AMENDMENT TO THE RECORD OF DECISION
Tri-Cities Barrel Superfund Site Town of Fenton, Broome County, New York
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United States Environmental Protection Agency Region II
New York, New York September 2011
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Tri-Cities Barrel Superfund Site Town of Fenton, Broome County, NewYotk>1J0XM9N 'A^UnOO 9UJ00Ja 'U0p9d p UMOl
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Superfund Site Identification Number: NYD980509285' Operable Unit 1
STATEMENT OF BASIS AND PURPOSE'
This amendment to the Record ofDecision (ROD Amendment) documents the U.S. Environmental Protection Agency's (EPA's) selection of a modified groundwater remedy for the Tri-Cities Barrel Superfund site (Site), which is chosen in accordance vvith the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. §9601, ef seq., and the National Oil and Hazardous Substances Pollution Contingency Plan, 40 CFR Part 300.• This decision document explains the factual and legal basis for selecting the modified remedy
(AI X!pu9ddv 99s) Apguiaj pg^pouj p9p9|9s B^\ qiiM sjnouoo }\ puB '{i)lZ9Q§for the Site. The attached index (see Appendix III) identifies the items that comprise the
'Wl-Sl U0IP9S Vn0d30 ^\\^ 90UBPJOOOB uj Ap9LU9J p9y!pouj p9uuB|d 9L|; UO p9i|nsuoo Administrative Record upon which the selection of the modified groundwater remedy is
SBM (03aSAN) U0JJBAJ9SU00 IBP9UJU0JJAU3 p lU9UJ}JBd9a ajB^g >|JOA M9N 9L|1 based. .p9SBq •The New York State Department of Environmental Conservation (NYSDEC) was
SI Ap9UJ9J J9iBMpunojB pajijpouj 9L|V P U0!P9|9S 9L|} qojqM uodn pjooay 9A!}BJiS!U!Ujpv consulted on the planned modified remedy in accordance with CERCLA S'ection 121 (f),
9LjJ 9S!JdUJ00 JBqj SUJ9}! 9L|J S9y!JU9P! (ill X|pU9ddV 99S) X9pU| p9L|0BWB 9L]1 Q^S Q^ JOj 42 U.S.C. §9621 (f), and it concurs with the selected modified remedy (see Appendix IV)..
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Actual or threatened releases of hazardous substances from the Site, if not addressed by . Ap9UJ9J J9jBMpunoj6 poyipouj B p uo!p9|9S (s,vd3) s.Aou9Bv ud|p9pjcJ |B;U9UJUOJ!AU3
implementing the action selected in this'ROD Amendment, may present an imminent and Sn ^m si.u9ujnoop (iu9Ujpu9UJV aoy) uo!S!09a P pJ009y 9qvo| ju9Ujpu9UJB sjqi
substantial endangerment to public health, welfare, or the environment
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DESCRIPTION OF THE SELECTED MODIFIED REMEDY
I \\un 9|qBJ9do A ROD signed on March 31,2000 selected a remedy for the Site, which called for, among
98Z609086aAN :-"8qLunN uo|;Boy|}U9p| 9;is puniJ9dns other things, the excavation and off-Site treatment/disposal of contaminated soil and sediment, and extraction and on-Site treatment of the contaminated groundwater. This ROD Amendment changes the groundwater component of the remedy. This action 8J!9 a^\ JOj pauueid Apaiuaj |Buy Qm sjuasajdaj •
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represents the final remedy planned for the Site.
DECLARATION FOR THE AMENDMENT TO THE RECORD OF DECISION NOIiVOOn QNV 3IAIVN 3ilS N0isi03a do ayoo3y 3Hi o i iN3iAiaN3iAiv 3Hi yod Noiivyvno3a
SITE NAME AND LOCATION
531184
The major components selected modified groundwater remedy include the following: The major components of theof the selected modified groundwater remedy include. the following:
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•• Monitored natural attenuation of groundwater ^ throughout the Site,Monitored natural attenuation of groundwater contaminationcontamination1 throughout the Site, except in the "MW-19 Area'"except in the "MW-19 Area;"
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Ii i '. . •• Long-term groundwater monitoringmonitoring to verify that the level and extent ofLong-term groundwater to verify that the level and extent of
groundwater contaminants are declining within the timeframe projected and thatgroundwater contaminants are declining within the timeframe projected and that conditions are protective of human health and the environment; and,conditions are protective of human health and the environment; and,
Periodic monitoring of nearby residential private wells to ensure the effectiveness•• Periodic monitoring of nearby residential private wells to ensure the effectiveness of the selected remedy.of th~ selected remedy.
In addition, biodegradation parameters {e.g., dissolved oxygen, nitrate, sulfate, methane,In addition, biodegradation parameters (e.g., dissolved oxygen, nitrate, sulfate,methane, ethene,alkalinity, potential, temperature, chloride,ethane,ethane, ethene, alkalinity, redoxredox potential, pH,pH, temperature, conductivity,conductivity, chloride,
sulfide, iron, and organic carbon) will be used to assess the progress of the~ulfide, iron, and totaltotal organic carbon) will be used to assess the progress of the t1egradation process.degradation process.,!
MW-19 Area groundwater is located in an approximately 120 feet (ft) by 80 ft by 30 ft deepMW-19 Area groundwater is located in an approximately 120 feet (ft) by 80 ft by 30 ftdeep technical impracticable zone and is depicted on Figures and of the ROD Amendment,technical impracticable zone and is depicted on Figures 22 and 33 of the ROD Amendment. the chemical-specific applicable or relevant and appropriate requirements are waived inThe chemical-specific applicable'or relevant and appropriate requirements are waived in thisthjs zone for tetrachloroethene, 1,1,1-trichloroethane, 1,1-dichloroethane,zone for tetrachloroethene, 1,1,1-trichloroethane, t,1-dichloroethane, cis-1,2-dichloroethene, and vinyl chloride. .cis-1 ,2-dichloroethene, and vinyl chloride. :. . i~i ; ' ' • •
Under this remedy, the installation and use of groundwater wells at the Site for drinking water purposes are prohibited by an existing deed restriction.Water purposes are prohibited by an existing deed restriction. Also under this remedy Under this remedy, the installation and use of groundwater wells at the Site for drinking
Also under this remedy h,odification, the groundwater cleanup goals remain the same as in the 2000 ROD,modification, the groundwater cleanup goals remain the same as in the 2000 ROD,II
~xcept to the extenttheyare waived.except to the extent they are waived. :,:
The SiteThe Site is zoned residential and is currently vacant.is zoned residential and is currently vacant. If, in the future, structures areIf, in the future, structures are proposed toto be builtbuilt on thethe property, thenthen aa soil intrusionintrusion and,be property, soil vapor evaluationevaluation and,proposed on vapor potentially, vapor mitigation maypotentially, vapor mitigation may be needed, or alternatively just soil vapor mitigation.be needed, or alternatively just soil vapor mitigation. AsAs
governmental institutional control, the Office of the Town of Fenton Building Inspectoraa governmental institutional control, the Office of the Town of Fenton Building Inspector has acknowledgedhas acknowledged toto EPA that such office. will notify any person seeking to buildEPA that such office will notify any person seeking to build residential structures at the Site of soil vapor concerns relating to the property, andresidential structures at the Site of soil vapor concerns relating to the property, and specifically of the need for soil vapor evaluation and potentially, soil vapor mitigation~pecifically of the need for aa soil vapor evaluation and potentially, soil vapor mitigation systems or, alternatively just soil vapor mitigation.~ystems or, alternatively justsoil vapor mitigation.
The soil and sediment component of the remedy selected in the 2000 ROD is not beingThe soil and sediment component of the remedy selected in the 2000 ROD is not being modified by this ROD Amendment.·· The soil and sediment component of the remedyhiodified by this ROD Amendment. The soil and sediment component of the remedy
Natural attenuation describes aa variety of in-situ processes, which under favorable conditions, actNatural attenuation describes variety of in-situ processes, which under favorable conditions, act without human intervention to reduce the mass, toxicity, mobility, volume, or concentration ofwithout human intervention to reduce the mass, toxicity, mobility, volume, or concentration of contaminants in groundwater. Groundwater monitoring would be conducted to assess the progresscontaminants in groundwater. Groundwater monitoring would be conducted to assess the progress of the natural attenuation.of the natural attenuation.
531185
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was completed in . Under this action, approximately 75,000 tons of contaminatedwas completed in 20032003.. Under this action, approximately 75,000 tons of contaminated soil and sediment were excavated and disposed off-Site. ..soil and sediment were excavated and disposed off-Site.
DECLARATION OF STATUTORY DETERMINATIONS·DECLARATION OF STATUTORY DETERMINATIONS
The selected modified groundwater remedy meets the requirements for remedial actions set forth in CERGLA Section 121, 42 U.S.C. because it: 1) is pro,tectiveofhuman The selected modified groundwater remedy meets the requirements for remedial actions set forth inCERCLASection121, 42 U.S.C. §9621§9621 ,, because it: 1) is protective of human health and the environment; 2) meets level or standard of control of the hazardoushealth and the environment; 2) meets aa level or standard of control. of the hazardous . substances, pollutants and contaminants, which at least attains the legally orsubstances, pollutants and contaminants, which at least attains the legally applicableapplicable or relevant and appropriate requirements under federal and state laws, except where therelevant and appropriate requirements under federal and state laws, except where the ARAR is waived; 3) is cost effective; and 4) provides long-term effectiveness.ARAR is waived; 3) is cost effective; and 4) provides long-term effectiveness.
Because the selected modified groundwater· remedy will result in contaminants remainingBecause the selected modified groundwater remedy will result in contaminants remaining on-Site that exceed acceptable health-based levels, CERCLA requires that the Site be reviewed every five years. If justified·If justified byby the review,review, additional actionsactions maymay bebe on-Site that exceed acceptable health-based levels, CERCLA requires that the Site be reviewed every five years. the additional implemented.implemented.
ROD DATA CERTIFICATION CHECKLISTROD DATA CERTIFICATION CHECKLIST
The ROD Amendment contains the modified .groundwater remedy selection information noted below.noted below. More details may be found in the Administrative Record file for this Site. The ROD Amendment contains the modified groundwater remedy selection information
More details may be found in the Administrative Record file for this Site.
of concern concentrations ROD·•• ContaminantsContaminants of concern. andand their respective. concentrations. (seerespective (seetheir ROD Amendment, pages 6-7);Amendment, pages 6-7);
Current and reasonably-anticipated future land use assumptions and current and•• Current and reasonably-anticipated future land use assumptions and current and potential future uses of groundwater used in the baseline risk assessment andpotential future uses of groundwater used in the baseline risk assessment and ROD Amendment (see ROD Amendment, pages 8-9);ROD Amendment (see ROD Amendment, pages 8-9);
•• Baseline risk represented by the contaminants of concern (see ROD Amendment,Baseline risk represented by the contaminants of concern (see ROD Amendment, pages 9-12);pages 9-12);
•• Cleanup levels established for contaminants of concern and the basis for theseCleanup levels established for contaminants of concern and the basis for these levels (see ROD Arnendment, Appendix II, Table 10);levels (see ROD Amendment, Appendix II, Table 10);
Key factors used in selecting.the modified remedy (i.e., how the selected modified·•• Key factors used in selecting the modified remedy {i.e., how the selected modified groundwater remedy provides the best balance of tradeoffs With respect to thegroundwater remedy provides the best balance of tradeoffs with respect to the balancing and modifying criteria, highlighting criteria key to the decision)(see RODbalancing and modifying criteria, highlighting criteria key to the decision)(see ROD Amendment, pages 21-26);Amendment, pages 21-26);
Key factors used in technical impracticability for the (see ROD•• Key factors used in technical impracticability for the MW-19 AreaMW-19 Area (see ROD Amendment, pages 26-27); and,Amendment, pages 26-27); and.
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Estimated capital, annual monitoring, and present-worth costs; discount rate; and the number of years over which the modified groundwater remedy cost estimates are projected (see ROD Amendment, page 23 and Appendix II, Table 11).
AUTHORIZING SIGNATURE
Walter E. Mugdan, Director Emergency and Remedial Response Division
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RECORD OF DECISION FACT SHEET EPA REGION ".
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Selected remedy: . Monitored natural attenuation of Site groundwater excluding
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Capital cost: $65,600
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Present-worth cost: $1,774,000 (7% discount rate. for 30 years)
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Waste type: Volatile organic compounds and metals in groundwater.
Waste origin: .Industrial waste containing hazardous substances remaining in drums that were sent to the Site for reconditioning
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AMENDMENT TO THE RECORD OF DECISIONAMENDMENT TO THE RECORD OF DECISION DECISION SUMMARYDECISION SUMMARY
Jri-Cities Barrel Superfund SiteTri-Cities Barrel Superfund Site Town of Fenton, Broome County, New YorkTown of Fenton, Broome County, New York
United States Environmental Protection Agency. United States Environmental Protection Agency Region IIRegion"
New York, New YorkNew York, New York SeptemberSeptember 20112011
531189
TABLE OF CONTENTSTABLE OF CONTENTS PAGE
?ITE NAME, LOCATION, AND DESCRIPTION : : ,. 1SITE NAME, LOCATION, AND DESCRIPTION 1
PAGE
SITE HISTORY AND ENFORCEMENT ACTiViTIES 2SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTiCiPATION 4HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF OPERABLE UNITSCOPE AND ROLE OF OPERABLE UNIT , 55
SUMMARY' OF SITE CHARACTERISTICS 6SUMMARY OF SITE CHARACTERISTICS... 6
PRINCIPAL THREAT WASTEPRINCIPAL THREAT WASTE 88
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USESCURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 88
SUMMARY OF SITE RISKS ~ 99SUMMARY OF SITE RISKS Human HealthRisk Assessment 99Human Health Risk Assessment Ecological Risk AssessmentEcological Risk Assessment 1212 Uncertainties Uncertainties 1313 Basis for Action 1313Basis forAction ;
REMEDIAL ACTION OBJECTIVES 1313REMEDIAL ACTION OBJECTiVES :
DESCRIPTION OF ALTERNATiVESDESCRIPTION OF ALTERNATIVES ... 1414
Alternative GW-1Alternative GW-1: NoNo ActionAction 1515 Alternative GW-2Alternative GW-2:' Monitored Natural AttenuationMonitored Natural Attenuation 1515 Alternative GW-3Alternative GW-3: Groundwater Extraction and TreatmentGroundwater Extraction and Treatment 1616
COMPARATIVE ANALYSIS OF ALTERNATIVES 1717"COMPARATIVE ANALYSIS OF ALTERNATiVES :
SELECTED MODIFIED GROUNDWATERSELECTED MODIFIED GROUNDWATER REMEDYREMEDy 2121
~TATUTORYSTATUTORY DETERMINATIONS DETERMINATIONS 2424
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26 TECHNICAL IMPRACTICABILITY DETERMINATIONS ; 26 TECHNICAL IMPRACTICABILITY DETERMINATIONS
ATTACHMENTSATTACHMENTS
ApPENDIX I.APPENDIX I. APPENDIX II. .APPENDIX II. APPENDIX III. APPENDIX III. APPENDIX IV.APPENDIX IV. APPENDIXV.APPENDIX V. APPENDIX VI. APPENDIX VI.
FIGURESFIGURES TABLESTABLES ADMINISTRATIVE RECORD INDEX ADMINISTRATIVE RECORD INDEX STATE LETTER OF CONCURRENCE STATE LETTER OF CONCURRENCE RESPONSIVENESS SUMMARY RESPONSIVENESS SUMMARY SETTLING DEFENDANTS SETTLING DEFENDANTS
ii
531191
SITE NAME, LOCATION, AND DESCRIPTIONSITE NAME, LOCATION, AND DESCRIPTION
The Tri-CitiesThe Tri-Cities Barrel Superfund Site (Site), which iswhich listedlisted on thethe NPL, includesincludesBarrel Superfund Site (Site), is on NPL, aa j 4. 9-acre parcel which became contaminated through operation of aa drum and barrel reconditioning business.reconditioning business. Operations at the Site included the receipt and reconditioning H-9-acre parcel which became contaminated through operation of drum and barrel
Operations at the Site included the receipt and reconditioning of drums and barrels previously used to contain variety of substances used in industrialof drums and barrels previously used to contain aa variety ofsubstances used in indus.trial or commercial processes. Wastewater from the reconditioning processWastewater from the reconditioning process waswas dischargedor commercial processes. discharged to the ground or into unlined lagoons on the Site.to the ground or into unlined lagoons on the Site. The Site is situated adjacent to OldThe Site is situated adjacent to Old Route 7, approximately five miles northeast of the City of Binghamton, in the Town ofRoute 7, approximately five miles northeast of the. City of Binghamton, in the Town of Fenton, Broome County, New York and is bisected by Interstate Highway 8 (1-88). TheFenton, Broome County, New York and is bisected by Interstate Highway 888 (1-88). The Site is bordered to the north by Osborne Creek and by rural residential areas, farmland,Site is bordered to the north by Osborne Creek and by rural residential areas, farmland,
on other is zonedand~nd woodlandswoodlands on thethe other sides.sides. TheThe propertyproperty is presentlypresently zoned residential/agricultural; the industrial use of the property was nonconforming use {i.e.,residential/agricultural; the industrial use of the property was aa nonconforming use (i.e., the drum reclamation facility was permitted to continue operating after zoning ordinancethe drum reclamation facility was permitted to continue operating after aa zoning ordinance that would have prohibited such industrial use had been established for this area).that would have prohibited such industrial use had been established for this area). TheThe current landcurrent land useuse in the immediate vicinity of the Site is residential, agricultural, andin the immediate vicinity of the Site is residential, agricultural, and recreational^.. .recreational2 .
The southern portion of the Site is relatively flat, except in the vicinity of 1-88, where theThe southern portion of the Site is relatively flat,except in the vicinity of 1-88, where the ground surface slopes steeply down to the highway.ground surface slopes steeply down to the highway. North of 1-88, the ground surfaceNorth of 1-88, the ground surface slopes gradually northward toward Osborne Creek.slopes gradually northward toward Osborne Creek. In the vicinity of Osborne Creek, theIn the vicinity of Osborne Creek, the ground surface slopes steeply to the creek and the associated flood plain.ground surface slopes steeply to the creek and the associated flood plain. The elevationThe elevation of the site ranges from 930 feet (ft) (at Osborne Creek) to 1,025 ft above mean sea levelpf the site ranges from 930 feet (ft) (at Osborne Creek) to 1,025 ft above mean sea level (south of Osborne Hollow Road).(south of Osborne Hollow Road). Refer to Figure 1.Refer to Figure 1.
Two small unnamed, intermittent streams parallel the eastern and the western sides of Jhe Site.the Site, The eastern tributary is located outside the property boundary; the western iTwo small unnamed, intermittent streams parallel the eastern and the western sides of
The eastern tributary is located outside the property boundary; the western tributary is located within the property boundary. Both streams collect the surface watertributary is located within the property boundary. Both streams collect the surface water runoff from the southern portion of the Site, including Osborne Hollow Road, Old Route 7,. runoff from the southern portion of the Site; including Osborne Hollow Road,Old Route 7, and the railroad tracks. Both of the streams flow north, discharging to Osborrie Creek.~nd the railroad tracks. Both of the streams flow north, discharging to Osborne Creek. I - . ' ' ' "
X man-made pond (a former lagoon) located north of 1-88 occupies approximately 6,000Aman-made pond (a former lagoon) located north of 1-88 occupies approximately 6,000 square feetfeet (sq ft).(sq ft). However, thethe size of the pond variesvaries greatly with seasonal~quare However, size of the pond greatly with seasonal precipitation, andprecipitation, and is often dry or nearly dry during the summer months.is often dry or nearly dry during the summer months. The pond coversThe pond covers the greatest amount of land surface and is deepest (2-3 ft) during the spring.the greatest amountbfland surface and is deepest (2-3 ft) during the spring. Currently,Currently, the pond receives water from precipitation directly into the pond and storm water runoffthe pond receives water from preCipitation directly into the pond and storm water runoff from 1-88 and the area between 1-88 and the pond.from 1-88 and the area between 1-88 and the pond.
The Tri-Cities Barrel Potentially Responsible Party Group (PRP Group) obtained aa deed restrictionThe Tri-Cities Barrel Potentially Responsible Party Group (PRP Group) obtained deed restriction from the current property owner to restrict the use of the property in perpetuity, recorded in thefrom the current property owner to restrict the use of the property in perpetuity, recorded in the
. Broome COunty Clerk's Office, State of New York, Book of Deeds No. 01875 at Page 1044.Broome County Clerk's Office, State of New Yoric, Book of Deeds No. 01875 at Page 1044.
531192
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SITE HISTORY AND ENFORCEMENT ACTIVITIESSITE HISTORY AND ENFORCEMENT ACTIVITIES
The property operated asas aa barrel and drum (hereinafter, "drum") reconditioningThe property waswas operated barrel and drum (hereinafter, "drum") reconditioning facility from about 1955 to 1992. TheThe Tri-Cities Barrel Co., Inc.,Tri-Cities Barrel Co., Inc., aa defunct corporation offacility from about 1955 to 1992. defunct corporation of which Gary Warner the most recent president, owned and operated the propertywhich Gary Warner waswas the most recent president, owned and operated the property during this period.during this period.
The drum reconditioning process involved cleaning and reconditioning the interior and .The drum reconditioning process involved cleaning and reconditioning the interior and exterior of drums through combination of physical, chemical, and mechanical means.exterior of drums through aa combination of physical, chemical, and mechanical means. The drums, which were brought to the Site from numerous different sources, typicallyThe drums, which were brought to the Site from numerous different sources, typically
of aa of chemical in orcontainedcontained residuesresidues of varietyvariety of chemical compounds employedcompounds employed in industrialindustrial or commercial operations.operations.commercial Depending on the nature of the residues, Tri-Cities Barrel Co.Depending on the nature of the residues, Tri-Cities Barrel Co. employed various processesemployed various processes to remove such residues,residues, includingincluding water andand causticto remove such water caustic sodiumsodium hydroxide solutions, incineration, particle blasting, and scraping.hydroxide solutions, incineration, particle blasting, and scraping. Much of theMuch of the available property south ofavailable property south of 1-88 was used for drum storage.1-88 was used for drum storage. As many as 1,000 drums perAs many as 1,000 drums per week were reconditioned at the facility. .. week were reconditioned at the facility.
From the beginning of the facility's operations to the early 1960s, liquid wastes from theFrom the beginning of the facility's operations to the early 1960s, liquid wastes from the reconditioning process were discharged to the and allowed to flow downslopereconditioning process were discharged to. the groundground and allowed to flow downslope toward Osborne Creek. This practice created From theFrom thetoward Osborne Creek. distinctive drainage pattern.This practice created aa distinctive drainage pattern. early 1960s to 1980s, liquid wastes were discharged into series of unlined lagoons onearly 1960s to 1980s, liquid wastes were discharged into aa series of unlined lagoons on the Site.the Site. Theselagoonswere reportedly three toThese lagoons were reportedly three to four ft deep.fourft deep. Prior to the completion ofPrior to the completion of construction of 1-88 in 1968, there were five lagoons located north of the former processconstruction of 1-88 in 1968, there were five lagoons located north of the former process building that were aligned along north-south line in the same general area as the earlierbuilding that were aligned along aa north-south line in the same general area as the earlier· discharge pattern. After the construction of 1-88, the liquid wastes were directed fromdischarge pattern. After the construction of 1-88, the liquid wastes were directed from east to west across the Site through the lagoons.east to west across the Site through the lagoons. The discharge from these lagoonsThe discharge from these lagoons flowed to the western tributary.flowed to the western tributary.
Tri-Cities Barrel Co. discontinued its practice of discharging liquid wastes to the lagoons inin 1980 after negotiations with NYSDEC.1980 after negotiations with NYSDEC. By 1981, the three lagoons south of 1-88 had Tri-Cities Barrel Co. discontinued its practice of discharging liquid wastes to the lagoons
By 1981, the three lagoons south of 1-88 had been backfilled with approximately 7,000 cubic yards of fill.been backfilled with approximately 7,000 cubic yards of fill. Following the closure of theFollowing the closure of the lagoons, the liquid wastes generated in the drum cleaning process were collected in aa holdingholding tank and hauled off-site for disposal. installationinstallation aa closed-loop lagoons, the liquid wastes generated in the drum cleaning process were collected in
tank for disposal. Upon of wastewater recirculation system, only infrequent off-site disposal of the liquid wastes was
and hauled off-site Upon of closed-loop wastewater recirculation system, only infrequent off-site disposal of the liquid wastes was done.done.
BasedBased upon the results of an EPA-performed site investigation and New Yorkupon the results of an EPA-performed site investigation and New York State-performed Phase and Phase listed on theI site investigations, the Site on the National Priorities Listen October4, 1989. State-performed Phase II and Phase III site investigations, the Site waswas listed Nati9nal Priorities List on October 4, 1989.
AA PRP search conducted by EPA in 1991 resulted in the initial identification of 23 PRPs for the Site.for the Site. In May 1991, EPA notified these parties that it considered them PRPs with
PRP search conducted by EPA in 1991 resulted in the initial identification of 23 PRPs In May 1991, EPA notified these parties that it considered them PRPs with
respect to the Site, and provided those parties with the opportunity to perform remedialrespect to the Site, and provided those parties with the opportunity to perform aa remedial investigation and feasibility study (RI/FS) for the Site under EPA oversight pursuant to aninvestigation and feasibility study (RifFS) for the Site under EPA oversight pursuant to an Administrative Order on Consent (AOC).Administrative Order on Consent (AOC)~ On May 14, 1992, EPA entered into an AOCOn May 14, 1992, EPA entered into an AOC
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with 14 6f these parties (i.e., the original members of the PRP Group), under which theywith 14 of these parties (i.e., the original members of the PRP Group), under which they pgreed to perform an RI/FS to determine the nature and extent of the contamination at theagreed to perform an RI/FS to determine the nature and extent of the contamination at the ~ite and Ito identify and evaluate remedial alternatives.Site and jto identify and evaluate remedial alternatives. I'i , • • i • • , • " .I prum reconditioning operations ceased at the facility in, 1992, in accordance with anDrum reconditioning operations ceased at the facility in, 1992, in accordance with an agreement between the PRP Group and Gary Warner. During 1992 and 1993, theagreement between the PRP Group and Gary Warner. During 1992 and 1993, the property was used by Tri-Cities Barrel Co. to broker clean drums that were brought in byproperty was used by Tri-Cities Barrel Co. to broker clean drums that were brought in by the company from off-site sources, and to sell the existing inventory of empty, cleanthe company from off-site sources, and to sell the existing inventory of empty, clean plastic drums.plastic drums.
,
Following issuance of the RI/FS AOC, EPA continued its PRP investigation and,Following issuance of the RI/FS AOC, EPA continued its PRP investigation and, inin ~ugust 1995, notified 64 additional parties of their potential responsibility at the Site.August 1995, notified 64 additional parties of their potential responsibility at the Site, rhirty-orie of these parties were determined by EPA to be parties with aa minimal, or de minimis, share of liability and were offered participation in de minimis settlement. Of ijrhirty-ohe of these parties were determined by EPA to be parties with minimal, or de
. };7inimis, !share of liability and were offered participation in aa de minimis settlement. Of those 31 parties, 26 elected to settle their liability with EPA as respondents in an AOC inthose 31 parties, 26 elected to settle their liability with EPA as respondents in an AOC in March 1996.March 1996. Three more de minimis parties settled with EPA in an AOC in July 1997.Three more de minimis parties settled with E~A in an AGC in July 1997.
On September 25, 1996,' EPA entered into an AOC with 34 PRPs whereby the PRP Group agreed to performagreed to perform aa removal action at the Site under EPA oversight.removal action at the Site under EPA oversight. EPA then On September 25, 1996, EPA entered into an AOC with 34 PRPs whereby the PRP ~roup EPA then issued aa Unilateral Administrative Order in December 1997 to eight non-consentingDecemberissued Unilateral Administrative Order, in 1997 to eight non-consenting PRPs, directing them to participate in the removal action along with the AOC parties.PRPs, directing them to participate in the removal action along with the AOC parties. jThe objectives of this action were to locate, characterize the contents, and properlyjfhe objectives of this aCtion were to locate, characterize the contents, and properly dispose of all containers, drums, tanks, and debris located on-site and decontaminate,~ispose of all containers, drums, tanks, and debris located on-site and decontaminate, demolish, and dispose of all buildings and structures. <• This work was completed in~emolish, and dispose of all buildings and structures. ! This work was completed in January 1997. Several concrete slabs and building foundations were present afterJanuary '1997. ' Several concrete slabs and building foundations were present after 1997. .1997.
" .
Based upon the results of the 1999 RI/FS reports and February 2000 public meeting,~ased upon the results of the 1999 RI/FS reports and aa February 2000 public meeting, aa Record of Decision (ROD) was signed on March 31, 2000, which called for the excavationRecord of Decision (ROD)wassigned on March 31,2000, which called for the excavation and off-site disposal of contaminated soil/sediment, backfill of the excavated area with~nd off-site disposal of contaminated soil/sediment, backfill of the excavated area with clean fill and the extraction and treatment of contaminated groundwater at the Site.flean fill and the extraction and treatment of contaminated groundwater at the S,ite.
in 2001, the United States settled with 43 PRPs in consent decree entered in Unitedj'n 2001, the United States settled with 43 PRPs in aa consent decree entered in United States district court.States district court. The consent decree required the settling PRPs to implement theThe consent decree required the settling PRPs to implement the
. ~esigndesign and remedial action for the Site that had been selected by EPA in the ROD.and remedial action for the Site that had been selected by EPA in the ROD. TheThe soil and sediment remedy selected in the ROD was completed in 2003 and resulted in the,roil and sedimentremedy selected in the ROD was completed in 2003 and resulted in the excavation and off-site disposal of 74,969 tons (40,000 cubic yards) of contaminated soil$xcavation and off-site disposal of 74,969 tons (40,000 cubic yards) of contaminated soil and sediment.and sediment. In 2003, the building foundations remaining after the 1997 removal wereIn 2003, the building foundations remaining after the 1997 removal were excavated, decontaminated, cut into manageable sizes, and buried in clean area~xcavated, decontaminated, cut into manageable sizes, and buried in aa clean' area on-site in an area that is designated as the "MW-19 Area" and shown on Figure 2. Thebn-site in an areathat is designated as the "MW-19 Area" and shown on Figure 2. The concrete foundations with visible staining were disposed off-site at Subtitle landfill.boncrete foundations withvisible staining were disposed off-site at aa Subtitle DD landfill.II " . . .. . ' .I· . .
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To evaluate the potential for natural attenuation of groundwater, an evaluationan wasto evaluate the potential for natural attenuation of groundwater, evaluation was conducted during the RI/FS.conducted during the RI/FS. The results of natural attenuation screening conductedThe results of natural attenuation screening conducted during the RI/FS were inconclusive and because of the lack of important site-specificduring the RI/FS were inconclusive and because of the lack of important site-specific
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"evidence"of natural attenuation, including characterization· data.informationinformation oror "evidence" of natural attenuation, including characterization data necessary to quantify the rates of biological degradation processes, it not possible tonecessary to quantify the rates of biological degradation processes, it waswas notpossiblE3 to develop time frames for the natural attenuation of contaminants in the groundwater.develop time frames for the natural attenuation of contaminants in the groundwater.
