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Third ~ive-Year Review Report

For

FMC Dublin Road Superfund ;Site

Townships of Ridgeway and Shelby, Orleans County, New York

Prepared by:

U~S. Environmental Protection Agency. ,Region II

New York, NY

July 2010

EXECUTIVE SUMMARY

The remedy for the FMC Dublin Road Site in the Towns ofRidgeway and Shelby, Orleans County, New York includes stabilization of contaminated materials, an on-Site containment cell with . leachate collection system and permanent cap, an on-Site groundwater pun::ip and treat system, ~estoration ofon-Site wetlands and engineering and institutional controls. The trigger for this five­year review was the previous five-year review conducted in September 2005.

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Based upon review of the 1993 Record of Decision, operation and maintenance reports and an inspectiQn ofthe Site, it has been concluded that the remedy currently protects human health and the environment in the short.,.term because the groundwater pump and treat system has lowered concentra~ions of contaminants of concern and the cell cap is functioning as intended. However, in order for the remedy to be protective in the long-term, instjtutional controls need to be implemented.

Five-Year Review Summary Form

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SITE IDENTIFICATION

Site Name (from WasteLAN): FMC Dublin Road Superfund Site

EPA 10 (from WasteLAN): NYD 00511857

City/County: Towns of Ridgeway and Shelby, Orleans County

D NPL Status: • Final D Deleted D Other (specify)

,Remediation Status (choose all that apply): D Under Construction • Operating

Multiple OUs? 0 YES • NO ' Construction completion date: 5/29/97

Are portions of til is site and/or investigated adjacen,t properties in use or suitable for reuse?yes

REVIEW STATUS

Lead agency: 0 EPA • StateD Tribe o Other Federal Agency

Author name: Isabel Rodrigues ,

Author title: Remedial Project ' Author affiliation: EPA Manager

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Review period: 9/28/2005 - 7/2010, ,

D~te(s) 6f site inspection: 4/27/2010 "

Type of review: • Post-SARA o Pre-SARA d NPL-Remoital only o Non-NPL Remedial Action Site o NPL StatelTribe-lead -' o Regional Discretion • Statutory

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Review number: o 1 (first) D 2 (second) • 3 (third) D Other (specify) /

Triggering action:, D Actual RA Onsite Construction at OU #_ o Actual RA Start at OU# __ D Construction Completion • Previous Fi\{e-Year ReviewReport o Other (specify)

Triggering action date (from WasteLAN): 9/28/2005 \

l -Due date (five years after triggering action date): 9/28/2010

Does the report include recommendation(s) and follow-up action(s)? • yes D no Is human exposure under control? • yes o no Is contaminated groundwater under control? • yes ~fno D not yet determined Is the remedy protective of the, environment? • yes D no D not yet determined Acres in use or available for use: restricted:~" unrestricted: ­

Five-Year Review Summary Form (Continued) , I

Remedy Assessment Summary

Based on the data reviewed and the Site inspection, the remedy is functioning as intended by the 1993 record of decision (ROD): The cap is effectively limiting the infiltration of water into and through the landfill materials, and it appears to have had positive impacts on groundwater conditions. The cap also,. prevents direct contact exposure and fencing restricts access to the Site. The pump and treat treatment system has proven to be effective in reducing concentrations of the indicator chemicals identified in the 1993 ROD~ There have been no changes in the physical conditions of the "Site that would affect the protectiveness of the remedy.

Issues, Recommendations, and Follow-Up Actions

The selected remedy has not beeri fully implemented. Institutional controls (ICs)to protect the landfill remedy and to prevent potable water wells in the vicinity ofthe landfill need to be implemented. The Potentially Responsible Party (PRP), FMC, working with the Environmental. Protection Agency (EPA) and New York State Department ofEnvironmental Conservation (NYSDEC), is expected to implement these institutional controls.

In the 2000 Five-Year Review report, it was stated that the PRP intended to request approval of significant changes in the monitoring program. In August 2005, FMC submitted a proposal to EPA and NYSDEC for the shutdown ofthe groundwater extraction system at the Site and for modifications ofthe Site monitoring program based on data collected and summarized in the Remedia.1 System Evaluation and Proposal for Shutdown Report. A discussion of the Shutdown Proposal was held during a conference call among the NYSDEC, EPA, and FMC's technical representatives on December 15,2005 . .It was agreed that FMC would provide the agencies with additional information related to the Shutdown Proposal. FMC submitted additional information by letter dated March 22,2006. By letter dated August 28,2006, the agencies provided comments to FMC and advised that for purposes ofthe evaluation by the agencies relative to discontinue or revision ofthe groundwater extraction remedy, FMC should perform a Technical Impracticability (TI) Evaluation based on EPA guidance. FMC is currently Undertaking this TI evaluation and plans to submit it, together with re'sponses to agency comments upon completion.

This Site has ongoing operation, maintenance and monitoring activities as part of the selected remedy. As anticipated by the decision documents, these activities are subject to routine modification and adjustments.

Additionally, FMC should inspect and repair the perimeter fencing. Also, all wellheads and sump labels should be clearly marked and maintained. -'

Protectiveness Statement

The remedy currently protects human health and the· environment in the short-tenTI because the. groundwater pump and treat system has lowered concentrations ofcontaminants ofconcern and the cell cap is functioning as intended. However, in order for the remedy to be protective in the long-term, institutional controls need to be implemented.

Table of Contents

I. Introduction

II. Site Chronology

III. Background Site Characteristics. GeologylHydrology Land and Resource Use History of Contamination Basis for Taking Action

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Initial Responses Contaminants

IV. Remedial Actions Remedy Selection Remedy Implementation Operation, Maintenance and Long-Terril Monitoring Institutional Controls

V. Progress Since Last Five-Year Review

VI. Five-Year Review Process Administrative Components

. Community Involvement Document'Review Data Review Site Inspection Interviews

VII. Remedy Assessment

VIII. Recommendations and Follow-up Actions

IX. Protectiveness Statement

X. Next Review

Appendices Appendix A - List of Documents Reviewed Appendix B - Chronology of Site Events

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3 3 4 5 6

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6 7 7 7 7 14 14 .'

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Figures Figure 1- Site Plan

Tables Table 1 - Pounds of Contaminants Removed Table 2 - Updates to Toxicity Values Used in Original Risk Assessment for·

Groundwater through Calculation ofResidential Preliminary Remedial Goals Table 3 - Chemicals of Concern Exceeding Cleanup Levels or Remedial

Action Detection Limits at the Extraction Well Locations Table 4 - Updates to Toxicity Values Used in Original Risk Assessment for Surface

Water Based on Residential Preliminary Remediation Goals Table 5 - Chemical of Concern Exceeding Cleanup Levels or Remedial

Action Detection Limits in Surface Water Table 6 - Acronyms used in this Document Table 7 - Vapor Intrusion Screening Values for Contaminants of Concern.

