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First Five-Year Review Report For the
Jackson Steel Superfund Site Nassau County
Mineola, Town of North Hempstead, New York
• ~ $
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Prepared by: United States Environmental Protect ion Agency
Region 2 New York, New York
August 2012
Walter E. Mugdan, irector Emergency and Remedial Response Division
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TABLE OF CONTENTS
List of Acronyms Used in tliis Document Executive Summary i Five-Year Review Summary Form ii I. Introduction 1 II. Site Chronology 1 III. Background 1
Physical Characteristics 1 Site Geology/Hydrogeology 2 Land and Resource Use 2 History of Contamination 3 Initial Response 3 Basis for Taking Action 3
IV. Remedial Actions 4 Remedy Selection 4 Remedy Implementation 6 Institutional Controls Implementation 9 Operation and Maintenance 9
V. Progress Since the Last Review 11 VI. Five-Year Review Process 11
Administrative Components 11 Community Involvement 11 Document Review 11 Data Review 11 Site Inspection 12 Interviews 12 Institutional Controls Verification 12 Other Comments on Operation, Maintenance, Monitoring and Institutional Controls 12
VII. Technical Assessment 13 Question A: Is the remedy functioning as intended by the decision documents? 13 Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives used at the time of the remedy still valid? 13 Question C: Has other information come to light which could affect protectiveness of remedy? 15 Technical Assessment Summary 15
VIII. Recommendations and Follow-Up Actions 15 IX. Protectiveness Statement 15 X. Next Review 15
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FIGURE
Figure 1: Site Plan
TABLES
Table 1
Table 2
Table 3
Table 4
Chronology of Site Events
Annual Operation and Maintenance Costs
Documents, Data, and Information Reviewed in Completing Five-Year Review
Soil Cleanup Levels and Cancer and Non-Cancer Risks
Table 5: Groundwater Cleanup Levels and Cancer and Non-Cancer Risks
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List of Acronyms Used in this Document
BGS
DCA
DCE
EPA
ESD
EWMI
FS
GAC
IRIS
ISCO
ISVE
MCL
MQ/I
Mg/m^
NCHD
NPL
NYSDOH
PCE
Rl
ROD
RPM
SDS
SVOCs
TAGM
TCA
TCE
VOCs
Below ground surface
Dichloroethane
Dichloroethylene
Environmental Protection Agency
Explanation of Significant Differences
Environmental Waste Minimization Inc.
Feasibility Study
Granular Activated Carbon
Integrated Risk Information System
In-Situ Chemical Oxidation
In-Situ Vapor Extraction
Maximum Contaminant Level
Micrograms per Liter
Micrograms per Cubic Meter
Nassau County Health Department
National Priorities List
New York State Department of Health
Tetrachloroethylene
Remedial Investigation
Record of Decision
Remedial Project Manager
SubSlab Depressurization System
Semi-Volatile Organic Compounds
Technical and Administrative Guidance Memorandum No. 4-HWR-4046 Objectives
Trichloroethane
Trichloroethylene
Volatile Organic Compounds
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EXECUTIVE SUMMARY
This is the first five-year review for the Jackson Steel Superfund site, located in Mineola, Town of North Hempstead, Nassau County, New York. The implemented actions at the site protect human health and the environment. Currently, there are no exposure pathways that could result in unacceptable risks and none are expected as long as the site use does not change and the vapor mitigation systems continue to be properly operated, monitored, and maintained.
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Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name:
EPA ID:
Region: 2
Jackson Steel site
NYDO01344456
state: NY City/County: Mineola, Town of North Hempstead/ Nassau County
NPL Status: Final
IVIultiple OUs? No
IHas the site achieved construction completion? Yes
Lead agency: EPA If "Other Federal Agency" was selected above, enter Agency name: Click here to enter text.
Author name (Federal or State Project Manager): Christos Tsiamis
Author affiliation: EPA
Review period: 8/30/2007- 8/10/2012
Date of site inspection: 07/9/2012
Type of review: Policy
Review number: 1
Triggering action date: 8/30/2007
Due date (five years after triggering action date): 8/30/2012
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Five-Year Review Summary Form (continued)
The table below is for the purpose of the summary form and associated data entry and does not replace the two tables required in Section VIII and IX by the FYR guidance. Instead, data entry in this section should match information in Section VII and IX of the FYR report.
