12 :13
13 :12
17:23 35:3
50:19
51:20
figures
48:20
fill 17:22
19:25
47:24
filled
52:12,13
finalize 5 : 3
25:18
53:18
find 2 7:7
29:2,4
fine 4 9:1
fire 2 8:15
floor 17:17
19:21
flow 34:9
36:4
fluctuations
30:18
flushed
31:21
flyer 3 9:23
folks 3 :1
follow 2 7:12
29:10
footprint
7:1
forget 3 7:6
42 :14
formalizes
20:14
found 7 : 7
8:23 13:22
16:5 18:3
20:25 30:2
34:2
foundation
17 :18
19:21
fourth 2 6:7
free 35:6
front 2 : 9
41:5,8
frost 18:12
functioning
49:7
fund 4 4:10
45:2
funding 4 4:8
funds 41:25
gas 12:10,
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Huseby Global Litigation
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: general..in-depth
13,22 13:2
general 3:18
4:2 13:6,8
generally
36:4 37:4
generate
28:3
geographic
5:23
Gillibrand's
24 :19
give 2:12,
19 21:11
33:4
glues 2 7:24
goals 15:3
16:9
good 2 : 1
35:3 40:20
government
26:8,9,14
47 : 4
graders
34 :23
green 6:13,
18
grey 14:6
Grossman
50:7 52:9
ground 6 : 3
22 :23
23:4,7,16
36:18
38:25
39:11
44:24
groundwater
7:24 14:15
16:15 27:1
29:3 30:16
33:20
34:8,9
36:3,9,12,
18, 23
39:24
42:3,23
46:20
51:5,12
groundwater-
monitored
42 : 6
groups 4 2:13
guys 50:12
H
halfway 4 3:6
handle 10:9
hands 22:16
happening
33:8 42:9
hard 12:24
Haskell
23:11
39:10
hate 2 4:4
hazard 31:17
hazardous
27:23 28:1
29:5
hazards 2 8:3
head 2 8:24
48:24
health 3:4,
13 16:10
19:9 28:3
32 :16,21
34 :13
35:11
hearing 5:18
heat 18:19,
21
held 2 4:23
hell 23:12
helpful
50:22
high 15:19
higher 22:13
36:21
highest
12 :25
13:3,10,22
18 :2
highlighted
12 :15
history 7 : 5
10:19
27 :15
43:10
hole 31:1
49:19
Horton's
27:20
house 2 3:13,
15, 18
39:12
human 16:9,
10, 16 19:9
hydraulic
9:19 48:3,
7
hydrogeology
12: 6
idea 35:3
identified
8:5 26:24
27:5 51:1
identify
21:9
impacts 3 6:2
implementabi1i
ty 19:16
important
5 :16
imported
17 :22
improving
47 :15
in-depth
4 :11
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Huseby Global Litigation
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-------
OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: in-situ..live
in-situ 9 : 1
10:16
18:5,17
51:3,11
including
24:12,16
industrial
16:3
industry
27 :25
influence
34:24 35:5
influences
36:9
information
24:24
27 :12
ingestion
15:25
inhalation
16:1
initial 4:4
initiation
44:5
inside 4 5:6
installation
7 :16
installed
18 :23
48:4,7
installing
17 :10
institutional
7:23
intended
49:8
interim 10:2
introduce
3:1
introduced
3:11
investigation
4:4,10,11,
14 7:5
11:20 12:1
29:12
investigations
3:20 12:9
involve
17:6,10,16
18:6,11,18
19:19
involved
35:8
involvement
5 :16
ionization
12 :10
issue 5 4:15
issued 8:4,
21
J
j ob 4 8:22
K
kavx 6:17
11:21,23
26:10
29:15
30:10,21
31:5 36:3,
6,8,9 37:3
40:7 41:3
48:4,10
kids 50:9
52 :15
kind 30:24
47 :25
50:20
51:20,22
53:1
kinds 50:8
kitchen
28 :12
Kivowitz
3:14
knives 50:11
52 :16
knowing
41:12
46:11
Kyocera 6:16
L
labs 4 5:3
larger 5:19
late 11:1
37 :13
41:24
laws 4 2:21
layers 3 4:25
leaked 2 3:8
38:25
leave 2 0:21
46:3
leaving
31:19
left 11:15
14:21 15:6
22:2
legend 12:24
legislator
22 : 9
level 4 : 6
29:24