Screening Values were Obtained from the OSWER Draft Guidance Table 8 - Recommendations and Follow-up Actions

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I. Introduction

This third five-year review for the FMC Dublin Road (FMC) Site (the Site), located partly in the Town ofRidgeway and partly inthe Town ofShelby, Orleans County, New York, was conducted by United States Environmental Protection Agency (EPA) Remedial Project Manager (RPM), Isabel Rodrigues. The five-year review was conducted pursuant to Section 121(c) ofthe Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, 42 U~S.C. §960 1 et seq. and 40 CFR 300.430(f)( 4 )(ii) and in accordance with the Comprehensive Five-Year Review Guidance, OSWERDirective 9355.7-03B-P (June 2001). The purpose ofafive-yearreview is to assure that implemented remedies protect public health and the' environment and that they

. function as intended by the site decision documents. This reportwill become part of the site file. Reports pertinent to this five-year review are listed in Appendix A.

In accordance with the Section 1.3.3 of the five-year review guidance, a subsequent statutory five­year review is triggered by the signing date of the previous five:.year review report. The previous five-year review report was signed on September 28,2005. This is the third five-year re'view report for the Site.

II. Site Chronology

Appendix B summarizes the Site-related events.

III. Background

Physical Characteristics

The Site is located in northwestern New York in Orleans County, and is situated partly in the town of Ridgeway and partly in the town of Shelby. The 30-acre propertY originally consisted of a rectangular portion ofapproximately 21 acres lying north ofDublin Road, and a triangular portion of approximately 9 acres lying south of Dublin Road. The northern section is partially wooded and co'ntains a wetland, a drainage swale, and two inactive rock quarries. Jeddo Creek runs in a northerly direction through the northeast comer of the Site. The southern portion of the Site is bound by the Ne'w York State Barge .Canal to the south and west, Dublin Road to the north, and a municipal ' landfill to the east and contained a waste 'pile, a Rectangular Pond and a swampy area. A Site Plan can be seen in Figure 1.

Site Geology/Hydrogeology

Overburden at the Site ranges from 0 to 25 feet in thickness and consists ofnaturaf'soils, fill, and waste material. The underlying Grimsby Formation, which is up to 52 feet in thickness, consists of red and white sandstone with the upper 25 feetofthe formation having intense fracturing. The major hydrogeologic formation consists of an overburden aquifer, upper bedrock aquifer, and a lower

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bedrock aquifer. The groundwater flowis generally towards the northeast.

Land and Resource Use

The Site is located within an industrial zoned area and is surrounded by fence. There are canals surrounding the Site that also limit access. The soils on the 30-acre property itself have been remediated, therefore, the property is considered suitable for reuse. The landfill area of the Site , would be suitable for restricted reuse ~nly. Other areas of the Site may be used for monitoring of gro'undwater and would also be considered available for restricted use.' On-Site wetlands were restored.

History ojContamination

FMC acquired the 30-acre Du~lin Road property from 1943 to 1946. From 1933 to 1968, approximately 9 acres ofthe southefl? portion oft4e Dublin Road Site were used for disposal ofcoal ash cinders, industrial debris and other materials, primarily from the Niagara SprayerlFMC manufacturing plant in Middleport, New York. These waste materials were placed in the Waste Pile, which consisted of a surface pile and a below-grade burial zone. .

Wastes disposed of in the Waste Pile included ash cinders from burning of coal, for power at the Middleport plant, lime-sulfur solutions residues from a filtration process? building debris,and a small amount oflaboratory wastes from the FMC Buffalo plant. Chemicals detected in the Waste Pile in excess of background concentrations include arsenic, copper, zinc, lead, benzene hexachloride (BHC) and its isomers, and dichlorodiphenyltrichloroethane (DDT) and its metabolites. Mercury was not included because the concentration of mercury was not significant in the 1988 data. However, the cleanup level for mercury has been specified.

Basis jor Taking Action

In 1978, an assessment ofgroundwater contamination indicated the presence ofchemicals in on-Site )

surface water and groundwater. Surface water runoff transported contaminants from the Waste Pile to the Rectangular POli.d, Swamp, and Quarries. Chemicals detected in sediment and surface water were arsenic, copper, lead, zinc, BHC and 'its isomer~, DDT and its metabolItes.

In 1981, additional monitoring wells were installed in· the overburden and bedrock, soil, and . sediment. Groundwater samples were collected and analyzed. Based on these results, it was

concluded the chemicals were migrating into the groundwater and offsite through the lower bedrock aquifer.

Initial Response

An Administrative Consent Order was entered into between New York State Department of

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Environmental Conservation (NYSDEC) and FMC in 1982, whereby FMC agreed to conduct a field investigation. In October 1984, EPA proposed the Site for inclusion on the National Priorities List (NPL). The Site was added to the NPL on June 1, 19~6. FMC and NYSDEC entered into a second Consent Order in February 1988 under which FMC agreed to further'define the extent of contamination at the Site, -complete the Remedial InvestigationlFeasibility Study (RIIFS) and perform the remedial action. The 1988 Consent Order superseded and replaced the 1982 Order. The RI, including a supplemental field investigation, wascompleted in May 1989 and was approved by NYSDEC in June 1990. The FSwas approved in January.

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Contaminants

The 1993 ROD identified the indicator chemicals selected for this Site based on persistence, , mobility, and toxicity to include Arsenic, Copper, Zinc, Lead, BHC (4 isomers), and DDT (and 2 metabolites). Mercury was not included because the concentration ofmercury was not significant in the 1988 data. Hq~ever, the cleanup level for mercury was specified.

IV. Remedial Actions

Remedy Selection

In March 1993, NYSDEC and EPA issued ajointROD selecting a remedial action forthe Site. The ROD listed R,eme'dial ACtion Objectives (RAOs) which are specific objectives to protect 'human health and the environment. These objectives are based on available information and standards, such as Applicable or Relevant and App~dpriate Requirements (ARARs). The following RAOs were establ\shed:

• Adequately protect against ingestion of, or contact with, contaminated soil; ) . ­

• Minimize damage to and provide adequate protection of the saturated zone from contaminants migrating from soil;

• Minimize damage from and adequately protect against the spread of the contaminated groundwater;

• AdequatelYprotect against future ingestion of, or contact with, contaminated groundwater;

• Adequately protect against contamination of surface water and sediments in the site vicinity; and

• Adequately protect against contaminated dust emissions into ambient air.