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
out
issues and Recommendations Identified in the Five-Year Review: |
OU(s): Click here to enter text.
Affect Current Protectiveness
Choose an item.
Issue Category: Choose an item.
Issue: No issues or recommendations are identified for the Jackson Steel site.
Recommendation: Click here to enter text.
Affect Future Protectiveness
Choose an item.
Implementing Party
Choose an item.
Oversight Party
Choose an item.
Milestone Date
Enter date.
To add additional issues/recommendations here, copy and paste the above table as many times as necessary to document all issues/recommendations identified in the FYR report.
Protectiveness Statement(s)
Operable Unit: 01
Protectiveness Determination: Protective
Addendum Due Date (if applicable): Click here to enter date.
Protectiveness Statement: The implemented actions at the site protect human health and the environment. Currently, there are no exposure pathways that could result in unacceptable risks and none are expected as long as the site use does not change and the vapor mitigation systems continue to be properly operated, monitored, and maintained.
Sitewide Protectiveness Statement (if applicable)
Protectiveness Determination: Protective
Addendum Due Date (if applicable): Click here to enter date.
Protectiveness Statement: The implemented actions at the site protect human health and the environment. Currently, there are no exposure pathways that could result in unacceptable risks and none are expected as long as the site use does not change and the vapor mitigation systems continue to be properly operated, monitored, and maintained.
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I. Introduction
This five-year review for the Jackson Steel site, located in Mineola, Town of North Hempstead, Nassau County, New York, was conducted by United States Environmental Protection Agency (EPA) Remedial Project Manager (RPM) Christos Tsiamis. The review was conducted pursuant to Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act, as amended, 42 U.S.C. §9601 etseq. and 40 CFR 300.430(f)(4)(ii) and in accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P (June 2001). The purpose of five-year reviews is to ensure that implemented remedies protect public health and the environment and that they function as intended by the site decision documents. This report will become part of the site file.
This is the first policy five-year review for the Jackson Steel site. The trigger for this five-year review is the signature date of the Preliminary Close-Out Report, which was August 30, 2007.
II. Site Chronology
Table 1 (attached) summarizes the site-related events from discovery to the present.
III. Background
The Jackson Steel site includes a parcel of property located at 435 First Street in Mineola, Town of North Hempstead, Nassau County, New York in a residential/commercial area. See Figure 1 for a site plan. The property is zoned B-1 for business use and retail or office space.
Physical Characteristics
The 1.5-acre property contains a one-story 43,000-square-foot building formerly used as a metal-forming facility and an approximately 10,000-square foot paved parking area. The building consists of two sections—the original building, constructed in 1959, is located closer to First Street, and the newer section, which was added in 1963, is at the rear. The former office space is located along the north wall, and a loading dock is located in the southwest corner of the front section of the building. The building is currently inactive and contains an active in-situ soil vapor extraction (ISVE) system. An old vertical aboveground storage tank—possibly used to store degreasing substances—is situated in the front section of the building next to the former offices. A trench is located in the floor along the Inside western wall of the building extension, above which a degreasing station is suspected to have been located. Two sumps are located in the front section of the building behind the former office space. One sump is located under the heater and the other one is located along the eastern wall of the main building. A third sump is located outside the building, near the main entrance.
The local topography surrounding the site consists of relatively flat terrain, with gentle changes in elevation that typically do not exceed twenty feet of vertical relief. The site
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itself is flat with no discernible change in topography, and has an elevation of 96-98 feet above mean sea level.
The site is bordered to the north by commercial and single-family dwellings, to the east by multiple-family dwellings in a two-story apartment complex, to the south by a retail store (Dollar Experience) and the Learn and Play Daycare Center, and to the west by an office building and restaurant. Herricks Road to the west has predominantly commercial properties on both sides of the heavily-traveled road.
Village of Mineola supply well #4 and Garden City Village supply wells #8 and #12 are located within a half-mile radius of the site (east-southeast or side-gradient of the property). There are no private wells in the area. Area residents utilize municipal water.
Site Geoloav/Hvdroaeoloav
Surface soils at the site are Upper Pleistocene Deposits, which are commonly referred to by the name of the hydrogeologic unit that they form, the Upper Glacial Aquifer. This Upper Glacial unit consists, predominantly, of varying consistencies of intermixed-to-interbedded, brown-orange-yellow sands and gravels to a depth of approximately 105 feet below ground surface (bgs). Some silts were observed, mainly near the ground surface, but also in smaller quantities deeper in the formation and in minor lenses throughout. Little or no clay was observed.