From 20012001 through 2005, seven rounds of groundwater samples were collected as part ofFrom through 2005, seven rounds of groundwater samples were collected as part of an MNA study and documented in the 2007 Revised Comprehensive Monitored Natural Attenuation Evaluation Report.Attenuation Evaluation Report. The data indicate that the total mass of contaminants an MNA study and documented in the 2007 Revised Comprehensive Monitored Natural
The data indicate that the total mass of contaminants had greatly reduced after the removal of the source of the groundwater contamination,had greatly reduced after the removal of the source of the groundwater contamination, vadose zone soil. In addition, the presence of reductive microbial metabolic products .. vadose zone soil. In addition, the presence of reductive microbial metabolic products indicates that the primary MNA mechanism responsible for the decline is biodegradation.indicates that the primary MNA mechanism responsible forthe decline is biodegradation. The findings of this effort were also summarized in PRP Group-prepared draftThe findings of this effort were also summarized in aa PRP Group-prepared 20082008 draft focused feasibility study (FFS) report with comparison of MNA to other alternatives suchfocused feasibility study (FFS) report with comparison of MNA to other alternatives such asas groundwater pump and treat.groundwater pump and treat. After reviewing the draft FFS report, EPA concludedAfter reviewing the draft FFS report, EPA concluded that while MNA may be feasible for the majority of the Site, the data did not demonstratethat while MNA may be feasible for the majority of the Site, the data did not demonstrate that MNA would address the groundwater contamination in the "MW-19 Area" (the sourcethat MNA would address the groundwater contamination in the "MW-19 Area" (the source of the contamination in this area could not be identified). It waswas also concluded byIt EPAof the contamination in this area could not be identified). also concluded by EPA that because of the low permeability of the aquifer, groundwater extraction and treatmentthat because of the low permeability of the aquifer, groundwater extraction and treatment
not technically viable for the Site.waswas not technically viable for the Site.
Based upon the recommendations in the draft FFS report, the PRP Group was directedBased upon the recommendations in the draft FFS report, the PRP Group was directed by EPA to implement an enhanced reductive dechlorination (ERD) pilot-scale treatabilityby EPA to implement an enhanced reductive dechlorination (ERD) pilot-scale treatability studystudy in thein the MW-19 Area.MW-19 Area. Following the completion of four rounds of performanceFollowing the completion of four rounds of performance monitoring events, the PRP Group submitted draft Pilot Study Report in January 2010.monitoring events, the PRP Group submitted aa draft Pilot Study Report in January 2010. Based upon its review of the report, EPA requested that the PRP Group performBased upon its review of the report, EPA requested that the PRP Group perform additional investigation to locate the source and, if located, then perform targeted ERD .additional investigation to locate the source and, if located, then perform targeted ERD treatment. The PRP Group performedThe PRP Group performed aa supplemental investigation from Septembertreatment. supplemental investigation from September through December 2010. This work included the performance of passive soil gasthrough December 2010. This work included the performance of aa passive soil gas survey^, collection of discrete groundwater samples from the silt and sand/gravel zonessurvei, collection of discrete groundwater samples from the silt and sand/gravel zones beneath and around the concrete rubble, permeability testing, and hydraulic conductivitybeneath and around the concrete rubble, permeability testing, and hydraulic conductivity testing. This investigation did not result in the identification of source of thetesting. This investigation did not result in the identification of aa source of the contamination in the MW-19 Area.contamination in the MW-19 Area.
OF COMMUNITY PARTICIPATIONHIGHLIGHTSHIGHLIGHTS OFCOMMUNITY PARTICIPATION
The Revised Comprehensive Monitored Natural Attenuation Evaluation Report (ESCThe Revised Comprehensive Monitored Natural Attenuation Evaluation Report (ESC Engineering, 2007), Pilot Study Report (Revision 2) (WSP Environmental, 2010), MW-19Engineering, 2007), Pilot StUdy Report (Revision 2) (WSP Environmental; 2010), MW-19 Area Supplemental Investigation Report (WSP Environmental, 2011), RiskRiskArea Supplemental Investigation Report (WSP Environmental, 2011), AA Assessment for Human HealthHealth and Ecological Risks developed inin 2008, FocusedAssessment for Human and Ecological Risks developed 2008, Focused Feasibility Study Report (Revision 2) (WSP Environmental, 2011), and 2011 ProposedFeasibility Study Report (Revision 2) (WSP Environmental, 2011), and 2011 Proposed
Fortyeseven passive soil gas samplers were installed in 15-ft intervals over the MW-19 Area. The3 Forty-seven passive soil gas samplers were installed in 15-ft intervals over the MW-19 Area. The results were used to aid in locating the potential source of 1,1,1-trichloroethane (1,1,1-TCA) andresults were used to aid in locating the. potential source of 1,1,1-trichloroethane (1,1,1-TCA) and tetrachloroethene (PCE) in MW-19 Area groundwater.tetrachloroethene (PCE) in MW-19 Area groundwater. 1,1,1-TCA was detected 14 times over the1,1,1-TCA was detected 14 times over the reporting limit and thereporting limit and the maximum detected was 832 nanograms. PCE was detected 18 times overmaximum detected was 832 nanograms. PCE was detected 18 times over the reporting limit and the maximum detected was 6,513 nanograms.the reporting limit and the maximum detected was 6,513 nanograms.
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Plan for Remedy Modification for the Site were' made available to the public in both thePlan for Remedy Modification for the Site were made available to the public in both the Administrative Record and information repositories'* maintained at the EPA Docket RoomAdministrative Record and information repositories4 maintained at the EPA Docket Room in the Region I New York City office at 290 Broadway in Manhattan and the informationin the R~gion III New York City office at 290 Broadway in Manhattan and the information repository at the Fenton Town Hall, 4 Park Street, Port Crane, Nevy York. AA notice ofrepository at the Fenton Town Hall, 444 Park Street, Port Crane, New York. notice of availability for the above-referenced documents was published in the Binghamton Pressavailability for the above-referenced documents was published in the Binghamton Press ?ndand Sun Bulletin on Sunday, JulySun;Bulletin on Sunday, July 31, 2011.31, 2011. public comment period ran from July 31,AA public comment period ran from July 31, 2011 to August 30, 2011.f011 to tugust 30,2011. , ,. i . , ." i
" On August 16, 2011, EPA conducted aa public meeting at the Town of Fenton Town Hall toOn August 16, 2011, EPA conducted public meeting at the Town of Fenton Town Hall to present 1he findings of the recent groundwater investigations and FFS and to answerpresent the findings of the recent groundwater investigations and FFS and to answer questions from the public about the Site and the groundwater remedial alternatives underquestions from the public about the Site and the groundwater remedial alternatives under consideration.consideration.
Responses to the comments received at the public meeting and in writing during theResponses to the comments received at the public meeting and in writing during the public comment period are included in the Responsiveness Summary (see AppendixAppendix V).public comment period are included in the Responsiveness Summary (see V).
SCOPE AND ROLE OF OPERABLE UNITSCOPE AND ROLE OF OPERABLE UNIT . ii . . » ' . • • • • • • ' •
I
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR[he National Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Section 300.5, defines an operableoperable unit as discretediscrete action thatthat comprises ananSection 300.5, defines an unit as aa action comprisesI,
incrementalincremental step toward comprehensively addressing sitesite problems.problems. ThisThis discretestep toward comprehensively addressing discrete portion of remedial response manages migration, or eliminates or mitigates release,portion of aa remedial response manages migration, or eliminates or mitigates aa release, threat ofthreat of aa release,orrelease, or pathway ofpathway of exposure.exposure. The cleanup of site can be divided intoThe cleanup of aa site can be divided into aa number of operable units, depending on the complexity of the problems associated withhumber of operable units, depending on the complexity of the problems associated with the Operable units may address geographical portionsOperable units may address geographical portions ofof site, specific sitethe site.site. aa site, specific site problems, or an initial phase of an action, or it may consist of any set of actions performedproblems, or an initial phase of an action, or it may consist of any set of actions performed pver time or any actions that are concurrent but located in different parts of a site.pver time or ,any actions that are concurrent but located in different parts ora site. I
JThis action applies comprehensive approach; therefore, only one operableoperable unit isunit isjrhis action applies aa comprehensive approach; therefore, only one |-equired to remediate the Site. The primary objectives of this action are to restoretequired to remediate the Site. The primary objectives of this action are to restore site-wide^ groundwater quality to levels which meet state and federal drinking-water~ite-wide5groundwater quality to levels which meet state and federal, drinking-water standards within reasonable time frame and reduce or eliminate any direct contact or~tandards within aa reasonable time frame and reduce or eliminate any direct contact or inhalation threat associated with contaminated groundwater.j'nhalation threat associated with contaminated groundwater. ,
Jhe action described in this ROD Amendment changes the groundwater remedy selectedThe action described in this ROD Amendment changes the groundwater remedy selected ~ . .
in the 2000 ROD, but does not alter the objectives except as to those objectives which arei,n the 2000 ROD, but does not alter the objectives except as to those objectives which are waived.waived. All objectives related to soil and sediment remediation identified in the 2000All objectives related to soil and sediment remediation identified in the 2000
4 As of August 1, 2011, another repository location has been added for this Site. Fenton Free Library,As of August 1, 2011, another repository location has been added for this Site. Fenton Free Library, II 1062 Chenango Street, Binghamton, NY.1062 Chenango Street, Binghamton, NY. 5 EPA concluded that since the source of the groundwatercontamination in the MW-19 Area could Ii not be identified despite multiple investigations, further efforts to try to identify the source would
EPA concluded that since the source of the groundwater contamination in the MW-19 Area could not be identified despite multiple investigations, further efforts to try to identify the 'source would
I likely be fruitless, and remedial action in the MW-19 Area to address the source or to address thelikely be fruitless, and remedial action in the MW-19 Area to address the source or to address the groundwater contamination is not warranted due to technical impracticability from an engineeringgroundwater contamination is not warranted due to technical impracticability from an engineering perspective.perspective.
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This action represents the final remedy planned for·ROD have been met and completed.ROD have been met and completed. This action represents the final remedy planned for the Site.the Site.
SUMMARY OF SITE CHARACTERISTICSSUMMARY OF SITE CHARACTERISTICS
The Site is underlain by 35 ft (southern portion of the Site, south of Old Route 7) toThe Site is underlain by 35 ft (southern portion of the Site, south of Old Route 7) to greater than 60ft (northern portion of the Site) of unconsolidated deposits, which are brown, silty, and clayey till, with discontinuous thin sand and gravel lenseslensesbrown, silty, and clayey till, with discontinuous thin sand and gravel ... The till greater than 60 ft (northern portion of the Site) of unconsolidated deposits, which are
The till deposits with sand layers form the unconsolidated water-bearing zone at the SiteSite...deposits with sand layers form the unconsolidated water-bearing zone at the Because of the slow recharge observed in the on-site wells and the low hydraulicBecause of the slow recharge observed in the on-site wells and the low hydraulic conductivity of the till, the groundwater present in the till is referred to as water-bearingconductivity of the till, the groundwater present in the till is referred to as aa water-bearing. zone and does not qualify as an aquifer®.aquifer6
. Beneath the unconsolidated deposits lieszone and does not qualify as an Beneath the unconsolidated deposits lies predominantly shale bedrock. Based on over fifteen years of data, it has been concludedpredominantly shale bedrock. Based on over fifteen years of data; ithas been concluded by EPA that the contamination in the groundwater at this Site is confined to the shallowby EPA that the contamination in the groundwater at this Site is confined to the shallow groundwater present in the till and sand layers mentioned above.groundwater present in the till and sand layers mentioned above.
TheyWithin 1,000 ft of the Site boundary, there are nine private drinking water wells?Within 1,000 ft of the Site boundary, there are nine private drinking water wells^. They are all located upgradient or cross-gradient from the Site and installed in bedrock andare all located upgradient or cross-gradient from the Site and installed in bedrock and are not considered potential receptors of affected groundwater.are not considered potential receptors of affected groundwater.
The affected groundwater at the Site is mainly restricted to the area south of 1-88, withinThe affected groundwater at the Site is mainly restricted to the area south of 1-88, within the shallow, unconsolidated water-bearing zone; the bedrock aquifer is not contaminated.the shallow, unconsolidated water-bearing zone; the bedrock aquifer is not contaminated. Prior to the 2003 removal of the contaminated soil, the groundwater plume at the SitePrior to the 2003 removal of the contaminated soil, the groundwater plume at the Site appeared to be located in isolated zones within an area approximately 240 ft wide by 500appeared to be located in isolated zones within an area approximately 240 ft wide by 500 ft long. The most prevalent volatile organic compounds (VOCs) and their correspondingft long. The most prevalent volatile organic compounds (VOCs) and their corresponding maximum concentrations detected in the groundwater prior to 2003 soil remediation weremaximum concentrations detected in the groundwater prior to 2003 soil remediation were toiuene (7,500 micrograms per liter (ug/l)), 2-butanone (5,300 ug/1), 1,1-dichloroethanetoluene (7,500 micrograms per liter (ug/I», 2-butanone (5,300. ug/l),1, 1-dichloroethane (1,1-DCA)(1,1-DCA) (4,700 ug/l), cis-1,2-dichloroethene (cis-1,2-DCE) (12,000 ug/l), 1,1,1-TCA(4,700 ug/l), cis-1,2-dichloroethene (cis-1,2-DCE) (12,000 ug/I), 1,1,1-TCA (310 ug/l), methylene chloride (1,600 ug/l), and vinyl chloride (VC) (21,000 ug/l). The(310 ug/l), methylene chloride (1,600 ug/I), and vinyl chloride (VC) (21,000 ug/l). The most prevalent semi-volatile organic compounds (SVOCs) and their correspondingmost prevalent semi-volatile organic compounds (SVOCs) and their corresponding maximum concentrationsconcentrations detected priorprior to 20032003 were phenolphenol (6,900 ug/l)ug/l)· andmaximum detected to were (6,900 and 4-methylphenol (13,000 ug/l). PCBs and pesticides (alpha-chlordane, 4,4'-DDE, and4-methylphenol (13,000 ug/I). PCBs and pesticides (alpha-chlordane, 4,4'-DDE, and heptachlor) were detected in monitoring wells outside of the VOC plume at relatively lowheptachlor) were detected in monitoring wells outside of the VOC plume at relatively low levels of 1.6 ug/l,levelsof 1.6 ug/l, 0.11 ug/l, 0.03 ug/l, and 0.09 ug/l, respectively.0.11 ug/l, 0.03 ug/l, and 0.09 ug/l, respectively. The prevalent metals ofThe prevalent me!als of concern and their maximum concentrations detected were iron (38,000 ug/l), manganeseconcern and their maximum concentrations detected were iron (38,000 ug/l), manganes'e(15,600 ug/l), antimony (59.2 ug/l), nickel (184 ug/l) and cadmium (15 ug/l). Other(15,600 ug/l), antimony (59.2 ug/l), nickel (184 ug/l) and cadmium (15 ug/l). Other metals were at background concentrations in the groundwater.metals were at background concentrations inthe groundwater.
6 ' Aquifer in this context is a permeable geologic unit that can transmit and store significant quantitiesAquifer in this context is a permeable geologic unit that can transmit and store significant quantities .of water.of water. The well yield at SiteThe well yield at Site is so low it is measured in milliliters per minute.is so low it is measured in milliliters per minute. The .RemedialThe Remedial Investigation report referred to the groundwater at the Site as water-bearing zone and not anInvestigation report referred to the groundwater at the Site as aa water-bearing zone and not an . aquifer due to the very low yield.aquifer due to the very low yield. The private drinking waterwells were sampled by the New York State Department of Health duringThe private drinking water. wells were sampled by the New York State Department of Health during thetheRI;Rl; nonoSite-related contaminants were detected.Site-related contaminants were detected. The residential well located closest to the SiteThe residential well located closest to the Site was resampledwas resampled inin 2005.2005. Site-related contaminants were not detected.Site-related contaminants were not detected.
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While th~ vertical and horizontal extent of the groundwater contaminant plume has not §ignificantlysignificantly changed since the removalremoval of the source, with the exception of While the vertical and horizontal extent of the groundwater contaminant plume has not
changed since the of the source, with the exception of trichloro~thenetrichloro^thene. (TCE)(TCE) which showedshowed aa moderatemoderate decreasedecrease in concentration,concentration, thethewhich in, concentrations of other contaminants have dramatically decreased since the removal of
soil 2003. 2010, most VOCs theirtheir concentrations of other contaminants have dramatically decreased since the removal of thethe contaminatedcontaminated soil inin 2003. InIn 2010, thethe most prevalentprevalent VOCs andand corresponding maximum concentrations detected in the groundwater are TCE (720 ug/l),corresponding maximum concentrations detected in the groundwater are TCE (720 ug/I), 1,1,1-DCA'(1601-DCAt (160 ug/I),ug/l), cis~1cis-1,2-DCE (270 ug/l), and VC (270 ug/l).,2-DCE (270 ug/I), and VC (270 ug/I). 2010 data for toluene,2010 data for toluene, methylene chloride, 2-butanone, and 1,1,1-TCA found previously in the groundwater whichwhich had exceeded the New York State Ambient Water Quality Standards (NYS methylene chloride, 2-butanone, and 1,1,1-TCA found previously in the groundwater
had exceeded the New York State Ambient Water Quality Standards (NYS f!\WQS) prior to the 2003 source removal, yvere either not detected or were within theAWQS) prior to the 2003 source removal, were either not detected or were within the drinking water standard for New York State. All of the maximum concentrations detected, ~xceptexcept TCE, were from monitoring well MW-3S.TCE, were from monitoring well MW-3S. Maximum levels of TCE were observed drinking water standard for New York State. All of the maximum concentrations detected,
Maximum levels of TCE were observed monitoring MW-16S. Most of the other wells of 1-88 atInin monitoring wellwell MW-16S. Most of the other wells southsouth of 1-88 had TCEhad TCE at
concentrations ranging fromconcentrations ranging from 13 to 75 ug/l.13 to 75 ug/L Monitoring well MW-16S is located in theMonitoring well MW-16S is located in the former operationalformer operational areaarea south of 1-88 and monitoring well MW-3S is located 140 ftsouth of 1-88 and monitoring well MW-3S is located 140 ft downgradient of monitoring well MW-16S.. downgradient of monitoring well MW-16S.
Historically, MW-19 Area TCE concentration ranged from non-detect to 1.3Area TCE concentration ranged from non-detect to 1.3 ug/l.ug/1. summary of groundwater Monitoring wells MW-3S and MW-16S are notMonitoring wells MW-3S and MW-16S are not in the MW-19 Area.in the MW-19 Area. Historically, MW-19
AA summary of groundwater ~atadata since the source removal of 2003 is provided of Appendix II.since the source removal of 2003 is provided in thein the Table 11 of AppendixTable II. Groundwater data from 2010 for all wells monitored are provided in Table of AppendixGroundwater data from 2010 for all wells monitored are provided in Table 22 of Appendix II.II. • ,
low observed north 1-88,TheThe relativelyrelatively low concentrationsconcentrations observed inin monitoringmonitoring wellswells. north ofof 1-88, downgradient of the source areas, suggest that the plume is not highly mobile. Fordowngradient of the source areas, suggest that the plume is not highly mobile. For example, the only contaminant of concern (COC) detecteddowngradient has been VC.example, the only contaminant of concern (COC) detected downgradient has been VC. The maximum detected concentrations of VC in 2010 were found in two monitoring wellsThe maximum detected concentrations of VC in 2010 were found in two monitoring wells located near the remediated source areas South of 1-88 at 68 ug/l and 270 ug/l, whereasl,ocated near the remediated source areas South of 1-88 at 68 ug/I and 270 ug/I, whereas the maximum detected concentrations of VC in monitoring wells which are 200 and 300the maximum detected concentrations of VC in monitoring wells which are 200 and 300 II •
atsiniilar depths, 6.8 ug/I and ug/l,feetfeet downgradientdowngradient andand screenedscreened at similar depths, werewere 6.8 ug/l and· 4.54.5 ug/I, respectively.respectively. .. . .
(Broundwater data collected after the 2003 source removal detected levels of SVOCs,broundwater data collected after the 2003 source removal detected levels of SVOCs, pesticides, and PCBs below the federalpesticides, and PCBs below the federal and state drinking water standards.and state drinking water standards. MaximumMaximum detected levels of metals which exceeded the federal and state drinking water standardsdetected levels of metals which exceeded the federal and state drinking water standards since the 2003 contaminated soil and sediment removal are as follows: iron (6,900 ug/l),pince the 2003 contaminated soil and sediment removal are as follows: iron (6,900 ug/I), manganese (1,600 ug/l), and cadmium (7.9 ug/l).manganese (1,600 ug/I), and cadmium (7.9 ug/I).
~l . ,-
During the RI/FS, two monitoring wells, MW-14 and MW-14B, and one piezometer, P-2,During the RI/FS, two monitoring wells, MW-14 and MW-14B, and one piezometer, P-2, (see Figure(see Figure 2) were located in the vicinity of what is now called the MW-19 Area.2) were located in the vicinity of what is now called the MW-19 Area. OnlyOnly jDiezometer P-2 showed PCE contamination above the cleanup levels. During the MNApiezometer P-2 showed PCE contamination above the cleanup levels. During the MNA study in 2001, monitoring well (MW-19) was installed approximately 20 ft easterly ofstudy in 2001, aa monitoring well (MW-19) was installed approximately 20 ft easterly of piezometer P-2. Since then, PCE and 1,1,1-TCA have persisted in the MW-19 Area wellspiezometer P-2. Since then, PCE and 1,1,1-TCA have persisted in the MW-19 Area wells with concentration levels ranging from 12 to 66 ug/l and 45 to 72 ug/l, respectively.with concentration levels -ranging from 12 to 66 ug/I and 45 to 72 ug/I, respectively.
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Piezometer P-2 has exhibited similar PCE and'1, 1,1-TCA contamination levels sincePiezometer P-2 has exhibited similar PCE and 1,1,1-TCA contamination levels since 1997. .The MW-19 Area plume is estimated to be about 120 ft by 80 ft. The' NYS1997. The MW-19 Area plume is estimated to be about 120 ft by 80 ft. The NYS AWQS and theJederal standard of Drinking Water Maximum Contamination level (MCl)AWQS and the federal standard of Drinking Water Maximum Contamination Level (MCL) for PCE is 55 ~g/l. See Tables l' and 2.for groundwater data.for PCE is ug/l. See Tables land 2 for groundwater data.
PRINCIPAL THREAT WASTEPRINCIPAL THREAT WASTE
The NCP establishes an expectation that EPA will use treatment to address the principal threats posed by site wherever practicable (NCP Section 300.430 (a)(1)(iii)(A)). The The NCP establishes an expectation that EPA will use treatment to address the principal threats posed by aa site wherever practicable (NCP Section 300.430 (a)(1)(iii)(A)). The "principal threat" concept is applied to the characterization of "source materials" at"principal threat" concept is applied to the characterization of "source materials" at aa Superfund site.site.Superfund sourcesource material is material that includes oror contains hazardousAA material is material that includes contains hazardous substances, . pollutants,substances, pollutants, or contaminants that actor as aacontaminants that act as reservoirreservoir for the migrationfor the migration ofof contamination to groundwater, surface water, or air, oror acts as sourcesourcecontamination to groundwater, surface water, or· air, acts as aa forfor· directdirect exposure.exposure. Principal threat wastes are those source materials considered to be highlyPrincipal threat wastes are those source materials considered to be highly toxic or highly mobile that generally cannot be reliably contained, or would presenttoxic or highly mobile that generally cannot be reliably contained, or would' present aa significant risk to human health or the environment should exposure occur.significant risk to human health or the environment should exposure occur. The decisionThe decision to treat these wastes is made on aa site-specific basis through aa detailed analysissite-specific basis through ofto treat these wastes is made on detailed analysis of alternatives, usingalternatives, using the remedy selectionremedy selection criteria which are below.below.the criteria which described Thisare described This analysis providesanalysis provides aa basis for making aa statutory finding that thebasis for making remedy employsstatutory finding that the remedy employs treatment as aa principal element. .treatment as principal element.
Principal threat wastes identified in the 2000 ROD located in the former incoming drumPrincipal threat wastes identified in the 2000 ROD located in the former incoming drum storage area, the former lagoon 11 area, and within the former process building area werestorage area, the former Lagoon area, and within the former process building area were removed with other contaminated soil and sediment in 2003 and treated as appropriaterem6ved with other contaminated soil and sediment in 2003 and treated as appropriate prior to disposal.prior to disposal.
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USESCURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
The property is presently zoned the industrial use of the propertyThe property is presently zoned residential/agricultural;residential/agricultural; the industrial use of the property' nonconforming use {i.e., the drum reclamation facility permitted to continuewaswas aa nonconforming use (i.e., the drum reclamation facility waswas permitted to continue
operating after zoning ordinance prohibiting such use had been established for thisoperating after aa zoning ordinance prohibiting such use had been established for this . area)area)^.8. The current land use in the·the immediate vicinity of the Site is residential,The current land use in immediate vicinity of the Site is residential, agricultural, and recreational.recreational. Based on numbernumber of factors,factors, including EPA'sEPA'sagricultural, and Based on aa of including observations as to land use in the area of the Site since at least 1989, the existing zoningobservations as to land use in the area of the Site since at least 1989, the existing zoning for the Site property, an August 1999 resolution by the Town Board of the Town of Fentonfor the Site property, an August 1999 resolution by the Town Board of the Town of Fenton affirming that zoning^, and subsequent communications between the Town Board, EPA,affirming that zoning9
, and subsequent communications between the Town Board, EPA,
8 Letter from Donald F. Brown, Town Engineer, Town of Fenton, to Joel Singerman, Chief, Central.Letter from Donald F. Brown, Town Engineer, Townof Fenton, to Joel Singerman, Chief, Central, New York Remediation Section, EPA, dated August 23, 1999.New York Remediation Section, EPA, dated August 23, 1999. See Site Administrative Record.See Site Administrative Record.
9 Resolution of August 23, 1999 by the of Fenton Board, and letter from Donald F.Resolution of August 23, 1999 by the TownTown of Fenton TownTown Board, and letter from Donald F. Brown, Town Engineer, of Fenton, to Jack Spicuzza, Ashland, Inc., dated November 2,1999.Brown, Town Engineer, TownTown of Fenton, to Jack Spicuzza, Ashland, Inc., dated November 2,1999. See Site Administrative Record.See Site Administrative Record.
8
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I
and the PRP Group, EPA determined that the reasonably-anticipated future use for theand the PRP Group, EPA determined that the reasonably-anticipated future use for the Site is residential/agricultural.Site is residential/agricultural.
Gurrently, the on-Site shallow contaminated unconsolidated water-bearing zone and the uncontaminated bedrock aquifer are not used for drinking water.uncontaminated bedrock aquifer are not used for drinking water. Residents living in the Currently, the on-Site shallow contaminated unconsolidated water-bearing zone and the
Residents living in the .. vicinity of the Site use the deep bedrock aquifer as the sole source of potable water whichvicinity of the Site use the deep bedrock aquifer as the sole source of potable water which was not impacted by the Site. Groundwater near the Site will continue to be used as aa source of potable water under scenarios. In addition, the potential future use was not impacted by the Site. Groundwater near the Site will continue to be used as source of potable water under future-usefuture-use scenarios. In addition, the potential future use of the unconsolidated water-bearing zone on Site may be used as drinking water sourceof the unconsoiidated water-bearing zone on Site may be used as aa drinking water source once clepnup levels have been achieved.
I once cleanup levels have been achieved.
SUMMARY OF SITE RISKSSUMMARY OF SITE RISKS
Based upon the results of the RI, aa baseline risk assessment waswas conducted to estimate the risks associated with current and future Site conditions.the risks associated with current and future Site conditions. A baseline risk assessment Based upon the results of the Rl, baseline risk assessment conducted to estimate
Abaseline risk assessment I'
i,s an analysis of the potential adverse human health and ecological effects caused byis an analysis of the potential adverse human health and ecological effects caused by razardous substance releases from aa site in the absence of any actions to control orhazardous substance releases from site in the absence of any actions to control or mitigate these under current and anticipated future land uses.initigate these under current and anticipated future land uses.
EPA developed an updated baseline risk assessment to estimate the current and future~PA deVeloped an updated baseline risk assessment to estimate the current and future ~ffectseffects of contaminants on human healthhealth and thethe environment following' theenvironment following the 2003of contaminants on human and 2003
action removed material andimplementationimplementation ofof thethe remedialremedial action whichwhich removed sourcesource material (soil(soil and sediment).sediment). baseline risk assessment is an analysis of the potential adverse humanAA baseline risk assessment is an analysis of the potential adverse human inealth and ecological effects of releases of hazardous substances from site in the~ealth and ecological effects of releases of hazardous substances from aa site in the absence of any actions or controls to mitigate such releases, under future groundwaterabsence of any actions or controls to mitigate such releases, under future groundwater uses. The updated baseline risk assessment includes aa human health risk assessmentThe updated baseline risk assessment includes. uses. human health risk assessment (HHRA) and an ecological risk assessment (ERA) that is presented in the 2008 document(HHRA) and an ecological risk assessment (ERA) that is presented in the 2008 document titled Future Groundwater Scenario for the Tri-Cities Barrel Superfund Site (USEPAtitled Future Groundwater Scenario for the Tri-Cities Barrel Superfund Site (USEPA 2008)2008) ...
Human Health Risk AssessmentHuman Health Risk Assessment
Four-step processesprocesses is utilizedutilized for assessingassessing site-related humanhuman' health risks forFour-step is for site-related health risks for reasonable maximum exposure (RME) scenarios and are identified below:reasonable maximum exposure (RME) scenarios and are identified below:
Hazard Identification (Data Collection and Evaluation): In this step, the COCs at site inHazard Identmcation (Data Collection and Evaluation): . In this step, the GOGs at aa site in various media (in this case, contaminants in groundwater) are identified based on suchvarious media (in this case, contaminants in groundwater) are identified based on such' factors as tcixicity, frequency of occurrence, fate and transport of the contaminants in thefactors as toxicity, frequency of occurrence, fate and transport of the contaminants in the environment, concentrations of the contaminants in specific media, mobility, persistence,~nvironment, concentrations of the contaminants in specific media, mobility, persistence, and bioaccumulation.and bioaccumulation. .
jThe 2008 risk assessment used the maximum concentrations from the shallow wellsIThe 2008 risk assessment used the maximum concentrations from the shallow wells (MW-2S, MW-3S, MW-7S, MW-16S, and MW-20S) collected on December 1 and 12,(MW-2S, MW-3S, MW-7S, MW-16S, and MW-20S) collected on December 111 and 12,. ?0072007 to identify the COCs.to identify the COGs. Based on theon results of the baseline human health riskBased the results of the baseline human health risk
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the' following were 1,1-DCA, 1,2-DCA, cis-1,2-DCE,1,1-DCA, 1,2-DCA, cis-1,2-DCE, methylene chloride, PCE, TCE, and VC (see Table 3). assessment,assessment, the'following COGsCOCs were identified:identified:methylene chloride, PCE, TCE, and VC (see Table 3).