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To address these RAOs, the ROD called for a number ofremedial actions to mitigate exposures and restore the environment. The major elements of the 1993 remedy are presented below"

• Excavation, screening, and stabilization of all contaminated materials (soil and sediments) from the Waste Pile, Rectangular Pond,Swamp,' Drainage Swale, the Quarries, and other areas contaminated above cieanup levels;

• Stabilization of materials that failed toxicity characteristic leaching procedure (TCLP); "­

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• Construction of a customized on-Site containment cell complete with a leachate collection system and peimanen~ cap designed to meet the New York States Landfill Regulations at 6NYCRR Part 360;

• Deposition ofstabilized material and other soil/sediment contaminated above cleanup levels , in the on-Site containment cell; " . ­

• Collection of contaminated groundwater via a series of extraction wells;

• Treatment ofcontaminated runoff water, construction water, and groundwater in an on-Site groundwater treatment system;

• Restoration of the wetlands that existed on-Site;

• Installation of permanent fencing around the Site;

• Placement of deed restrictions on the property at the .completion of remediation~ and

• Performance of a long-term operation, maintenance, and monitoring at the Site.

An explanation of significant differences (ESD) was issued in July 1995, which amended the ROD and addressed placement of a greater quantity of contaminated soils into the containment cell than contemplated .in the 1993 ROD.

Remedy Implementation

The remedial design for this Site was completed and approved in- May 1994. The remedial action began in May 1994 and construction was completed in September J 996. The entire Site was cleared of trees and vegetation except for a small area north of Dublin Road .. The wood was chipped; stockpiled, and later used as road bed material on-Site. In 1994, excavation work began in the Waste Pile area and proceeded to the Rectangular Pond, ~wamp, Quarries and exclusion zones. Material requiring. stabilization was temporally stockpiled until stabilization was completed. The total volume ofcontilminated material excavated in 1994 was 44,931 cubic yards. In 1995, materials were

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excavated from the entire area south ofDublin Road. The depth ofexcavation varied, but most areas· were excavated down to bedrock. The roadbed of Dublin Road was also excavated. Contaminated

. soils passing TCLP analysis were directly deposited into the contai'nment cell. Excavated material that failed TCLP were treated and then placed directly in the containment cell. A Part 360 cap was placed over the containment cell. The total volume of-contaminated soil excavated in 1995 was

. 25,947 cubic yards. In 1996, the quarries and the areas between them were sampled. Sample results showed that the material exceeded RAOs. The quarries were dewatered, sediments were removed, soil between them ~as er:cavated, and the material was disposed ofoff-Site at the Chemical Waste Management facility in Model City, New York. The total volume of contaminated sediment disposed ofof~-Site was 77.1 cubic yards. A new wetland was constructed north ofDub lin Road and the area south of Dublin Road was graded arid a soil layer placed over the bedrock. The disturbed areas were then seeded and the Site was enclosed by a fence. Surface water run-off from the controlled areas was collected, treated, and discharged to Jeddo Creek and later to the on-Site.

In 1995, .the groundwater extraction system was installed and the treatment plant was constructed. In the fall of 1996,. the groundwater extraction and treatment systems were placed into operation. The groundwater extraction system is comprised ofeleven extraction wells and sumps. The treated groundwater is being discharged to the on-Site wetland in accordance with the established discharge limits.

In 1996; the wetlands were restored. The former drainage swale north ofDublin Road was restored as an open water impoundment between the original Swamp and the East Quarry. Isolated vegetation, peninsulas, and island habitat were incorporated in this wetland design.

EP A documented completion of construction activities in the Preliminary Close Out Report dated May 29,1997.

Operation; Maintenance, and Long-Term Monitoring

An operation and maintenance (O&M) program is part of the remedy for the Site and has 'been developed and implemented. The O&M program includes operation and maintenance of the pump . apd treat system, leachate collection system, and maintenance of the 'containment cell. The monitoring program also includes groundwater, surface water, and treatment system monitoring: , Details of the O&M program are included in the O&M Manual which was approved by the NYSDEC on December 3, 1996. Periodic adjustments and/or modifications to the constructed remedy are performed by FMC to maintain optimum perf?rmance.

FMC submitted the First Quarterly-Operations and Maintenance Status Report in May 1997. Since then FMC has submitted quarterly reports which contain the results of groundwater, surface water and treatment system discharge monitoring. The monitoring results indicate that the groundwater extraction and treatment systems are performing as designed. Groundwater level monitoring demonstrates that the extraction well~ are achieving containment and capture of contaminated

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groundwater. The treatment system monitoring also demonstrates that none ofthe effluent discharge limits for discharge to the on-Site w~tlands were exceeded at any time.

Institutional Controls

The ROD included recommendations for limiting future use ofthe Site and the groundwater through deed restrictions, to insure that the remedial measures which have been taken on the Site will not be disturbed'and that the Site will not be used for purposes incompatible with the completed remedial

. acti'on. These deed restrictions have not been implemented yet. .

On October 7, 2003, Governor Pataki signed into law legislation which, in part, refinanced and reformed the State Superfund Program and created a new Brownfield Cleanup Program. A new section was thus added to the New York State Environmental Conservation Law (ECL) that specifically concerns Environmental Easements, Based upon the requi'rements of this provision', NYSDEC developed and recently finalized a model environmental easement. EP A is currently working withNYSDEC on an appropriate easement that shall be filed at the, Site.

V.' Progress Since the Last Five-Year Report

The second five-year review for this Site was signed on September 28, 2005. The 2005 five-year review concluded that the remedies selected in the 1993 ROD and implemented were protective of human health and the environment.' The report recommended implementation of institutional .

, coritrols. Appropriate institutional controls have not yet been implemented. . . ,",

In the 2000 Five-Year Review report, it was stated that the PRP intended to request approval of significant changes in the monitpring program. 'In August 2005, FMC submitted a proposal to EPA and NYSDEC for the shutdown of the groundwater extraction system at the Site and for modifications of the Site monitoring program based on data collected and summarized in the Remedial System Evaluation and Proposal for ShutdoWn Repo~. A discussion of the Shutdown Proposal was held during a conference call among the NYSDEC, EPA, and FMC's technical representatives on December 15,2005. It was agreed that FMC would provide the Agencies with additional information related to the Shutdown Proposal. FMC submitted additional infonpation by letter dated March 22, 2006: By letter dated August 28, 2006, the Agencies provided comments to FMC arid advised that for purposes of the evaluation by the Agencies relative to discontinue or ' revision of the groundwater extraction remedy, FMC should perform a Technical Impracticability (TI) Evaluation based on EPA guidance. FMC is currently undertaking this TI evaluation: and plans to submit it, together with responses to the comments from the Agencies upon completion.