levels 5:13
13:3,10,22
15:4,20
Library 21:2
limit 7:23
list 2:11
4:8,9
listed 4 4:18
listing
24 :13
literature
36:17
live 4 5:6
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE
Public Meeting on 08/08/2023
UNIT 5
Index: lived..meetings
46:18 52:9 low 5:13
lived 50:6
52 : 8
local 32:16
47:3,4
located 6:25
location
12:2 26:17
locations
11:3
12:14,23
13:2,5,19
27:9 29:6
long 2 7:15
49:10
long-term
17:5,12
19:11
longer 5:14
8:25
Loohn's 6:5,
19 8:7,17
26:7 38:16
39:16
41:16,18
42 :10
looked 2 8:25
29:1
lot 15:5
23:24 24:2
27 :19
30:14,16
34 :17 46:6
lower 15:6
30:12
M
machine 11:7
13:6,24
made 4 5:22
47 :13
Maeve 2:13
3:7,8,9
21:6 25:7
26:24
32:9,15,
21,25 33:7
51:15
53:14,16,
22 54:5,25
magnitude
30:19
mailing 2:11
maintains
5:12
maintenance
11:7 13:7,
25 49:11
make 2:19
31:10
33:15 35:9
41:1,10
4 9:6
makes 2 3:9
making 3 : 2
managed 31:1
management
31:20
manager 2:13
3:8
Mannino
25:24
27:21
28 : 9,
30:1,
9, 14
33:14
34
36
38
14
39
40
41
6
22
lr
17
4,
19
10
20, 23
43:2,
24
46
47
48
49
50
51
53
24
23
45
10
2,
2,
2,
1,
17
12
54
3:6
13, 21
4,6,
, 23
35:16
37:2
11,
, 20
21
, 22
,18,
9,20,
: 16
,16
16
23
16,20
16
52 : 4
,15,
: 11,
manufacturing
9:13,15,
23,25
10:5,20
11:4,13
12:4,16,
18,19
13:15
15:22 37:5
map 51:25
material
17:21,22
19:24
46:13
matter 52:22
maximum
14 :22
mayor 2 2:7
24 :15
Mazziotta
3:13
Mcgraw 6:5,
21 8:7,16
26:11
means 2 9:10
39:11
meant 33:24
measures
31:18
meet 4 5:18
meeting 8 : 3
10:14,15
24:22,25
25:2 27:3
50:19,24
51:19
54 :10
meetings
24:20,21
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE
Public Meeting on 08/08/2023
UNIT 5
Index: meets..O!ean's
meets 31:11
members 2 7:5
met 31:15
methods 8 : 9
12:8
MICHAEL 2 : 1
21:5,18
24:9 53:5,
8 54:12
middle 6:15
migrate
18 :10
migration
16:14
Mike 2 : 2
3:10
million
13 :11
14:24,25
mind 2 7:21
33:18 34:4
minimums
35:1
mobi1i ty
19:13
mobilize
18 :19
modifications
54 : 7
Moeller 3:15
money 4 6:5
monitor 4 2:3
49:4,5
monitoring
17:5,6,11,
12, 13
30:16
31:16
48 :15
month 4 2:9
months
51:16,17
move 18:10,
19, 22
moves 4 6:25
moving 4 9:11
mud 4 8:1
municipal
7:8,17
N
names
28:22
national
4:8,9
naturally
17:8
nearby 7 : 8
31:17
needed 5:14
35:9 37:10
neighbors
22 :10
nice 4 0:17
Nick 3:12
no-action
16:23,24
norm 2 9:23
30:2,5,7,
12 32:3,
10,19,23
33:6,11,
21,25
35:10,13,
15 36:16,
24 37:25
40 :17
41:15,19,
22 43:1,3,
12, 22
44:2,12,23
45:25
46:15
51:25
52 :11, 20,
25 53:7,9,
13, 20
north 12:17
13:14 36:5
37 :15
40 :14
northern
40:10
notable 14:2
nothing's
33:7
notification
25:9,21
notifications
42:16,22
notify 2 2:24
nowadays
35:2
Number 53:21
O'NEILL 3:16
03 4 9:24
objectives
16:9,19
occurring
17 : 9
off-site
17 :19
19:23
office 2 4:20
officials
24 :11,13
offline
51:19
Olean 2:5,6
6:1 7:19
10:20
21:2,20
22:4,5,7,
13 23:11
26:17,18
29:12
39:10
46:19
Olean's 31:8
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE
Public Meeting on 08/08/2023
UNIT 5
Index: online..Pete
online 2 0:25
open 4:25
opened 10:21
opens 4:24
operable
5:21 6:2
9:5 37:21
51:10
operates
5:11 48:17
operating
49:7
operation
49:5,10
operations