Exposure Assessment: In this step, the different exposure pathways through which exposed the contaminants identified in the are
Exposure Assessment: In this step, the different exposure pathways through which people mightpeople might bebe exposed toto the contaminants identified in the previousprevious stepstep are
. Examples of exposure pathways include ingestion of and dermal contactevaluatedevaluated.. Examples of exposure pathways include ingestion of and dermal contact with contaminated groundwater and inhalation exposures while showering. Factorswith contaminated groundwater and inhalation exposures while showering. Factors relating to the exposure assessment include, but are not limited to, the concentrations inrelating 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 thatspecific media that people might be exposed to arid the frequency and duration of that exposure.exposure. Using these factors,Using these factors, aa RME scenario, which portrays the highest level ofRME scenario, which portrays the highest level of human exposure that could reasonably be expected to occur, is calculated.human exposure that CQuid reasonably be expected to occur, is calculated.
Potential receptors and exposure pathways were based on current and future land use. The exposure routesThe exposure routes were evaluated as appropriate for the potential receptors.were evaluated as appropriate for the potential receptors. See Potential receptors and exposure pathways were based on current and future land use.
See Table for the Selection of Exposure Pathways.Table 44 for the Selection of Exposure Pathways.
In addition to calculating the risks and hazards to the RME individual, calculations of risksIn addition to calculating the risks and hazards to the RME individual, calculations of risks and hazards to the Central Tendency Exposed (CTE) individual are also provided forand hazards to the Central Tendency Exposed (CTE) individual are also provided for those chemicals exceeding the risk range.those chemicals exceeding the risk range.
Toxicity Assessment: In this step, the types of adverse health effects associated withToxicity Assessment: In this step, the types of adverse health effects associated with contaminant exposures and the relationship between magnitude of exposure (dose) andcontaminant exposures and the relationship between magnitude of exposure (dose) and severity of adverse health effects (response) are determined. Potential health effects areseverity of adverse health effects (response) are determined. Potential health effects are contaminant specific and may include the risk of developing cancer over aa lifetime orcontaminant specific and may include the risk of developing cancer over lifetime or other non-cancer health effects, such as changes in the normal functions of organs withinother non-cancer 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 cancercapable of causing both and non-cancer TablesTables 55 and 66 the body (e.g., changes in the effectiveness of the immune system). Some contaminants are cancer and non-cancer health effects.health effects. and provide summary of the COCs and their respective toxicity values for carcinogenic andprovide aa summary of the COCs and their respective toxicity values forcarcinogenic and non-carcinogenic health effects.non-carcinogenic health effects.
Risk Characterization:Risk Characterization: This step summarizes and combines outputs of the exposure andThis step summarizes and combines outputs of the exposure and toxicity assessments to provide quantitative assessment of site risks for all COCs.toxicity assessments to· provide aa quantitative assessment of site risks for all COCs. Exposures are evaluated based on the potential risk of developing cancer and theExposures are evaluated based on the potential risk of developing cancer and the potential for non-cancer health hazards. The likelihood of an individual developing cancerpotential for non-cancer health hazards. The likelihood of an individual developing cancer is expressedexpressed as aa probability. For example, aa 10'" cancercancer risk meansmeansis as probability. For example, 10-4 risk aa one-in-ten-thousandone-in-ten-thousand excess cancer risk;risk; or one additionaladditional cancer may bemay be seen ininexcess cancer or one cancer seen aa population of 10,000 peoplepopulation of 10,000 people asas aa result of exposure to site contaminants under theresult of exposure to site contaminants under the conditions identified in the Exposure Assessment. Current Superfund regulations forconditions· identified in the Exposure Assessment. Current Superfund regulations for acceptable exposures are an individual lifetime site-related excess cancer .risk in theacceptable exposures are an individual lifetime site-related excess cancer ,risk in the range of 10"''to 10" , corresponding to one-in-ten-thousand to one-in-a-million excess.range of 10-4 to 10-6
, corresponding to aa one-in-ten-thousand to aa one-in-a-millionexcess cancer risk or less. For non-cancer health effects, hazard index (HI) is calculated. Ancancer risk or less. For non-cancer health effects, aa hazard index (HI) is calculated. An HI represents the sum of the individual exposure levels compared to their correspondingHI represents the sum of the individual exposure levels compared to their corresponding Reference Doses. The key conceptThe key concept for a non-cancer HI is thatfora non-cancer HI is that aa "threshold" (measuredReference Doses. "threshold" (measured as an HI of less than or equal to 1) exists below which non-cancer health hazards are notas an HI of less than or equal to 1) exists below which non-cancer health hazards are not expected to occur.expected to occur. The goal of protectionThe goal of protection is 10"® for cancer risk and an HI ofis 10-6 for cancer risk and an HI of 11 for a.for a
.
..
..
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II
Chemicals that exceed aa 10-4 cancer risk Or an HI of 11 arenon-cancer health hazard.non-cancer health hazard. Chemicals that exceed 10"* cancer risk or an HI of are typically those that will require remediation at the site.typically those that will require remediation at the site.
The cancer risk and non-cancer health hazard estimates in the HHRA are based on future·The cancer risk and non-cancer health hazard estimates in the HHRA are based on future RME scenarios and were developed by taking into account various health proteCtiveRME scenarios and were developed by taking into account various health protective estimates· about the frequency and duration of an individual's exposure to chemicals selectedselected as COCs, as well as the toxicityCOCs, as well the toxicity of these contaminants.of these contaminants. Cancer risks and estimates about the frequency and duration of an individual's exposure to chemicals
as as Cancer risks and non-cancer His are summarized below.non-cancer His are summarized below.
The 2008 risk assessment evaluated the health effects for both future children, adults,The 2008 risk assessment evaluated the health effects for both future children, adults, and on-site workers in aa residential setting exposed to direct contact with contaminatedand on-site workers in residential setting exposed to direct contact with contaminated groundwater in the shallow wells (e.g., through ingestion of groundwater and inhalation of Volatiles released intointo indoor air fromindoor air from groundwater while showering in an·· enclosedenclosed groundwater in the shallow wells (e.g., through ingestion of groundwater and inhalation of volatiles released groundwater while showering in an$pace).space). The updated risk assessment began by selecting COCs in groundwater thatThe updated risk assessment began by selecting COCs in groundwater that would be representative of Site exposures and resulting risks.yvould be representative of Site exposures and resulting risks.
Based on the 2008 risk assessment, future risks to the adult resident were 6.3x 10-4 (6.3Based on the 2008 risk assessment, future risks to the adult resident were 6.3 x lO"'' (6.3 ~dditio'1al cancers within aa population of 10,000 people based on ingestion of 22 liters/dayadditional cancers within population of 10,000 people based on ingestion of liters/day bf shallow groundwater for aa period of 350 days/year for 24 years) and to the child resident were 3.6 lO""* (3.6 additional cancers within(3.6 additional cancers within aapopulation of 10,000 people of shallow groundwater for period of 350 days/year for 24 years) and to the child resident were 3.6 xx 10-4 population of 10,000 people based on ingestion of liter/day for period of 350 days/year for years). The risks to thebased on ingestion of 11 liter/day for aa period of 350 days/year for 66 years). The risks to the combined future adult and child resident are 9.9 10""* (an increased risk of approximately~ombined future adult and child resident are 9.9 xx 10-4 (an increased risk of approximately jl additional cancer within population of 1,000 based on the exposureon the exposure assumptionsassumptions~ additional cancer within· aa population of·1 ,000 based identified above). Risks to the future adult worker were 4.8 10"* (4.8 additional cancers~dentified above). Risks to the future adult worker were 4.8 xx 10-4 (4.8 additional cancers among aa population. of 10,000population of 10,000 workerswork~rs assuming ingestion of liters/day for 250among assuming· ingestion of 22 liters/day for 250 (Jays/year for period of 25 years). See Table for summary of risks to carcinogens.days/year for aa period of 25 years). See Table 66 for summary of risks to carcinogens.
The non-cancer hazards based on the same exposure assumptions used in the cancerThe non-cancer hazards based on the same exposure assumptions used in the cancer assessment were approximately HI of for the future adult resident; 4.7 for the futureassessment were approximately HI of 22 for the future adult resident; 4.7 for the future child resident; and 1.4 for the future worker. See Table for summary of non-cancerchild resident; and 1.4 for the future worker. See Table 88 for summary of non-cancer hazardshazards...
The toxicity values used in thein the 20082008 assessment were evaluated againstagainst currentlycurrentlyThe toxicity values used assessment were evaluated available toxicity values.available toxicity values. This comparison found that the toxicity values for TCE andThis comparison found that the toxicity values for TCE and ¢is-1,2-DCE were revised since the 2008 assessment.cis-1,2-DCE were revised since the 2008 assessment. The oral cancer slope factor forThe oral cancer slope factor for TCE changed from 1.3 xxTCE changed from 1.3 10-10" mg/kg-day to 5.92 mg/kg-day to 5.9 xx 10-3 mg/kg-day which resulted in10" mg/kg-day which resulted in aa change in· thein the calculated risks.risks. This reduction does notnot significantly change thechange calculated This reduction does significantly change the ~alculatedcalculated risks found in the original assessment. summary of the changes in therisks found in' the original assessment. AA summary of the changes in the I ... .
cancer risks for all receptors are provided in Table 9. . .~ancer risks for all receptors are provided in Table 9.
revised through the IRIS process.process. This revision resulted in an increase in the non-cancer health hazard for the inIn addition, theaddition, the oral Reference Dose for cis-1,2-DCEoral Reference Dose for cis-1,2-DCE waswas revised through the IRIS
This revision resulted in an increase in the non-cancer health hazard for the future exposures for the child from HI of 2.8 to 14; adult from HI of 0.86 to 4.3; and adultfuture exposures for the child from HI of 2.8 to 14; adult from HI of 0.86 to 4.3; and adult Worker from HI of 0.86 to 4.3. These changes in toxicity values do not result in significantworker from HI of 0.86 to 4.3. These changes in toxicity values do not result in significant changes to the overall conclusions from the risk assessment. . . .'9hanges to the overall conclusions from the risk assessment. ..
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• • : r - i A ' ' f ' ' " - ' ' ' • ' ' • ^ ' ^ ' • : . ,.- .• - : i 17n? 5!5LVV?•>>5•.^!%'*ft'fc,.V4 '
The risks for the future adult and child resident are above the risk range established in theThe risks for the future adult and child resident are above the risk range established in the NCPNCP (lO'"*(10-4 to 10"®) described above.) described above. The risks to the future workers are within the upperto 10-6 The risks to the future workers are within the upper bounds of the risk range. The non-cancer hazards exceeded EPA's goalgoal of protection ofThe non-cancer hazards exceeded EPA'sbounds of the risk range. of protection of anan HIHI = for all three receptors (i.e., future adult and child resident, and future on-site=11 for all three receptors (Le., future adult and child resident, and future on-site worker).worker). The main COCs were VC, TCE, andThe main COCs were VC, TCE, and cis-1cis-1,2-DCE.,2-DCE. Evaluation of cancer risksEvaluation of cancer risks and non-cancer hazards associated with showering were within the risk range for alland non-cancer hazards associated with showering were within the risk range for all receptors.receptors. complete discussion of the exposure pathways and estimates of risk can beAA complete discussion of the exposure pathways and estimates of risk can be found in the Human Health Risk Assessment Future Groundwater Scenario for thefound in the Human Health Risk Assessment Future Groundwater Scenario for the Tri-Cities Barrel Site.Tri-Cities Barrel Site.
In addition, the assessment also evaluated cancer risks and non-cancer health hazardsIn addition, the assessment also evaluated cancer risks and non-cancer health hazards associated with exposures to the future adult, child and the worker exposed under centralassociated with exposures to the future adult, child and the worker exposed Under central tendency or average exposure scenarios.tendency or average exposure scenarios. The CTE assessment evaluated risks toThe CTE assessment evaluated risks to aa future adult from ingestion of groundwater and inhalation of VOCs while showering andfuture adl,Jlt from ingestion of groundwater and inhalation of VOCs while showering and other household uses. The total risks wereThe total risks were 7.87.8 xx 10-5 and this calculated risk is within theother household uses. 10'^ and this calculated risk is within the risk range. TheThe cancer risks to the future child from ingestion of groundwater andrisk range. cancer risks to the future child from ingestion of groundwater and inhalation of VOCs while showering and other household uses. The total risks were 1.3 .inhalation of VOCs while showering and other household uses. The total risks were 1.3 Xx 10-10""*4 and this riskand this risk isis withinwithin the upper bounds of the risk range.the upper bounds of the risk range. The non-cancer HazardThe non-cancer Hazard· Indices to the future residential child and adult under CTE scenarios were 3.3 and 1,Indices to the future residential child and adult under CTE scenarios were 3.3 and 1, respectively; however, using the revised toxicity value for cis-1,2-dichloroethylene therespectively; however, using the revised toxicity value for cis-1,2.,.dichloroethylene the Hazard Indices were 1 and 3.4, respectively. The updated non-cancer HI exceed theHazard Indices were 111 and 3.4, respectively. The updated non-cancer HI exceed the goal of protection of HI = 1.= The main contributor to the non-cancer Hazard Indicesgoal of protection of aa HI 1. The main contributor to the non-cancer Hazard Indices was cis-1,2-dichloroethene.was cis-1,2-dichloroethene. The cancer risks to the future worker consuming shallowThe cancer risks to the future worker consuming shallow drinking water provides the risk to the future adult worker from ingestion groundwater anddrinking water provides the risk to the future adult worker from ingestion groundwater and inhalation of VOCs while showering and other household uses.inhalation of VOCs while showering and other household uses. The total risks to theThe total risks to the future worker were 6.5 10-5 and are within the risk range. The HI for the on-site workerfuture worker were 6.5 xx 10-5 and are within the risk range. The HI for the on-site worker
0.71 under the previous toxicity value; however the use of the revised toxicity valuewaswas 0.71 under the previous toxicity value; however the use of the revised toxicity value resulted in an HI greater than up to an HI of 2.4.resulted in an HI greater than 11 up to an HI of 2.4.
In summary, the greatest potential future carcinogenic risk attributable to the Site isIn summary, the greatest potential future carcinogenic risk attributable to the Site is associated with the ingestion of groundwater. The potential cancer risk and non-cancerassociated with the ingestion of groundwater. The potential cancer risk and non-cancer Hazard Indices are based on current levels of groundwater contaminants.Hazard Indices are based on current levels of groundwater contaminants.
Ecological Risk AssessmentEcological Risk Assessment
The potential risk to ecological receptors was evaluatedevaluatedThe potential risk to ecological receptors was ... For there to be an exposure,For there to be an exposure, there must be pathway through which receptor (e.g. plant, animal) comes into contactthere must be aa pathway through which aa receptor (e.g. plant, animal) comes into contact with one or more of the contaminants of potential concern. WithoutWithout aa complete pathwaywith one ormore of the contaminants of potential concern. complete pathway or receptor, there is no exposure and hence, rio risk.or receptor, there is no exposure and hence, 1')0 risk.
Based on review of existing data, there no ecological receptorsecological receptors at the Site.at the Site. As noted above, all of the contaminated soil and Based on aa review of existing data, there areare no potential exposure pathways forpotential exposure pathways for
As noted above, all of the contaminated soil and sediment have been excavated and disposed of off-site.sediment have been excavated and disposed of off-site. The depth to groundwater (theThe depth to groundwater (the
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I medium !Of concern) is approximately 30 ft and is unlikely to affect any surface water ~odies.bodies. {; " rnedium ,of concern) is approximately 30 ft and is unlikely to affect any surface water
, '
UncertaintiesUncertainties " I
~he to risks as in allall such assessments, are subject to wide variety of uncertainties. In general, the main sources The probedures andprocedures and inputsinputs usedused to assessassess risks inin thisthis evaluation,evaluation, as in such assessments, are subject to aa wide variety of uncertainties. In general, the main sources of uncertainty include the following: environmental chemistry sampling and analysis;of uncertainty include the following: environmental chemistry sampling and analysis;' environnientar parameter measurement; ,fatemeasurement; fate and transport modeling; exposure, environ~ental "parameter and transport modeling; exposure 'paramet~rparameter estimation; and toxicological data.estimation; and toxicological data. Uncertainty in environmental samplingUncertainty in environmental sampling arises injpart from the potentially uneven distribution of chemicals inthe media sampled.
there significant uncertainty toto the actual levels present. arises injpart from the potentially uneven distribution of chemicals in the media sampled. ConseqLjently,Consequently, there cancan bebe significant uncertainty asas the actual levels present. Environmental chemistry-analysis error can stem from several sources, including theEnvironmental chemistry.;analysis error can stem from several sources, including the errors inherent in the analytical methods and characteristics of the matrix being sampled.errors inherent in the analytical methods and characteristics of the matrix being sampled. , ,
UncertaintiesUncertainties inin thethe exposure a,ssessment areexposure assessment are related to estimates of how often anrelated to estimates of how often an individual would actually come in contact with the COCs, the period of time over whichindividual would actually come in contact withfhe COCs, the period of time over which such exposure would occur, and the fate and transport models used to estimate the concent~ationsconcentrations of the chemicals of concern at the point ofof the chemicals of concern aUhe point of exposure.exposure. ' ' such exposure would occur, and the fate and transport models used to estimate the
I' '
Uncertairties' in toxicological data occur in extrapolating both from animals to humansUncertaiiities 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 theand from high to low doses of exposure, as well as from the difficulties in assessing the II
toxicitytoxicity ofof mixture of chemicals.of chemicals. TheseThese uncertainties are addressed by making conservative assumptions concerning risk and exposureexposure parameters throughout theparameters throughout the
aa mixture uncertainties are addressed ,by making bonselliative assumptions concerning risk and I " ' '
9ssessment.assessment. As a result, the Risk Assessment provides upper-bound estimates of theAs aresult, the Risk Assessment provides upper-bound estimates of the risks to populations near the Site, and it is highly unlikely to underestimate actual risksrisks to populations near the Site, and it is highly unlikely to underestimate actual risks related to the Site. More specific information concerning public health risks, includingrelated to the Site. More specific information concerning public health risks, including aa quantitative evaluation of the degree of risk associated with various exposure pathways is, quantitative evaluation of the degree of risk associated with various exposure pathways is presented in the updated 2008 risk assessment.,presented in the updated 2008 risk assessment. ,
Ii ' Basis for ActionBasis for Action I I • . •I'II
iili ',Based upon the results of the RI, the risk assessment" and updated 2008 riskBased upon the results of the Rl, the risk assessment, and updated 2008 risk assessment, EPA has determined that the action selected in this ROD Amendment isassessment, EPA has determined that the action selected in this ROD Amendment is necessary to protect the public health or welfare or the environment from actual ornecessary to protect the public health or welfare or the environment from actual or threatened releases of hazardous substances into the environment.threatened releases of hazardous substances into the environment.
'I '
REMEDIAL ACTION OBJECTIVESREMEDIAL ACTION OBJECTIVES Ii!
Remedial action objectives (RAOs) are specific goals to protect human health and theRemedial action objectives (RAOs) are specific goals to protect human health and the environment. These objectives are based on available information and standards such~nvironment. These objectives are based on available information and standards such as Applicable or Relevant and Appropriate Requirements (ARARs) for drinking water.as Applicable or Relevant and Appropriate Requirements (ARARs) for drinking water.
The following RAOs are established for the Site groundwater:The following RAOs are established for the Site groundwater:
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Restore Site~wide 10• Restore Site-wide^° groundwater quality to levels which meet state and federalgroundwater quality to levels which meet state and federal drinking-water standardswlthin aa reasonable time frame; and .drinking-water standards within reasonable time frame; and
• contact inhalationReduceReduce oror eliminateeliminate any directany direct contact oror inhalation threatthreat associatedassociated withwith contaminated groundwater.contaminated groundwater.
DESCRIPTION OF ALTERNATIVESDESCRIPTION OF ALTERNATIVES
CERCLA§121(b)(1), 42 U.S.C. §9621(b)(1), mandates that remedial actions must beCERCLA §121(b)(1), 42 U.S.C. §9621(b)(1), mandates that remedial actions must be protective of human health and the environment, cost-effective, comply with ARARS, and utilize permanent' solutionspermanent and alternative treatment technologies and resource protective of human health and the environment, cost-effective, comply with ARARS, and utilize solutions and alternative treatment technologies and resource recoveryrecovery alternatives to the maximum extent practicable. Section 121 (b)(1) alsoalternatives to the maximum extent practicable. Section 121(b)(1) also establishes preference for remedial actions which employ, as aa principal element,principal element,establishes aa preference for remedial actions which employ, as treatment to permanently and significantly reduce the volume, toxicity, or mobility of thetreatment to permanently and significantly reduce the volume, toxicity, or mobility of the hazardous substances, pollutants, and contaminants at site. CERCLA §121 (d), 42hazardous substances, pollutants, and contaminants at aa site. CERCLA §121(d), 42 U.S.C. §9621 (d), further specifies that remedial action must attain level or standard ofU.S.C. §9621 (d), further specifies that aa remedial action must attain aa level or standard of control of the hazardous substances, pollutants, and contaminants that at least attainscontrol of the hazardous substances, pollutants, and contaminants that at least attains ARARs under federal and statestate laws, unlessunless aa waiverwaiver can be justified pursuant tobe justified pursuant toARARs· under federal and laws, can CERCLA §121 (d)(4), 42 U.S.C. §9621 (d)(4).CERCLA §121 (d)(4), 42 U.S.C. §9621 (d)(4).
evaluated address Site-widealternatives Site-wideTheThe 2000· ROD2000 ROD evaluated three. remedialthree remedial alternatives toto address thethe groundwater contamination: no action; MNA; and groundwater extraction and treatment.groundwater contamination: no action; MNA; and groundwater extraction and treatment. At that time, there was insufficient data to demonstrate that MNA was occurring at theAt that time, there was insufficient data to demonstrate that MNA was occurring at the Site.Site. Groundwater extraction and treatmenttreatment waswas in the ROD as thethe mostGroundwater extraction and selected in the ROD asselected most appropriate alternative.appropriate alternative. As described above, since the ROD, MNA has been evaluatedAs described above, since the ROD, MNA has been evaluated further and now sufficient data exists which that MNA is occurring at thefurther and now sufficient data exists which demonstratesdemonstrates that MNA is occurring at the Site, except in the MW-19 Area.Site, except in the MW-19 Area. The Focused Feasibility Study Report (Revision 2)The Focused Feasibility Study Report (Revision 2) (WSP Engineering, 2011) evaluates no action, MNA, and groundwater extraction and(WSP Engineering, 2011) evaluates no action, MNA, and groundwater extraction and treatment.treatment.
Detailed descriptionsdescriptions of theof the remedial alternativesalternatives for addressing the contaminationfor addressing the contaminationDetailed remedial associated with the Site (excluding the MW-19 Area) can be found in the FFS report.associated with the Site (excluding the MW-19 Area) can be found in the FFSreport.
Since the PRP Group effectuated deed restriction with the current Site property ownerSince the PRP Group effectuated aa deed restriction with the current Site property owner· to prohibit, among other things, the installation and use of groundwater wells at the Site,to prohibit, among other things, the installation and use of groundwater wells at the Site, this institutional control is considered component of all of the remedial alternativesthis institutional control is considered aa component of all of the remedial alternatives described below.described below.
1010 EPA concluded that since the source of the groundwater contamination in the MW-19 Area couldEPA concluded that since the source of the groundwater contamination in the MW-19 Area could notnot be identifiedbe identified despite multiple investigations, further efforts to try to identify the source woulddespite multiple investigations, further efforts to try to identify the source would likely be fruitless, and remedial action in the MW-19 Area to address the source or to address thelikely be fruitless, and remedial action in the MW-19 Area to address the source or to address the groundwater contamination is not warranted due to technical impracticability from an engineeringgroundwater contamination is not warranted due to technical impracticability from an engineering perspective.perspective.
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',. . ,. .'.
The construction time for each alternative reflects only the time required to construct or implement the remedy and does not include the time required to design the remedy, The construction time for each alternative reflects only the time required to construct or implement the remedy and does not include the time required to design the remedy, negotiate the performance of the remedy with the responsibleresponsible parties,parties, procurenegotiate the performance of the remedy with the oror procure contracts for designcontracts for design andand construction.construction. The present-worth costs for the alternativesThe present-worth costs for the alternatives ~iscussed below are calculated using aa discount rate of seven percent and aa 30-year timediscussed below are calculated using discount rate of seven percent and 30-year timeIIinterval.interval. - -
The alternatives described below have been renumbered from the FFS Report to facilitateThe alternatives described below have been renumbered from the FFS Report io facilitate the presentation of the analysis.the presentation of the analysis.
No ActionAlternative GW-1:Alternative GW-1: No Action 1:II . .
Capital Cost: $0Capital Cost: $0 Annual Monitoring Cost: $0Annual Monitoring Cost: $0 Present-Worth Cost: $0Present-Worth Cost: $0
Construction Time: omonthsConstruction Time: 0 months
The Superfund program requires that the "no-action" alternative be considered as aaThe Superfund program requires that the "no-action" alternative be considered as baseline for comparison with the other alternatives.baseline for comparison with the other alternatives. The no-action remedial alternativeThe no-action remedial alternative ~oes not include any measures problem ofdoes not include any physical- remedialphysical remedial measures thatthat addressaddress thethe problem of groundwater contamination at the Site.groundwater contamination at the Site.- '
Because this alternative would result in contaminants remaining on-site above levels thatBecause this alternative would result in contaminants remaining on-site above levels that allow for unrestricted use and unlimited exposure, CERCLA requires that the Site bepllow for unrestricted use and unlimited exposure, CERCLA requires that the Site be Ifeviewedreviewed everyevery five years.years. by the review,' remedialremedial actions maymayfive If justified by the review, beIf justified actions be implemented in the future to remove or treat the contamination.,implemented in the future to remove or treat the contamination. _
Alternative GW-2: Monitored Natural Attenuation:Alternative GW-2: Monitored Natural Attenuation
Capital Cost:Capital Cost: $65,600$65,600 i ' ' • • • ,
Annual Monitoring Cost:Annual Monitoring Cost: $134,800$134,800
Present-Worth Cost: $1,775,000$1,775,000-Present-Worth Cost:
Construction Time:Construction Time: 0 monthsomonths II
I: Under this alternative, the groundwater contamination would be addressed through,Under this alternative, the groundwater contamination would be addressed through natural attenuation processes {i.e., biodegradation, dispersion, sorption, volatilization,batural attenuation processes (i.e., biodegradation, dispersion, sorption, volatilization, and oxidation-reductionoxidation-reduction reactions). As part of long-term groundwater monitoringlong-term groundwater monitoringand reactions). As part of aa program, performance monitoring plan would be needed to monitor the effectiveness ofprogram, aa performance monitoring plan would be needed to monitor the effectiveness of the MNA remedy.,~he MNA remedy.
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For cost estimating purposes, groundwater samples were assumed to be collected andFor cost estimating purposes, groundwater samples were assumed to be collected and analyzed quarterly in order to verify that the level and extent of groundwater contaminantsanalyzed quarterly in order to verify that the level and extent of groundwater contaminants (e.g., VOCs) are declining and that conditions are protective of human health and ~he{e.g., VOCs) are declining and that conditions are protective of human health and the environment. In addition, biodegradation parameters (e.g., dissolved oxygen, nitrate,environment.. In addition, biodegradation parameters (e.g., dissolved oxygen, nitrate,
ethane, alkalinity, potential, temperature,temperature,sulfate,sulfate, methane,methane, ethane, ethene,ethene, alkalinity, redoxredox potential, pH,pH,. .
conductivity, chloride, sulfide, iron, and organic carbon) would be used to assess theconductivity; chloride, sulfide, iron, and totaltotal organic carbon) would be used to assess the progress of the degradation process.progress of the degradation process.
The capital cost associated with this alternative is for the preparation of aa performance monitoring plan. For the present worth cost calculation, aa 3D-year monitoring time wasFor the present worth cost calculation,The capital cost associated with this alternative is for the preparation of performance monitoring plan. 30-year monitoring time was assumed.assumed.
Because this alternative would result in contaminants remaining on-site which exceedBecause this alternative would result in contaminants remaining on-site which exceed acceptable health-based levels, CERCLA requires that the Site be reviewed every fiveacceptable health-based levels, CERCLA requires that the Site be reviewed every five years.years. If justified by the review, additional actions may be implemented.If justified by the review, additional actions may be implemented.
Groundwater Extraction and TreatmentAlternative GW-3:Alternative GW-3: Groundwater Extraction and Treatment
Capital Cost:;Capital Cost:; $792,000$792,000
Annual Operation, Monitoring andAnnual Operation, Monitoring arid $125,000$125,000
Maintenance (OM&M) Cost:Maintenance (OM&M) Cost:
Present-Worth Cost:Present-Worth Cost: $2,381,000$2,381,000
Construction Time:Construction Time: 3 months 3 months
Under this alternative, aa network of recovery wells would be used to extract contaminatedUnder this alternative, network of recovery wells would be used to extract contaminated groundwater which would be and discharged to surface water.groundwater which would be treatedtreated and discharged to surface water.
As part of a long-term groundwater monitoring program to evaluate the effectiveness ofAs part of along-term groundwater monitoring program to evaluate the effectiveness of the groundwater extraction and treatment remedy, an OM&M Plan would be needed.the groundwater extraction and treatment remedy, an OM&M Plan would be needed.
3D-year operation time used and groundwaterFor cost estimating purposes,For cost estimating purposes, aa 30-year operation time waswas used and groundwater sampling was assumed to be collected and analyzed semiannually.sampling was assumed to be collected and analyzed semiannually.
Because this alternative would· result in contaminants remaining on-site which exceedBecause this alternative would result in contaminants remaining on-site which exceed acceptable health-based levels, CERCLA requires that the Site be reviewed every fiveacceptable health-based levels, CERCLA requires that the Site be reviewed every five years.years. If justified by the review, additional actions may be implemented.If justified by the review, additional actions may be implemented.
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II
I I
c:OMPARATIVE ANALYSIS OF ALTERNATIVESCOMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting remedy, EPA considered the factors set out in CERCLA Section 121, 42In selecting aa remedy, EPA considered the factors set out in CERCLA Section 121, 42 U.S.C. by conducting detailed analysis of the viable remedial- alternativesdetailed analysis of the viable remedial-alternativesU.S.C. §9621§9621 ,, by conducting aa
the 40 OSWER 9355.3-01pursuantpursuant toto the NCP,NCP, 40 CFRCFR §300.430(e)(9),§300.430(e)(9), andand OSWER DirectiveDirective 9355.3-01 Conducting Investigations Feasibility underunder(Guidance{Guidance forfor Conducting RemedialRemedial Investigations andand Feasibility StudiesStudies
CERCLA: Interim Final,CERCLA: Interim Final, EPA, OctoberEPA, October 1988).1988). The detailed analysis consisted of anThe detailed analysis consisted of an assessment of the individual alternatives against each of nine evaluation criteria andassessm1ent of the individual alternatives against each of nine evaluation criteria and aa comparative analysis focusing upon the relative performance of each alternative againstcomparative analysis focusing upon the relative performance of each alternative against those criteria.those criteria.
The following "threshold" criteria are the most important and must be satisfied by anyThe following "threshold" criteria are the most important and must be satisfied by any alternative in order to be eligible for selection:alternative in order to be eligible for selection:
1.1. Overall protection of human health and the environment addresses whether or notOverall protection ofhuman health and the environment addresses whether or not remedy provides adequate protection and describes how risks posed throughaa remedy provides adequate protection and describes how risks posed through
each exposure pathway (based on a reasonable maximum exposure scenario) areeach exposure pathway (based ona reasonable maximum exposure scenario) are eliminated, reduced,eliminated, reduced, or controlled through treatment, engineering controls, oror controlled through treatment, engineering controls, or institutional controls.institutional controls.