VI. Five-Year Review Process

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Administrative Components

. The five-year review team consisted of Is'abel Rodrigues (Remeqial Project Manager), Ashley "Wiedemer (Remedial Project Manager), Kevin Lynch (Western New York Remediation Section Chief), Marian Olsen (Risk Assessor), Mindy Pensak (Ecological Risk Assessor) and Marc Yalom , .

(Hydr6geologist)ofEPA and Vale~ie Woodward (Project Manager) ofNYSDEC. .

Community Involvement

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EPA notified the community of the initiation of the five-year review process by publishing a notice . '

in the Lockport Union S~I1and Journal, a local newspaper, on Friday, June 25,2010. The noticed, indicated that EPA would be conducting a five-year review of the remedy as the FMC Dublin Road Superfund Site to ensure the remedy remains protective of public health and are functioning as intended by the decision ~ocuments. It also indicated that the five-year review will be made available in the local sit~ repositories and at the U.S. EPARecords Center at 290 Broadway, New York, NY. The RPM's contact information was also provided for questions related to the five-year review process or the FMC Site. ' -

Document Review

The documents, data, and information which wer~ reviewed in compiling the five-year review report " are summarized in Appendix B.

Data Review

Groundwater Extraction and Treatment System

, The average monthly discharge to the wetland in 2009 was 3,451 gallons. A total of44,062 gallons' or groundwater were treated and discharged.to the wetland in 2009. A comparison ofthe yearly amount ofgroundwater removed and discharged since 1998 can be seen in Table 1. Overall, water volume extracted d~creased significantly until 2007, but began'to incr~ase in 2008 and 2009. In 2007, the decreases in flow, leading to decreases in constituent removal, were largely due to frozen airlines, inoperable groundwater extraction :and treatment system computer, .air 'compress,Or operational issues, pump requiriuKreplacement, forcemain replacement and tank repair. Increases in 2008 and 2009 are due to fewer maintenance related shutdowns. '

J;:leven extraction wells (EWOl through EW06, and EW08 through EW12) are sampled monthly fcir pesticides,ethylenethiourea, herbicides and metals. ( ,

From 2005 to 2009, pesticides4,4'-DDE, 4,4'-DDD and 4,4'-DDT were not detected in extraction wells. By late 2006, BHC isomers were no longer detected or estimated in extraction wells, except in EW08. Alpha-BHC was detected frequently in EW08 during the review period, above the

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RAD.

Ethylenethiourea was not detected in extraction wells during the review period.

Herbicides 2,4..,0 and 2,4,5-T were not detected in extraction wells afierSeptember 2006. 2,4,5-TP I \

was not detected during the five-year review period.

Ofthe metal parameters, in 2009, arsenic and zinc ~ere detected ih. extraction wells exceeding their respective cleanup levels of 0.025 mg/l and 0.3 mg/I.

Table 1 summarizes the contaminant removal since operation in 1996. From November 1996 to December 2009,0.0010 pound of total pesticides (predominately alpha-BHC), 0.00208 pound of herbicides, and 5.47 pounds of metals (mainly, zinc, arsenic and copper) were removed from the groundwater at the Site. '

Treated Water Sampiing

Treated water samples were collected and analyzed monthly for the inorganIc and organic effluent discharge parameters specified in the O&M Plan. None of the effluent discharge limits specified.in Appendix I of the O&M Plan for discharge to the on-Site wetlands ~ere exceeded in any of the treated water samples,.

Note that the typical laboratory detection limits for 2,4-D and 2,4,5-T in treated water effluent ,are higher than the maximum daily discharge limitations. ')

Sampling oftreated effluent will contihue monthly as required by the O&M Plan.

Containment Cell '. .

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The containment cell cap remains fully vegetated with no b3!e spots and no evidence of erosion. ,

The landfill cap is also inspected for any impacts from terrestrial receptors (i.e., burrowing organisms) which may affect the integrity of tpe cap. The water levels in the, 12 containment cell collection sumps were measured at a minimum ofonce per month in accordance with the O&M Plan.

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Containment Cell

Containment Cell Monitoring Wells

The seven containment cell monitoring wells (three overburden and four bedrock) were sampled in November 1996 to establish baseline conditions. The containment cell is monitored by three wells installed in the overburden (MW27, MW92, and MW93) and four wells installed in the upper bedrock (MW 40, MW89, MW90, MW91). The containment cell wells have been monitored semi-annually for pesticides, ethylenethiourea, herbicides and metals.

The 2005 through 2009 analytical data from the containment cell monitoring wells indicated no detections ofpesticides, ethylenethiourea, herbicides, arsenic or mercury. Copper was either detected or estimated in several wells, but below the cleanup level for groundwater of0.2 mgll. Lead and zinc were detected exceeding their respective cleanup levels of 0.015 mg/l and 0.3 mg/l in well MW40 during the November 2007 monitoring event at 0.0632 mg/L and 0.657 mg/L respectively.

In summary, there were two exceedances in containment cell monitoring wells from 2005 to 2009. Both exceedances were resolved to below cleanup levels by the following sampling event

Perimeter Monitoring Wells

The site perimeter is monitored by four wells: overburden well MW20, upper bedrock wells MW42 and MW61, and lower bedrock well MW60.

From 2005 to 2009, the monitoring wells were sampled quarterly.- Analytical data indicated no detections of pesticides, ethylenethiourea, or mercury. Estimated concentrations were noted for herbicides 2,4,5-T (MW42 in June 2006) and 2,4-D (MW61 in April 2009). There are no cleanup

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levels for herbiCides ..

Arsenic; copper, mercury and zinc were either detected' or estimated in wells; but below the . respective groundwater cleanup levels ofO.025111g(l, 0.2 rug/I, 0.002 ing/l and 0.3 mg/I. The March

2009 estimated lead Concentration of0.0193 mg/l in well MW42 exceeded the cleanup level of0.015 ~. . .

mg/I. . ' . '. •

In summary, there was one exceedance in perimeter monitoring wells from 2005 to 2009·. The exceedancewas resolved·to below cleanup levels by the following mOhitoring event.

Surface-Water Quality Sampling

Surface water samples were collected quarterly from three locations at the Site (Wetland [SW-l], East Quarry [SW-2] and West Quarry [SW-3]). Ethylenethiourea was not detected in the wells. \

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Ofthe pesticide compounds; delta~BHC was detected at SW-2 and SW-3 in 2007 at concentrations bfO.ll Jlg/I and 0.026 Jlg/I, respectively. The delta:-BHC cleanup level for surface water is 0.01 Jlg/l. 4,4'-DDT was estimated in SW-3 in June 2006 at 0.052 Jlg/l. The cleanup level for 4,4'-DDT in surf~ce water is 0.001 Jlg/l.'. . . '

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Herbicide 2,4,5-TP was detected in SW-3 at 0.074~g/1 in June 2006. 2,4,5-T was estimated inSW-2

( (0.066 Jlg/I) and SW-3 (0.1 Jlg/I) in June 2006. There are no cleanup levels for herbicides in surface water.