7:12 10:5
11:13
47:19
opportunity
2:12,19
options 3:22
10 :11
orange 6:14
order 7:13,
20 10:8
12:6 30:19
organic
46:12
47 :25
orient 12:14
original
15:13
26:20
37 :11
42 :15
oui 6 :2
OU2 6:3,13,
18 8:4
9:17 15:13
27:4 48:6
OU3 6:5,14
9:5
OU4 6:6,18
10:12
OU5 4:22
6:7,18,23
10:18
12:2,9
16:7,13
outline
12:20
13:14,16
17:24
outlined
14 : 6
oversee
26:10
overseeing
26:4
overseen
26:13
oversight
23:1,22,23
26:2,4,15
31:13
owned 6:12,
16,21
oxidation
9:2 10:17
parcel 6 : 6
51:10
parcels 51:9
part 14:4
15:12,14
22 :14
37 :10,21
42:15 48:5
parties
26:5,13
parts 13:11
14 :24,25
past 2 9:2
pathways
12 : 7
Paul 21:19
pay 4 5:15
pce 10:25
14:18 23:6
people 22:11
23:25 24 :2
percent
41:25
performance
32 :2
performed
15:12,14
42:2
performing
31:13
period 4:24
5:2,6
20 :17
25:16
53:17
periodic
45:20
periodically
31:10
42 :12
permanence
19:12
permanently
20:2
personally
24:2
pertains
26:4 39:23
Pete 3 : 6
25:24
27:21
28:9,13,21
30:1,4,6,
9, 14
33:14,23
34:6 35:16
36:22 37:2
38:1,11,
14,17,20
39:4,21
40:19,22
41:10,18,
20, 23
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE
Public Meeting on 08/08/2023
UNIT 5
Index: phase..property
43
24
46
47
48
49
50
51
53
24
2,9,20,
45:16
10, 16
2,16
2, 23
2,16,20
1,16
17 52
15
11
4
12
54
13, 23
phase 2:15
4:21 5:8
19:1 31:22
49:9,12,13
photo 12:9
picked 9:17
piece 2 6:2
ping-ponged
33:16
pink 12:25
17:25 32:7
piped 18:24
place 31:21
39:2 43:12
44:21
54 :23
places 13:23
plan 2:5,15
4:23 10:15
11:24
20 :12
25:10,12,
13, 21
53:18
planning
4:20
plant 9:25
23:5 28:6
31:5 37:5
38:22
39:14
43:16
44:16
47:19
48 :12
plenty 45:3
point !
25:15
26
34
41
51
16
10
11
14
points
26:1
38:4
: 14
19
37 :8
43: 1
. 21
12:22
28 :21
popped 13:3
pose 16:8
31:17
position
40:24
potential
12:7 14
17
15
16
26
27
9
16,21
21
6,10,16
potentially
26:12
27 :25
pour 23:3
powder 11:11
Power 6:22
Powerpoint
2 :14
practices
31:20
predates
26:19
preferred
3:22 19:17
53:23 54:4
preliminary
4:3
prepare
20:13
presentation
2:14,20
11:5 20:24
21:14
44 :18
presentations
3:2
presented
54 :5
press-release
54 :18
pretty 52:20
previous
13:5
previously
8:24 9:4,
11 28:25
prior 2 2:21
priority
4:8,9
private 7:9,
22
process 3:18
4:1 5:15
10:8 54:3
processes
17 : 9
produced
10:22
producing
35:19
profile
12 :12 14:7
program
17 :12
progress
8:11
project 2:13
3:7 49:12
promote
18:13
properties
16:20 48:5
property
6:7,8 7:2
9:16 29:15
30:10,21
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: proposed..reduce
31:6 36:6,
10 37:3
40:8,11,
15, 16
41:3,14
42:7,10,
18,25 43:7
44:8,13,14
50:18
51:1,8
proposed
2:4,15
4:20,23
10:15
11:24
17:23,25
20:12 25:9
protect 16:9
18 :13
protection
19:8
provide
27 :11
prp 31:13
42 :12
prps 2 6:13
public 2:17
4:24 5:6
7:21 20:16
21:2,13
25:16 27:3
53:17,25
54:8,19
published
7:15 10:12
25:20
pull 50:19
pulled 48:11
pump 8:17
pumped 8 :2
pumping 9:19
punch 4 3:16
purpose
23:24
purview 4 7:7
put 21:12
23:6 28:16
29:25 46:4
47:10,13,
21
quality 3 4:8
42:4 45:13
quarterly
45:21
question
22:19
24 :10
34 :12
49:22 53:6
questions
2:20 3:24
5:1,5
21:4,7,13,
17,21 24:7
26:1 53:4