2. Compliance with ARARsCompliance with ARARs addresses whether or notaddresses whether or not aa remedy would meet all of the2. remedy would meet all of the applicable or relevant and appropriate requirements of other federal and stateapplicable or relevant and appropriate requirements of other federal and state environmental statutes and requirements or the circumstances to provide groundsenvironmental statutes and requirements or the circumstances to provide grounds for invoking waiver.for invoking aa waiver.
The following "primary balancing" criteria are used to make comparisons and to identifyThe following "primary balancing" criteria are used to make comparisons and to identify the major tradeoffs between alternatives:the major tradeoffs between alternatives:
':
Long-Term effectiveness and permanence refers to the ability of aa remedy to3.3. Long-Term effectiveness and permanence refers to the ability of remedy to !I
maintain reliable protection of human health and the environment overtime, oncemaintain reliable protection of human health and the environment over time, once cleanup goals have been met. It also addresses the magnitude and effectivenesscleanup goals have been met. It also addresses the magnitude and effectiveness of the measures that may be required to manage the risk posed by treatmentof the measures that may be required to manage the risk posed by treatment residuals and/or untreated wastes.residuals and/or untreated wastes.
4.~.. Reduction of toxicity, mobility, oror volumevolume throughthrough treatment is the anticipatedReduction of toxicity, mobility, treatment is the anticipated performance of the treatment technologies, with respect to these parameters, aperformance of the treatment technologies, with respect to these parameters,a remedy may employ.remedy may employ.
Short-term addresses the period time needed to achieve protection and any adverse impacts on human health and the environment that
5.5. Short-term effectivenesseffectiveness addresses the period ofof time needed to achieve protection and any adverse impacts on human health and the environment that may be posed during the construction and implementation period until cleanupmay be posed· during the construction and implementation period until cleanup goals are achieved.goals are achieved.
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Implementability is thethe and feasibility of· aa remedy,remedy, includingincluding the availability of materials andand services neededneeded to implementimplement
6.6. Implementability is technicaltechnical and administrativeadministrative feasibility ofthe availability of materials services to aa
particular option.particular option. .
7.7. CostCost includes estimated capital, operation and maintenance and net present-worthincludes estimated capital, operation and maintenance and net present-worth costs.costs. .
following "modifying" are inin the final evaluation remedialremedial·TheThe following "modifying" criteriacriteria are usedused the final evaluation of theof the alternatives after the formalalternatives after the formal comment period,period, and may prompt modificationmay prompt modification of thecomment and of the preferred remedy thatpreferred remedy that waswas presented in the Superfund Proposed Plan for Remedy·presented in the Superfund Proposed Plan for Remedy Modification:Modification:
8. acceptance whether, on review the Revised MonitoredMonitored Natural AttenuationNatural Attenuation Evaluation Report, 2008 FFS
8. StateState acceptance indicatesindicates whether, basedbased on itsits review ofof. the Revised ComprehensiveComprehensive Evaluation Report, 2008 FFS report, and Superfund Proposed Plan for Remedy Modification, the State concursreport, and Superfund Proposed Plan for Remedy Modification, the State concurs with, opposes, or has no comments on the selected modified remedy. .with, opposes, or has no comments on the selected modified remedy.
9.9. Community acceptanceCommunity acceptance refers to the public's general response to the alternativesrefers to the public's general response to the alternatives described in the 2008 FFS report and Superfund Proposed Plan for Remedydescribed in· the 2008 FFS report and Superfund Proposed Plan for Remedy Modification.Modification.
AA comparative analysis of these alternatives based upon the evaluation criteria. noted·comparative analysis of these alternatives based upon the evaluation criteria noted above, follows.above, follows.
Overall Protection of Human Health and the EnvironmentOverall Protection of Human Health and the Environment
Although Alternative GW-3 would rely upon extraction and treatment of contaminated: Although Alternative GW-3 would rely upon extraction and treatment of contaminated groundwater to restore to groundwater while Alternative GW-1 and Alternativeand Alternative GW-2GW-2 .groundwater to restore to groundwater while Alternative GW-1 would rely upon natural attenuation to restore groundwater quality to drinking waterwould rely upon natural attenuation to restore groundwater quality to drinking water standards,standards, based upon preliminary modeling results,results, it isis estimated that all threeall threebased upon preliminary modeling it estimated that
.alternatives would resultalternatives would result inin thethe restoration of groundwater quality torestoration of groundwater quality to drinkingdrinking waterwater standards in approximately 50 years. Under Alternative GW-1, however, since monitoringstandards in approximately 50 years. Under Alternative GW-1, however, since monitoring. would not be performed, there would be no way to gauge the overall protectiveness of thewould not be performed, there would be no way to gauge the overall protectiveness of the remedy.remedy.
Until groundwater standards are met under all of the alternatives, human exposure to theUntil groundwater standards are met under all of the alternatives, human exposure to the contaminated groundwater would be mitigated through the existing deed restrictions thatcontaminated groundwater would be mitigated through the existing deed restrictions that would prevent thewould prevent the use of the shallow groundwater for drinking water purposes. Inuse of the shallow groundwater for drinking water purposes. In addition, five-year reviews would be conducted at the Site as described above.addition, five-year reviews would be conducted at the Site as described above.
Compliance with ARARsCompliance with ARARs
EPA and NYSDEC have promulgated health-protective MCLs, which are enforceableEPA and NYSDEC have promulgated health-protective MCLs, which are enforceable standards for various drinking water contaminants (chemical-specific ARARs).standards for various drinking water contaminants (chemical-specific ARARs). WhileWhile
:1 .
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I
I contamination from the Site has not been found in any existing private wells in the vicinitycontamiriation from the Site has not been found in any existing private wells in the vicinity of the Site, groundwater contamination at the Site itself presents human health cancerof the Site, groundwater contamination at the Site itself presents human health cancer risks for future on-site residents and workers if not addressed by one of the remedialrisks for future on-site residents and workers if not addressed by one of the remedial
· alternatives.alternatives.
I Alternatives GW-1 and GW-2 do not provide for any direct remediation of groundwaterAlternatives GW-1 and GW-2 do not provide for any direct remediation of groundwater and would; therefore, rely upon natural attenuation to achieve chemical-specific ARARs.and would, therefore, rely upon natural attenuation to achieve chemical-specific ARARs. Based upon groundwater modeling, all three alternatives would be effective in reducing groundwater contaminantcontaminant concentrations belowbelow MCLs. UnderUnder GW-1, Based upon groundwater modeling, all three alternatives would be effective in reducing
concentrations Alternativegroundwater MCLs. Alternative GW-1, rowever; since monitoring would not be performed, there would be no way togauge thehowever, since monitoring would not be performed, there would be no way to gauge the effectiveressofthe remedy in meeting ARARs.effectiveness of the remedy in meeting ARARs.
I^ i ' • ' •
~ong-Term Effectiveness and PermanenceLong-Term Effectiveness and Permanence ..
Alternative GW-1 and Alternative GW-2 would rely upon natural attenuation to restoreAlternative GW-1 and Alternative GW-2 would rely upon natural attenuation to restore groundwater quality to drinking water standards, whereas the Alternative GW-3 would
and treatment of groundwater to to groundwater quality to drinking water standards, whereas the Alternative GW-3 would relyrely uponupon extractionextraction and treatment of contaminatedcontaminated groundwater to restorerestore to groundwater.groundwater. Based on modeling results, allall three alternativesalternatives wouldwould result inin theBased on modeling results, three result the restoration of groundwater quality to drinking water standards in approximately 50 years;restoration of groundwater quality to drinking water standards in approximately 50 years;
· therefore,therefore, thethe havehave similar long-termlong-term effectiveness andandalternatives similar permanence.permanence.alternatives effectiveness Under Alternative GW-1, however, since monitoring would not be performed, there wouldUnder Alternative GW-1, however, since monitoring would not be performed, there would be no way to gauge the long-term effectiveness and permanence of the remedy.be no way to gauge the long-term effectiveness and permanence of the remedy.
treatment which have bewould to. beAlternativeAlternative GW-3GW-3 would generategenerate treatment residuesresidues which wouldwould· have toappropriately handled; Alternatives GW-1 and GW-2 would not generate such residues.appropriately handled; Alternatives GW-1 and GW-2 would not generate such residues.
Reduction of Toxicity, Mobility, or Volume Through Treatmentfeduction of Toxicity, Mobility, or Volume Through Treatment ,.
Alternatives GW-1 and GW-2 would rely upon natural attenuation, not treatment, toAlternatives GW-1 and GW-2 would rely upon natural attenuation, not treatment, to . reduce the volume of contaminants. Collecting and treating contaminated groundwater.~educethe volume of contaminants. Collecting and treating contaminated groundwater Linder Alternative GW-3, on the other hand, would reduce the toxicity, mobility, andILnder Alternative GW-3, on the other hand, would reduce the toxicity, mobility, and volume of contaminants through treatment, thereby satisfying CERCLA's preference forVolume of contaminants through treatment, thereby satisfying CERCLA's preference for, .
treatment.treatment. However, as noted earlier, because of the low hydraulic conductivity of theHowever, as noted earlier, because of the low hydraulic conductivity of the I .
till, pumping the contaminated groundwater present in the shallow zone at this Site willtill, pumping the contaminated groundwater present in the shallow zone at this Site will · yieldyield aa very small volume.very small volume. As result, collecting the contaminated groundwater forAs aa result, collecting the contaminated groundwater for
treatment would be difficult and inefficient.treatment would be difficult and inefficient.·
Short-Term Effectiveness.Short-Term Effectiveness
Alternatives GW-1 and GW-2 do not include any active remediation; therefore, they woujdAlternatives GW-1 and GW-2 do not include any active remediation; therefore, theywou!d not present an additional risk to the community or workers resulting from activities at thenot present an additional risk to the community or workers resulting from activities at the Site. Alternatives GW-2 and GW-3 might present some limited risk to on-site workers~ite .. Alternatives GW-2 and GW-3 might present some limited risk to on-site workers
contact and .inhalation to activities.throughthrough dermaldermal contact and inhalation relatedrelated to groundwatergroundwater samplingsampling activities. Alternative GW-3 would pose an additional risk to on-site workers since it would involveAlternative GW-3 would pose an additional risk to on-site workers since it would involve
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. • • • • • • • i ^ . '
Thethe installation of extraction wells through potentially contaminated groundwater.the installation of extraction wells through potentially contaminated groundwater. The risks to on-site workers could, however, be minimized by' utilizing proper protectiverisks to on-site workers could, however, be minimized by utilizing proper protective equipment.equipment.
no be performed under Alternative GW-1,' there would implementation time. ItIt is estimated that Alternative GW-2 would requireis estimated that Alternative GW-2 would require aa month to SinceSince no actions would under Alternative be noactions would be performed GW-1, there would be no implementation time. month to implement, since developing long-term groundwater monitoring program would be theimplement, since developing aa long,..term groundwater monitoring program would be the only activity that is required.required. It is estimated that theestimated that the groundwater extraction andonly activity that is It is groundwater extraction and treatment systems under Alternative GW-3 would be constructed in three months.treatment systems under Alternative GW-3 would be constructed in three months.
Based upon groundwater modeling results, it has been estimated that the contaminatedBased upon groundwater modeling results, it has been estimated that the contaminated groundwater would naturally attenuate to groundwater standards (under Alternativesgroundwater would naturally attenuate to groundwater standards (under Alternatives
and years. It is also estimated under Alternative. GW-3,GW-1GW-1 and GW-2)GW-2) inin 5050 years. It is also estimated thatthat under Alternative GW-3, groundwater standards would be met after 50 of extractionof extraction and treatment.treatment.standards would met after years andgroundwater be 50 years
long as the Alternatives GW-1 and GW-2AlternativeAlternative GW-3GW-3 is estimated to takeis estimated to take asas long as the Alternatives GW-1 and GW-2 because of the low yielding shallow groundwater atbecause of the low yielding shallow groundwat~rat site.site.
ImplementabilityImplementability
Alternative GW-1 would be the easiest groundwater alternative to implement, since itAlternative GW-1 would be the easiest groundwater alternative to implement, since it would require no activities.would require no activities. With the performance of monitoring of natural attenuationWith the performance of monitoring of natural attenuation parameters to demonstrate that it is reliable in achieving the specified performance goals,parameters to demonstrate that it is reliable in achieving the specified performance goals, Alternative GW-2 would require more effort to implement than Alternative GW-1, butAlternative GW-2 would require more effort to implement than Alternative GW-1, but would be easily implemented.would be easily implemented. Alternative GW-3 would be the most difficult to implementAlternative GW-3would be the most difficult to implement in that it would require the construction of groundwater extraction system andin that it would require the construction of aa groundwater extraction system and pipelinespipelines... The services and materials that would be required for the implementation of all of theThe services and materials that would be required for the implementation of all of the groundwater remedial alternatives areare readily available. However, as noted earlier,groundwater remedial alternatives readily available. However, as noted earlier, becausebecause .ofof the lowlow hydraulic conductivity of the till, pumping the contaminatedthe hydraulic conductivity of the till, pumping the contaminated groundwater present in the shallow zone at this Site for Alternative GW-3 will yield verygroundwater present in the shallow zone at this Site for Alternative GW-3 will yield aa very small volume. AsAs aa result, collecting the contaminated groundwater for treatment wouldsmall volume. result, collecting the contaminated groundwater for treatment would be difficult and inefficient.be difficult and inefficient.
All of the treatment equipment that would be utilized in Alternatives GW-3 are proven andAll of the treatment equipment that would be utilized in Alternatives GW-3 are proven and commercially available.commercially available. Transportation and disposal of treatment residues could beTransportation and disposal of treatment residues could be easily implemented using commercially-available equipment. Under these alternatives,easily implemented using commercially-available equipment. . Under these alternatives, sampling for treatment effectiveness and groundwater monitoring would be necessary,sampling for treatment effectiveness and groundwater monitoring would be necessary, but could be easily implemented.but could be easily implemented.
CostCost
capital, operation, and/or andandTheThe estimatedestimated capital, annualannual operation, monitoring,monitoring, and/or maintenance,maintenance,present-worth costs for each of the alternatives are presented below. Present-worth costspresent-worth costs for each of the alternatives are presented below. Present-worthcosts are calculated using discount rate of seven percent and 30-year time interval.are calculated using aa discount rate of seven percent and aa 30-year time interval.
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Alternative Capital . Annual Present-Worth CostAlternative Capital Annual Present-Worth Cost Cost CostCost Cost
~~::;;;-;-:-~.,.,-..".,.~~~~~c:--:-:-=~
i .GW-1 . ^ •$o , •' " " , ' y „$0' , " .„ , $0 1
GW-2GW-2 $65,600$65,600 $134,800$134,800 $1,774,000$1,774,000
I,:;.,: Gmi, : $792,000 5125,000 >• , , . , . ' $2,381,000:
As be by theby the cost estimates, thecost estimates, the least costly alternativeleast costly alternative isis GW-1GW-1 at $0. Alternative GW-3 is the most costly alternative at $2,381,000. As cancan be seenseen at $0. Alternative GW-3 is the most costly alternative at $2,381,000.
State AcceptanceState Acceptance
NYSDECNYSDEC concurs with the selected' modifiedmodified groundwater remedy;remedy; aa letter ofconcurs with the selected groundwater letter of concurrence is attached (see Appendix IV).concurrence is attached (see Appendix IV).
Community AcceptanceCommunity Acceptance
Comments received during the public comment period indicate that the public generally~omments received during the public comment period indicate that the public generally supports the selected modified groundwater remedy.~upports the selected modified groundwater remedy. These comments are summarizedThese comments are summarized and addressed in the Responsiveness Summary, which is attached as Appendix to thisand addressed in the Responsiveness Summary, which is attached as Appendix VV to this document.document.
SELECTED MODIFIED GROUNDWATER REMEDYSELECTED MODIFIED GROUNDWATER REMEDY
Summary of the Rationale for the Selected Modified Groundwater Remedy$ummary of the Rationale for the Selected Modified Groundwater Remedy
Based upon an evaluation of the various groundwater alternatives, Alternative GW-2,Based upon an evaluation of the various groundwater alternatives, Alternative GW-2,II. .
Monitored Natural Attenuation, provides the best balance of tradeoffs with respect to theMonitored Natural Attenuation, provides the best balance of tradeoffs with respect to the evaluation~valuation criteriacriteria asas describeddescribed below.below. UnderUnder thisthis alternative,alternative, thethe groundwatergroundwater
be through attenuation (i.e.,{i.e.,contamination~ontamination willwill be addressedaddressed through naturalnatural attenuation processesprocessesbiodegradation, dispersion, sorption, volatilization, and oxidation-reduction reactions).biodegradation,- dispersion, sorption, volatilization, and oxidation-reduction reactions). As part of a long-term groundwater monitoring program, groundwater samples will beAs part of along-term groundwater monitoring' program,groundwater samples will be collectedcollected andand analyzed periodically inin orderorder toto verify that the levellevel andand extentextent ofanalyzed periodically verify that the of groundwater contaminants (e.g., VOCs) are declining and that conditions are protectivegroundwater contaminants (e.g., VQCs) are declining and that conditions are protective of human healthof human health and the environment.and the environment. In addition, biodegradation parameters (e.g.,In addition, biodegradation parameters (e.g., dissolved oxygen, nitrate, sulfate, methane, ethane, ethene, alkalinity, redox potential,~issolved oxygen, nitrate, sulfate, methane, ethane, ethene, alkalinity, redox potential, pH, temperature, conductivity, chloride, sulfide, iron, and organic carbon) would bepH, temperature, conductivity, chloride, sulfide, iron, and totaltotal organic carbon) would be !Jsedused to assess the progress of the degradation process.to assess the progress of the degradation process. The installation and use ofThe installation and use of groundwater wells at the Site for drinking water purposes will be prohibited by the existinggroundwater wells atthe Site for drinking water purposes will be prohibited bythe existing deed restriction.deed restriction. This selected remedy includes an informational institutional control toThis selected remedy includes an informational institutional control to notify prospective builders of soil vapor intrusion concerns which could be addressed by. hotify prospective builders of soil vapor intrusion concerns which could be addressed by
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soil vapor intrusion evaluation and, if needed, .vapor mitigation, or alternatively just soil.· vapor mitigation. . soil vapor intrusion evaluation and, if needed, vapor mitigation, or alternatively just soil vapor mitigation.
While Alternative GW.,3 would actively treat the groundwater and Alternatives GW~1 andWhile Alternative GW-3 would actively treat the groundwater and Alternatives GW-1 and GW-2 would rely upon natural attenuation, it is estimated that it would take 50 years toGW-2 would rely upon natural attenuation, it is estimated that it would take 50 years to achieve groundwater standards under all three alternatives. However, as noted earlier, because of the low hydraulic conductivityhydraulic conductivity of thethe till, pumpingpumping the contaminatedcontaminated achieve groundwater standards under all three alternatives. However, as noted earlier, because of the low of till, the groundwater present in the shallow zone at this Site will yield very small . Asgroundwater present in the shallow zone at this Site will yield aa very small volumevolume.. As aa result, collecting the contaminated groundwater for treatment would be difficult andresult, collecting the contaminated groundwater for treatment would be difficult and· inefficient.inefficient. Alternative GW-3 is, however, significantly more costly than AlternativesAlternative GW-3 is, however,significantly more costly than Alternatives GW-1GW-1 andand GW-2GW-2... While Alternative GW-1 would achieve the cleanup objectives in theWhile Alternative GW-1 would achieve the cleanup objectives in the same time frame as the other alternatives and would be the least costly alternative, since .same time frame as the other alternatives and would be the least costly alternative, since.· monitoring would not be performed under this alternative, there would be no way to gaugemonitoring would not be performed under this alternative, there would be no Way to gauge the overall effectiveness of the remedy. Therefore, EPA and NYSDEC believe thatEPA and NYSDEC believe thatthe overall effectiveness of the remedy. Therefore, Alternative GW-2 would minimize the migration of contaminated groundwater at the Site,Alternative GW-2 would minimize the migration of contaminated groundwater at the Site, while providing the best balance of tradeoffs among the alternatives with respect to thewhile providing the best balance of tradeoffs among the alternatives with respect to the nine evaluation criteria.nine evaluation criteria.
The selected modified remedy is protective of human health and the environment,. provides long-term effectiveness, will achieve the in reasonable time frame . The selected modified remedy is protective of human health and the environment, provides long-term effectiveness, will achieve the ARARsARARs in aa reasonable time frame (exceptto the extent that they are waived),(except to the extent that they are waived), and is cost-effective.and is cost-effective. Therefore, the modifiedTherefore, the modified selected remedy will provide the best balance of tradeoffs among the alternatives withselected remedy will provide the best balance of tradeoffs among the alternatives with respect to the evaluation criteria.respect to the evaluation criteria.
Description of the Selected Modified Groundwater RemedyDescription of the Selected Modified Groundwater Remedy
The of the modified remedy include the following: The major· componentsmajor components of the selectedselected modified groundwatergroundwater remedy include the following:
•• MNA of groundwater contamination throughout the Site, except in the "MW-19MNA of groundwater contamination throughout the Site, except in the "MW-19 Area;"Area;"
Long-term groundwater monitoring to verify that the level and extent of•• Long-term groundwater monitoring to verify that the level and extent of groundwater contaminants are declining within the timeframe projected and thatgroundwater contaminants are declining within the timeframe projected and that conditions are protective of human health and the environment; and,conditions are protective of human health and the environment; and,
•• Periodic monitoring of nearby residential private wells to ensure the effectiveness.Periodic monitoring of nearby residential private wells to ensure the effectiveness of the selected remedy.of the selected remedy.
MW-19 Area groundwater is located in an approximately 120 ft by 80 ft by 30 ft deepMW-19 Area groundwater is located in an approximately 120 ft by 80 ft by 30 ft deep technical impracticable zone. The chemical-specific ARARsARARs are waivedThe chemical-specific in this zone fortechnical impracticable zone. are waived in this zone for PCE, 1,1,1-TCA, 1,1-DCA, cis-1,2-DCE, and VC.PCE, 1,1,1-TCA, 1,1-DCA, cis-1,2-DCE, and VC.
Under this remedy, the installation and use of groundwater wells at the Site for drinkingUnder this remedy, the installation and use of groundwater wells at the Site for drinking
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water purposes are prohibited by an existing deed restriction.water purposes are prohibited by an existing deed restriction.
If, in the· future, structures are proposed to be built on the property, then aa soil vaporIf, in the future, structures are proposed to be built on the property, then soil vapor intrusion evaluation and, potentially, vapor mitigation may be needed, or alternatively just soil vapor mitigation. As aa governmental institutional control, the Office of the Town ofAsintrusion evaluation and, potentially, vapor mitigation may be needed, or alternatively just soil vapor mitigation. governmental institutional control, the Office of the Town of Fenton Building Inspector has acknowledged to EPA that such office will notify anyFenton Building Inspector has acknowledged to EPA that such office will notify any person S,eeking to build residential structures at the Site of soil vapor concerns relating toperson seeking to build residential structures at the Site of soil vapor concerns relating to ~he and specifically of the need for aa soil vapor evaluation and potentially, soilthe property, and specifically of the need forprop~rty, soil vapor evaluation and potentially, soil yapor Illijtigation systems or, alternatively just soil vapor mitigation.vapor mitigation systems or, alternatively just soil vapor mitigation.
I .
fhe soil land sediment component of the remedy selected in the 2000 ROD is not being modified,modified, byby this ROD Amendment.this ROD Amendment. The soil and sediment component of the remedy JThe soil jand sediment component of the remedy selected in the 2000 ROD is not being
The soil and sediment component of the remedy in During 2003 approximately 75,000 ofWaswas completedcompleted in 2003.2003. During thethe 2003 action,action, approximately 75,000 tonstons of
II , •
contaminated soil and sediment were excavated and disposed off-Site.contaminated soil and sediment were excavated and disposed off-Site. ,I:.. ' ','. .
:i Because the selected modified groundwater remedy will result in contaminants remainingBecause the selected modified groundwater remedy will result in contaminants remaining
. on-Site that exceed acceptable health-based levels, CERCLA requires that the Site be five If justified by the review,review, actions be
on-Site that exceed acceptable health-based levels, CERGLA requires that the Site be reviewedreviewed everyevery five years.years. If justified by the additionaladditional actions maymay be implementedimplemented
Summary of the Estimated Modified Groundwater Remedy CostsSummary of the Estimated Modified Groundwater Remedy Costs . . '.
The estimated capital, annual (cost to monitor groundwater), and present-worth costs·The estimated capital, annual (cost to monitor groundwater), and present-worth costs (using a 7% discount rate for period of 30 years) for the selected modified groundwater. (using a7% discount rate for aa period of 30 years) for the selected modified groundwater remedy are $65,600, $134,800,remedy are $65,600, $134,800, and $1,774,000, respectively.and $1,774,000, respectively. TableTable 1111 provides theprovides the basis for the cost estimate for the selected modified remedy.basis for the cost estimate for the selected modified remedy. 1
1 '. .
It should be noted that these cost estimates are order-of-magnitude engineering costIt should be noted that these cost estimates are order-of-magnitude engineering cost estimates that are expected to be within +50 to -30 percent of the actual projecit cost.~stimates that are expected to, be within +50 to -30 percent of the actual project cost. i!fh~seFhese cost estimates are basedbased on the best available information regarding the.cost estimates are on the best available information regarding the anticipated scope of the selected modified remedy.anticipated scope of the selected modified remedy. Changes in the cost elements mayChanges in the cost elementsmay bccur as result of new information and data collected during the annual monitoring ofbccur as aa result of new information and data collected during the annual monitoring of Ii
the modified groundwater remedy.the modified groundwater remedy.I
. , ' '. Expected Outcomes of the Selected Modified Groundwater RemedyExpected Outcomes of the Selected Modified Groundwater Remedy
The 2000 ROD called for excavation and off-Site treatment/disposal of contaminatedThe 2000. ROD called for excavation and off-Site treatmenUdisposal of contaminated soils and sediments, and extraction and on-Site treatment of the contaminatedsoils .and sediments, and extraction and on-Site treatment of the contaminated groundwater.groundwater. The results of post-soil remediation aquifer testing indicated that theThe results of post-soil remediation aquifer testing indicated that the selected groundwater remedy would not be effective in addressing the groundwaterselected groundwater remedy would not be effective in addressing the groundwater contamination. As aa result, the remedial alternatives for the groundwater component ofAscontamination. result, the remedial alternatives for the groundwater component of
. the remedy were reevaluated.the remedy were reevaluated. Land use associated with the Site has been discussedLand use associated with the Site has been discussed above and is not anticipated to change as result of the implementation of the selectedabove and is not anticipated to change as aa result of the implementation of the selected temedy.remedy. However, in the future, if structures are proposed to be built on the property.However, in the future, if structures are proposed to be built on the property,.
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then aa soil vapor intrusion evaluation and, potentially, vapor mitigation may be needed orthen soil vapor intrusion evaluation and, potentially, vapor mitigation may be needed or alternatively just soil vapor mitigation.alternatively just soil vapor mitigation.
The current action addresses the groundwateL . The results of the risk assessmentThe current action addresses the groundwater. The results of the risk assessment indicate that the hypothetical future. use of the groundwater at the Site will· pose anindicate that the hypothetical future use of the groundwater at the Site will pose an unacceptable increased future cancer risk and an unacceptable non-cancer hazard risk to human health.to human health. Under the selected alternative, the groundwater contamination would unacceptable increased future cancer risk and an unacceptable non-cancer hazard risk
.Under the selected alternative, the groundwater contamination would bebe addressedaddressed through natural attenuationattenuation and long-term groundwater monitoringthrough natural aand· along-term groundwater monitoring· program to verify that the level and extent of groundwater contaminants are declining andprogram to verify that the level and extent of groundwater contaminants are declining and that conditions are protective of human health and the environment.that conditions are protective of human health and the environment. Under the selectedUnder the selected remedy, the installation and use of groundwater wells at the Site for drinking waterremedy, the installation and use of groundwater wells at the Site for drinking water purposes would be prohibited by the existing deed restrictionpurposes would be prohibited by the existing deed restriction
By having had addressed thehad addressed the source material in 2003 and with MNA selected asasBy having source material in 2003 and with MNA selectedmodifiedmodified remedy,remedy, will restore thethe groundwater in the shallowshallowthis groundwater in thethis will restore unconsolidated.unconsolidated
. water-bearing zone in aa reasonable time frame by reducing contaminant levels to thewater-bearing zone in reasonable time frame by reducing contaminant levels to the federal and state MCLs. Also, with the existing deed restriction, the direct contact and inhalationinhalation threatthreat withwith the contaminatedcontaminated groundwater isis federal and state MCLs. Also, with the existing deed restriction, the direct contact and
associated groundwater Federal and state MCLs are presentedFederal and state MCLs are presented in Table 10.in Table.1 O. Achieving the cleanup levels will
associated the eliminated.eliminated. Achieving the cleanup levels will
restore the aquifer to its beneficial use.restore the aquifer to its beneficial use.
It is estimated that it will take 50 ++ years to achieve the groundwater cleanup objectives . under the selected remedy. . It is estimated that it will take 50 years to achieve the groundwater cleanup objectives under the selected remedy.
STATUTORY DETERMINATIONSSTATUTORY DETERMINATIONS
Under CERCLA Section 121 and the NCP, the lead agency must select remedies that areUnder CERCLA Section 121 and the NCP, the lead agency must select remedies that are protective of human health and the environment, comply with ARARs (unless statutoryprotective of human health and the environment, comply with ARARs (unless aa statutory waiver is justified), are cost-effective, arid utilize permanent solutions and alternativewaiver is justified), are cost-effective, arid utilize permanent solutions and alternative
technologies or resource technologies totreatmenttreatment technologies or resource recoveryrecovery technologies to thethe maximummaximum extentextent· practicable. SectionSection 121(b)(1) also establishes121 (b)(1) also establishes aa preference for remedial actions whichpracticable. preference for remedial actions which employ treatment to permanently and significantly reduce the volume, toxicity, or mobilityemploy treatment to permanently and significantly reduce the volume, toxicity, or mobility of the hazardous sut)stances, pollutants, or contaminants at site.of the hazardous substances, pollutants, or contaminants at aa site.
For theFor the reasonsreasons discussed below,below, EPA has determined that the selectedselected modified groundwater remedy meets these statutory requirements, except for the MW-19 Area
discussed EPA has determined that the modified groundwater remedy meets these statutory requirements, except for the MW-19. Area . groundwater where chemical specific are waived in the 120 ft by 80 ft by 30 ftgroundwater where chemical specific ARARsARARs are waived in the 120 ft by 80 ft by 30 ft ... depth zone for PCE, 1,1,1-TCA, 1,1-DCA, cis-1,2-DCE, and VC.depth zone for PCE, 1,1, 1-TCA, 1, 1-DCA, cis-1 ,2-DCE, and VC.
Protection of Human Health and the EnvironmentProtection of Human Health and the Environment
The results of the risk assessment indicate that, if no action is taken, the hypotheticalThe results of the risk assessment indicate that, if no action is taken, the hypothetical future use of the groundwater at the Site will pose an unacceptable increased futurefuture use of the groundwater at the Site will pose an unacceptable increased future cancer risk andcancer risk and an unacceptable non-cancer hazard risk to human health.an unacceptable non-cancer hazard risk to human health. The selectedThe selected
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, I ~emedy will be protective of human health and the environment in that it will restore groundwater quality at the site over the long term.groundwater quality at the site over the long term. Combined with institutional controls, i emedy will be protective of human health and the environment in that it will restore
Combined with institutional controls, the selected remedy will provide protectiveness of human health and the environmentthe selected remedy will provide protectiveness of human health and the environment over both the short and long termterm..over both the short and long
. Complia:nce with ARARs and Other Environmental CriteriaCompliance with ARARs and Other Environmental CriteriaI .