Arsenic was estima'ted or detected in SW-2 and SW-3 at various times, and lead was estimated in SW-2 in September 2007. The concentrations were less than the surface watercleanup levels for

. arsenic (0.19 mg/l) and lead (0.011 mg/l). Mercury was estimated in SW-l at 0.000061 mg/l in September 2009. There is no cl~anup level for mercury in surface water. .

Copper Was detected once (0.0408 mg/l) in SW-l, in September 2009, that exceeded the surface • I ( .

water cleanup level (0.027 mg/l). Copper was present at SW-2 and SW-3 at various times below the cleanup level.

\ Zinc was estimated at SW-2 (0.0339 mg/l) in September 2007, above the cleanup level (0.03 mg/l),

. and estimated below the cleanup level at SW-l (September 2007) aild SW-3 (January 2007). i r

In summary,' there were five exceedances in surface water samples from 2005 to' 2009. The exceedances were resolved to below:cleanup levels by the next, or second subsequent monitoring event. '( (

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Groundwater Elevation Data

Groundwater elevation data are routinely plotted on the facility site plan. The groundwater elevation contours indicate that the eleven well upper-bedrock groundwater extraction system maintains a consistent inward groundwater flow gradient. A site plan showing the location ofwells is located in Figure 1.

Containment Cell Collection Sumps Monitoring and Leachate Extraction

Liquid levels are typically checked weekly and leachate is extracted as required.

Wetlands. Quarries and Drainage Culverts

Observations of the Site ditches and culverts indicated that they are all free of debris and are free flowing. Also, observations made during routine visits revealed no problem with wetland vegetation or the integrity of the dike associated with the wetlands.

East Quarry

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West Quarry

Wetland

Fencing

Upon inspection for this review by the PRPs, EPA, and NYSDEC, it was noted that repairs to the perimeter fencmg are needed.

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Fence Fronting Dublin Road

Fence Damage at Jeddo Creek

Miscellaneous Routine Inspections

Periodically inspections of the groundwater extraction and treatment system components, including piping, air compressor, air system piping, and general Site grounds, are performed. All systems are operating within design parameters.

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Site Inspection

A Site visit related to this five-year review was conducted on April 27, 2010. The EPA representative, Marc Yalom, was accompanied by Shawn Skelly from Arcadis on behalf ofthe PRP and Valarie Woodward from NYSDEC. During the Site inspection, the hydrogeologist did not observe any problems or deviations from the on-going operation and maintenance activities being implemented at the Site. The containment cell cap appeared fully vegetated with no bare spots and no evidence of erosion.. Wetlands and quarries were 'observed with generally clear, non-odorous water. Site fencing was observed to be in a state of general disrepair and. damage. Issues that will need attention include significant repairs to the perimeter fencing and clearly marking all wells.

Interviews

The Site remedies were discussed with State program representatives and PRP representatives. There were no interviews with local officials or community representatives.

VII. Remedy Assessment

Question A: Is the remedy functioning as intended by the decision documents? . , . ' . ,

Yes. The ROD called for stabilization ofcontaminated 'materials in a customized containment cell, hydraulic containment of groundwater by extraction, and on-Site water treatment. The ROD goals were met by the remedial activities.

Performance evaluation data indicate that the extraction system captures contaminated groundwater and maintains inward groundwater flow gradients toward the eleven extraction. wells that are screened in the upper bedrock aquifer. Groundwater analytical results from the containment cell and perimeter monitoring wells, with few exceptions « 1 % ofall analytical results), were below cleanup level concentrations, indicating acceptable groundwater protection. The containment cell leachate sumps are regularly inspected and leachate is removed as required. These actions reduce the risk of contaminant release to the subsurface. The. groundwater treatment system is regularly inspected and maintained; where analytical detection limits are below discharge standards, treated water is shown to meet discharge limitations. The groundwater, remedy appears to be interrupting potential exposures to contaminants in the groundwater

Theintegrity ofthe cap has been maintained and the cell collection sumps are operating as designed and maintain water levels at the prescribed levels beneath the cell. The cap is fully vegetated with no signs of erosion. The grass cover serves as a barrier to potential exposures to contaminants below the cover. Site fencing was observed to be in a state of general disrepair and damage, resulting in diminished site,security. The fencing acts as another barrier to potential exposures and the disrepair may provide a potential route of entry onto the site although the location of this facility, in an

-14

j industrial area, may further limit site accessibility.

, , Surface water control structures (e.g., swales, wetland, and quarries) are in place and functioning. These structures prevent or limit erosion and potential exposures to the surface water.

The remedy has eliminated exposu~e to ecological receptors by excavating contaminated sediments from the swamps, quarry and rectangular pond and placing these materials along with contaminated soils in an on-site containment cell with a leachate collection system and acap which meets 6

" NYCRR'Part360 regulations. The October 2009 Operations and Maintenance Plan notes no change to the wetland vegetation or the integrity ofthe dike associated with the wetlands. A formal wetland monitoring plan does not appear to be in effect. Treated effluent discharged to the on-site surface water, as well surface water locations in the wetland area, east ,and west ends of the quarry are monitoredto. ensure that concentrations of contaminants of concern do not exceed the site-specific RAOs. The most recent surface water data indicate that concentrations are within the RAOs. It should be noted that the 1993 ROD recommended that sediments be monitored along with groundwater and surface 'water,· although sediment samples have not been coll~cted. This may be because contaminated sediments were excavated and contained within a secure cell as part of the remedy. Therefore, the' remedial actions are functioning as intended and remain protective of ecological resources at this site.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time ofthe remedy still valid?

There have been no changes in the physical conditions and land use of the Site over the past five years that would affect the protectiveness ofthe remedy. In general, the Site has limited access based on location within an industrial area,fencing although the disrepair lessens its effectiveness, and the presence of canals surrounding the Site also further limits on-Site access.