radiation
18 :18
railroad
37 :20, 23
46:20
47:23 50:5
52:1,7
rain 4 6:6
rainbows
46:7
ran 50:3,4
range 13:10
14 :23
ranked 4 : 9
raos 16:12
reach 32:25
35:6
Reading 52:7
real 38:9
realtor
42:20
rear 41:5
receive
20:18
24 :23, 24
42 :13
45 :18
received 5 : 5
20:16
receiving
4:25 11:8
13:8 14:1
48 : 9
recognize
40 :23
41:2,14
recommend
32:16
re commenda ti on
s 35: 9
re commendi ng
2:16
reconstruction
7:2
record 4:20
5:4 7:14
8:8 10:13
12:21
13:18
20:13
21:3,13
31:23 48:6
53:19
54:15,16,
20,24
recorded
9:21 25:19
records
20:15 27:8
recovery
8:19
red 6:18
12:25
reduce 16:13
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: reduced..running
reduced 17:8
reduction
19:12
reel 11:10
refer 33:13
regular
45 :12
regulations
16:23
related 4 0:7
46:13
relates
50:23
release
53:19
released
25 :12
releases
4:22 27 :8
releasing
11:23
relevant
19:10
remedial
2:13 3:7
4:10,14
5:7 16:8
31:22
remediate
15:5
remediation
15:3 17:2,
3 20:4
remedy 5:9,
11, 12
8 :16,24
9:1,6,17
10:1,2,15
14:5 20:15
54 : 6
remember
13:4 28:23
remind 33:6
removal
17 :16
19:20
remove 17:4
removes 2 0:3
removi ng
50 :14
report 4 5:13
representative
33:17
43:25 44:4
representative
s 24:16,21
47 : 4
request 32:3
require
16:24
required 8 : 8
45:11,18
requirements
19:11
31:11
residences
37 :1
residential
7 : 9
residents
7:13,20
31:17
resistors
10:23
respect 2 0:7
26:16 27:4
29:13
40:1,12
42 :16,22
48 :10
responsible
26:5,13
restoration
17 :21
19:25
restrict
7:24
result 7:10
results
15:7,16
review
25:13,17
54 :14
Richard
21:16,19
25:3,23
27 :17
28:4,10,14
38:8,12,
15,18,21
39:6 40:20
41:9 45:5,
9,14 54:9,
22
rid 23:7
Ring 3 : 3
34:4,11,12
35:12,14,
15 44 : 3, 17
45:1,8,11
risk 3:13
15:8,11,
13, 19
16:4,8
risks 15:9,
23
river 2 3:12
36:7 39:11
road 3 9:10
43:13
rod 7:22
8:4,20
9:7,17
15:13,15
27 : 4
rolling 44:1
rollout 2 :5
roughly
43:17
run 4 3:5
running 8:15
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: safety..slab
S
safety 31:18
sample
14:10,12
40:25
41:1,13
45 : 4
sampled
31:10
37 :19
42 :12
samples
13:13,21
14:7,10,
12, 14 38 : 6
sampling
12:8,11,12
13:20
14:9,15
36:13
37:21 42:8
45:21
47:14,15
50:25
sandy 34:3
saturated
38 :2
scheduled
51:13,15
Schumer
24 :19
scope 30:22
screen 2 0:21
32:5
screening
12:10,11,
14,23 13:2
sections
5:23
sediment
16:7
selected
8:24 9:2,7
10:16
54:4,6
selection
20:1,14
sell 2 3:15
42:17,18
semi 14:15
semi-annual
45:22
senator
24 :17,19
send 2 4:14,
15, 21
Seneca 21:24
23:14 43:5
46:18
sense 2 3:9
44:5
separation
19:1
September
54 :17
service 7:11
shaded 37:12
share 2 9:8
48 :25
Sharon 3:14
Shawmut 52:1
She'll 2:14,
18
shop 11:7
13 : 7,24
short 2 0:4
short-term
19:15
shortly
10:25
show 37:23
45:23
50:20
showed 38:7
shown 37:12
shows 32:6
46:3
shut 7:11
side 37:22
40 :11
52:2,6,8
sign 2:10
signed
54 :17,21
significant
30:24 40:5
signing 2:10
similar
13:23
similarly
9:9 13:13,
22
simple 2 : 8
sink 2 8:12
sir 21:15
53:8
site 2:6
3:12,14,
19,20 4:5,
7,8,13,19
6:10,23
7:4 8:6
9:6,9
14 :18
16:16
20:24
21:22
24 :12 27:1
29:13
36:2,12
si te' s 21:1
site-sampling
15:7
site-specific
16:11
sites 5:20