. I. .
AA summ~ry of theARARs and "Other Criteria, Advisories, or Guidance TBCs" which willsummary of the ARARs and "Other Criteria, Advisories, or Guidance TBCs" which will be complied with during implementation of the selected remedy, is presented below.be complied with during implementation of the selected remedy, is presented below.
! .
ii
• New Department Environmental WaterNew YorkYork StateState Department ofof Environmental ConservationConservation Water QualityQuality .Regulations for Surface Waters and Groundwater (6 NYCRR Parts 700-705);Regulations for Surface Waters and Groundwater (6 NYCRR Parts 700-705);
New York State Department of Health Drinking Water Standards (10 NYCRR Part• New York State Department of Health Drinking Water Standards (10 NYCRR Part 5); and,5); and,
•• Safe Drinking Water Act National Primary Drinking Water Standards (MCLs andSafe Drinking Water Act National Primary Drinking Water Standards (MCLs and non-zero maximum contaminant level goals) (40 CFR Part 141).non-zero maximum contaniinant level goals) (40 CFR Part 141).
Cost-EffectivenessCost-Effectiveness
AA cost-effective remedy is one whose costs are proportional to its overall effectiveness (NCP Section 300.430(f)(1)(ii)(D)).(NCP Section 300.430(f)(1 )(ii)(D)). Overall effectiveness is based on the evaluations of:
cost-effective remedy is one whose costs are proportional to its overall effectiveness Overall effectiveness is based on the evaluations of:
long-term effectiveness and permanence; reduction in toxicity, mobility, and volume!,eng-term effectiveness and permanence; reduction in toxicity, mobility, and volume through treatment; and short-term effectiveness.through treatment; and short-term effectiveness. Based on the comparison of overallBased on the comparison of overall effectiveness to the remedy the statutoryeffectiveness (discussed above)(discussed above) to cost,cost, the selectedselected remedy meetsmeets the statutory, . . r"equirement that Superfund remedies be cost-effective in that it is the least-cost actionrequirement that Superfund remedies be cost-effective in that it is the least-cost action alternative and will achieve the remediation goals in reasonable time frame.alternative and will achieve the remediation goals in aa reasonable time frame.
Each of the alternatives has undergone detailed cost analysis. In that analysis,capitalEach of the alternatives has undergone aa detailed cost analysis. In that analysis, capital and annual monitoringannual monitoring oror costscosts used developOM&MOM&M have been estimated and used toto develop~nd have been estimated and present-worth costs.present-worth costs. In the present-worth cost analysis, annual monitoring or OM&MIn the present-worth cost analysis, annual monitoring or OM&M costs were calculated for the estimated life of an alternative using 7% discount rate.costs were calculated for the estimated life of an alternative using aa 7% discount rate. .
Utilization of Permanent Solutions and Alternative Treatment Technologies to theVtilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent Practicable.Maximum Extent Practicable 1':
The selected remedy provides the best balance of tradeoffs among the alternatives withThe selected remedy provides the best balance of tradeoffs among the alternatives with respect to the balancing criteria set forth in NCP Section 300.430(f)(1)(i)(B), such that itrespect to the balancing criteria set forth in NCP Section 300.430(f)(1 )(i)(B), such that it representsrepresents the maximum extent to which permanent solutions and treatmentthe maximum extent to which permanent solutions and treatment technologiestechnologies cancan in practicablepracticable manner at theat the Site.Site.be utilized in aa InIn addition, theaddition, thebe utilized manner selected remedy provides the protection of human health and the environment, providesselected remedy provides the protection of human health and the environment, providesI. .the long-term effectiveness, is able to achieve the as quickly as the otherthe long-term effectiveness, is able to achieve the ARARsARARs as quickly as the other alternatives, and is cost-effective. . . . .klternatives, and is cost-effective. . I . >. .
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" ...., .
While the selected groundwater remedy will not actively treat the groundwater, there isWhile the selected groundwater remedy will not actively treat the groundwater, the~e is an overall downward trend of the contamination in the groundwater plume, and there is'an overall downward trend of the contamination in the groundwater plume, and there is currently no exposure pathway to the contaminated groundwater at the Site, becausecurrently no exposure pathway to the contaminated groundwater at the Site, because there are no drinking water wells on the Site. The existing deed restriction prohibitsthere are no drinking water wells on the Site. The existing deed restriction prohibits installation of new drinking water wells and nearby residences' private drinking waterinstallation of new drinking water wells and nearby residences' private drinking water wellswells areare not impacted by contamination from the Site as they are using the deepnot impacted by contamination from the Site as they are using the deep bedrock aquifer which is not contaminated. InIn addition,addition, aa review of the MNAdata showsbedrock aquifer which is not contaminated. review of the MNA data shows thatthat natural attenuationnatural attenuation isis occurringoccurring at Site exceptat Site except inin MW-19 Area. The selectedMW-19 Area. The selected groundwater remedy will provide permanent remedy to reduce the toxicity, mobility,groundwater remedy will provide aa permanent remedy to reduce the toxicity, mobility, and volume of the contaminants in the groundwater over long-term.and volume of the contaminants in the groundwater over aa long-term.
Preference for Treatment as Principal ElementPreference for Treatment as aa Principal Element
The statutory preference for remedies that employ treatment as aa principal element is notThe statutory preference for remedies that employ treatment as principal element is not satisfied under the selected modified remedy since there is no active treatment of thesatisfied under the selected modified remedy since there is no active treatment of the contaminated groundwater. 'contaminated groundwater.
Five-Year Review RequirementsFive-Year Review Requirements
Since the selected modified groundwater remedy will allow for hazardous substances toSince the selected modified groundwater remedy will allow for hazardous substances to remain at this Site above levels that would allow for unlimited use without restriction,remain at this Site above levels that would allow for unlimited use without restriction, pursuant to Section 121 (c) of CERCLA, EPA or the State will review implementedpursuant to Section 121 (c) of CERCLA, EPA or the State will review implemented remediesremedies no less often than every five years. Although the contaminated soil andno less often than every five years. Although the contaminated soil andsediments have been excavated, each five-year review will cover all aspects of the soilsediments have been excavated, each five-year review will cover all aspects of the soil and groundwater remedies.and groundwater remedies.
TECHNICAL IMPRACTICABILITY DETERMINATIONTECHNICAL IMPRACTICABILITY DETERMINATION
The restoration of contaminated groundwater is one of the primary objectives of theThe restoration of contaminated groundwater is one of the primary objectives of the SuperfundSuperfund program.program. Experience at Superfund however,at Superfund sites has shown,sites has shown, however, that theExperience that the restoration of contaminatedof contaminated groundwater may not always bebe achievable fromfrom 'anrestoration groundwater may' not always achievable an engineering perspective.engineering perspective.
As was noted in the "Site History" section, above, seven rounds of groundwater samples were collected as part ofwere collected as part of anan MNA study.MNA study. The findings of this effort were summarized in As was noted in the "Site History" section, above, seven rounds of groundwater samples
The findingsofthis effortwere summarized in aa PRPPRP Group-prepared report entitled Revised Comprehensive Monitored NaturalGroup-prepared report entitled Revised Comprehensive Monitored Natural Attenuation Evaluation Report (ESC Engineering, 2007).Attenuation Evaluation Report (ESC Engineering, 2007). Based upon its review, EPABased upon its review, EPA concluded that the data did not demonstrate that MNA would address the groundwaterconcluded that the data did not demonstrate that MNA would address the groundwater' contamination in the MW-19 Area. It was also concluded that because of the lowalso concluded that because of the lowcontamination in the MW-19 Area.' It was permeability of the aquifer, groundwater extraction and treatment not viable for thepermeability of the aquifer, groundwater extraction and treatment waswas not viable for the Site.Site.
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Based upon the recommendations in the 2008 draft FFS report, the PRP GroupBased Jpon the recommendations in the 2008 draft FFS report, the PRP Group waswas (directed by EPA to implement an ERD pilot-scale treatability study in the MW-19 Area.directed by EPA to implement an ERD pilot-scale treafability study in the MW-19 Area. Following the approval of work plan, the PRP Group initiated an ERD pilot test inFollowing the approval of aa work plan, the PRP Group initiated an ERD pilot test in DecemberDecemb~r 2008.2008. As part of the pilot test, approximately 50 gallons of Hydrogen ReleaseAs part of the pilot test, approximately 50 gallons of Hydrogen Release Compound (HRC) and 35 gallons of HRC primer were applied to an 800 sq ft area viaCompou'nd (HRC) and 35 gallons of HRC primer were applied to an 800 sq ft area via eight direct push delivery points. Following the completion of four rounds of performance~ight direct push delivery points. Following the completion of four rounds of performance monitoring events, the PRP Group submitted report entitled draft Pilot Study Report in,monitoring events, the PRP Group submitted aa report entitled draft Pilot Study Report in [JanuaryJanuary :201j2010.O. Based upon its review of the report, EPA requested that the PRP GroupBased upon its review of the report, EPA requested that thePRP Group JDerform additional investigation to locate the source and, if located, then perform targeted'perform additional investigation to .locate the source and, if located, then perform targeted ,!=RQERD treratment.treatment. The PRPPRP Group performedperformed supplementalsupplemental investigationThe aa fromGroup investigation from Septemtper through December 2010. This work included the performance of aa passiveThis work included the performance ofSeptember through December 2010. passive soil gas survey, collection of discrete groundwater samples from the silt and sand/gravel~oil gas survey, collection of discrete groundwater samples from the silt and sand/gravel zones~ones beneath and around thearound the concrete rubble,rubble, permeability testing, and hydraulicbeneath and concrete permeability testing, and hydraulic conductivity testing. BasedBased on the results of this effort, the PRP Group submittedon the results of this effort, the PRP Group submitted aa draft'conductivity testing. draft report entitled Draft MW-19 Area Supplemental Investigation Report on February 3, 2011.report entitlep Draft MW-19 Area Supplemental Investigation Report on February 3,2011. After review of the document, EPA concluded that the source of the PCE and 1,1,1-TCA1\fter review of the document, EPA concluded that the source of the PCE and 1,1,1-TCA contamination had not been identified and further efforts to try to identify the source would,~ontamination had not been identified and further efforts to try to identify the source would jikely be fruitless. Nevertheless, the mbble in this area was excavated and disposedlikely be fruitless. Nevertheless, the rubble in this area was excavated and disposed . bff-Site at permitted landfill by the PRP Group in August 2011. Samples collected.,9ff-Site at aa permitted landfill by the PRP Group in August 2011. Samples collected ciuring the excavation did not identify any source material.puring the excavation did not identify any source material.
Contaminants exceeding the federal MCLs and NYSDEC Water Quality Regulations for:Contaminants exceeding the federal MCLs and NYSDEC Water Quality Regulations for (Groundwater (NYCRR, Title 6, Part 703) in the monitoring wells and piezometer located:~roundwater (NYCRR, Title 6, Part 703) in the monitoring wells and piezometer located inin thethe MW-19 Area have been PCE, 1,1,1-TCA, andMW-19 Area have been PCE, 1,1,1-TCA, and 1,1,1-DCA.1-DCA. Since 2003Since 2003 sourcesource i-emoval, MW-19 Area plume detected PCE from 30 to 69 ug/L, 1,1,1-TCA from 41 to 9'~emoval, MW-19Area plume detected PCE from 30 to 69 ug/L, 1,1,1-TCA from 41 to 999 I~g/I,ug/l, and 1,1-DCA from 5.7 ug/I. cis-1,2-DCE and VC are also breakdownand1,1-DCA from 5.7 toto 2121 ug/l. cis-1,2-DCE and VC are also breakdown products of PCE, however, they have not been detected in the groundwater of the'products of PCE, however, they have not been detected in' the groundwater of the' MW-19 Area plume in exceedance of the standards. The NYS AWQS land the federal:~W-19 Area plume in exceedance ofthe standards. TheNYS AWQS~and the federal MCLs for PCE, 1,1,1-TCA, 1,1-DCA, and cis-1,2-DCE are ug/l and for VC is ug/l.I~CLs for PCE, 1,1,1-TCA, 1,1-DCA, and cis-1,2-DCE are 55 ug/l and for VC is 22 ug/1. The MW-19 Area plume is estimated to be about 120 ft by 80 ft and 30 ft in depth.fhe MW-19 Area plume is estimated to be about 120 ft by 80 ft and 30ft in depth.
"II EPA has determined that the restoration of the groundwater in the MW-19 Area is,FPA has determined that the restoration of the groundwater in the MW-19 Area is technically impracticable from an engineering perspective due to the ineffectiveness of~echnically impracticable from an engineering perspective due to the ineffectiveness of lactive remedies in the low permeable soils found at the Site, the limited mobility of theactive remedies in the low permeable soils found at the Site, the limited mobility of the groundwater contamination (the contaminant plume is not migrating), and the inability togroundwater contamination (the contaminant plume is not migrating), and the inability to locate aa source. Therefore,Therefore, EPA is proposing aa technical impracticability waiverimpracticability waiver,'ocate source. EPA is proposing technical pursuant to CERCLA §121 (d)(4)(C) and NCP§300.430(f)(1)(ii)(C)(3) for the groundwaterpursuant to CERCLA §121 (d)(4)(C) and NCP§300.430(f)(1 )(ii)(C)(3) for the groundwater'in this area. . . . '.in this area. III • • • •
'~ecause the existing deed restriction prohibits the installation and use of the groundwaterBecause the existing deed restriction prohibits the installation and use of the groundwater yvells at the Site for drinking water purposes, the potential for direct contact or inhalation~ellsat the Site for drinking water purposes, the potential for direct contact or inhalation threat associated with contaminated groundwater does not exist. Also, therethreat associated with contaminated groundwater does not exist. Also, there areare nono burrent and potential receptors downgradient of MW-19 Area.burrent and potential receptors downgradient of MW-19 Area. If, in the future, structuresIf, in the future, structures are proposed to be built on the property, thenproposed to be built on soil vapor intrusion evaluation and,~re the property, then aa soil vapor intrusion evaluation and, "
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potentially, vapor mitigation may be needed, or alternatively just soil vapormitigation.potentially, vapor mitigation may be needed, or alternatively just soil vapor mitigation. AsAs aa governmental institutional control, the Office of theTown of Fenton Building Inspector has acknowledgedhas acknowledged to EPA that such any person seeking to build
governmental institutional control, the Office of the Town of Fenton Building Inspector to office will. notify any person seekingEPA that such office will notify to build
residential structures at the Site of soil vapor concerns relating to the property, andresidential structures at the Site of soil vapor concerns relating to the property, and specifically of the need for soil vapor evaluation and potentially, soil vapor mitigationspecifically of the need for aa soil vapor evaluation and potentially, soil vapor mitigation systems or, alternatively just soil vapor mitigation.systems or, alternatively just soil vapor mitigation.
While it has been estimated that site-wide groundwater restoration would be achieved inWhile it has been estimated that site-wide groundwater re~toration would be achieved in 50 years, the restoration timeframe forthe MW-19 Area is unknown, since source of the50 years, the restoration time frame for the MW-19 Area is unknown, since aa source of the. contamination has not been identified.contamination has not been identified. It is anticipated that the restoration time frameIt is anticipated that the restoration time frame would be significantly greater than 50 years.would be significantly greater than 50 years.
The "technical impracticability zone" is the approximate 120 ft by 80 ft MW-19 Area to aa depth of 30 ft (see Figures and 3). The ARARs that would be' waived for this zone The "technical impracticability zone" is the approximate 120 ft by 80 ft MW-19 Area to depth of 30 ft (see Figures 22 and 3). The ARARs that would be waived for this zone would be the federalwould be the federal MCLs and NYSDEC Water Quality Regulations for GroundwaterMCLs and NYSDEC Water Quality Regulations for Groundwater (NYCRR, Title(NYCRR, Title 6, Part 703) for PCE,6, Part 703) for PCE, 1,1,1-TCA,1,1,1-TCA, 1,1,1-DCA,1-DCA, cis-1,2-DCE, and VC.cis-1,2-DCE, and VC. BothBoth ARARs cited above are applicable requirements which are being waived. The MW-19ARARs cited above are applicable requirements which are being waived. The MW-19 Area groundwater will continue to be monitored periodically to confirm that the technicallyArea groundwater will continue to be monitored periodically to confirm that the technically impracticable zone is not expanding in size and no additional contaminants other thanimpracticable zone is not expanding in size and no additional contaminants other than those waived are detected above MCLs. .those waived are detected above MCLs.
DOCUMENTATION OF SIGNIFICANT CHANGESDOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan released for public comment on July 31, 2011, identified AlternativeThe Proposed Plan released for public comment on July 31, 2011, identified Alternative GW-2, MNA,GW-2, MNA, as the preferred modified groundwater remedy.as the preferred modified groundwater remedy. It also identified the EPAIt also identified the EPA·' plans to invoke aa technical impracticability waiver for the MW-19 Area groundwater.plans to invoke technical impracticability waiver for the MW-19 Area groundwater. Based upon its review of the written and oral comments submitted during the publicBased upon its review of the written and oral comhients submitted during the public comment period, EPA has determined that no significant changes to the remedy, ascomment period, EPA has determined that no significant changes to the remedy, as originally identified in the Proposed Plan for Remedy Modification, are necessary ororiginally identified in the Proposed Plan for Remedy Modification, are necessary or appropriate.appropriate.
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APPENDIX IIAPPENDIX
FIGURESFIGURES
Figure 11Figure Site LayoutSite Layout Figure 22Figure MW-19 Area (Horizontal)MW-19 Area (Horizontal) Figure 33Figure MW-19 Area (Vertical)MW-19 Area (Vertical)
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• ^ ^ - tDO ANQ 100 nAR lOOO ^UW UUT
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1. TEMPORARY MONfTORlNfG WElLSSAMPLE CCLLECTIOK.
ABANDONED ArTER
2. GROUNDWATER DATA USED TO LOCATE ISOCONCENTRATION LiNES WERE CCLL£CTE D iN' JU?-JE 20C9 FOR PERMANENT WELLS P - 2 AND WW-^9
J . GROUNDWATER DATA USED TO LOCATE ISOCONCENTRATION L-NES WERE COLLECTED N DECEMBER 2C06 FOR TEK^PGRA>?y A'ELLS ( T U W - ^ T H R 0 L X ; H T W W - 5 ) A N D I N OCT09=:R 2 0 Q 7 F D S
TEVPORAflr WELLS (TMW-6 THROUGH XMW-12) -
Technically Impracticable Zone
•J T M T l ' - l '
GRAVEL PARKING AREA
/ /
J ^ ' i ' , ! * ! - ! !
/
SS-33 K - J « .
PB-19
PB-20
/ . F T M K - 1 2
SO-Jl X
\. tWRTUAHM ASSCC MC. Dlh^«M) TTTJZi ' ' S l ; * ^ ^ ! ) LOCCOW -
CCTCflOt IVH , LA5T KV. KdCKBEn 11, 1993, i M . MO. U-O^T- tU.
3 RCHWl M. R*BwSirr. L I . O ^ W B ' 'VJS. "WELL. K W W *«B 3WPLM LOUnOVS'. KTES OECtWet* 14. 3901. [EK 10: 1«&- IM
rtmcMoiif lotoj] *. F^J•uC AK»V£Oit»^ ffCiJTt, ftNC-outniM UMMStRTT CtUWMO TTPJI) "OLTLftM. WXCOtCC UAMA£CiJ»T UMVCY, iTMl£ l | AKhAEOLOCKX. RCCCHKHSIANCC" EM'S} (U/U/CQ hLS. SOtX 1 " - ac .
i f iM* . Fiooo MsurwKE w n Nt«^. Tom Of romw. H E * « » ( , BOCUC COMTr, r * K L l i O^ 30, CCMMU^«TY-f>ANa NiUKR U004« 0013 a, OTtc ive i u T t August 3, i » n . W ^ T O I W V T I K A U : 1" * SOD'.
S. SKUUAXO! COttSULTM ENarCXliWS AJtO lAVQ Sk lNniFaG, PC O C
K - 1 » X
P B - l f t
m » ' " . i
M W - 1 9 ®
M W - U *
M W - 1 4 B i l
P - 2 O
«
PASSIVE SOiL GAS SfWPUNG POINT
PROPOSED PiLOT BORiNC
TEMPORARY MONITORING WEa
SHAJLLOW MONITORINO WELL
DEEP MONfTORING WEU
BEDROCK MONITORING WEU
PIEZOMETER
UTILITY POLE/LIGHT POLE
ilSSHD
PROPERTY UNE
TREE UNE
TOTAL DHECTED VOCs ISOCONCEMTRATION 0 ^ / 1 )
EXISTING 10 FOOT CONTOUR
DUSTING 2 FOOT CONTOUR
FENCE LINE
TKE ofaeiNM. y f j iacM Cf T H S ORUHMO I S H COLOA. BUCK * WHTE COPCS MY NOT
/•CCijMTZCr DCPCT aSTAiN r*Ofi»WT:CN,
SCALE, FEET
tat;
<
<SI O)
3 5
i o
LJ _J a a. D 10
•SP c- e;
•c-g ax
I f Mi 5 111 2 f
531222
L L L
L L L
n f OF •CM40/ML1. I. KTEXTttCINC SURTACC MWttXMUlD rmm IKU amcriD IXMNO IW MKMDI
9CMEEMD NTDNU. lOOT HUSDWrOi
1. n t m TMU DCFTM NOm AJ T M Cf i KEY MAP 1 l i I
1010 i -
H hi
JO liji
CROSS SECTION A-A'
D 00006725-008
531223
Table 11 Table 22 . TableTableTable 33TableTable4Table 4Table 55TableTable 66TableTable 77TableTable 88TableTable 99TableTable 10Table 10Table 11Table 11
APPENDIX IIIAPPENDIX I
TABLESTABLES
Summary of Groundwater Data Since 2003Summary of Groundwater Data Since 2003 Groundwater Data in 201201 00 .Groundwater Data in Summary of Chemicals of ConcernSummary of Chemicals of Concern Selection of Exposure PathwaysSelection of Exposure Pathways Cancer Toxicity Data SummaryCancer Toxicity Data Summary Non-CancerToxicity Data SummaryNon-Cancer Toxicity Data Summary Risk Characterization - Summary of Carcinogenic RisksRisk Characterization - Summary of Carcinogenic Risks Risk Characterization - Summary ofNon- Carcinogenic RisksRisk Characterization - Summary of Non-Carcinogenic Risks Updates to Toxicity Values and Calculated RisksUpdates to Toxicity Values and Calculated Risks Federal and State MCLs for Drinking WaterFederal and State MCLs for Drinking Water Cost Estimate for Selected Remedy.. Cost Estimate for Selected Remedy
531224
Table Summary of Groundwater Data Since 2003Table 11 Summary of Groundwater Data Since 2003
ContaminantsContaminants Numb'erof NumberNumber Min. Max. Cone. Conc.ug/lCone, ug/l
Number of Min. Max. ARARARAR DetectionsDetections AnalyzedAnalyzed Cone. . Cone.Cone;
aboveabove ARARARAR UQ/Iug/l uQ/Iug/l VOCsVOCs 2-Butanone (MEK) 151 1010 UU 50 1,1-Diehlorpethane 4141 151151 1.U1.U 1,100 55 2-Butanone (MEK) 00 151 1010 UU 50 1,1-Dichloroethane 1,100 1,2-Dichloroethane1,2-Diehloroethane 1 151 0.6 39 JJ 0.6111 151 0.6 UU 39 0.6 1,1,1-Triehloroethane 19 42 11 UU 9999 551,1,1-Trichloroethane . 19 42 cis-1,2-Dichloroethenecis-1,2-Dichloroethene 45 151 11 UU 9,0009,000 5545 151 Methylene chlorideMethylene chloride 44 151151 5U 59J59J5U 55 TetrachloroetheneTetrachloroethene 23 151 11 UU 696923 151 55 Toluene 55 151 11 UU 11Toluene 151 190190 TrichloroetheneTrichloroethene 27 151 72072027 151 11 UU 55 Vinyl chlorideVinyl chloride 52 151 28028052 151 11 UU 22
SVOCsSVOCs 11 5Ubis(2-Ethylhexyl)phthalate·bis(2-Ethylhexyl)phthalate 3636 5U 5.45.4 55
MetalsMetals CadmiumCadmium 22 3636 5U5U 7.97.9 55 IronIron 13 36 37J 6,900J 30013 36 37J 6,900J 300 ManQaneseManganese 32 36 56 1,600 30032 36 56 1,600 300
Note: Most stringent of Federal Maximum Cleanup Level and New York State Drinking Water Standard waswasNote: Most stringent of Federal Maximum Cleanup Level and New York StateDrinking Water Standar~
used for ARAR ConeCone..used for ARAR . . . ..
constituent not detected at the noted detection limitUU -- constituent not detected at the noted detection limit JJ -- constituent detectedconstituent detected at an estimated concentrationat an estimated concentration
531225
Table 22 Groundwater Data in 2010Table Groundwater Data In 2010
Well IDWelilD MW-2SMW-2S MW-2MW-2 MW-3SMW-3S MW-7SMW-7S MW-14MW-14
Sample DateSample Date 6/156/15 1 12/2112/21 6/156/15 12/2112/21 6/166/16 12/2112/21 6/15. 6/15 12/2112/21 6/156/15 Parameters (ug/l)Parameters (ug/I) VOCsVOCs 2-Butanone (MEK). -2-Butanone (MEK) 1010 UU 1010 UU 1010 UU 1010 UU 1010 UU 1010 UU 1010 UU 1010UU 1010 UU . 1,1-Dichloroethane1,1-Dichloroethane 3.43.4 1212 .' 1.71.7 4.14.1 200200-' 160160 1U1U 11 UU 1.71.7 1,2-Dichloroethane1,2-Dichloroethane 0.60.6 UU 0.6U0.6U 0.60.6 UU 0.60.6 UU 3.73J 2.5. 2.5 0.6 U0.6U 0.6 U0.6U 0.610.61 1,1,1-Triehloroethane1,1,1-Trichloroethane - . - -- -- -- -- • • • -- • - • ' , : - -- • , . —
. -cis-1,2-Diehloroethenecis-1,2-Dichloroethene 1.91.9 5.85.8· . 0.210.21 JJ 5.45.4 270270 130130 11 UU u11 W 0.850.85 JJ Methylene chlorideMethylene chloride 5U5U 5 U5U 5U5U 5U5U 3.83.8 JJ 4 J4J 5 U5U 5 U5U 1U1U Tetrachloroethene .Tetrachloroethene 11 UU 11 UU 11 UU 11 UU 1.51.5 1.11.1 U. 11 U.· 11 UU 11 UU TolueneToluene 11 UU 11 UU 11 UU 11 UU 11 UU J 11 UU u11 U 11 UU 11 UU TrichloroetheneTrichloroethene 0.220.22 JJ 0.21 J0.21J 0.720.72 JJ :..... 3131 1.91.9 1.11.1 11 UU 11 UU 11 UU Vinyl chlorideVinyl chloride 0.210.21 JJ 1.21.2 11 UU 6.46.4" 68'68. .6.96.9 ; 11 UU 11 UU 2 U2U
Well IDWelilD MW-16SMW-16S MW-19MW-19 MW-20SMW-20S MW-20MW-20 P-2P-2.
Sample DateSample Date 6/156/15 12/2112/21 6/166/16 12/2212/22 6/156/15 12/21-12/21 6/156/15 6/166/16 12/2112/21 Parameters (ug/l)Parameters (uQII) VOCsVOCs 2-Butanone (MEK) 1,1-Diehloroethahe 2-Butanone (MEK) 1,1-Dichloroethane 10 :
1010 UU 10 .. 8.8 J '
1010 UU 8.8J' 4.4
1010 UU 4.4 3.9
1010 UU 3.9
1010 UU 11 UU
1010 UU 11 UU
1010 UU 11 UU
, 5.9
1010 UU 5.9 4.9
1010 UU . 4.9
1,2-Dichloroethane 1,1,1-Trichloroethane cis-1,2-Dichloroethene
1,2-Dichloroethane 1,1,1-Trichloroethane cis-1,2-Dichloroethene
0.21 - • .
630
0.21 JJ -
630'
0.6 -
610
. 0.6 UU -
610 ....
0.6 99
0.6 UU 99 11 UU
0.6 «• ' 67
0.29
0.6 UU I:·· 67 '..
0.29 JJ
0.6 L) -
0.6 U -
11 UU
0.6 -
0.6 UU -
11 UU
0.6 U •
u
.O.6U -
11 U
0.6 •': - 7 2 ••
0.89
0.6 UU 72 ..
0.89 JJ ; • • • . '...•.
0.6 -64 1.2
0.6 UU '64' . 1.2
Methylene chlorideMethylene chloride 5U5U 5U5U 5U5U 5U5U 5 U5U 5U5U 5 U'5U 5 U5U 5 U5U TetrachloroetheneTetrachloroethene 11 UU 11 UU 6666 6969 1 U1U 11 UU 11 UU 4646 6464 TolueneToluene 11 UU 11 UU 11 UU 11 UU u11 U 11 UU 11 UU 11 UU 11 UU TrichloroetheneTrichloroethene 720720'" 680v>.680; 1.71.7 1.81.8 11 UU 11 UU 11 UU 2.12.1 1.91.9 Vinyl chlorideVinyl chloride 270 .. 270·... i7o;*170:; 11 UU 11 UU 1.41.4 22 1 u'·.1 U 2 U2U 11 UU
Notes:Notes: ". Highliglited data exceeds ARARs.Highlighted data exceeds ARARs.
- constituent not detected at the noted detection limitUU - constituent not detected at the noted detection limit constituent detected at an estimated concentration. JJ - constituent detected at an estimated concentration
531226
. .
Table 3. Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations.Table 3. Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations.
Scenario Timeframe:Scenario Timeframe: FutureFuture
Medium:Medium: GroundwaterGroundwater
Exposure Medium:Exposure Medium: GroundwaterGroundwater ..