Soil. Soil use atthe Site is not expected to c~ange during the next five years covered by this review. The land use consideration,s, 1. e" industrial land use, and potential exposure pathways considered in the baseline human health risk assessment have not changed since the original assessment. Consistent with the ROD, direct exposure to soils were interrupted by the excavation, stabilization and screening ofall contaminated materials in soil and sediments from the Waste Pile, Rectangular Pond, Swamp, Drainage Swale, and the Quarries. Other areas ofthe Site contaminated above RAOs and material that failed TCLP toxicity characteristics were stabilized under the Part 360 cap in the on-Site containment cell. In addition, fencing was placed around the Site to further prevent access but repairs are needed to limit potential Site access. The remedy remains protective since these actions Have interrupted exposures through direct contact with the contaminated material by

. trespassers and other potential Site users. I

. Ground.,. and Surface Water. The original risk assessment evaluated exposures to:

15

• Surface water by an on-Site intruder,\ • Surface water and groundwater pathways ofexposures to future on-Site residents at the Site

boundary; and, ­• Groundwater exposures to current off-Site residents.

(

The hydraulic containment of groundwater by extraction, and on-Site water treatment, has interrupted potential exposures to the contaminated groundwater.

Since the ROD was signed: several toxicity values used in the original risk assessment were ~pdated. To evaluate the potential impacts of these changes on the RAOs and Remedial Action Detection limits (RADs), the values listed in the ROD were compared to Preliminary Remedial Goals (PRGs) for the specific chemicals. ThePRGs assume ingestion of ground'Yater by residents with consumption rate of 2 liters/day by an adult resident for 350 days/year for a period of24 years and 1 liter/day ofgroundwater by a child residentfor 350 days/year fora period of6 years. The PRGs also reflect the latest toxicity values and'were obtained from the Regional Risk Screening Level tables (available at: , http://www .epa. gov /reg3hwmd/risk/humanlrb­concentration_table/Generi~_Tables/pdf/restap_sl_table~run_MA Y20 1 O.pdf).,

In general, all cleanup levels were within or below the risk range with the exception ofarsenic. The . remaining valuesare protective. The cleanup level for arsenic was based on the state drinking water concentration which at the time the ROD was signed in 1993 was more stringent than the federal Maximum Concentration Level (MCL). The cleanup level for arsenic was changed from 50 ug/l to 10 ug/l on January 26,2006. '

\ ' . Groundwater. Table 2 compares the ROD cleanup levels and RADs with current drinking water concentrations associated with cancer risks and non-cancer Health Bazards equaling 1. These drinking water concentrationsreflectcurre1j1t toxicity values and exposure assumptions based on

l

a residential 'exposure (described above). . Only arsenic exceeded the risk range. '

Table 3 compares the 2006~2009 groundwater Site data,to the cleari'up levels. The comparison is based on sampling results from 11 extraction wells sampled monthly for pesticides, ethylenethiourea, herbicides and metals. DDD, DDE, and DDT, ethylenethiourea and beta-BHC were not detected in the extraction wells. The cleanup levels were exceeded for arsenic, lead, zinc, alpha;.BHC and delta­

, \

BHC based on a comparison to the maximum concentration to the residential PRG: The cleanup ,levels were not exceeqed for these chemicals in the perimeter wells where the maj<?rity of sample results were non-detects These extraction wells are not currently used as a source for drinking water where direct exposures would be expected to occur. Previous sampling ofoff-Site wells did not indicate any off-Site migration ofthese contaminants. The remedy remains protective since off-Site migration of the contaminants is not occurring and potential off-Site exposures have been interrupted. \ J

16

)/,

",-' " ," -". -.~

, Table 4 provides a comparison of the detected surface waterconcentratiQns to residential drinking water PRG concentrations based on the exposure assumption described above. This comparison is health proteCtive since potential ~xposures/to the surface water by a trespasser Qr future Site residents are anticipated to be lower (e.g., the amount ingested and the frequency and duration of e?,posures are lower than individuals relying on groundwater for their drinking water' s~mrce on a daily basis). The cleanup lev~lsidentifiedin the ROD were developed to prot~ct ecological-re,ceptors,andare lower concentrations than ,the human health b~sed cleanup levels used in the comparison. The comparison found that with the exception ofarsenic, the Cleanup levelslRADs were within or ,below the ris~ range. Based,on this ,information, the'surface water cleanup levels are protective ofhuman health. ' " (- , '

Surface Water': Table 5 provides acomparison of the cleanup levelslRADs to surface water data collected from 2006 to 2009. , The concentrations found in the surface water were less than their

, ,

respectivt1 Cleanup levels with the excepti~n of zinc, cooper, 4,4-DDT, and delta-BHC. All other surface water concentrations were below detection limits.

Several detected chemicals lacked cleanup levelslRADs. Following 'is '~comparison ofthe detected concentrations, locations, and residenti~il drinking waterPRGs.

• Mercury wasfound in SW:-1 at a concentration of 0.061ug/1 J ,in Septemb~r 2009. This concentnitioil is below the PRG of 0.570 ug/l fOf ele~ental mercury. ;

• 2,4,5-trichlor6phenoxyprop,ionic acid (2,4,5-TP) was detected inSW-3 a~ 0.074 /-lg/l in June 2006. This concentration is below the drinking wat'er PRG of290 ug/I. '

• 2,4,5-trichlorophenoxyacefic acid (2,4,5-T) was found in well'SW-2 at a cOllcentration of 0.066 /-lg/l J and in,well SW-3 at a concentration of 0.1 /-lg/l J in June 2006. This concentration is! below the drinking water PRG of 370 ug/l j

Ecological )lesources. Although the exposure lassumptions and toxicity assessment conducted to . support the 1989 Ecological Risk Assessment may not necessarily r~f1ect the current methodology, the remedy is protective of ecological resources as contaminated' sediments and ,soil were dredged/excavated and contained within a secure covered landfill. Further, surface watet:dat.a indicate that concentrations are below surface water cleanup levels which are protective ofecological

. \. '. '

resources. ( ,

Vapor Intrusion. Soil vapor intrusion based-ongrounqwater concentrations was evaluated in the 2005 Five-Year Review:- The results from the current a'nalysis are ,collsistent with those from the 2005 analysis. The only chemical detected in groundwater with soil vapor intrusion inforIl1ation was ' alpha-BHC. Alpha-BHC was found in groundwater at aconcentration of0.098 ug/l in well EW-08. For comparison, th~ soil vapor intrusion screening concentration in groundwater for alpha-BHC is 3.1 ug/l. The/detected concentration ofalpha-BHC in groundwater is below the screening values and therefore, vaporintrusionis not' of concern at this Site~

17 I',

, ' ­

I

Based on this analysis, the remedy remains protective.

Question C: Has any other information come to light that could call into question the protectiveness o/the remedy?

No. All data indicate that the remedy is operating efficiently and effectively.

Technical Assessment Summary

Based upon/the results of the five-year review, it has been conc1udedthat:

• The leachate monitoring/collection system is operating properly; • The cap and vegetative cover are intact and in good condition; • The fence around the Site is in disrepair, and evidence of dumping was found at the Site; • The groundwater long-term monitoring wells are functional; and • The wetlands have been reestablished.