At approximately 105 feet bgs, the top of the Magothy Formation is encountered. The top of the formation (the Magothy Confining Bed) consists of characteristic fine-to-medium sands interbedded with clay and sandy-silty clay, with gray coloration, and the presence of organic lignite (wood) fragments. The Magothy Confining Bed appears to be a localized occurrence overlying the Magothy Aquifer in the vicinity of the site. Its observed thickness at the site was approximately 296 feet. This thickness decreases significantly over a relatively short lateral distance to the northeast (approximately 600 feet) to 42 feet thick. Its thickness decreases to approximately 167 feet approximately 600 feet southwest of the site.
The silty clay of the Magothy Confining Bed is believed to be a semi-confining layer effectively separating the Upper Glacial Aquifer and the Magothy Formation.
The groundwater flow In the Upper Glacial and Magothy Aquifers in this vicinity is to the southwest under non-stressed conditions. Pumping of the public supply and irrigation wells influences the groundwater flow direction.
Land and Resource Use
The property, which has been used for industrial/commercial purposes since it was constructed, has been zoned for a number of different uses through the past several decades. The property is presently zoned "B-1" for business use as retail or office space.
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History of Contamination • I
The property was used from the mid-1970s until 1991 as a "roll form metal shapes" manufacturing facility. Degreasers, including tetrachloroethylene (PCE), trichloroethylene (TCE), and 1,1,1-trichloroethane (TCA), were used at the facility until 1985. Sludges from degreasing equipment were stored in drums and in an on-property 275-gallon tank.
The analytical results from samples collected by the Nassau County Department of Health (NCHD) in the early 1990s from within, around, and below three on-property dry wells indicated the presence of PCE, TCE, 1,1,1-TCA, 1,2-dichloroethylene (DCE), and 1,1-dichloroethane (DCA) at depths down to 40 feet below the ground surface. PCE, TCE, 1,1,1-TCA, 1,2-DCE, and 1,1-DCA were also detected in groundwater samples collected from monitoring wells located downgradient of the dry wells.
Dumping of wastes into the dry wells and spills and leaks from drums storing various chemicals during the facility's operations are the likely sources of the contamination found at the site.
Initial Response
In October 1999, the site was proposed for placement on EPA's Superfund National Priorities List (NPL). On February 4, 2000, the site was listed on the NPL.
Following commencement of remedial investigation (Rl)-related field work in October 2001, because of concerns about the proximity of the site to a daycare center, NCHD performed air sampling inside the daycare center's building. The air samples detected PCE at levels below the New York State Department of Health's (NYSDOH's) guideline for indoor PCE exposure. Given the sensitivity of the population exposed (preschool children), NCHD collected additional samples in mid-December 2001. At that time, indoor testing was also conducted inside the Jackson Steel building and a restaurant located adjacent to the site. The results indicated that PCE levels in the indoor air of several rooms in the daycare center were above NYSDOH's guideline for indoor PCE exposure. As a result, in January 2002, four subslab depressurization system (SDSs) were installed by EPA. In addition, a ventilation system was installed by the daycare center's contractor. Samples taken to assess the effectiveness of the measures implemented showed that the PCE levels in the air were significantly below NYSDOH's guideline and below EPA's acceptable noncancer risk levels. Because elevated PCE levels were also detected in a former billiards club, which shared common walls with the site building and the former daycare center, EPA installed an SDS system under the concrete slab of this building, as well.
Basis for Takinp Action
The Rl, which was completed in 2003, indicated the presence of elevated levels of volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), pesticides and metals in site soils.
In addition, elevated levels of VOCs were found in soil gas and the building was found to
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be contaminated.
As was noted above, there are three hydrogeologic units underlying the site—the Upper Glacial Aquifer (upper aquifer); Magothy Confining Bed (a localized low permeability, clayey layer separating the upper and deep aquifers); and the Magothy Aquifer (deep aquifer). VOC contamination above state and federal standards was detected both in the Upper Glacial Aquifer and Magothy Aquifer underlying the site.