21:21
24 :12
slab 11:15
15:21
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: slapped..suggest
17 :17
19:20
slapped
22 :15
slide 3:25
13:5
snapshot
27 :14
soil 6:25
11:18
12:10,11,
13, 22
13:1,13,21
14 :22
15:2,11,
20,24
16:7,14,
17,19
17:4,8,19
18:5,20,22
19:23,24
20:3 29:3,
14 30:15
32:4 33:20
36:25
37:2,23
39:24
40:1,6,8,
13, 25
41:4,13
42:2,24
51:2,6
soils 6 : 8
solid 18:8
solidification
18 : 6
solidified
18:7
solve 4 7:6
source 6:4,7
8:5,10,12,
15 12:20
13:17
26:6,7,21
27:6,11
sources 8:13
26:25
36:11
south 6 : 6
9:14,17
36:5 37:4
40:9
southeast
11:6 14:3
southerly
37 :17
southern
37 :22 52:6
speak 4 7:3
specific
29:7 40:12
specifically
9:12 41:12
specifications
31:25
spell 2:24
21:10
spots 32:7
Stan 4 5:6
stand 2:23
standards
8:3 31:14
45:19
Stanley
46:17
47:9,21
48 :18
49:1,14,
17,21 50:2
52:5,13,22
53:3
start 4:10
28 :18
44 :22
54 :10
started 7:12
10:7
starting
25:11
starts 4 : 2
state 2:23
3:16 8:3
16:18 19:6
24 :16,17
26:22
42 :1,21
44:7 45:2,
19
State's
29:12
statement
39:22
s tenographer
2:22,25
21:12
22 :12
steps 2 0:10
Steve 3:15
stopped 4 3:6
storage
11:9,10,11
13:9 14:1
storm 18:13
straight
44:16
street
21:20,24
36:10
structure
37 : 9
studies 8:23
study 4:15
10:8
11:19,20
stuff 4 3:16
50:9,10
52:16,18
substances
28:1
substantially
15:18
successful
9:1 10:4
suggest
36:13
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: summer..tracks
summer 10:14
Superfund
3:18 4:1
5:20 6:10
16:23
24 :12
29:13
supervisor
22:8 24:15
supply 7:8,
21 35:20,
22
supports
17 :18
19:21
surface
18:24,25
34:18,19,
24 35:6
switched
10:24
system 9:20
31:9 48:16
49:3,7
Systems 6:22
T
table 14:22
15:1,6
29:17
30:8,10
38 :3
tad 30:12
36:21
takes 2 0:15
taking 2 : 7
talk 4 3:24
44:3
51:18,20
talking 3:17
6:24 21:22
38:10
41:15
42 :11
46:8,19
47:16 48:3
50:21
tap 4 5:18
tape 11:10
TCA 11:1
14 :19
tce 10:23
14:18 15 : 1
24:5 38:9
39:3,12
team 3:5,12
tear 2 2:22,
23
technologies
51:3
technology
4 :17
telling
23:14
term 4 9:10
test 10:8
44:20
tested 32:4
33:20
44:24
50:13
testing 18:3
32:18 35:7
45:2,12,14
50:12
tests 4 6:1
thereabout
29:20
thermal
18 :17
thing 22:16,
25 23:23
28:17,18
38 : 9
things 33:9
35:1
thinking
50:12
thought 9 : 4
throwing
29:21
tile 22:13
26:17,18
27:18,22,
25 28:2
38 :22
39:14
Tim 2 7:20
time 2:7,25
3:1,24
9:21 10:1,
3 21:3,6,
14 42:19
46:5 48:17
53:2
timeframe
20:4 41:21
timeframes
37 : 7
today 2 7:14
29:11
told 2 2:20
38:8
toluene
14:20
tonight 2 : 8
3:10,11,17
5:18 6:24
20:18
top 2 8:23
48:24
52:24
tore 21:23
totality
54 :1
touched 2 2:3
town 7:19
22:4,8
43:11,25
44:3
toxicity
19:13
tracks
37:20,23
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OLEAN WELL FIELD SUPERFUND SITE: OPERABLE
Public Meeting on 08/08/2023
UNIT 5
Index: tradeoffs..wells
46:21
47 :11,23
50:5
tradeoffs
20: 6
trans 14:19
transport
12:8
transportation
17 :20
19:23
trap 18:9
treat 8:17
treatability
11:20
treated
18:12,25
19:1 48:11
treatment
7:11 18:14
19:14
31:4,9
35:23
48 :12
51:3,11
trench 9:19
47 :22
48:4,7
trucks 31:19
43:13
type 4:4,12
types 4:17
5:22
typically
27 :22
35:18 49:2