VIII. Recommendations and Follow-Up Actions

The selected remedy has not been fully implemented. Iristitutiona! controls to protect the landfill remedy and to prevent potable water wells in the vicinity ofthe landfill need to be iniplemented. The PRP, working with EPA and NYSDEC, is expected to implement these ~nstitutional controls.

In the 2000 Five-Year Review report, it was stated that the PRP intended to request approval of ~ significant changes in the monitoring program. In August 2005, FMC submitted a proposal to EPA

and NYSDEC for the shutdown of the groundwater extraction' system at the Site and for modifications of the Site monitoring program based on data collected and summarized in the Remedial System Evaluation and Proposal for Shutdown Report. A discussion of the Shutdown Proposal was held during a conference call among the NYSDEC, EPA, and FMC's technical representatives on December 15,2005." It was agreed that FMC would provide th~ Agencies with, additional information related to the Shutdown Proposal. FMC submitted additional information by letter dated March 22, 2006. By letter dated August 28, 2006, the Agencies provided comments to FMC and advised that for purposes of the evaluation by the Agen~ies relative to discontinue or revision of the groundwater extraction remedy, FMC should perform a Technical Impracticability (TI) Evaluation based on EPA guidance. FMC is currently undertaking this, TI evaluation and plans to submit it, together with responses to the ,comments from the Agencies upon completion.

This Site has ongoing operation, maintenance and monitoring activities as p~rt of the selected remedy. As anticipated by the decision documents, these activities are subject to routine modification and adjustments.'

Additionally, the perimeter fencing should be inspected and any damage should be repaired. Also, '

18

..J'

, all wellheads and sump labels should be cle~rly marked and maintained.

Table 8 shows recommendations and follow-up actions.

IX. Protectiv~~ness Statement

The remedy currently protects human health and the environment in the 'short-term because the groundwater pump and treat system has lowered concentrations ofcontaminants ofconcern and the cell cap is functioning as intended. However, in order for the remedy to be protective in the long­term, institutional controls need to be implemented.

X. Next Review ,

The next five-year review for'the FMC, Dublin Road Superfund Site should be completed before July 2015.

Appr'oved: (

~7* Walter E. Mugdan, Director Date Emergency and Remedial Response Division

(

,./

, I

19

Appendix A - List of Documents Reviewed

1. Record of Decision, NYSDEC and EPA (1993) J

2. Quarterly Operation, Maintenance and Long-Term Monitoring Reports, submitted by Blasland, Bouck & Lee Inc.

3. Five-Year Review Reports, EPA (September 2000, September 2005)' 4. Quarterly Operation and Maintenance Status Reports, submitted by Arcadis 5. Annual Performance Reports, submitted by Arcadis

Appendix B .Chronology of Site Events

Event Date

.' .1982Administrative Order on Consent (AOC)

, 1982Remedial Investigation

'1 1984Proposal to NPL

1988Final Listing on NPL

1989Remedial InvestigationlFeasibility Study completed by the responsible party (PRP)

·Record bfDecision(ROD) 1993

1994. Remedial Design performed by the PRP

1995Explanation of Significant Differences (ESD)

1994-1996Remedial Action performed by PRP

Preliminary Close-out Report 1997

2000First Five-Year Review conducted by EPA

Second Five-Year Review conducted by. EP A 2005

20

-, ·-jl'~:

L£GEND:

1.1'*-'0 ~ 'UPPER BEDROCK MQNITOt'l!r-lG VIUL LOCAilQN

1.101'-13 (} OVERBURDEN MONITORINC "''Ell LOCATION

LOWER BEDROCK MONITORING ~ lOCA.~ON· .

f"1-!1 EXTRACTlQH WE,!-llOCA.TlON

i) SUIdP LOCA nON

LEACH" T£ COllEcnoN' SUM? LOCA TlOH

PO'o\'ER POlE

- .- -._ PIP1f~G

_G'_ OVERHEAD ElECTRICAL UNE

NOTES:

1. BASE ~AP PREP/I..REO rROM ELECTRONIC CAD mE FROt.! CUENT MADE SY ·CON[$TOGA-RO'.'[RS &: ASSOclA1B-, ORA'MNG 1.0. OH52-10'027}Gt~-NFOO2. OAltO ;.flRlL 10, 2003, AT A" SCALE OF I""" i~·.

2. AU. lOC.AnOtis. ARE: APPROXlt.~AT£.

. 3. ONLY Me.mCRING A.NO EXTRACTION WELLS fROM . FIGURE. )" or THE 0&:1.4 PLAN ARE. SHOntt

4, SITE :S \,,HHIN FENCe: UHf.

o 159: 3qO·=!-

SITE PLAN

-~ARCADIS ·1 .

,

.)

J

J I

-d

. '

Table 1

Pounds of Contaminants Removed

HerbicidesAmount Pesticides Metals, Year . (Ibs)Removed (lbs) including

I(gallons) arsenic .,

(lbs)

. 0.80 0,00051996-1997 400,166 0.00000

'1998 224,420 .0.00000 0.600.0003

. 0.00000 211,930 0.0002 0.401999

204,340 0.00000 0.202000 0.0000

0.0000 0.00001 0.202001 209,010 ~

0.00000 0.702002 175,180 0.0000

0.00001 l.21175,514 0.00002003

' 100,130 0.00000 0.200.00002004

0.00206133,884 0.402005 0.0000

98,921 0.00000 0.242006 0.0000

16;360 0.0000 0.00000 0.152007 "

29,375 0.00000 0.172008 0.0000 .~

0.000002009 44,062 0.0000 ·0.20

2,023,292 0.0010 0.00208 5.47Totals

22

Table 2

Updates to Toxicity Values Used in Original Risk Assessment for Groundwater through Calculation of Residential Preliminary Remedial Goals*

, Residential Groundwater Preliminary

Remediation Goals in Groundwater **,*

r

Chemical Cleanup Level**

(ug/l)

'RAD* *

l(ug/l)

, Cancer Risk

1 x 10-6

(ug/l)

Non-Cancer HQ=l (ug/l)

\

Comments

\

AlphaBHC 0.05 0.01 290 Withinxisk range' 'Beta BHC 0.05 0.037 Below risk range Gamma BHC

I 0.05 0.061 11 Within risk range'

DDE 0.1 0.21 NA Within risk range -DDD 0.1 028 NA Within risk range

DDT 0.1 02 18 , Below risk range Arsenic 25 0.015 11 Exceeds risk range \

Copper 200 1500 Below risk range Lead 15 Action Level (effective February 1993 by USEPA (40 CFR Part 131).