Exposure Point Exposure Point
Chemical of ConcernChemical of Concern Concentration Detected
Concentration Detected
UnitsUnits Frequency of
Detection
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
EPC Units EPC Units
Statistical UnitStatistical Unit
MinMin MaxMax
1,1 Dichloroethane1,1 Dichloroethane 1(U)1 (U) 160160 ug/lug/I 2/5215 160160 ug/lug/I 10 samplesMaxMax << 10 samples
1,2 Dichloroethane1,2 Dichloroethane 0.6 (U)0.6 (U) 22 ug/lug/I 1/51/5 22 ug/lug/I Max 10 samplesMax << 10 samples
Tap and Showerhead Tap and Showerhead
cis 1,2-Dichloroethene
1,2 Dichloroethylene (total)
cis 1.2-Dichloroethene
1,2 Dichloroethylene (total)
1(U)
(U)
1 (U)
22 (U)
440
470
440
470
ug/l
ug/l
ug/I
ug/I
:
3/5
3/53/5
3/5
440
470
440
470
ug/l
ug/l
ug/I
ug/I
Max 10 samples
Max 10 samples
Max << 10 samples
Max << 10 samples
Methylene chlorideMethylene chloride 1(U)1 (U) 2.62.6 ug/lug/I 1/5 :1/5 2.62.6 ug/lug/I 10 samplesMaxMax << 10 samples
TetrachloroethyleneTetrachloroethylene (U)11 (U) 1.3.. 1.3 ug/lug/I 1/51/5 1.31.3 ug/lug/I 10 samplesMaxMax << 10 samples
TrichioroethyleneTrichloroethylene 1(U)1 (U) 1.31.3 ug/lug/I 3/53/5 460460 ug/lug/I .... Max 10 samplesMax << 10 samples
Vinyl chlorideVinyl chloride 2(U)2 (U) 8383 ug/lug/I 4/54/5 460460 ug/lug/I Max 10 samplesMax << 10 samples
notes:
(U) = non-detect
ug/l micrograms/liter
notes:
. (U)= non~detect
. ug/l == micrograms/liter
531227
TABLE 44TABLE
SELECTION OF EXPOSURE PATHWAYSSELECTION OF EXPOSURE PATHWAYS
ScenarioScenario TimeframeTimeframe
FutureFuture
FutureFuture
Medium andMedium and
ExposureExposure MediumMedium
GroundwaterGroundwater
GroundwaterGroundwater
ExposureExposure PointPoint
TapwaterTapwater
Shower headShower head
TapwaterTapwater
Shower headShowerhead
ReceptorReceptor PopulationPopulation
..
ResidentResident
ResidentResident
On-site workerOn-site worker
On-site workerOn-site worker
Tri-Cities Barrel, Fenton, New YorkTri-Clties Barrel, Fenton, New York
<
Type of
Age RouteRoute Analysis
ReceptorReceptor ExposureExposure Type of Age Analysis
AdultAdult Ingestion'Ingestion QuantQuant.
ChildChild IngestionIngestion QuantQuant.
AdultAdult InhalationInhalation QuantQuant.
ChildChild InhalationInhalation QuantQuant.
Adult IngestoinIngestoin QuantQuantAdult .
AdultAdult InhalationInhalation QuantQuant.
Rationale for Selection or ExclusionRationale for Selection or Exclusion of Exposure Pathwayof Exposure Pathway
Private wells are currently used in the area for potable purposes. TherePrivate wells are currently used in the area for potable purposes. There is aa potential for future exposure to groundwater through ingestion ofis potential for future exposure to groundwater through ingestion of contaminated groundwater and inhalation of volatile organic compoundscontaminated groundwater and inhalation of volatile organic compounds while showering if the groundwater under the site was used for potablewhile showering if the groundwater under the site was used for potable purposes by current/futurepurposes by aa currenUfuture residentresident.
Private wells are currently used in the area. There is aa potential for futurePrivate wells are currently used in the area. There is potential for future exposure to groundwater through ingestion of contaminated groundwaterexposure to groundwater through ingestion of contaminated groundwater and inhalation of volatile organic compounds while showering if theand inhalation of volatile organic compounds while showering if the groundwater under the site was used for potable purposes bygroundwater under the site was used for potable purposes by aa current/futurecurrenUfuture residentresident. .
Private wells are currently used in the area. There is potential for futurePrivate wells are currently used in the area. There is aa potential for future exposure to groundwater through ingestion of contaminated groundwaterexposure to groundwater through ingestion of contaminated groundwater and inhalation of volatile organic compounds while showering if theand inhalation of volatile organic compounds while showering ·if the groundwater under the site was used for potable purposes bygroundwater under the site was used for potable purposes by aa cun-ent/future esident.currenUfuture esident'
Private wells are currently used in the area. There is potential for futurePrivate wells are currently used in the area. There is aa potential for future exposure to groundwater through ingestion of contaminated groundwaterexposure to groundwater through ingestion of contaminated groundwater and inhalation of volatile organic compounds vyhile showering if theand inhalation of volatile organic compounds while showering if the groundwater under the site was used for potable purposes bygroundwater under the site was used for potable purposes by aa current/future .currenUfuture residentresident
Private wells are currently used in the area for potable purposes. TherePrivate wells are currently used in the area for potable purposes. There is potential for future exposure to groundwater through ingestion ofis aa potential for future exposure to groundwater through ingestion of contaminated groundwater and inhalation of volatile organic compoundscontaminated groundwater and inhalation of volatile organic compounds while showering if the groundwater under the site was used for potablewhile showering if the groundwater under the site was used for potable purposes by the current/future worker.purposes by the currenUfuture worker.
Private wells are currently used in the area. There is a potential for futurePrivate wells are currently used in the area. There isa potential for future exposure to groundwater through ingestion of contaminated groundwaterexposure to groundwater through ingestion of contaminated groundwater and inhalation of volatile organic compounds while showering if theand inhalation of volatile organic compounds while showering if the groundwater under the site was used for potable purposes by thegroundwater under the site was used for potable purposes by the current/future worker.currenUfuture worker.
531228
Table 5. Cancer Toxicity Data SummaryTable 5. Cancer Toxicity Data Summary
Pathway: Ingestion, DermalPathway: Ingestion, Dermal
Chemical of ConcernChemical of Concern Oral CancerOral Cancer Dermal CancerDermal Cancer Slope FactorSlope Factor Slope FactorSlope Factor
1,1 Dichloroethane1,1 Dichloroethane 0.00570.0057 0.00570.0057
1,2 Dichloroethane1,2 Dichloroethane 0.0910.091 0.0910.091
cis 1,2-Dichloroethenecis 1,2-Dichloroethene NANA NANA
1,2 Dichloroethylene(total) . NA1,2 Dichloroethylene (total) NANA NA
Methylene chlorideMethylene chloride 0.00750.0075 0.00750.0075
TetrachloroethyleneTetrachloroethylene 0.540.54 0.540.54
.TrichloroethyleneTrichioroethylene 0.0130.013 0:0130:013
Vinyl chlorideVinyl chloride 0.720.72 0.720.72
.' notes:notes:
known carcinogenAA -- known carcinogen
82B2 -- probable human carcinogenprobable human carcinogen
- possible human carcinogenCC - possible human carcinogen
- not classifiableDD - not classifiable
- non-human carcinogen.EE - non-human carcinogen.
CAL EPA - California Environmental Protection AgencyCAL EPA - California Environmental Protection Agency . . . ..' '. IRIS - Integrated Risk Information Systern (vwvw.epa.qov/iris)IRIS - Integrated Risk Information System (www.epa.govliris)
NA - Not availableNA - Not available
Slope FactorSlope Factor UnitsUnits
mg/kg-daymg/kg-day
mg/kg-daymg/kg-day
mg/kg-daymg/kg-day
mg/kg-daymg/kg-day
mg/kg-daymg/kg-day
ing/kg-daymg/kg-day
Weight of EvidenceWeight of Evidence Classification
CC
Classification
82
DD
DD
B2
82B2
C-82C-B2
C-82
AA
C-B2
SourceSource
CalEPACalEPA
IRISIRIS
IRISIRIS
IRISIRIS
IRISIRIS
CalEPACalEPA
CalEPACalEPA
IRISIRIS
DateDate
. 9/1/089/1/08
911/089/1/08
9/1/089/1/08 ..
9/1/08.9/1/08
911/089/1/08
. 9 / 1 / 0 89/1/08
. 9/1/089/1/08
. 9/1/08911/08
531229
--
Table 5. Cancer Toxicity Data Summary (continued)Table 5. Cancer Toxicity Data Summary (continued)
InhalationPathway:Pathway: Inhalation
Chemical of ConcernChemical of Concern
•
1,1 Dichloroethane1,1 Dichloroethane
1,2 Dichloroethane1,2 Dichloroethane
cis 1,2-Dich/oroethehecis 1,2-Dichloroethene
1,2Dichloroethylene (total)1,2 Dichloroethylene (total)
Methylene chlorideMethylene chloride
TetrachloroethyleneTetrachloroethylene
TrichloroethyleneTrichioroethylene
Vinyl chlorideVinyl chloride
notes:notes:
known carcinogenAA -- known carcinogen
Inhalation UnitInhalation Unit UnitsUhits RiskRisk
1.6E-061.6E-06 (uglmY(ug/m3r1
2.62.6 E-05E-05 {uglmY(ug/m3r1
.... :'
NANA I···.... ,.:;d•.•\: . I/V·:;;:;.;~~.NA DDNA
t· . . '; ...
4.7 E-07 (ug/mV 82B24.7 E-07 (ug/m\1
5.9 E-06 (uglmY C-82C-B25.9 E-06 (ug/m3r1
2.0 E-06 (ug/m3r12.0 E-06 (uglmY C-82C-B2
4.4 E-06 (ug/m^)-' AA4.4 E-06 (ug/m3r1
B2. probable human carcinogen82 -- probable human carcinogen
CC -- possible human carcinogenpossible human carcinogen
DD -- not classifiablenot classifiable
non-human carcinogenEE -- non-human carcinogen
CalEPACalEPA -- California Environmental Protection AgencyCalifornia Environmental Protection Agency
IRIS -Integrated Risk Information System (www.epa.qov/iris)IRIS - Integrated Risk Information System (vww/.epa.qov/iris)
NA -- Not applicableNA Not applicable
ug/mug/m3 =micrograms/cubic meter^ = micrograms/cubic meter
Weight of EvidenceWeight of Evidence Classification
Cc
B2
; Classification
82
DD
SourceSource : DateDate
CalEPACalEPA 9/1/089/1/08
IRISIRIS 9/1/089/1/08
IRISIRIS 9/1/089/1/08 ..
IRISIRIS 9/1/089/1/08
IRISIRIS 9/1/089/1/08
CalEPACalEPA 9/1/089/1/08
CalEPACalEPA 9/1/089/1/08
IRISIRIS 9/1/089/1/08 .
531230
531231
Table 6.Table 6. Non-Cancer Toxicity Data Summary.Non-Cancer Toxicity Data Summary.
Pathway:Pathway: Ingestion, DermalIngestion, Dermal
COCCOC Chronic/ Subchronic
Chronicl Subchronic
Oral RfD Value
Oral RfD Value
UnitsUnits Dermal RfD
Dermal RfD
UnitsUnits Primary Target Organ
Primary Target Organ
Combined UF/MF
Combined UF/MF
Source of RfD Target Organ Source of RfD -Target Organ
DatesDates
1,1 Dichloroethane1,1 Dichloroethane ChronicChronic 0.200.20 mg/kg-daymg/kg-day 0.200.20 mg/kg-daymg/kg-day NOAELNOAEL 30003000 PPRTVPPRTV 9/1/089/1/08
1,2 Dichloroethane1,2 Dichloroethane ChronicChronic N/AN/A mg/kg-daymg/kg-day N/AN/A mg/kg-daymg/kg-day N/AN/A N/AN/A IRISIRIS 9/1/089/1/08
cis 1,2-Dichloroethenecis 1,2-Dichloroethene ChronicChronic 0.010.01 mg/kg-daymg/kg-day 0.010.01 mg/kg-daymg/kg-day NOAELNOAEL 30003000 PPRTVPPRTV 9/1/089/1/08
1,2 Dichloroethylene (mixed isomers)1,2 Dichloroethylene (mixed isomers) ChronicChronic 0.0090.009 mg/kg-daymg/kg-day 0.0090.009 mg/kg-daymg/kg-day LOAELLOAEL 10001000 HEASTHEAST 9/1/089/1/08
Methylene chlorideMethylene chloride ChronicChronic 0.060.06 mg/kg-daymg/kg-day 0.060.06 mg/kg-daymg/kg-day LiverLiver 100100 IRISIRIS 9/1/089/1/08
TetrachloroethyleneTetrachloroethyfene ChronicChronic 0.010.01 mg/kg-daymg/kg-day 0.010.01 mg/kg-daymg/kg-day LiverLiver 10001000 IRISIRIS 9/1/089/1/08
TrichioroethyleneTrichloroethylene ChronicChronic N/AN/A mg/kg-daymg/kg-day N/AN/A mg/kg-daymg/kg-day NANA NANA IRISIRIS 9/1/08911/08
Vinyl chlorideVinyl chloride ChronicChronic 0.0030.003 mg/kg-daymg/kg-day 0.0030.003 mg/kg-daymg/kg-day LiverLiver 3030 IRISIRIS 9/1/08911/08
notes:
Absorption rates were derived from the U.S. EPA Dermal Guidance (USEPA, 2004)
RfD Reference Dose
NOAEL No Observed Adverse Effect Level
LOAEL Lowest Observed Adverse Effect Level
PPRTV Provisional Peer Reviewed Toxicity Value
IRIS Integrated Risk Infonnation System obtained from www.epa.gov/iris on 9/1/08
HEAST Health Effects Assessment Tables
NA ^ Not available
notes:
Absorption rates were derived from theLJ.S. EPA Dermal Guidance (USEPA, 2004)
RfD -- Reference Dose
NOAEL -- No Observed Adverse Effect Level
LOAEL -- Lowest Observed Adverse Effect Level
PPRTV -- Provisional Peer Reviewed Toxicity Value
IRIS -- Integrated Risk Information System obtained from www.epa.gov/iris on 9/1/08
HEAST -- Health Effects Assessment Tables
NA ~ Not available
531232
Table 6.Table 6. Non-Cancer Toxicity Data Summary, (continued)Non:-Cancer Toxicity Data Summary. (continued)
Pathway:Pathway: InhalationInhalation
COCCOC Chronic/ Subchronic
Chronicl Subchronic
Inhalation RfC Value Inhalation RfC Value
UnitsUnits Inhalation RfD
'Inhalation RfD
UnitsUnits Primary Target Organ
Primary Target Organ
Combined UF/MF
Combined UF/MF
Source of RfD Target Organ Source of RfD Target Organ
DatesDates
1,1 Dichloroethane1,1 Dichloroethane ChronicChronic 0.500.50 ^mg/mmg/m3 N/AN/A mg/kg-daymg/kg-day KidneyKidney 10001000 HEASTHEAST 9/1/089/1/08
1,2 Dichloroethane1,2 Dichloroethane ChronicChronic 2.402.40 ^mg/mmg/m3 N/AN/A mg/kg-daymg/kg-day NOAELNOAEL 9090 ATSDRATSDR 9/1/089/1/08
cis 1,2-DicKloroethenecis 1,2-Dichloroethene ChronicChronic N/AN/A ^mg/mmg/m3 N/AN/A mg/kg-daymg/kg-day N/AN/A IRISIRIS 9/1/089/1/08
1,2 Dichloroethylene (mixed isomers)
Methylene chloride
1,2 Dichloroethylene (mixed isomers)
Methylene chloride
Chronic
Chronic
Chronic
Chronic
N/A
1.10
N/A
1.10
^
^
mg/mmg/m3
mg/mmg/m3
N/A
N/A
N/A
N/A
mg/kg-day
mg/kg-day
mg/kg-day
mg/kg-day
N/A
NOAEL
N/A
NOAEL 30
"'''.
' 30
HEAST
ATSDR
HEAST
ATSDR
9/1/08
9/1/08
9/1/08
9/1/08
TetrachloroethyleneTetrachloroethylene ChronicChronic 0.270.27 ^mg/mmg/m3 N/AN/A mg/kg-daymg/kg-day LOAELLOAEL 100100 ATSDRATSDR 9/1/089/1/08
TrichioroethyleneTrichloroethylene ChronicChronic 0.60.6 ^mg/mmg/m3 N/AN/A ' mg/kg-daymg/kg-day Nervous System/Eye
Nervous System/Eye
NANA CalEPACalEPA 9/1/089/1/08
Vinyl chlorideVinyl chloride ChronicChronic 0.10.1 ^mg/mmg/m3 N/AN/A mg/kg-daymglkg-day LiverLiver 3030 IRISIRIS 9/1/089/1/08
notes:
RfC Reference Concentration
RfD Reference Dose
NOAEL No Observed Adverse Effect Level
LOAEL Lowest Observed Adverse Effect Level
ATSDR Agency for Toxic Substances and Disease Registry
CalEPA California Environmental Protection Agency
HEAST Health Effects Assessment Tables
NA Not available
notes:
RfC -- Reference Concentration
RfD -- Reference Dose
NOAEL -- No Observed Adverse Effect Level
LOAEL -- Lowest Observed Adverse Effect Level
ATSDR -- Agency for Toxic Substances and Disease Registry
Cal EPA -- California Environmental Protection Agency
HEAST -- Health Effects Assessment Tables
NA -- Not available
Table 7.Table 7. Risk Characterization Summary of CarcinogensRisk Characterization -- Summary of Carcinogens
Scenario Timeframe:Scenario Timeframe: FutureFuture
Receptor Timeframe:Receptor Timeframe: FutureFuture
Receptor Age:Receptor Age: Adult ResidentAdul(Resident •
MediaMedia ExposureExposure ExposureExposure COCCOC Carcinogenic RiskCarcinogenic Risk
MediaMedia pointpoint
IngestionIngestion InhalationInhalation DermalDermal ExternalExternal ExposureExposure (Rad)(Rad) Routes TotalRoutes Total
GroundwaterGroundwater GroundwaterGroundwater Tap Water /Tap Water I 1,1 Dichloroethane1,1 Dichloroethane 8.6E-068.6E-06 1.3E-061.3E-06 NANA NANA 9.9E-069.9E-06 ShowerShower
1,2 Dichloroethane1,2 Dichloroethane 1.7E-061.7E-06 2.6E-072.6E-07 NANA NANA 1.96E-061.96E-06
Methylene chlorideMethylene chloride 2.3E-082.3E-08 4.9E-094.9E-09 NANA NANA 2.8E-082.8E-08
TetrachloroethyleneTetrachloroethylene 6.6 E-066.6 E-06 3.0E-083.0E-08 NANA NANA 6.6E-066.6E-06
TrichioroethyleneTrichloroethylene 5.6E-055.6E-05 3.7E-063.7E-06 NANA NANA 6.0E-056.0E-05
Vinyl chlorideVinyl chloride 5.5E-045.5E-04 1.5E-061.5E-06 NANA NANA 5.5E-045.5E-04
Pathway TotalPathway Total 6.1E-046.1E-04 6.7E-066.7E-06 NANA NANA 6.2E-046.2E-04
Total RiskTotal Risk 6.2E-046.2E-04
NA:NA: Route of exposure is not applicable to this mediumRoute of exposure is not applicable to this medium
531233
Table . . Risk Characterization Summary of Carcinogens (continued)Table 77.. Risk Characterization -- Summary of ,Carcinogens (continued)
Scenario Timeframe:Scenario Timeframe: FutureFuture
Receptor Timeframe:Receptor Timeframe: FutureFuture
Receptor Age:Receptor Age: Child ResidentChild Resident
Media Exposure Exposure coe point
Media Exposure Exposure COC point
MediaMedia
Groundwater Tap Water / 1,1 Dichloroethane Shower
GroLindwaterGroundwater Groundwater Tap Water I 1,1 Dichloroethane Shower
.1,2 Dichloroethane1,2 Dichloroethane
Methylene chlorideMethylene chloride
TetrachloroethyleneTetrachloroethylene
TrichloroethyleneTrichioroethylene
Vinyl chlorideVinyl chloride
Pathway TotalPathway Total
Route of exposure is not applicable to this mediumNA:NA: Route of exposure is not applicable to this mediuhi
IngestionIngestion
5.0E-065.0E-06
1.0E-071.0E-07
1.1 E-071.1E-07
3.8E-063.8E-06
3.3E-053.3E-05
3.2E-043.2E-04
3.6E-043.6E-04
Carcinogenic RiskCarcinogenic Risk
InhalationInhalation DermalDermal ExternalExternal (Rad)(Rad)
4.0E-094.0E-09 NANA NANA
5.2E-085.2E-08 NANA NANA
1.2E-091.2E-09 NANA NANA
7.6E-097.6E-09 NANA NANA
9.1 E-079.1E-07 NANA NANA
3.6E-073.6E-07 . NANA NANA
1.3E-061.3F06 NANA NANA .
Total RiskTotal Risk
ExposureExposure Routes TotalRoutes Total
5.0E-065.0E-06
1.0E-061.0E-06
1.1E-071.1E-07
3.8E-063.8E-06
3.3E-053.3E-05
3.2E-043.2E-04
3.6E-043.6E-04
3.6E-043.6E-04
531234
Table 77 Risk Characterization -- Summary of Carcinogens (continued)Table Risk Characterization Summary of Carcinogens (continued)
Scenario Timeframe:Scenario Timeframe: FutureFuture
Receptor Timeframe:
Receptor Age:
Receptor Timeframe:
ReceptorAge:
Future
On-Site Worker
Future
On-Site Worker
MediaMedia ExposureExposure ExposureExposure COCCOCo Carcinogenic RiskCarcinogenic Risk
MediaMedia pointpoint
IngestionIngestion InhalationInhalation DermalDermal ExternalExternal ExposureExposure (Rad)(Rad) Routes TotalRoutes Total
GroundwaterGroundwater GroundwaterGroundwater Tap Water /Tap Water I 1,1 Dichloroethane1,1 Dichloroethane 6.4E-066AE-06 1.7E-081.7E-08 NANA NANA 6.4E-066AE-06 ShowerShower
1,2 Dichloroethane1,2 Dichloroethane 1.3E-061.3E-06 2.2E-072.2E-07 NANA NANA 1.52E-061.52E-06
Methylene chlorideMethylene chloride 1.4E-071AE-07 5.1E-095.1E-09 NANA NANA 1.4E-071AE-07
TetrachloroethyleneTetrachloroethylene 4.9E-064.9E-06 3.2E-083.2E-08 NANA NANA 4.9E-064.9E-06
TrichioroethyleneTrichloroethylene 4.2E-054.2E-05 3.8E-063.8E-06 NANA NANA 4.5E-054.5E-05
Vinyl chlorideVinyl chloride 4.2E-044.2E-04 1.5E-061.5E-06 NANA NANA 4.2E-044.2E-04
Pathway TotalPathway Total 4.7E-044.7E-04 5.6E-065.6E-06 NANA NANA 4.7E-044.7E-04
Total RiskTotai Risk 4.7E-044.7E-04 ..
NA:NA: Route of exposure is not applicable to this mediumRoute of exposure is not applicable to this medium
531235
Table 8. Risk Characterization -- Summary of Non-CarcinogensTable 8. Risk Characterization Summary of Non-Carcinogens
Scenario Timeframe:Scenario Timeframe: FutureFuture
Receptor Timeframe:
Receptor Age:
Receptor Timeframe:
Receptor Age:
Future
Adult
Future
Adult
MediaMedia Exposure Media
Exposure Media
Exposure point
Exposure point
COCCOC Target Organ Target Organ
IngestionIngestion
Non-Cancer Health Hazard
Inhalation Dermal External (Rad)
Non-Cancer Health Hazard
Inhalation Dermal External (Rad)
Exposure Routes Total
Exposure . Routes
Total
GroundwaterGroundwater GroundwaterGroundwater Tap Water / Shower
Tap Water I Shower
cis 1,2- dichloroethene
Vinyl chloride
cis 1,2- dichloroethene
Vinyl chloride
NOAEL
Liver
NOAEL
Liver
1.2
0.76
1.2
0.76
NA
0.003
NA
0.003
NA
NA
NA
NA
NA
NA
NA
NA
1.2
0.76
1.2
0.76
Pathway TotalPathway Total 2.02,0 0.0030.003 NANA NANA 2.02.0
Total RiskTotal Risk 2.02.0
Scenario Timeframe:Scenario Timeframe: FutureFuture
Receptor Timeframe:
Receptor Age:
Receptor Timeframe:
Receptor Age:
Future
Child Resident
Future
Child Resident .
MediaMedia Exposure Media
Exposure Media
Exposure point
•
Exposure. point
COCCOC Target Organ Target Organ
IngestionIngestion
Non-Cancer Health Hazard
Inhalation Dermal External (Rad)
Non-Cancer Health Hazard
Inhalation Dermal External . (Rad)
,
Exposure Routes Total
Exposure Routes Total
GroundwaterGroundwater GroundwaterGroundwater Tap Water / Shower
Tap Water I Shower
cis 1,2- dichloroethene
Viny! chloride
cis 1,2- dichloroethene
Vinyl chloride
NOAEL
Liver
NOAEL
Liver
2.8
1.8
2.8
1.8
NA
0.00082
NA
0.00082
NA
NA
NA
NA
NA
NA
NA
NA
2.8
1.8
2.8
1.8
Pathway TotalPathway Total· .
4.64.6 0.000820.00082 NANA NANA 4.64.6
NA:NA: Route of exposure is not applicable to this mediumRoute of exposure is not applicable to this medium
531236
Table 8. Risk Characterization- Summary of Non-Carcinogens (continued) Table 8. Risk Characterization - Summary of Non-Carcinogens (continued)
Scenario Timeframe: FutureScenario Timeframe: Future
Receptor Timeframe: FutureReceptor Timeframe: Future
Receptor Age:Receptor Age: Adult On-Site Worker Adult On-Site Worker
Media Media· Exposure Exposure Exposure Exposure COC eoe Media Media point point
Groundwater Tap Water / cis 1,2- dichloroethene Shower
GroundwaterGroundwater Groundwater Tap Water I cis 1,2-dichloroethene Shower
Vinyl chloride· Vinyl chloride
.
Route of exposure is not applicable to this medium NA:NA: Route of exposure is not applicable to this medium
TargetTarget OrganOrgan
NOAELNOAEL
LiverLiver
Pathway Total Pathway Total
IngestionIngestion
0.860.86
0.54 0.54
1.4 1.4
Non-Cancer Health Hazard Non-Cancer Health Hazard
Inhalation Inhalation Dermal Dermal External External Exposure Exposure (Rad) (Rad) Routes Routes·.
Total Total
NA NA NA NA NA NA 0.86 0.86
0.0025 0.0025 NA NA NA NA 0.54 0.54
0.0025 0.0025 NA NA NA NA 1.4 1.4
Total Risk Total Risk 1.4 1.4
531237
Table 99 Updates to Toxicity Values and Calculated RisksTable Updates to Toxicity Values and Calculated Risks
. Sincethe completion of the 2008 Human Health Risk Assessment, the following toxicity values changed.Since the completion of the 2008 Human Health Risk Assessment, the following toxicity values changed.
ChemicalChemical
TrichloroethyleneTrichioroethylene cis-1,2-dichloroethe necis-l,2-dichloroethene
TrichloroethyleneTrichioroethylene
ReceptorReceptor
Child ResidentChild Resident Adult ResidentAdult Resident On-Site WorkerOn-Site Worker
cis~1,2-dichloroetl1"enecis-l,2-dichloroethene
ReceptorReceptor
Child ResidentChild Resident Adult ResidentAdult Resident On-Site WorkerOn-Site Worker
. Toxicity Va,lue TypeToxicity Value Type
Oral Cancer Slope FactorOral Cancer Slope Factor Oral Reference DoseOral Reference Dose
2008 Value2008 Value
1.3 E-02 (mg/kg-dayr11.3 E-02 (mg/kg-day)-' 1.0 E-02 mg/kg-day1.0 E-02 mg/kg-day
_..~.-
Updated calculated RisksUpdated Calculated Risks Chemical SpecificChemical Specific
Future Cancer Risk
20082008 2011
Future Cancer Risk 2011
3.33.3 E-05E-05 1.5 E-051.5 E-05
5.6E-05 2.5 E-055.6 E-05 2.5 E-05 4.24.2 E-05E-05 1.9 E-051.9 E-05
Chemical SpecificChemical Specific Future Non-Cancer HazardFuture Non-Cancer Hazard
20082008 20112011
2.82.8 14.014.0
1.21.2 6.06.0
0.860.86 4.34.3
2011 Value2011 Value
5.9 E-03 (mg/kg-dayr15.9 E-03 (mg/kg-day)-' 2.0 E-03 mg/kg-day2.0 E-03 mg/kg-day
Reason for Change andReason for Change and Source of Toxicity ValueSource of Toxicity Value Updated Cal EPA ValueUpdated CalEPA Value
Updated IRIS ValueUpdated IRIS Value
Total Future Cancer RiskTotal Future Cancer Risk
20082008 20112011
3.4 E-043.63.6 E-04E-04 3.4 E-04 6.2 E-04 5.9 E-046.2 E-04 5.9 E-04
4.5 E-044.74.7 E-04E-04 4.5 E-04
Total Future Non~Cancer HazardTotal Future Non-Cancer Hazard
2008 20112008 2011
4.64.6 16.016.0 2.02.0 6.86.8 1.41.4 4.94.9
531238
Table 10 Federal and State MCLs for Drinking WaterTable 10 Federal and State MCLs for Drinking Water
ContaminantsContaminants Federal Safe New York State New York PublicFederal Safe New York State New York Public Drinking Water Act Water QualityDrinking Water Act Water Quality Water SupplyWater Supply .,
Standards for Class RegulationsStandards for Class Regulations GA (Groundwater)GA (Groundwater)
MClMCL (ug/l)(ug/l) NYCRR, Title 66NYCRR, Title NYCRR, Title 10NYCRR, Title 10 Part 701-703Part 701-703 (ug/l)(ug/l) Part 5-1Part 5-1
(ug/I)(ug/l) VOCsVOCs 2-Butanone (MEK) 50 1,1-Dichloroethane1,1-Diehloroethane 55 55 1,2-Diehloroethane 55 0.6 55
2-Butanone (MEK) 50 5050
1,2-Dichloroethane 0.6 1,1,1-Trichloroethane1,1,1-Triehloroethane 200 55200 55 cis-1,2-Dichloroetheneeis-1,2-Diehloroethene 70 5570 55 Methylene chlorideMethylene chloride 55 55 55 . Tetrachloroethene 55 55Tetrachloroethene, 55 TolueneToluene 11 55"
Trichloroethene Vinyl chloride 22 22 22 Trichloroethene 55 55 Vinyl chloride
" :>i> , ' ," !. ." .. ",," ,'./ .....,..." , ,,' '
SVOCsSVOCs bis(2-Ethylhexyl)phthalate 55bis(2-Ethylhexyl)phthalate 66 66
..•
..,.,' j:• . . . . , . • . • ,.. . ] • ' ^ " • • ' . " . ' • , . . • " / ' • • . - - y
MetalsMetals Cadmium Iron 300300 '300 Cadmium 55 55 55 Iron 300 Manganese.Manganese . 300300 300300
531239
Table 111Table 1
Cost EstimateCost Estimate
MNA (Site-Wide Excluding MW-19 Area)MNA (Site-Wide Excluding MW-19 Area) Tri-Cities Barrel Superfund SiteTri-eities Ba rrel Superfund Site
Fenton, New York (a)Fenton, New York (a)
Description:Description: Implement groundwater monitoring programImp.lement groundwater .monitoring program Capital costs occur in YearCapital costs occur in Year 00 Annual O&M costs occur in Years 1-30.Annual O&M costs occur in Years 1·30
Periodic costs occur every yearsPeriodic costs occur every 55 years QTYaTY Unit Unit Cost Total Notes
CapitalCapital .