IV. Remedial Actions
Remedy Selection
The following remedial action objectives were established for the site:
• Minimize or eliminate contaminant migration from contaminated soils and dry wells to the groundwater;
• Minimize or eliminate any contaminant migration from contaminated soils and groundwater to indoor air;
• Restore groundwater to levels which meet state and federal standards within a reasonable time frame;
• Mitigate the migration of the affected groundwater; and • Reduce or eliminate any direct contact, ingestion, or inhalation threat associated
with contaminated soils, soil vapor, contaminated surfaces in the on-property building, and groundwater.
Following the completion of the Rl/feasibility study (FS), a Record of Decision (ROD) for the site was issued on September 24, 2004.
The major components of the selected remedy as described in the ROD include: ,
• Excavation of the surface soils located near the building which are contaminated with VOCs, semi-volatile organic compounds, pesticides and metals and excavation of the contents of the two dry wells and sump located outside the building and the dry well, sumps, and trench located inside the building. Confirmatory sampling will be conducted to ensure that all contaminated soils above the cleanup objectives have been removed. The excavated areas will be backfilled with clean fill and previously paved areas will be repaved. All excavated material will be characterized and transported for treatment and/or disposal at an off-site RCRA-compliant facility.
• Treatment of the VOC-contaminated unsaturated subsurface soils using in-situ vapor extraction in on-property source areas and underneath two adjacent affected buildings. The extracted vapors will be treated by granular activated carbon and/or other appropriate technologies before being vented to the atmosphere. Post treatment confirmatory soil samples will be collected to ensure that the unsaturated subsurface soil source area has been effectively treated to meet the cleanup objectives.
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• Decontamination of the building floor through vacuuming and power washing. All vacuumed dust and wash water will be transported for treatment and/or disposal at an off-site RCRA-compliant facility.
• In-situ treatment of the contaminated groundwater in the upper aquifer in the source area with an oxidizing agent, such as potassium permanganate, hydrogen peroxide, or ozone/air. The oxidizing agent will transform the VOCs into less toxic compounds or to carbon dioxide, and water. The exact configuration and number of injection wells will be determined during the remedial design. The system will be operated until state and federal groundwater standards are attained in the groundwater.
• Collection of the contaminated groundwater in the lower aquifer with extraction wells if confirmatory sampling during the remedial design phase indicates that the site is the source of the contamination. The size of a groundwater extraction system in the lower aquifer will be defined during the design phase based upon whether or not contamination from the site is impacting or potentially impacting the aquifer at off property locations.
• If contaminated groundwater is extracted from the lower aquifer, treatment of the water at an on-property facility by air stripping, carbon adsorption, and methods appropriate for treatment of metals. The treated water will be reinjected into the aquifer.
• In consultation with NYSDEC, the extent of the off-property groundwater contamination and its potential impact on the public water supply wells will be determined during the remedial design phase. Based on the evaluation of off
I property groundwater data that will be collected, if it is determined that site-related contamination is affecting the aquifer, the selected remedy will be expanded, as necessary, to include the off-property groundwater contamination and its potential impacts on the public water supply wells.
• Long-term groundwater monitoring to verify that the concentrations and the extent of groundwater contaminants are declining, that the remedies remain effective and public water supplies are protected. The frequency and parameters of sampling and the location of any additional monitoring wells will be determined during the design phase.
In addition, during the course of the remediation, should the former daycare center or former billiards parlor buildings be occupied, monitoring to assure that no unacceptable vapor exposure takes place will be instituted, and the ventilation systems installed during the Rl will be appropriately maintained.
Soil cleanup objectives were established pursuant to the New York State Department of Environmental Conservation's Technical and Administrative Guidance Memorandum No. 94-HWR-4046 (TAGM) soil cleanup objectives^ These levels are the more stringent cleanup level between a human-health protection value and a value based on protection of groundwater. All of these levels fall within EPA's acceptable risk range. Groundwater cleanup goals will be the more stringent of the state or federal promulgated standards.
' Division Technical and Administrative Guidance Memorandum: Determination of Soil Cleanup Objectives and Cleanup Levels, Division of Hazardous Waste Remediation, January 24, 1994.
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Remedy Implementation
Building Decontamination
The design specifications for the building decontamination were completed by EPA's contractor, CH2MHill, in October 2005.