Mercury Cleanup level for contaminant no established. It was anticipated that cleanup to the cleanup level for the remaining contaminants will remove all or more of this contaminant. (

Zinc 300 I 111,000 1Below risk range

(

* Based on Table 2-4 titled "Remedial Action Objectives for the FMC Dublin Road Site" in the 1993 Record of-Decisiori ** 'RAD - Remedial ActionDetection Limit

Cleanup level - Proposed Cleanup Level for Groundwater *** PRGs from the Regional Risk Screening Level Table available at: http://www.epa.gov/reg3hwmd/risk/human/rb- ' concentration table/Generic Tables/pdfirestap sl table runMAY201 O.pdf

23

I Table 3~

Chemicids of Concern Exceeding Clea.nup Levels or Remedial Action Detection Limits at the Extraction Well Locations

Chemical Cleanup LevellRAD*

Maximum Concentration Well

Date of Sample

Arsenic

\

0.025 mgll (Cleanup level)

1.37 mgll EW-ll 06/29/07

Lead 0.015 mgll (Cleanup level)

0.0305 mgll

, ,

EW-05 06/28/07

Zinc ~

0.3 mgll (Cleanup level)

2.98 mg/l EW-08 09/26/06

I

alpha-BHC 0.05 ug/l (RAD) 0.11 ugll EW-08 06112/06

delta-BHC 0.05 ug/l (RAD) 0.052 ug/l EW-08 09/29/09

* RAD - Remedial Action Detection Limit Cleanup level - Proposed Cleanup level for Groundwater

24

Table 4

Updates to Toxicity Values Used in Original Risk Assessment for Surface Water Based on )\ .

Residential Preliminary Remediation Goals )

I

Residential Groundwater Preliminary

Remediation Goals

Chemical Cleanup

. level (ug/l)

RAD* (ug/l)

Cancer Risk

1 x 10-6 (ug/l)

Non-Cancer HQ=1 (ug/l)

Comments on Risks Associated

with Cleanup levellRAD

AlphaBHC 0.05 0.01 290 Within risk range BetaBHC 0.05 0.037 NA Below risk range GammaBHC 0.05· 0.061' 11 Within risk range Total BHC· (technical BHC)

0.01 0.037 NA Below risk range

ODE 0.001 0.21 NA Within risk range DDD ) 0.001 0.28 NA Within risk range DDT 0.001 0.2 18 Below risk range Arsenic

"­

19 0.015 11 Exceeds .risk range

Copper 27 1500 Below risk range Lead 11 Action Level (effective February 1993 by USEPA (40 CFR

Part 131). r

Mercury

I

Cleanup level for contaminant no established. \ '

It was anticipated that cleanup to the cleanup level for the remaining contaminants will remove all or more of this contaminant

Zinc 30 11,000 Below risk range

*PRGs from the Regional Risk Screening Level Table available at: . http://www.epa.govlreg3hwmdlrisk/human/rb­concentration table/GeneriC Tables/pdlirestap sl table run MA Y201O.pdf * * RAD .,- Remedial Action Detection Limit

Cleanup level- Proposed Cleanup level for Groundwater

25

· Table 5

. Chemical of Concern Exceeding Cleanup ~evels or Remediai Action Detection Limits in Surface Water

-

Chemical Cleanup

Level* (ug/I)

RAD* (ug/I)

Maximum Concentration

(ug/l) , Sample Location

Sample Date

Zinc '\ 30 33.9 EQ SW-2 , ,

9110/2007

Copper 27 40.8 EQSW 1 9/10/2007 DDT 0.001 0.052J EQ SW-3 6/2006 Delta-BHC 0.01 0.11 EQ SW-2 911012007

* RAD - Remedial Action Detection Limit Cleanup Level- Proposed Cleanup level for Groundwater

I , '.

'I

26

/

, Table6 ' Acronyms used in this Document

l

AOC Administrative Order on Consent ARAR , Applicable or Relevant and Appropriate

Requirement ,

BHC Benzene Hexachloride CERCLA Comprehensive Environmental Response,

Compensation, and Liability Act CFR Code of Federal Regulations CIC Community Involvement Coordinator DDT 'DichlorodipheI!Yitrichloroethane . ,-

ECL . Environmental Conservation Law ,

EPA United States EnvironmentalProtection Agency -

,ESD Explanation of Significant Differences IC Institutional Control mg/kg Milligram per kilogram mg/l Milligram per liter ' NPL National Priorities List NYSDEC New York State Department of Environmental

Conservation O&M Operation, Maintenance, and Long-ternl

, Monitoring ,

r

OU Operable Unit PCB, Polychlorinated Biphenyl PRP Potentially Responsible Party RA ' .' - . Remedial Action RAD Remedial Action Detection Limit ,

RAO ) / Remedial Action Objective I

RCRA 'Resource Conservation and Recovery Act RD Remedial Design RIIFS Remedial InvestigationlFeasibility, Study ROD ) Record of Decision ,

RPM \ Remedial Project Manager , ,

TCLP Toxicity Characteristic Leaching Procedure TI Technical Im~acticability ug/L Microgram per liter VOC Volatile Organic Compound

27

Table 7

Vapor Intrusion Screening Values for Contaminants of Concern. Screening Values were Obtained from the OSWER Draft Guidance

-

Vapor Intrusion Concentration (ug/I)

Chemical Vapor Intrusion Concern

Cancer Risk 1 x 10-6

Non-Cancer HI= 1

Comments

alpha - BHC 3.1

beta - BHC Not sufficiently volatile'

gamma-BHC (Lindane)

, 1.1

delta-BHC (assumed technical BHC

NA NA

4,4,'-DDE (as DDE)

Target gas concentration exceeds maximum possible vapor concentration pathway incomplete.

4,4'-DDD (as DDD)

Not sufficiently volatile

4,4'-DDT J

Not sufficiently volatile

Ethylenethiourea NA

2,4-D NA

2,4,5-TP NA

2,4,5-T NA

Arsenic , NA

Copper NA

Lead NA

Mercury (assumed to be elemental mercury)

0.68 ug/l

Zinc NA

28

Table 8

Recommendations and Follow-up Actions

Issue Recommendations and Follow-up ,

Party Responsible

Oversight Agency

Milestone Date(s)

Affects Protectiveness

(YIN) , Ac.tions Current Future.

Protect landfill remedy and prevent potable water wells

in the vicinity of landfill

\

Implement institutional controls

PRP NYS 12/3112010 . N Y

Shutdown of groundwater

extraction system by PRP

Review and finalizeTI and shutdown proposal

(-

PRP NYS 9/30/2011 N Y

Perimeter fence damage, wellheads

and sump labels poorly maintained

Inspect and repair damages PRP NYS

. ­

9/30/2010 N· Y

(

29

)