Administrative RequirementsAdm.inistrative Requirements Rod Modification SupportRod Modification Support LS11 LS 15,000$$ 15,000 $ 15,000$ 15,000 arbitraryarbitrary GW Monitoring PlanGW Monitoring Plan LS11 LS s 35,000$ 35,000 35,000$ 35000
s 50,000$ 50,000
SUBTOTALSUBTOTAL $ 50,000$ 50,000 ContingencyContingency $/ 12,500$ 12,500 25%25%
SUBTOTALSUBTOTAL $ • 62,500$ 62,500 '
SUBTOTALSUBTOTAL 62,500$$ 62,500 Project ManagementProject Management 3,125$$ 3,125 5%5%
TOTAL CAPITAL COSTTOTAL CAPIlAL COST 65,625$$ 65,625
MonitoringMonitoring
Perfonriance MonitoringPerformance Monitoring Procurement/SetupProcurement/Setup 24 ,24 HoursHours $ 120$ 120 $ 2,880$ 2,880 TravelTravel 2 Trip2Trip . $ 500$ 500 $ 1,000$ 1,000 Annual sampling (two full time) Groundwater lab MNA Parameters Equipnnent Rental Shipping Report
Annual sampling (two full time) Groundwater lab
,, MNA Parameters Equipment Rental Shipping Report
Days 13 Each 10 Each
Week . Each Each
66 Days 13 Each 10 Each
11 Week 33 Each 11 Each
$ S $ $ $ $
1,500 220 500
5,000 150
7,500
$ 1,500 $ 220 $ 500 $ 5,000 $ 150 $ 7,500
$ $ $ • $ .
$ •
1_
9,000 10 wells 2,860 metals. VOCs 5,000 5,000
450 7,500
$ 9,000 $ 2,860 $ 5,000 $ 5,000 $ 450 $ 7500
10 wells metals, VOCs
EventEvent $-. 33,690$ 33,690 matches actual effortmatches actual effort AnnualAnnual s 134,760$ 134,760 .
Five Year Review ReportsFive Year Revi.ew Reports Years5,10.15, 20. 25. 30Years 5,10,15, 20, 25,.30 15,000 .$ 15,000
AbandonnnentAbandonment Well AbandonmentWell Abandonment 40 Each40 Each 700$ 700 $.$. 28,00028,000 Site RestorationSite Restoration acre11 acre 3,500$ 3,500 _ 3.500$$ 3500
S 31,500$ 31,500
Present Value Analysis, Present Value Analysis
DiscountDiscount PresentPresent TypeType Year Total CostTotal Cost Annual Cost Factor (7%)Annual Cost Factor (7%) ValueValue
CapitalCapital 0 65,625o $$ 65,625 6562565625 11 s 65,625$ 65,625 Annual O&M Periodic Cost Periodic Cost Periodic Cost
AnnualO&M Periodic Cost Periodic Cost Periodic Cost
1-30 .
10 15
1-30 55
10 15
404280015,00015,00015,000
4042800 $$ 15,000 $$ 15,000 $$ 15,000
134,760 15000
• , 15000 15000
$$ 134,760 15000 15000 15000
12.409 0.713 0.508 0.362
12.409 0.713 0.508 0.362 •
$ $ $
$ • .
1,672,237 : 10,695
7,620 5,430
$ 1,672,237' $ 10,695 $ 7,620 $ 5,430
Periodic Cost Periodic Cost Periodic Cost Abandon System
Periodic Cost Periodic Cost Periodic Cost Abandon System'
20 25 30 S
• 30 _
15,00015,00015,00031,500
20 25 30 30
$$ 15,000 $$ 15,000 $ 15,000 $$ 31,500
•
$
15000 15000 15000
31,500
15000 :15000 15000
31.500
0.258 0.184 0.131 0.131
0.258 0.184 0.131 0.131
$ $ $ s.
3,870 2,760 1,965 4.127
$ 3,870 $ 2,760 $ 1,965 $ 4127
4,229,925$$ 4,229,925 s 1,774,328$ 1,774,328
Total Present ValueTotal Present Value $ 1,774,328$ 1,774,328
531240
· APPENDIX III.APPENDIX III
ADMINISTRATIVE RECORD INDEX ADMINISTRATIVE RECORD INDEX
531241
1111111111111111111111111111111111111111.II 111397111397
TRI-CITIES BARREL CO., INC.TRI-CITIES BARREL CO., INC. OPERABLE UNIT ONEOPERABLE UNIT ONE
ADMINISTRATIVE RECORD FILE UPDATE #6ADMINISTRATIVE RECORD FILE UPDATE #6 INDEX OF DOCUMENTSINDEX OF DOCUMENTS
RECORD DECISION5.05.0 RECORD OF DECISIONOF
5.2 Amendment the of5.2 AmencJinent to the Record of Decisionto Record Decision
- Final 500419 Natural Attenuation Evaluation, Tri-Cities .Attenuation Evaluatioh~ Tri-Cities
P.·500173P. 500173 -Report:Report: Final Revised Comprehensive MonitoredRevised Comprehensive Mon{tored 500419 Natural
Barrel Superfund Site, Fenton, New York,Barrel Superfund Site, Fenton, New York, prepared by ESC Engineering of New York, P.C.,prepared by ESC Engineering of New York, P.C.,
Doc. ID# 111379Doc. ID# 111379 prepared for U.S. Environmental Protectionprepared for u.S. Environmental Protection Agency, Region 2, August 16, 2007.Agency, Region 2, August 16, 2007.
P. 5004205 0 042 0- -Report: .Revised MonitoredReport: Comprehensive 500701500701 Natural Attenuation Evaluation, Tri-CitiesAttenuation Evaluation,
P. FinalFinal Revised Comprehensive Monitored Natural Tri-Cities Barrel Superfund Site, Fenton, New York, AppendixAppendix -- Groundwater Monitoring Logs, Barrel Superfund Site, Fenton, New York,
CC Groundwater Monitoring Logs, Doc. ID#111380ID# 111380 (Provided on CD), prepared by ESC Engineeringon prepared by EngineeringDoc. (Provided CD), ESC
of New York, P.C., prepared for u.S.of New York, P.C., prepared for U.S. Environmental Protection Agency, Region 2, August 16,August 16, 2007.2007. . , Environmental Protection Agency, Region 2,
500702 - Revised Monitored .503791503791 Natural Attenuation Evaluation, Tri-CitiesAttenuation Evaluation,
P.P. 500702 - Report:Report: FinalFinal Revised Comprehensive MonitoredComprehensive Natural Tri-Cities Barrel Superfund Site, Fentoh, New York~Barrel Superfund Site, Fenton, New York, Appendix D, Part 1, December 2001, prepared byAppendix D, Part I, December 2001, prepared by
Doc. ID#ID# 111381 ESC Engineering of New York, P.C., prepared forEngineering New P.C., forDoc. 111381 ESC of York, prepared U.~. Environmental Protection Agency, Region 2,U.S. Environmental Protection Agency, Region 2, August 16, 2007.August 16, 2007.
503792 - Revised Monitored 506936506936 Natural Attenuation Evaluation, Tri-CitiesAttenuation Evaluation,
P.P. 503792 - Report:Report: FinalFinal Revised Comprehensive MonitoredComprehensive Natural Tri-Cities Barrel Superfund Site, Fenton, New York,Barrel Superfund Site, Fenton, New York, Appendix D, Part 2, Summer 2002, prepared byAppendix D, Part 2, Summer 2 0 02, prepared by
Doc. ID# 111382 ESC Engineering of New York/P.C., prepared forDoc. ID# 111382 ESC Engineering of New York, P.C, prepared for u.S. Environmental Protection Agency, Region 2,U.S. Environmental Protection Agency, Region 2, August 16, 2007.August 16., 2007.
531242
P. - Final Comprehensivep. 506937506937 -Report:Report: Final Revised Comprehensive MonitoredRevised Monitored •513402 Natural Attenuation Evaluation, Tri-CitiesAttenuation Evaluation, Tri-Cities,513402 Natural j Barrel Superfund Site, Fenton, New York,Fenton, York,Barrel Superfund Site, New i Appendix D, Part 3, SpringPart Spring 2003,'prepared2 0 03, prepared bybyAppendix D, 3,
Doc.ID#Doc. ID# 111383 ESC Engineering of New York, P.C,Engineering New P.C., prepared for111383 ESC of York, pr~pared for U.S. Environmental Protection Agency, Region 2,U.S. Environmental Protection Agency, Region 2, August 16, 2007.August 16, 2007.
P. 513403 -Report:^513403 Report: Final Revised Comprehensive MonitoredRevised MonitoredP. - Final Comprehensive , • 514024 Natural Attenuation Evaluation, Tri-Cities, 514024 Natural Attenuation Evaluation, Tri-Cities
Barrel Superfund Site, Fenton, New York,Barrel Superfund Site, Fenton, New York, Appendix D, Part 4, Summer 2 0 03, prepared byAppendix D, Part 4, Summer 2003, prepared by
Doc. ID#ID# 111384 ESC Engineering of New York, P.C,Engineering New P.C., prepared forforDoc. 111384 ESC of York, prepared U.S. Environmental Protection Agency, Region 2,U.S. Environmental Protection Agency, Region 2, August 16, 2007.August 16, 2007.
514025 - Revised Monitored . 517345517345 Natural Attenuation Evaluation, Tri-Cities
P.P. 514025 - Report:Report: FinalFinal Revised Comprehensive MonitoredComprehensive Natural Attenuation Evaluation, Tri-Cities Barrel Superfund Site, Fenton, New York,Barrel Superfund Site, Fenton,New York, Appendix D, Part 5, Spring 2004, prepared 'by
Doc. ID#ID# 111385 ESC Engineering of New York, P.C,Engineering New P.C., prepared forfor Appendix D, Part 5, Spring 2004, prepared by
Doc. 111385 ESC of York, prepared U.S. Environmental Protection Agency, Region 2,U.S. Environmental Protection Agency, Region 2, August 16, 2007.August 16, 2007.
P. 517346517346 -Report:Report: Final Revised Comprehensive MonitoredP. - Final Revised Comprehensive Monitored .520237 Natural Attenuation Evaluation, Tri-CitiesAttentiation Evaluation, Tri-Cities~20237 Natural
Barrel Superfund Site, Fenton, New York,Barrel Superfund Site, Fenton, New York, Appendix D, Part 6, Summer 2004, prepared byAppendix D, Part 6, Summer 2 0 04, prepared by.
Doc. 111386 ESC Engineering of New York, P .,C., prepared forDoc. ID#ID# 111386 ESC Engineering of New York, P..C., prepared for U.S. Environmental Protection Agency, Region 2,U.S. Environmental Protection Agency, Region 2, August 16, 2 0 07.August 16, 2007.
P. 520238 - Report: Final Revised Comprehensive Monitored 522656522656 Natural Attenuation Evaluation, Tri-CitiesAttenuation Evaluation,
P. 52 023 8 - Report: Final Revised Comprehensive Monitored Natural Tri-Cities Barrel Superfund Site, Fenton, New York,
, Appendix D, Part 7, FallPart Fall 2 004, preparedprepared by ESCby Barrel Superfund Site, Fenton, New York, Appendix D, 7, 2004, ESC
Doc. ID#ID# 111387 . Engineering of New York, P.C,of York, prepared forprepared forDoc. 111387 . Engineering New P.C., U.S. Environmental' Protection Agency, Region 2,U.S. Environmental Protection Agency, Region 2, August 16, 2007.August 16, 2007.
522657 - Revised Monitored 525318525318 Natural Attenuation Eyaluation, Tri-CitiesAttenuation Evaluation,
P.P. 522657 - Report:Report: FinalFinal Revised Comprehensive MonitoredComprehensive Natural Tri-Cities Barrel Superfund Site, Fenton, New York,Barrel Superfund Site, Fenton, New York, Appendix D, Part 8, January 2 0 05, prepared byAppendix D, Part 8, January, 2005, prepared by
DocDoc... ID# 111388111388 ESC Engineering of ~ew Ybrk, P.C;, prepared forID# ESC Engineering of New York, P.C, prepared for
2
531243
i:\)vfV*Sjli'fllif^ p U > ^ ^ i f ^ ^ ' ' J. Si :^
U.S. Environmental Protection Agency, Region 2, .•.August 16, 2007.
U.S. Environmental Protection Agency, R:egion 2, August 16, 2 0 07.
P. - Finai Comprehensive 525720525720 Natural Attenuation Evaluation, Tri-CitiesAttenuation Evaluation,
P. 525319 -Report:525319 Report: Final Revised ComprehensiveRev1sed MonitoredMonitored Natural Tri-Cities Barrel Superfund Site, Fenton, New York,Barrel Superfund Site, Fenton, New York, Appendix D, PartAppendix D,Part SpringSpring 2005,2005, prepared by99 prepared by
Doc. ID# 111389 ESC Engineering of New York, P.C, prepared forDoc. ID# 111389 ESC Engineerin~ of New York, P.C., prepared for U.S. Environmental Protection Agency, Region 2 ,U.S. Environmental Protection Agency, Region 2,. August 16, 2007.. August 16, 2007.
525721 Pilot Repo~t(Revision2)P.P. 525721 -Report:-Report: Pilot Study ReportStudy (Revision 2) 525768 Tri-Cities Barrel Superfund Site, Fenton, New525768 Tri-Cities Barrel Superfund Site, Fenton, New
York, prepared by WSP Engineering of New York, Doc ID# 111390 P.C., prepared for U.S. Environmental
York, prepared by WSP Engineering of New York, P.C, prepared for U.S. EnvironmentalDoc. ID# 111390 Protection Agency, Region 2, January 15, 2010.Protection Agency, Region 2, January 15, 2010.
P. Report: (Revision 2) 527591 Tri-Cities Barrel Superfund Site, Fenton, NewFenton,
P. 525769525769 -- Report: .pilotPilot Study ReportStudy Report (Revision 2) 527 5 91 .Tri-Cities Barrel Superfund Site, New
York, AppendixYork, -- Laboratory Data ~- ProvidedAppendix DD Laboratory Data Provided on CD, prepared by WSP Engineering of New York,ori CD, prepared by WSP Engineerihg of New York,
Doc.Doc. ID# 111391111391 P.C, prepared for U.S.prepared U.S. EnvironmentalID~ P.C., for Environmental Protection Agency, Region 2, January 15, 2010.Protection Agency, Region 2, January 15, 2010.
527.592 - Area Investigation 528408528408 . .Report, Tri-Cities Barrel Superfund Site,
P.P. 527592 - Report:Report: MW-19 Area SupplementalMW-19 Supplemental Investigation Report, Tri-Cities Barrel Superfund Site, Fenton, New York, prepared by WSP EngineeringNe0 prepared by WSP Engineering .Feriton, York, ofof New York, P.C,York, preparedprepared forfor.New P.C., U.U.S.S.
Doc.Doc. ID# 111392111392 Environmental Protection Agency, Region 2,Protection Agency, Region 2,ID# Environmental February 3, 2011.February 3, 2011.
P. - Report: Focused 528526528526 Tri-Cities
P. 528409528409 - Report: FinalFinal Focused Feasibility Study,Feasibility Study, (Revision(Revision 2), Tri-Cities Barrel Superfund2), Barrel Superfund Site,Site,. Fenton, New York, prepared by WSP EngineeringFenton,New York, prepared by WSP Engineering ofof New , P.P. C.C,; prepared for U.S..,prepared for U. S.New York,York,
Doc. ID# 111394 Environmental Protection Agency, Region 2,Doc. ID# 111394 Environmental Protection Agency, Region.2, July 21, 2011.• July 21, 2011.
. 528527528527 -- Report: Final Focused Feasibility Study,FocusedP.P. Report: Final Feasibility Study, 531007 (Revision 2), Tri-CitiesTri-Cities Barrel Superfund Site,Superfund Site,531007 (Revision 2), Barrel
Fenton,Fenton, New York, AppendixYork, - MW-19,MW-19, AreaNew Appendix AA - Area Reports, prepared by WSP Engineering of
Doc. ID#ID# 111395 .NewNew York, P.C,P.C., for Environmental Reports, prepared by WSP Engineering of
Doc. 111395 York, preparedprepared , for U.S.U.S. Environmental Protection Agency, Region 2, July 21,.2011.Protection Agency, Region 2, July 21, 2011.
P. 531008531008 - Report: FinalFinal Focused Feasibility Study,F~asibility Study,P. - Report: Focused 531169 (Revision Tri-CitiesTri-Cities Barrel Superfund Site,Superfund Site,531169 (Revision 2)2) ,, Barrel
Doc. ID#ID# 111396 3Doc. 111396
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Fenton, New York, Appendices B-E, prepared byFenton, New York; AppendicesB-E, prepared by WSP Engineering of New York, P.C, prepared forWSP Engineering of New York,P. C. '. prepared for U.S. Environmental Protection Agency, Region 2,U.S. Environmental Protection Agency, Region 2, July 21, 2011.July 21, 2011.
P.P. 531170 - Report:Report: SuperfundSuperfund Proposed Plan for RemedyProposed for531170 - Plan Remedy 531182531182 Modification, Tri-Cities Barrel Site, Town ofModification, Tri-Cities Barrel Site, Town of
Fenton, Broome County, New York, prepared byFenton, Broome County, New York, prepared by U.S. Environmental Protection . Region 2,U.S. Environmental Protection Agency,Agency, Region 2,
Doc. ID# 111393Doc. ID# 111393 July 2011. .July 2011.
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,,;1.',_4.': . ' .k;??. ;• " - .'
APPENDIX IV APPENDIX IV
STATE LETTER OF CONCURRENCESTAtE LETTER OF CONCURRENCE
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New York State Department of Environmental ConservationNew York State Department of Environmental Conservation Division ofEnvironmentaJRemediationDivision of Environmental Remediation .~Office of the Director, 12th FloorOffice of the Director, 12th Floor ......625 Broadway, Albany, New York 12233-7011625 Broadway, Albany, New York 12233-7011 ..~
~ ..Phone: (518) 402-9706 o Fax: (518) 402-9020Phone: (518) 402-9706'Fax: (518) 402-9020 Website:Website: www.dec.nv,govwww.dec.ny.gov. Joe MartensJoe Martens
September 13, 2011 CommissionerSeptember 13, 2011 Commissioner SENT VIA EMAIL ONLYSENT VIA EMAIL ONLY
.Mr. Walter E. Mugdan, Director ([email protected])Mr. Walter E. Mugdan, Director (mugdan.\valter(@epa.gov) . Emergency and Remedial Response DivisionEmergency and Remedial Response Division United States Environmental Protection AgencyUnited States Environmental Protection Agency Region iIRegion II 290 Broadway, Floor 19290 Broadway, Floor 19 New York, New York 10007-1866New York, New York 10007-1866
.. Tri-City Barrel Company, Site No.: 704005 Amendment to the Record of Decision '
Re:Re: Tri-City Barrel Company, Site No.: 704005 Amendment to the Record ofDecision New York State ConcurrenceNew York State Concurrence
Dear Mr. Mugdan:Dear Mr. Mugdan:
The New York State Department ofof EnvironmentalEnvironmental (Department)The New York State Department ConservationConservation (Department) andand (NYSDOH) have reviewed the draft Amendment the ofDepartmentDepartment ofof HealthHealth (NYSDOH) have reviewed the draft Amendment toto the RecordRecord of
Decision dated September 2011 and concur with the amendment.Decision dated September 2011 and concur with the amendment. We understand the amendedWe understand the amended remedy for this site includes aa modification from aa pump and treat alternative to monitoredremedy for this site includes modification from pump and treat alternative to monitored naturalnatural attenuation.attenuation. As partpart of aa long-term groundwater monitoring program,program,of long-term groundwater monitoring groundwaterAs groundwater
collected and and ofsamples willsamples will bebe collected and analyzed periodically toanalyzed periodically to verifyverify that the, levelthat the level and extentextent of groundwater contaminants (e.g., VOCs) are declining and that conditions are protective ofofgroundwater contaminants (e.g., YOCs) are declining and that conditions are protectivehuman health and the environment. If this review indicates that monitored natural attenuationhuman health and the environment. If this review indicates that monitored natural attenuation was not effective, more aggressive remedies, such as enhanced monitored natural attenuation, .was not effective, more aggressive remedies, such as enhanced monitored natural attenuation" may be implemented.may be implemented.
In addition, as part of the amended remedy, EPA has determined that the restoration ofIn addition, as part of the amended remedy, EPA has determined that the restoration of . the groundwater in the MW-19 Area {i.e., attainment of the MCLs) is technically impracticablethe groundwater in the MW-19 Area (i.e., attainment of the MCLs) is technically impracticable from anan engineering perspective due toto the ineffectiveness of activeof active remedies inin the lowfrom engineering perspective due the ineffectiveness remedies the low permeable soils found at the Site, the limited mobility of the groundwater contamination (thepermeable soils found at the Site, the limited mobility of the groundwater contamination (the contaminant plume is not migrating), the absence of current and potential receptors, and thecontaminant plume is not migrating), the absence of current and potential receptors, and the inability to locate source. Therefore, EPA is issuing technical impracticability waiver for theinability to locate aa source. Therefore, EPA is issuing aa technical impracticability waiver forthe groundwater in this area. It is our understanding that the rubble near MW-19 has been excavatedgroundwater in this area. It is our understanding that the rubble near MW-19has been excavated and disposed off site at permitted landfill by the PRP Group as of August 2011.and disposed off site at aa permitted landfili by the PRP Group as ofAugust 2011.
The amended remedy was presented to the public at an August 16, 2011 meeting andThe amended remedy was presented to the public at an August 16, 2011 meeting and aa . public comment period was provided. Comments from the meeting and comment period arepublic comment period was provided. Comments from the meeting and comment period are presented and answered in the responsiveness summary included in the amendment. With thispresented and answered in the responsiveness summary included in the amendment. With this understanding, we concur with the selected remedy for the Tri-City Barrel Site.understanding, we concur with the selected remedy for the Tri-City Barrel Site.
If you have any questions or need additional information, please contact Mr. EdwardIf you have any questions or need additional information, please contact Mr. Edward Hampston at (518)402-9814. .Hampston at (518)402-9814.
Sincerely,Sincerely, .
£kQ..QaQ.~ . Dale A. Desnoyers, DirectorDale A. Desnoyers, Director Division of Environmental RemediationDivision of Environmental Remediation
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J. Singerman, USEPA (singerman;[email protected]) ec:ec: J. Singerman, USEPA ([email protected]) Y.Chang, USEPA ([email protected]) y. Chang, USEPA ([email protected]) S. Bates, NYSDOH ([email protected]) S. Bates, NYSDOH ([email protected]) ,G. Laccetti, NYSDOH ([email protected]) .G. Laccetti, NYSDOH ([email protected]) .R.Schick ,R. Schick 'M. Cruden 'M. emden ' j . White 'J. White ,E. Hampston :K Hampston ,
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APPENDIX VVAPPENDIX
RESPONSIVENESS SUMMARYRESPONSIVENESS SUMMARY
Appendices
V-a.V-a. Emails Submitted During the Public Comment Period
Appendices
Emails Submitted During the Public Comment Period
V-b.V-b; Public NoticePublic Notice
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RESPONSIVENESS SUMMARYRESPONSIVENESS SUMMARY Tri~Cities Barrel Superfund Site"Tri-Cities Barrel Superfund Site
INTRODUCTIONINTRODUCTION
Summary provides summary citizens' andThisThis ResponsivenessResponsiveness Summary provides aa summary ofof citizens' commentscomments and concerns received during the public" comment period relatedreceived during the public comment to the Jri-Cities Barrelconcerns period related to the Tri-Cities Barrel Superfund site (Site) Proposed Plan for Remedy Modification (Proposed Plan) and theSuperfund site (Site) Proposed Plan for Remedy Modification (Proposed Plan) arid the U.S. Environmental Protection Agency's (EPA's) and the New York State Department of EnvironmentalEnvironmental Conservation's (NYSDEC's) responses toto those "comments and U.S. Environmental Protection Agency's (EPA's) and the New York State Department of "
Conservation's (NYSDEC's) responses those comments and concerns.concerns. All comments summarized in this document have been considered in EPAAll comments summa"rized in this document have been considered in EPA and NYSDEC's final decision in the selection of modified groundwater remedy at theand NYSDEC's final decision in the selection of aa modified groundwater remedy at the Site.Site.
SUMMARY OF COIvlMUNITYRELATIONS ACTIVITIES"SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The Revised Comprehensive Monitored Natural Attenuation Evaluation Report (ESCThe Revised Comprehensive Monitored Natural Attenuation Evaluation Report (ESC Engineering, 2007), Pilot Study Report (Revision 2) (WSP Engineering, 2010), MW-19Engineering, 2007), Pilot Study Report (Revision 2) (WSP Engineering, 2010), MW-19 Area Supplemental Investigation Report (WSP Engineering, 2011), Focused FeasibilityArea Supplemental Investigation Report (WSP Engineering, 2011), Focused Feasibility Study Report (Revision 2) (WSP Engineering, 2011), and 2011 Proposed Plan forStudy Report (Revision 2) (WSP Engineering, 2011), and 2011 Proposed Plan for Remedy ModificationRemedy Modification for" thefor Site were made availableavailable to the public inin boththe Site were made to the public theboth the Administrative RecordRecord and"and informationinformation. repositoriesrepositories1 maintained at the EPA "maintained at the DocketAdministrative EPA Docket" "" Room in the Region I New York City office at 290 Broadway in Manhattan and theRoom in the Region III New York City office at 290 Broadway in Manhattahal1d the information repository at the Fenton Town Hall, 44 Park Street, Port Crane, New York.information repository at the Fenton Town Hall, 44 Park Street, Port Crane, New York.
notice of the commencement of the public comment period, the public meeting date,AA notice of the commencement of the public comment period, the public meeting date, the preferred modified groundwater remedy, contact information, and the availability ofthe preferred modified groundwater remedy, contact information, and the availability of the above-referenced documents published in the Binghamton Press and Sunthe above-referenced documents waswas published in the Binghamton Press and Sun Bulletin on Sunday, July 31, 2011. AA public comment period ran frompublic comment period ran from July 31,JUly 31, 20112011 toBulletin on Sunday, July 31, 2011. to August30, 2011.August 30, 2011.
at 7:00 P.M. at the Town of Fenton TownTown Hall toto present the findings of the recentrecent groundwater investigations andand EPA heldEPA held aa public meetingpublic meeting on Auguston August 16,16, 20112011 at 7:00 P.M. at the Town of Fenton
Hall present the findings "of the groundwater investigations aa focused feasibility study (FFS) and to answer questions from the public about the Sitefocused feasibility study (FFS) and to answer questions from the public about the Site and the groundwater remedial alternatives under consideration. Approximately 20and the groundwater remedial alternatives under consideration." Approximately" 20 people, including area residents, and state and local government officials, attended thepeople, including area residents, and state ahd local government officials, attended the public meeting. On the basis of comments received during the public comment period,public meeting. On the basis of comments received during the public comment period, the public generally supports the selected modified groundwater remedy.the public generally supports the selected modified groundwater remedy.
On August 1, 2011, another repository was added for this Site ~-- Fenton Free Library, 1062Fenton Free Library,On August 1, 2011, another repository was added for this Site 1062 Chenango Street, Binghamton, NY. "Chenango Street, Binghamton, NY.
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SUMMARY OF COMMENTS AND RESPONSESSUMMARY OF COMMENTS AND RESPONSES
The following correspondence (see AppendixAppendix V-a) wereThe following correspondence (see V-a) were received during thereceived during the publicpublic comment period:comment period:
•• Email YoLing Chang, August 3, from Kenyon,Email toto Young Chang, dateddated August 3, 2011,2011, from KeevinKeevin Kenyon, areaarea resident.resident.
. Email to Judith Enck, Regional Administrator, dated August 16, 2011 from James•• Email to Judith Enck, Regional Administrator, dated August 16, 2011 from James Little, Western Broome Environmental Stakeholders Coalition~.Little, Western Broome Environmental Stakeholders Coalition.
AA summ?ry of the comments contained in the above emails and the comments providedsummary of the comments contained in the above emails and the comments provided at the August 16, 2011 public meeting, as well as EPA and NYSDEC's responses to them, have been organized into the following topics: at the August 16, 2011 public meeting, as well as EPA and NYSDEC's responses to them, have been organized into the following topics:
Extent of Contamination~ Extent of Contamination • . Remedial AlternativesRemedial Alternatives
MW-19 Area and Technical Impracticability Waiver Concerns.• MW-19 Area and Technical Impracticability Waiver Concerns • Private Well ConcernsPrivate Well Concerns
. • Vapor Intrusion ConcernsVapor Intrusion Concerns
AA summary of the comments and concerns and EPA responses thereto are providedsummary of the comments and concerns and EPA responses thereto are provided below:below:
Extent of ContaminationExtent of Contamination . . . .
Comment #1: commenter requested details related to the 2003 soil and sedimentComment #1: AA commenter requested details related to the 2003 soil and sediment excavation activities conducted at the Site.excavation activities conducted at the Site.
Response #1: Based upon the results of the 1999 RI/FS reports, ROD was signed onResponse #1: Based upon the results of the 1999 RifFS reports, aa ROD was signed on March 31, 2000, which called for the excavation and off-site disposal of contaminatedMarch 31,2000, which called for the excavation andoff~site disposal of contaminated soil and sediment and the backfilling of the excavated area with clean fill. Pursuant toPursuant to aa. soil and sediment and the backfilling of the excavated area with clean fill. consent decree, in 2003, the potentially responsible parties (PRPs) .excavated and2003, the potentially responsible parties (PRPs) excavated and. consent decree, in disposed of off-site 74,969 tons (40,000 cubic yards) of contaminated soil and sediment.disposed of off-s.ite 74,969 tons (40,000 cubic yards) of contaminated soil and sediment.
'.' .
Comment #2: Several commenters expressed concern that contamination may haveComment #2: Several commentersexpressed concern that contamination may have spread to soils north of lnterstate-88 (1-88) up to, into, and along Osborne Creek, due tospread to soils north of Interstate-88 (1-88) up to, into, and along Osborne Creek, due to barrels traveling from the facility in flooding events during the mid-1970's and earlyparrels traveling from the facility in flooding events during the mid.;1970's and early 2000's.2000's;
Response #2: During the remedial investigation (Rl), sampling in Osborne Creek didResponse #2: During the remedial· investigation (RI), sampling in Osborne Creek did not any contaminationcontamination surface samples.not detectdetect any site-relatedsite-related inin surface waterwater oror sedimentsediment samples.
22
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""; '," .. '
found During the 2003However, contaminationHowever, contamination waswas found in soilsin soils located northlocated north ofof 1-88.1-88~ During the 2003 remedial action, contaminated soil in various areas of north of 1-88 excavated toremedial action, contaminated soil in various areas of north of 1~88 waswas excavated to depths of two to six feet (ft) and disposed of off the Site.depths of two to six feet (ft) and disposed of off the Site.
CommentComment #3: SeveralSeveral commenters expressed concern about groundwater#3: commenters expressed concern about groundwater contamination potentially moving off the Site.contamination potentially moving off the Site.
Response #3: The Site is underlain by 35 ft(southern portion of the Site, south of OldResponse #3: The Site is underlain by 35 ft (southern portion of the Site, south of Old Route 7) to greater than 60 ft (northern portion of the Site) of unconsolidated deposits,Route 7) to greater than 60 ft (northern portion of the Site) of unconsolidated deposits, which consist of clayey till with discontinuous thin sand and gravel lenses. Beneathwhich consist of aaclayey till with discontinuous thin. sand and gravel lenses. Beneath the unconsolidated deposits lies predominantly shale bedrock.the unconsolidated deposits lies predominantly shale bedrock. Based on over fifteenBased on over fifteen years of data, it has been concluded by EPA that the contamination in the groundwateryears of data, it has been concluded by EPA that the contamination in the groundwater at this Site is confined to the shallow groundwater present in the till and discontinuousat this Site is confined to the shallow groundwater present in the till and discontinuous sand layers mentioned above.sand layers mentioned above.
. . '. .