The building decontamination was performed by Environmental Waste Minimization, Inc. (EWMI) Office equipment and construction material were removed from the interior of the Jackson Steel building on October 15, 2005. The cleanup of the building floor commenced on January 6, 2006. Broom sweeping, as well as pressure washing with a 3,500-psi power washer, was used to remove residual waste. Once the initial removal was complete, the building floor was decontaminated using a floor scrubber. All rinse water was collected using shop vacuums and stored in 55-gallon drums. Solid debris was also stored in separate 55-gallon drums. In total, 10 drums of rinse water waste and 18 drums of solid waste were transported to a nonhazardous waste facility.
Soil Excavation and Disposal
The design specifications for the soil excavation were completed in October 2005.
The excavation of the contaminated surface soil and the contaminated material in the building sumps and trench, and in the dry wells and their disposal were performed at the site from October 2005 to February 2006. C&Z Construction, Inc., a local company, performed the excavation of the surface soil along the eastern boundary of the site. EWMI performed the excavation and removal of soil from all other areas and the removal and disposal of the contaminated materials from the sumps and the trench inside the building, and from the dry wells. A total of 170 cubic yards of material was excavated and disposed of at an EPA-approved off-site facility.
The analytical results from post-excavation soil samples collected from the excavation limits indicated that the residual levels of VOCs were below the TAGM objectives.
In-Situ Soil Vapor Extraction
The design specifications for the Phase 1 and Phase 2 ISVE were completed in February 2005 and May 2005, respectively.
A pilot test was conducted in March 2005 to evaluate the effectiveness of ISVE in treating VOCs in the subsurface soil and soil gas at the site and to establish the design parameters for the full-scale system. The pilot test, which was implemented by CH2MHill, consisted of the installation of four ISVE wells and eight vapor monitoring probes. Since the results of this test showed promise, the full-scale system ISVE system was constructed in July 2005. This included the installation of a total of five additional ISVE wells and three additional vapor monitoring probes. The coverage area included a section of the parking lot and the section of the building where historic sources were located. All of the process equipment, except the granular activated carbon (GAC)
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vessels, is housed in an insulated, fully enclosed trailer. The trailer and the GAC vessels are located inside of the building. A discharge vent was installed along the outside wall of the building. Piping inside the building was installed above grade on the concrete floor slab. The vacuum blower operates to remove more than 1,000 cubic feet per minute of vapor from the subsurface and maintains a net negative pressure in the subsurface while operating.
A Remedial Action Report was approved on September 30, 2008 following the determination that the ISVE system had met the cleanup objectives for the soil. The results of equilibrium sampling and groundwater partitioning calculations suggested that vapor concentrations remaining in the subsurface vadoise zone could be attributed to the low concentrations of contaminants remaining in groundwater in the upper aquifer beneath the site. Although the soil cleanup objectives were met, since vapors continued to be recovered, it was decided that the ISVE system would continue to operate until the vapors are reduced to levels that achieve the remedial objective of minimizing or eliminating migration to indoor air^.
Remediation of the Upper Glacial Aquifer
The design specifications for the in-situ chemical oxidation (ISCO) system were completed in June 2005.
Redox Tech, LLC was subcontracted to perform the ISCO operation in the Upper Glacial Aquifer. A bench-scale study was performed in March 2005 to evaluate and select the oxidant media and dosage to be used in the injections. An implementation plan detailing the design of the injection system, injection locations, and specific quantities of oxidant to be used was prepared in June 2005. Between July and December 2005, approximately, 15,000 gallons of iron-catalyzed sodium persulfate (with small amounts of buffering agents) and 600 gallons of hydrogen peroxide were injected in the aquifer through a network of 20 injection wells.
Upon review of the post-chemical oxidation injection data for the groundwater in the Upper Glacial Aquifer, it was noted that the concentrations of several contaminants in the monitoring wells had slightly rebounded after a significant initial drop. As a polishing step, air oxidation was implemented in order to further reduce the VOC concentrations. The design specifications for the air oxidation were developed in May 2006 by CH2MHill. The air injection system operated from June 7-26, 2006 and August 18 to September 15, 2006.
The Upper Glacial Aquifer remedy was determined to be operational and functional with the approval of an interim Remedial Action Report on September 29, 2006. A final Remedial Action Report will be prepared in the near future.
2 At that time, it was believed that the source of the vapors was residual soil and/or groundwater contamination. However, based upon the results of an investigation performed January-February 2012 (see the "Operation and Maintenance" section, below), three subsurface soil hot-spots were found under the floor.