u
underneath
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36:8
18
21
23
39
49
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25
4, 17
12
25
understand
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24:7 25:4
40:22
41:2,9
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undeveloped
9 :14
unit 9 :5
37 :22
51:10
units 5:21
6:2
unload 4 3:13
unsaturated
17 :19
19:22
38:2,6
update 2 5:1
39:23
upgradient
V
vacuum 8:18
valid 41:11
verbal 2 0:17
vertical
12:12 14:7
view
25 :15
vinyl 14:20,
24
voc 16:14
vocs 4 2:5
volume 19:13
w
wait 4 3:15
45:25
53:24
walked 4 9:18
wanted 4 4:9
waste 2 7:23
29:5
watched
49:18
water 6 : 3
7 :11,13,21
8:1 14:9,
11 18:14
23 :17
29:17
30:2,7,10,
23,25 31:3
33:22
34:2,15,
19,21,22,
24 35:4,8,
19,20 38:3
44:6,24
45:13,14,
17,20
46:1,7,25
47:8,12,18
48 :11
waterline
7:19 43:4,
11 45:10
Weber 21:16,
19 25:3,23
27 :17
28:4,10,14
38:8,12,
15.18.21
39:6 40:20
41:9 45:5,
9,14 54:9,
22
webpage 21:1
website
54 :25
weeded 22:1
week 2 5:12
well-field
29:13
wells 7:8,9,
10.17.22
17 :11
www.huseby.com
Huseby Global Litigation
800-333-2082
-------
OLEAN WELL FIELD SUPERFUND SITE: OPERABLE UNIT 5
Public Meeting on 08/08/2023 Index: Wesley..zooming
18 :23
30:16
35:20,22
42 : 6
Wesley
46:17,18
47:9,21
48 :18
49:1,14,
17,21 50:2
52:5,13,22
53:3
wondering
48:19
49:15
wooded 9:14
work 8:22
26:5,11
29:10
30:22
31:6,9,14,
25 32:2
33:14 48:8
49:9 51:11
workers 16:2
31:18
working 8 : 1
world 2 4:6
worst 2 4:5
32 : 6
worth 50:14
write 2 0:22
written
20:11,19
wrong 3 9:6 zooming 6:22
Wurtz 2:13
3:7,9 25:7
32:9,15,
21,25 33:7
51:15
53:14,16,
22
x
xylene 14:20
Y
yard 46:13
year 2 4:23
31:7 48:9
49:5
years 2 3:6
28:11,15,
17 29:25
40:5 41:22
yellow 12:15
17:25 32:8
York 2 : 6
3:16 16:18
21:20 22:6
26:22
29:11
42:1,21
46:19
z
zone 18:15
3 8:2,3,6
www.huseby.com
Huseby Global Litigation
800-333-2082
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ATTACHMENT D
WRITTEN COMMENTS
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From: Patrick Vecchio
Date: July 27, 2023 at 9:36:36 PM EDT
To: "Basile, Michael"
Subject: Olean well field Superfund
Good evening, Mike.
In looking at the EPA website about the Olean Well Field Superfund site, I found this sentence in the
"site background":
The Allegheny River and two of its tributaries, the Olean and Haskell creeks, flow
through the site.
The map on the website, though, does not show the Haskell Creek within the boundaries of OU1. This is
of interest to me because I live between the map's eastern boundary for OU1 and the Haskell Creek.
Haskell Creek is perhaps a quarter mile from my house.
It seems to me that either the sentence in the site background or the map boundary is incorrect, which
leads me to ask this question: Is it possible my private water well is drawing water that has been
polluted by the PRPs? If the answer is "yes," then what should I do? The well is my sole source of water.
Thank you for your attention to my question.
Patrick Vecchio
FOIA Exemption 6
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