The affected groundwater atthe Site: is mainly restricted to the area south of 1-88, within thethe shallow, unconsolidated water-bearing zone;zone; the bedrock aquifer is not The affected groundwater at the Site; is mainly restricted to the area south of 1-88, within
shallow, unconsolidated water-bearing the bedrock aquifer is not contaminated.contaminated. Prior to the 2003 removal of the contaminated soil, the groundwaterPrior to the 2003 removal of the contaminated soil, the groundwater plume at the Site appeared to be located in isolated zones within an area approximately 240 ft wide by 500by 500 ftft long.long. The vertical andand horizontal extent of the groundwatergroundwater plume at the Site appeared to be located in isolated zones within an area approximately 240 ft wide The vertical horizontal extent of thecontaminant plume has not expanded since the Rl. Therefore, it is not anticipated thatcontaminant plume has not expanded since the RI. Therefore, it is not anticipated that the groundwater will migrate off-site in the future.the groundwater will migrate off-site in the future.
Remedial AlternativesRemedial Alternatives
Comment #4: commenter requested that EPA clarify the processes that would resultComment #4: AA commenter requeste~ that EPA clarify the processes that would result the in levels under the monitored natural·· attenuationinin the reductionreduction in contaminantcontaminant levels under the monitored natural attenuation
alternative.alternative.
Response #4:#4: NaturalNatural attenuation describes aa varietyvariety of in-situin-situ processes (i.e.,{i.e., biodegradation, dispersion, sorption, volatilization, oxidation-reduction reactions), which Response attenuation describes of proce~ses
biodegradation, dispersion, sorption, volatilization, oxidation~reduction reactions),which under favorable conditions, act without human intervention to reduce the mass, toxicity,under favorable conditions, act without human intervention to reduce the mass, toxicity, mobility, volume, or concentration of contaminants in groundwater. From throughmobility, volume, orconcentration of contaminants in groundwater. From 20012001 through 2005,2005, seven rounds were collected asas part of aa naturalseven rounds of groundwater samples naturalof groundwater samples were collected part of attenuation study.attenuation study. The data indicate that the total mass of contaminants had greatlyThe data indicate that the total mass of contaminantshadgreatly . reduced afterafter thethe removal ofof thethe contaminatedcontaminatied soil, whichwhich was. the· sourcethe ofof thethereduced removal soil, was sourcegroundwater . The data also showed the presence of reductive microbialgroundwater contaminationcontamination.. The data also showed the presence of reductive micrObial metabolic products, which indicate that the primary mechanism responsible for themetabolic products, which indicate that the primary mechanism responsible for the decline is biodegradation.decline is biodegradation.
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Under the monitored contamination wouldwould be addressed through natural attenuation.b~ Groundwater monitoring would be Under the monitored natural attenuation alternative,natural attenuation alternative, thethe groundwater contaminationgroundwater
addressed through natural attenuation. Groundwater monitoring would be I .
conducted to assess the progress of the natural attenuation. Specifically, groundwaterconducted to assess the progress of the natural attenuation. Specifically, groundwater samples, would be collected and analyzed periodically in order to verify that the levelsamples would be collected and analyzed periodically in order to verify that the level and extent of groundwater contaminants are declining and that conditions are protectiveand extert of groundwater contaminants are declining and .that conditions are protective of human health and the environment. In addition, biodegradation parameters (e.g.,of humah. health and the environment. In addition, biodegradation parameters (e.g., dissolved oxygen, nitrate, sulfate, methane, ethane, ethane, alkalinity, redox potential,. dissolved oxygen; nitrate, sulfate, methane; ethane, ethane, alkalinity, redox potential, pH, temperature, conductivity, chloride, sulfide, iron, and total organic carbon) would bepH, tem~erature, conductivity, chloride, sulfide,iron, and totalorganic carbon) would be
.used toused to assess the progress of the degradation~ssess process. Monitoring would continuethe progress of the degradation process. Monitoring would continue until the state and federal drinking water standards are met.until the state and federal drinking water standards are met.'
. Commeht#5: AA commenter asked if bioremediation, aa technology that encourages theComment #5: commenter asked if bioremediation, technology that encourages theI . ." .
growth and reproduction of indigenous microorganisms to enhance biodegradation ofgrowth 9nd reproduction of indigenous microorganisms to enhance biodegradation of organic constituents in the water table, would be an appropriate technique to remediateorganic constituents in the water table, WOLJld bean appropriate technique to remediate
. the contaminated groundwater.the contaminated. groundwater. . I
The 1999 report, which identified and evaluated remedialResponseResponse #5:#5: The 1999 FSFS report, which identified and evaluated remedial alternatives for the Site, evaluated bioremediation and concluded that the delivery ofalternatives for the Site, evaluated bioremediation and concluded that the delivery of bioremediation agents throughout the affected areaarea of groundwater would be' verybioremediation agents throughout the affected of groundwater would be very difficult at this Site. Nonetheless, one form oLbioremediation(injection of aa HydrogenNonetheless, one form of,bioremediation (injection ofdifficult at this Site. Hydrogen Release Compound) pilot-tested in the groundwater at one area of the Site. It wasRelease Compound) waswas pilot-tested' in the groundwater atone area of the Site. It was not, however, successful in breaking down the volatile organicnot, however, successful in breaking down the volatile organic compoundscompounds..
MW-19 Area and Technical Impracticability Waiver Concerns. MW-19 Area and TechnicallmpracticabilityWai'ler Concerns
. Comment #6:Comment #6: Several commenters .requestedSeveral commenters requested clarification regarding thethe technicalclarification regarding technical impracticability (TI) waiver that was proposed for the MW-19 Area.impracticability (TI) waiver that was proposed for the MW-19 Area.
Response #6: The restoration of contaminated groundwater is one of the primaryResponse #6: The restoration of contaminated groundwater is one of the primary objectivesobjectives of theof the Superfund program.program. Experience atat Superfund sites hasSuperfund Superfund. sites has shown,Experience shown, however, that. thethat the restoration of . contaminatedcontaminated groundwater may not always .behowever, restoration of groundwater may·' not always be achievable from an engineering perspective. .achievable iroman engineering perspective:
It was concluded that because of the low permeability of the aquifer, groundwaterIt' was concluded that because. of the low. permeability of the aquifer, groundwater extraction and treatment was not viable for the . •Seven rounds of groundwaterextractiohand treatment' was not viable for the SiteSite.. Seven rounds of groundwater samples were collected as part of natural attenuation study at the Site. Based uponsamples Were collected as part of aa natural attenuation study at the Site. Based upon its review, EPA concluded that while natural attenuation would be feasible for theits review, EPA concluded that while natural attenuation would be feasible for the contaminated groundwater for the majority of the Site, the data did not demonstratecontaminated groundwater. for the majority of the Site, the data did not demonstrate that natural attenuation would address the tetrachloroethylene (PCE) and 1,1,1that natural attenuation would address the tetrachloroethylene (peE) and 1,1,1
• A • • - . • • • ' . •"·4 .
531253
(1,1, 1-TCA) contamination in MW":19 Area (this
approximately 120 ft by 80 ft to depth of 30 ft.). trichloroethanetrichloroethane (1,1,1-TCA) contamination in thethe MW-19 Area (this areaarea isis approximately120 ft by 80 ft to aa depth of 30 ft.).
As part of aa PRP-performed field test in December 2008, approximately 50 gallons ofAs part of PRP-performed field test in December 2008, approximately 50 gallons of Hydrogen Release Compound (HRC) and approximately 35 gallons of HRC primer were injectedinjected in the MW-19in the MW-19 AreaArea ... Theresuits of fourrounds of subsequent sampling were Hydrogen Release Compound (HRC) and approximately 35 gallons of HRC primer were
The results of four rounds of subsequent sampling were inconclusive. EPAEPA requested that the PRPs perform additionalinconclusive. subsequently. requestedsubsequently that the PRPs perform additional investigation to locate the source and, if located, then perforrntargeted treatment.investigation to locate the source and, if located, then perform targeted treatment. TheThe PRPs performed this investigation from September through December 2010. This work includedincluded the performanceperformance of aa passivepassive soil· gassoil gas survey, collectioncollection PRPs performed this investigation from September through December 2010. This work
of of groundwater samples from the silt and sand/gravel zones beneath and around building debris that .
the survey, of groundwater samples from the silt and sand/gravel zones beneath and around building debris that waswas buried on the Site, permeability testing, and hydraulic conductivity testing. . Basedburied on the Site, permeability testing, and hydraulic conductivity testing. Based on the results of this effort, EPA concluded that the source of the PCE and 1,1, 1-TCAon the results of this effort, EPA concluded that the source of the PCE and 1,1,1-TCA contamination had not been identified and further efforts to try to identify the source would likelywould likely be fruitless.be fruitless. Nevertheless, the building debris in this area was excavated contamination had not been identified and further efforts to try to identify the source
Nevertheless, the building debris in this area was excavated· and disposed off-Site at aa permitted landfill by the PRP Group in August 2011.and disposed off-Site at permitted landfill by the PRP Group in August 2011.
EPA determineddetermined that thethe restoration ofof the groundwater in the MW-19 Area isEPA that restoration thegroundwat~r in the MW-19 Area is technically impracticable from an engineering perspective due to the ineffectiveness oftechnically impracticable from an engineering perspective due to the ineffectiveness of active remedies in the low permeable soils found at the Site, the limited mobility of the ...active remedies in the low permeable soils found at the Site, the limited mobility of the groundwater contamination (the contarninant plume is not migrating), and the inability togroundwater contamination (thecontaminant plume is not migrating), and the inability to locate aa source.locate source. Therefore, EPA proposed technical impracticability waiver from theTherefore, EPA proposed aa technical impracticability waiver from the regulatory requirements of the federal Safe Drinking Water Maximum Contaminationregulatory requirements of the federal Safe Drinking Water. Maximum Contamination Levels and NYSDEC Water Quality Regulations for Groundwater.Levels and NYSDEC Water Quality Regulations for Groundwater.
,
MW-19 Area groundwater will continue to be monitored periodically to confirm that theMW-19 Area groundwater will continue to be monitored periodically to confirm that the TI zone is notnot expanding or moving verticallyor or horizontally, and no additionaladditionalTl zone· is expanding moving vertically or horizontally, and no contaminants other than those waived are detected.contaminants other than those waived are detected.·
Comment #7: commenter questioned why the contamination in the MW-19 AreaComment #7: AA commenter questioned why the contamination in the MW-19 Area could not be excavated.could not be excavated.
. . ..
Response #7: The contamination in the MW-19 Area is confined to the groundwater.Response #7: The contamination in the MW-19 Area is confined to the groundwater. Since the soil in this area is not contaminated, its excavation would not remediate theSince the soil in this area is not contaminated, its excavation would not remediate the groundwater contamination.groundwater contamination.
CommentComment #8:#8: AA commenter asked whethercommenter asked whether anan air sparging system or groundwaterair sparging system or groundwater extraction system would be an appropriate technique to remove contamination in theextraction system· would be an appropriate technique to remove contamination in the MW-19 Area.MW-19 Area.
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Response #8: Air sparging is an in-situ treatment method that consists of injecting airResponse #8: Air sparging is an in-situ treatment method that consists of injecting airI
into the groundwater through drilled wells or driven points. Volatile organic constituentsinto the groundwater through drilled wells or driven points. Volatile organic constituents in groundwater partition into the injected· air. The air and organic compounds then risein groundwater partition into the injected air. The air and organic compounds then rise to the vadose.zone where they are typically removed by aa soil vapor extraction systemsystem .. This method was considered in the 1999 FS, but was not retained for detailed analysis to the vadose zone where they are typically removed by soil vapor extraction
. this method was considered in the 1999 FS,· but was not retained for detailed analysis due to ineffectiveness. TheThe low permeability soilssoils at the Site would inhibit thethedue to:ineffectiveness. low permeability at the· Site would inhibiteffectiveness of injection and movement of air into and through the subsurface.effectiveness of injection and movement of air into arid through the subsurface.
. I I
• i •
Groundwater extraction and treatment were also evaluated in the FFS. While thisGroundwater extraction and treatment were also evaluated in the FFS. While this remedy would be implementable, it is severely limited in its effectivenes.s by the lowremedy would be implementable, it is severely limited in its effectiveness by the low permeability of the soils at the Site. Also contributing to the decreased effectiveness ofpermeability of the soils at the Site. Also contributing to the decreased effectiveness of
.such a r~medy is the Iimite~ mobility ofthe groundwater contamination and the inabilitySuch a remedy is the limited mobility of the groundwater contamination and the inabilityto locate a contamination source in the MW-19 area. There are also significantly higherto locate a contamination source in the MW-19 area. There are also significantly higher capital a!nd operation and maintenancecosts associated with this remedy. As a result, itcapital and operation and maintenance costs associated with this remedy. As a result, it was determined not to be an appropriate remedy.was determined not to be an appropriate remedy.I
t It '
Several commenters expressed concern that a. TI waiver was being.CommentComment #9: Several commenters#9: expressed concern that a TI waiver was being sought for an area where aa source cannot be found.sought for an area where source cannot be found.
Response #9: Sufficient for protection human environment are in place. Currently, there is no one on the Site using the groundwater Response #9: Sufficient safeguardssafeguards for thethe protection ofof human healthhealth andand thethe environment are in place. Currently, there is no one on the Site using the groundwater for drinking water purposes. InIn addition,addition, aa deed restriction prohibits the installation andfor drinking water purposes. deed restriction prohibits the installation and use of groundwater wells at the Site for drinking water purposes until drinking wateruse of groundwater wells at the Site for drinking water purposes until drinking water
II
standards have been met Continued monitoring will ensure that the Site remainsstandards have been met. Continued monitoring will ensure that the Site remains protective of human health until the cleanup levels have beenprotective of human health until the cleanup levels have been achievedachieved..
.It should also be noted that the bedrock aquifer, which is used for potable purposes inIt should also be noted that the bedrock aquifer, which is used for potable purposes 'in the area, is not contaminated.the area,is not contaminated.
Private Well ConcernsPrivate Well Concerns
Comment #10: Several commenters expressed concern that drinking water wells on. Comment #10: Several· commenters expressed concern that drinking water wells on their respective properties have not been adequately monitored.their respective properties have not been adequately monitored.
Response #10: Within 1,000 ft of the Site boundary, there are nine private drinkingResponse #10: Within 1,000 ft of the Site boundary, there are nine private drinking water wells. They are all located upgradient or cross-gradient from the Site and are~ater wells. They are all located upgradient or cross-gradient from the Site and are installedinstalled inin bedrock.bedrock. Therefore, they are not considered potential receptors of theTherefore, they are not considered potential receptors of the affected groundwater. Based on over fifteen years of data, EPA has concluded that thepffectedgroundwater. Based on overfifteeri years of data, EPAhas concluded that the contamination in the groundwater at this Site is confined to the shallow groundwatercontamination in the groundwater at this Site is confined to the shallow groundwater·
6
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addition, concentrations wellsunit.unit. InIn addition, thethe relativelyrelatively lowlow concentrations observedobserved inin monitoringmonitoring wells downgradient of the source areas suggest that the plume is not mobile, since the plumedowngradient of the source areas suggest that the plume is not mobile, since the plume has not expanded since the 1999 Rl. The private drinking water wells were sampled byhas not expanded since the 1999 RI. the private drinking water wells were sampled by the New York State Department of Health during the Rl; no Site-related contaminantsthe New York State Department of Health during the RI; no Site-related contaminants were detected.were detected. The residential well located closest to the Site was resampled in 2005.The residential well located closest to the Site was resampled in 2005. Site-related contaminants were not detected.Site-related contaminants were not detected. For these reasons, EPA does not believeFor these reasons, EPA does not believe that monitoring is warranted for thewarranted for the private drinking water wells.wells. However,However, sincesincethat monitoring is private drinking waterconcerns related to contamination were expressed, the New York State Department ofconcerns related to contamination were expressed, the New York State Department of Health will sample several of residents' private drinking water wells.Health will sample several of residents' private drinking water wells.
Vapor Intrusion ConcernsVapor Intrusion Concerns
Comment #11: commenter expressed concerns about vapor intrusion.Comment #11: AA commenter expressed concerns about vapor intrusion.
Response #11: Because the groundwater contamination is not migrating beyond theResponse #11: Because the groundwater contamination is not migrating beyond the Site boundary, vapor intrusionSite boundary, vapor intrusion is not consideredis not considered aa concern for nearby residences.concern for nearby residences. InIn . the future, if any structure is constructed on the Site, soil vapor intrusion study may be. the future, if any structure is constructed on the Site, aa soil vapor intrusion study may be warranted.warranted.
7
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APPENDIX V-a APPENDIX V-a
Emails Submitted During the Public Comment PeriodEmails Submitted During the Public Comment Period
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Pagel of IPage 1 of 1
/ "" Tri cities .Burrel SuperFund SiteTri cities Barrel SupcrFund Site/ Kcevin Kenyoni )fM Keevin Kenyon .(ltt*• ^ ^ ^ to:
,----"y to: YOllng Chang 08/0312011 03: 10 PM Young Chang 08/03/2011 03:10 PM Hide DetailsHide Details From: "Kecvin Kenyon" <[email protected],com> From: "Keevin Kenyon" <kkenyon 1 @stny.rr.com>
. To: Young Chang/R2/USEPA/US@EPATo: Young Chang/R2/USEPA/US@EPA
To whom it may Concern:To whom it may Concern:
We have lived at 56 Pleasant Hill Rd. in Port Crane.NY since October 1982 and our property is bordered byWe have Jived at 56 Pleasant Hill Rd. in Port Crane,NY since October 1982 and our property is bordered by Osborne Creek, in April 1988 our water well ceased to provide enough water and we had new 300 ft. wellOsborne Creek. In April 1988 our water well ceased to provide enough water and we had aa new 300 ft. well drilled. The new well has great deal of sediment and significant amount of an unidentified gas. We initiallydrilled. The new well has aa great deal of sediment and aa significant amount of an unidentified gas. We initially drank the water but eventually switched to bottled water because of the strong odor and taste of the welt water.drank th.e water but eventually switched to bottled water because of the strong odor and taste of the well water.
We previously opposed any modification to the soil and sediment portion of the remedy. We are alsoWe previously opposed any modification to the soil and sediment portion of the remedy. We are also opposed to this modification unless it can be shown that aa full hydrogeologic investigation has been completedopposed to this modification unless it can be shown that full hydrogeologic investigation has been completed and no risk to the communtiy exists.and no risk to the communtiy exists.
Regards,Regards,
Keevin and Cheyanne KenyonKeevin and Cheyanne Kenyon
filc://C:\Documents and ScUings\ychang\Local Settings\Tcmp\notes57899E\~web0438.htm 8/3/2011filc:IIC:\Documents and Scttings\ychang\Local Settings\Tcmp\notes57899E\-web0438,htm 8/3/2011
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To:.Jo; Ce:Cc: Bee:¥.> . Bcc: Subject: Fw: hltp:/lwww.pressconnects.com/article/2011 0815/NEWS0111 08150364/-2-4M~effort-won.Subject: Fw: http://www.pressconnects.com/ai1icle/20110815/NEWS01/108150364/-2-4IVI-effort-won-From: young Chang/R2/USEPNUS • Tuesday 09/06/2011 04:01 PMFrom: Young Chang/R2/USEPA/US - Tuesday 09/06/2011 04:01 PM
----. Forwarded by Walter Mugdan/R2/USEPNUSon 08/1712011· 10:25 AM -----Forwarded by Walter Mugdan/R2/USEPA/US on 08/17/2011 10:25 AM • . ~ r • . . • • • • • •
••••• Forwaided by Judith EncklR2IUSEPNUS on 08/16/2011 10:57 AM .--_.Forwarded by Judith Enck/R2/USEPA/US on 08/16/2011 10:57 AM —
From: [email protected] From: [email protected] To:To: Judith Encl</R2/USEPA/US@ERA Judith EncklR2/USEPNUS@EPA Date:Date: 08/16/2011 10:39 AM 08/16/201110:39AM Subject:Subject: http://www.pressconnects.com/artlcle/20110815/NEWS01/108150364/-2-4M-effort-wonhttp://www.pressconneets.eom/articleI2011 0815INEWS01/108150364/·2·4M·effort·won------'----'-----------------------------'--
I 'Would biq remediation be an option forcleanup here? James Little Endicott NYWould bib remediation be an option for cleanup here? James Little Endicott NY ," ,'. '.... .' . .
. http://www.pressconnects.com/article/2011 0815/N EWS0111 081503641-2-4M-effort-won-t-clean·up-Tri-Citi hltp://www.pressconnects.com/article/20110815/NEWS01/108150364/-2-4M-effort-won-t-clean-up-Tri-Citi es-Barrehfacilitv?odvsseY=tabltopnewsltext|FRONTPAGE es-Barrel-facility?odyssey=tabltopnewsltextIFRONTPAGE
i I
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APPENDIX V-b·APPENDIX V-b
Public NoticePublic Notice
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. 16A, I 1'Rr.'iS~;SIlN-BlJLLliIN1 6 A . I PRLSSi SllN-BllLLETIH WORLD� Sunday, July 31, 2011WO R LD Sunday. July 31. 2011
THE UNITED STATES ENVlRONMENTAL:PROTECTION AGENCY. THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY . INVITES• INVITES Afghans arrest Taliban leader'Afghans arrest Taliban leaderPUBLIC COMMENT ON THE PROPOSED MODIFIED GROUNDWATER REMEDY FOR, PUBLIC COMMENT ON THE PROPOSED MODIFIED GROUNDWATER REMEDY FOR
THE TRI-CITIES BARREL SUPERFUND SITETHE TRI-CITIES BARREL SUPERFUND SITE . . Insurgent, official , .•••;"?fif
The U.S. Environmental Protection Agency (EPA) and the New York State Department of also detained • Insurgent, official
The U.S. En>ironmental Protection Agency (EPA) and the New York Slate Department of also detained En>ironmental Conservation viII hold a public meeting on August 1&, 2011 at 7 p.m. in theEnwronmenta! Conservation will hold a public meeyng on August 16,2011 at 7 p.m. in the Town of fenton Town Hall, 44 Pari< Stree\ Port Crane, NY, to discuss EPA's Proposed P~nTown of Fenton Town HaB. 44 Park Street, Port Crane, NY, to discuss EPA's Proposed Plan
KABUL, Afghanillan - Aforfor Remedy Modification {Proposed Plan)Remedy Modificat~n fof the Tri-Cities Barrel Superfund site. EPA is senior Derensc Ministry� KABUL, Afgtianitian — A i ^ y(Proposed Plan) lor the Tr>-Cities Barrel Supertund site. EPA is senior Defense Ministry
issuing the Proposed Plan as part of its public partidpation responsibilities under Section whoissuing the Proposed Plan as part of its public participation responsibiilties under Section officiul allegedlynfficiul who allegedly leaked secrets that117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act of ^
SJ^Ms S117(a) of the Comprehensive E0\1ronmentai Response, Compensation, and Uabitity Act of leaked secrets that helped thc'Talihan stagehelped the'Hiiihnn .stage ^^^H..� 1980, as amended, and Section 300.430(f) of the National Contingency Plan.1980, as amended, and Section 300.430m oflhe Nat~nal Contingency Plan. suicide attacks in Kabulsuicide iitt&ck.s in Kabul has beenhas been arrestedarrested by theby the fe^ ^ ^ ^ ^ W^M^ i ? * ' ^ Afghlln Intclligence ScrInIn 2000,2000, 'EPA selected a remedy for the sile that "ctuded the excavation of oonlaminated Afghan Iniulligeucc SerEPA selected a remedy for the site that included the excavation of contaminated vice.- one of lhr~e high�
soils and sediments, foBowed off-site treatmenl'disposal, and extrai^on and on-sile profileprofile arre.st.sarrests anvice.— one o f I h r t e high M ^^Si 1^^PiMsoils and sediments, foDowed byby off-site trealmenVdisposal, and ex~action and on~sile onnouncc'd Sllt~rdllY by the Marine Cpl. Patrick Ducey, 21, of Garfield,-NJ.• left. aodIVIarine Cpl. Patrick Ducey. 21 , of Garfield, N.J., l e f t andtreatinenttreatment totoaddressaddress thethecontaminatedcontaminated groundwater.groundwater. TheThe soilsoil andand sedimentsediment portionportion·of·theof the nounced Saturday by the lance Cpl. Charlie Quintana, 22. of Manhattan. rMt for a
remedywas implemented in 2003: • . moment while hiking down from an observation point Lance Cpl. Charlie Quintana. 22. of Manhattan. re«t for a . . agellcy.remedy was implemented", ZOO),' . • agency. moment while hiking down from an observation point
AA spokesman said also.spokesman said also Saturday, In Helmand province, Afg~anistan. AS!rOCLAfW f'RmSaturday, in Helmand province, Afghanistan, ASSOCIAIEU PN^SSarrcsted aa senior TheThe ProposedProposed PlanPlan describesdescribes proposedproposed changeschanges to(o thethe groundwatergroundwater componentcomponent ofof thethe ThUban officialofficial accused U.S.-led military alliance institutions, iricludin~ an
arrested werewere senior Tuliban accused U.S.-lcd military alliance institutions, including aitofof leadingleading till insurgentinsurgent that'is training theman April suicide bombing byThe main leature of the preferred� that ' i s them —
often on bases they an at tackerattacker wearing-anan remedyremedy andand identifiesidentifies thethe rationalerationale lorfor thisthis preference,preference. The main feature of the preferred training April suicide bombing by
propagandapropllgllllda cllmplligncampaign inin ofteil on huses they nn wearingmodifiedmodified groundwater remedygroundwater remedy isis thetheutilizationutilization ofofmonitoredmonitored natural attenuationnatural attenuation toto restore,therestore the eastern Arghanistim, andensl'ern Afghtmistltn, and share. The TalibanTaJihlln havehave nrmy uniform thatthat killedshare. Tht~ army uniform killed groundwater instead of groundwater extaction and treatment. . an insurgenl who alleged said~aid the practice has be three peoplepeople lHgroundwaler instead of groundwater extraction and treatment. an insurgent who alleged three at the Dethe practice has be the De
ly helped organiz anorgllni...ee main fense Ministry.ly helped lin come'onecome' one ofof theirl'heir mIJin fen,se Ministry.April ] attack again.-il the strategicsstrlltegies in theirtheir TheThe intelligenceintelligence servin warwIJr serv
TheThe modified remedy desaibedmodified remedy described inin thetiie Proposed PlanProposed Plan isis thethe preferredpreferred modified remedymodified remedy forfor thethe ..~~~~IU.N. ~c:~~~~r~~~~ni~:headquarters in the~~: against the U.S.-led coali icc reccntly arrested Gulagainst the U.S.-led coali ice recently arrested Oulnorthern city of Ma/,ar-isite. Changes to the preferred modified remedy,� tiolland President Hamid an army ofsite. Changes to tfie preferred modified remedy, oror aa changechange fromfrom thettepreferredpreferred modifiedmOdified northcrn dty or MlIUJr-i- tion and President Hamid Mohammad,Mohnmmu(l, an army orSbarif that killed 11 peo Kar/iii'sKnrzai's goverrunenl.governrnenl. ficer who was serving atficer who was serving atdata indicate that sevenremedyremedy toto anotheranother remedy,remedy, maymay bebe mademade ififpublicpublic commentscomments oror additionaladditional data indicate that ple, including for~~~lJ,rt~~:~Il~i~~ll:~lv~~ll;~~: the Defense MinistrySeveral altaeksSevcralnltllc.:ks involvinvolv. the Defense Ministryeign U.N. employees, ,more appropriate remedial action. The ing bombers wearing headquarters in Kabul,suchsuch aa changechange will resultwill resu" inin aamore appropriate remedial action. The finalfinal decisiondecision regardingregarding cign U.N. cmployec:l. ing hom hers wearing hendquarl,ers in Kabul,
the modified remedy will be made after EPA has taken into consideration all public" Infiltraiion has l)ecoi:ne rnilitai'y unifclrmfi have spokesmanthe modified remedy will be made after EPA has taken into consideration all public • Inriltnttiolllws become military uniforms have thethe agency'sagency'£; spokesman d serious concern lor Hlrgcted foiLignforcign troops Uitifullah Mashal said j tLtigeted tioops tutifullnh Mashnl said at
comments. EPA is soliciting public commsnis on D)e aliernalives considered in the Proposed :~~comments. EPA is soliciting public comments on /he alternatives considered in the Proposed " .~ r;~~~oui~H'~~~c~:~~~ conferenceAfghan fotces as well as offii-ial a newsn. new:; conference..ind the ns well as official AfghallAfghan Plan and in the 1 Focused Feasibility Study report because EPA relies on public input toPlan and in the 201201 t focused feasibility Study report because EPA relies on public input to ensure that the concerns of the community are considered in selecting an effective remedyensure that the concerns of the community are considered in sele~ing an effective remedy for each Superfund site, •lor each Supertund site.
uncover^Youriiiiier Beauty The administrative record file contains the information upon which the selection of theThe adminislralive record file contains the informaton upon which the selection of the I lahler Smoother BilfinterSkm response action will be based and is available at the following locations:response action will be based and is available at the following locations: l^^P>L.aX«M^tfia.»
USEPA Records Center i< 4444 Park StreetPari< Street 290 Broadway. 1 a"'Floor
fentonFenton Town HallTown Hall USEPA Records Center 290 Broadway. 18· floor�
PortPort Crane,Crane, NYNY t138333833 NewYork, NY 10007-1866 I O I B ' A K ; .NewYorl<, NY 10007-18&6
?'fjk'}t ' M E D I C A LResponses to the comments received at the public meeting and in writing during the publicResponses to the comments received at the public meeting and in writing during the public comment period, which run, from Ju~ 31, 2011 to August 30. 2011, \>ill be documented incomment period, which runs from July 31,2011 to August 30.2011, will be documented in the Responsiveness Summary sectbn of an Amendment to the Record of Decision, thethe Responsiveness Summary sect~n of an Amendment to the Record of Decision, Ihe ; Your skin IS pur reputation.documentdocument that formalizes the selecfonthat formalizes the selection ofof thethe modified remedy.modified remedy. All written comments sfiouWAll wrillen comments shO\J~
be addressed to; Young S. Chang. Remedial Project Manager, USEPA, 290 Broadway, 20"be addressed to: Young S. Chang, Remedial Project Manager, USEPA, 290 Broadway, 20· 1 ^Contact our"speciaiist'to find'out hovj' ; ' the Obagi.skin "care system can h'eip'
•Floor, NewYork, NY 10007-1865, Fax: {212)537-3956, or chang.young^epa.gov.mai]]^'floor, New YOlk, NY 10007-1.8&&, fax: (212) &37-39&&, or chang.YO\[email protected],ilto:
^ . i ^ k / ' J ^ ' restore youfTiiatural beauty."- f Community Involvement Coordinator at; echois.cecili aeDa.aov, or call (212) 637-3678 or If you have any quesl~ns regarding the public meeting you can ..mail Ms. Cecilia Echols, .If you have any questions regarding the public meetii lyou can e-mail Ms, Cecilia Echols, Community Involvement Coordinator at: echols.cecitiaiiileoa.oov, or call (212) &37-3&78 or loll-free at 1-800-346-5009 • .� Dr. Joseph M Newmark M.D., F.A.A.D. BOARD CERTIFIEDloll-Iree aI1-800-346-5009 .
' 4104 Veslal Rd, Suite 203 Ve^-tal, NY 13850 607-797-903G
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