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Magothy Aquifer Investigation
As part of the Rl, in July 2002, a vertical profile of the VOC contamination was obtained in on-site monitoring well 5M. Samples were obtained at various depths, starting at the top of the Upper Glacial Aquifer (50 feet), continuing into the Magothy Confining Bed (129 to 379 feet), and concluding in the Magothy Aquifer at a depth of 454 feet. The vertical data profile indicated that although there had been a continuous vertical column of PCE, TCE, and DCE contamination in monitoring well 5M from the Upper Glacial Aquifer all the way down to the Magothy Aquifer, the VOC concentrations detected in the Magothy Aquifer (404 feet) immediately underlying the Magothy Confining Bed were significantly higher than the concentrations in the Magothy Confining Bed. It was, therefore, concluded that the site might not constitute a major source of the Magothy Aquifer contamination. Further confirmatory sampling would, however, be required to confirm this conclusion.
A supplemental groundwater investigation was conducted from March 2005 to September 2006 to determine the source of the Magothy Aquifer contamination underneath the Jackson Steel site and to establish whether there is a relationship between the contamination at the site and the VOC contamination detected in Village of Mineola Supply Well #4. As part of this investigation, six monitoring wells were installed. Three wells were installed in the Magothy Confining Bed at the location of the on-site dry wells where the dumping of chemicals occurred. Three additional wells were installed off-site into the Magothy Aquifer (at approximately 455 feet). One well is located approximately 300 feet northwest of the site. This well is considered upgradient under regional flow conditions and sidegradient when Village of Mineola Supply Well #4 is pumping. The second monitoring well is located southwest of the site. This well is considered downgradient under regional flow conditions and sidegradient when Village of Mineola Supply Well #4 is pumping. The third well is located between the site and Village of Mineola Supply Well #4, approximately 1,200 feet southeast of the site. This well is considered sidegradient under regional flow conditions and downgradient when Village of Mineola Supply Well #4 is pumping.
The results of the investigation, which are summarized in the Supplemental Groundwater Investigation, CH2MHill, October 2006, and Findings of the Supplemental Groundwater investigation, EPA, September 2006, indicate that multiple sources appear to contribute to the contamination in the Magothy Aquifer underneath the site. The investigati9n showed that the levels of contamination in the Magothy Aquifer increase or decreasejn response to whether or not various production wells in the vicinity of the site {e.g., Village of Mineola Supply Well #4) are operating or not. The investigation also showed that the contribution of contamination from the site is minimal. Specifically, VOCs were not detected in the three monitoring wells that were installed at various depths in the Magothy Confining Bed underlying the location of the two former dry wells where the dumping of chemicals occurred. In monitoring well 5M (located downgradient or sidegradient of the dry wells, depending on whether or not the various production wells are pumping at the time), the maximum TCE concentration was 1.8 micrograms per liter (pg/1) and the maximum PCE concentration was 1.2 pg/1 (the state and federal standard for TCE and PCE is 5.0 pg/l). In comparison, the levels of contamination in the underlying Magothy Aquifer ranged from 100-200 pg/1 TCE and 57-160 |jg/l PCE.
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The fluctuations in the on-site Magothy Aquifer contamination as a result of whether or not the municipal well is operating, in conjunction with the absence of contamination in the strata overlaying the Magothy Aquifer (Magothy Confining Bed) point to sources of contamination beyond the site. Based on the above, it was concluded that the site is not a current source of contamination in the Magothy Aquifer. Therefore, EPA decided not to implement the Magothy Aquifer groundwater remedy. An Explanation of Significant Differences (ESD) was issued on August 28, 2007, documenting this decision.
Institutional Controls Implementation
Since area residents utilize municipal water, there are existing county restrictions limiting the use of groundwater as a potable or process water, it was anticipated that the soil remedy and the groundwater remedy in the Upper Glacial Aquifer would be implemented expeditiously, and vapor intrusion mitigation systems were installed in the affected buildings, the ROD did not foresee a need for institutional controls.
Operation and Maintenance
Long-term O&M activities include:
• Maintenance of the subslab mitigation systems; • Recording ISVE well flow rates, vacuum readings, and system performance
readings; • Collecting ISVE field screening data at various points of the system; • Recording ISVE well pressure readings; and • Collecting samples from the ISVE system influent and effluent for laboratory
analysis for contaminants to assess the need for GAC change-out.
The following samples have been collected to monitor the performance of the ISVE and vapor intrusion mitigation systems and to assess the progress toward realizing the remedial objectives of minimizing or eliminating contaminant migration from soil and groundwater to indoor air^:
• Samples from up to three subslab vents located around the daycare center and from the one subslab vent adjacent to the retail store;
• Soil gas samples from soil gas monitoring ports from 5 sampling ports in the daycare center (corresponding to the indoor air sampling locations within the building), 7 sampling ports in the Jackson Steel building, and one sampling port in the retail store;
• Indoor air samples from up to 17 locations on the site and off-site including the retail store, daycare center, boiler room of the apartment complex, a neighboring restaurant, and neighboring office building.
^ From startup in 2007 until July 2011, samples were collected monthly. After that time the frequency was reduced to every 2-3 months.
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Based upon the results of groundwater samples collected in July and August 2007, it was determined that no further ISCO injections or air oxidation was required. Since the groundwater standards had been met for several years subsequently, groundwater sampling was discontinued after the September 2011 sampling event.
Since soil gas samples collected from below the concrete slab of the Jackson Steel building continued to contain elevated concentrations of PCE and TCE, from January 24, 2012 to February 15, 2012, a Membrane Interface Probe (MIP)'' investigation was performed to delineate the lateral and vertical extent of PCE and TCE in the soils as;a potential source of soil gas concentrations. Soil confirmation samples were collected ito assist in the evaluation of the MIP results by associating MIP field data with soil sample results. Probing was. initially conducted on a grid system with approximately 30-foot spacing and were terminated at 50 feet bgs. Subsequently, probe locations and terminal depth were adjusted in accordance with real time results. A limited soil boring prograhri was implemented in conjunction with the MIP investigation to visually inspect and log soil cores and ground truth the observed MIP sensor responses against field observations.'.
In general, the comparison of soil boring log observations, soil analytical results and MIP logs showed a general concurrence. The soil sample's analytical results showed PCE ranging in concentration from 0.0051 to 14 mg/kg (the TAGM is 1.4 mg/kg) in soils just beneath the floor of the building and TCE concentrations ranging from not detected to 0.016 mg/kg (the TAGM is 0.7 mg/kg).
The MIP technology identified three potential shallow subsurface (2- 6 feet below grade) hot-spots where confirmatory soil samples were collected using conventional drilling and soil sampling methods. Based on the results of the MIP investigation and confirmatory soil samples, enhancements were made to the existing ISVE system. Specifically, nine new extraction wells were installed in the three discrete hot-spot areas inside the building in early June 2012.
The operation, maintenance, monitoring, data evaluation, and reporting costs are approximately $21,000 on an annual basis; these costs are broken down in Table 2.
The MIP fits onto conventional GeoProbe direct-push technology (DPT) drilling equipment and is inserted into the target investigation zone in a manner similar to a standard DPT sampling device. The MIP tool contains a membrane in the tip that is permeable to VOCs and a built-in heating element that heats the soils and groundwater adjacent to the probe, causing VOCs near the MIP to volatilize and the vapors diffuse across the membrane, where an inert carrier gas transports the VOCs through sealed tubing to the data acquisition vehicle containing a Photoionization Detector, a Flame Ionization Detector, and an Electron Capture Detector. The detectors do not provide a quantitative concentration of VOCs in the soil, nor do they differentiate between compounds (e.g., identify PCE or TCE). However, the response level from the detector corresponds to the amount of VOCs present in the carrier gas, which is proportional to the amount of VOCs in the soil or groundwater at the MIP location. A greater response from the detector indicates greater VOC concentrations in the subsurface. Since MIP analytical detection systems do not provide fully quantitative results, accuracy is assessed qualitatively by measuring the agreement between detect and non-detect determinations made by the MIP and by corresponding confirmatory laboratory samples.
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V. Progress Since the Last Review
This is the first five-year review for the site.
VI. Five-Year Review Process
Administrative Components
The five-year review team consisted of Christos Tsiamis (RPM), Robert Alvey (hydrogeologist), Marian Olsen (human health risk assessor), and Michael Clemetson (ecological risk assessor).
Community Involvement
The EPA Community Involvement Coordinator for the site, Cecilia Echols, published a notice in the May 24, 2012 edition of the Mineola American, a local newspaper, notifying the community of the initiation of the five-year review process. The notice indicated that EPA would be conducting a five-year review of the site to ensure that the site is protective of public health and the environment and that the implemented components of the remedy are functioning as designed. It also indicated that once the five-year review is completed, the results will be made available in the local site repository. In addition, the notice included the RPM's address and telephone number for questions related to the five-year review process or the site.
Document Review
The documents, data, and information which were reviewed in completing the five-year review are summarized in Table 3.
Data Review
Prior to the remediation of the Upper Glacial Aquifer, cis-1,2-DCE was detected at a maximum concentration of 340 pg/1 and PCE was detected at a maximum concentration of 63 pg/l (the Maximum Contaminant Levels [MCLs] for cis-1,2-DCE and PCE are both 5 pg/l.) With the exception of cis-1,2-DCA marginally exceeding the state MCL at 5.6 pg/1 in March 2010, there have been no other exceedances in the groundwater since the remediation of the Upper Glacial Aquifer was completed. During the final sampling event in September 2011, the only contaminant detected was PCE at 1.3 |jg/l.
Subslab soil gas samples are collected from under the Jackson Steel facility, retail store, and daycare center. While soil gas vapor concentrations at a number of locations continue to exceed the NYSDOH criteria for PCE (100 micrograms per cubic meter [pg/m^]) and TCE (5 [iglm^) in the subslab samples, with the exception of an increase in some of the sampling locations in the most recent sampling event in July 2012, there is an overall downward trend. It should be noted that exceedances of the NYSDOH criteria are an indication that a problem may exist with indoor air within the structure that needs to be addressed. As is noted above, such systems have been installed at the facility and
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are working effectively (as noted by sampling results described below).
At the Jackson Steel building, elevated concentrations of PCE and TCE were detected in all 7 of the subslab samples in August 2007, with the maximum concentrations being 48,000 [jg/m^ and 2,000 pg/nn ,̂ respectively. While samples from one location no longer exceed NYSDOH's criteria, and samples from three locations have had only sporadic exceedances during the review period, the most recent sample results from July 2012 show elevated concentrations of PCE and TCE in six of the locations; the maximum concentrations are now 4,800 pg/m^and 250 pg/m^for PCE and TCE, respectively.
At the lone sampling station at the retail store, PCE and TCE were detected in the subslab in August 2007 at 320 jug/m^ and 13jug/m^, respectively. In August 2008, PCE was detected at 110 ĴQ/m .̂ Since that time, there were sporadic detections of PCE (all below ^QOpg/m^).
At the daycare center, elevated concentrations of PCE and TCE were detected in three of the five sampling locations in August 2007, with the maximum concentrations being 2,800 ;jg/m^ and 110 pg/vn^, respectively. Since that sampling event, only sporadic exceedances have occurred in each sampling location. The most recent sample results from July 2012 show elevated concentrations of PCE and TCE in only one location at 140 pg/m^ and 7.4 jug/m^for PCE and TCE, respectively.
Indoor air samples were collected from the retail store, daycare center, restaurant, apartment building boiler room, and office building. All of the indoor air samples are consistently significantly below the NYSDOH guideline and EPA's acceptable noncancer risk levels during the review period.
Site Inspection
A site inspection was conducted on July 9, 2012.
Interviews
No interviews were conducted during the review period.
Institutional Controls Verification
Since area residents utilize municipal water, there are existing county restrictions limiting the use of groundwater as a potable or process water, it was anticipated that the soil remedy and the groundwater remedy in the Upper Glacial Aquifer would be implemented expeditiously, and vapor intrusion mitigation systems were installed in the affected buildings, the ROD did not foresee a need for institutional controls.
Other Comments on Operation, Maintenance. Monitoring and Institutional Controls
There are no follow-up actions stemming from this five-year review.
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VII. j Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
The ROD, as modified by the ESD, called for the excavation of the surface soils located near the building which were contaminated with VOCs, SVOCs, pesticides and metals; excavation of the contents of the two dry wells and sump located outside the building and the dry well, sumps, and trench located inside the building; treatment of the VOC-contaminated unsaturated subsurface soils using ISVE; decontamination of the building floor through vacuuming and power washing; off-site disposal of the excavated material, vacuumed dust, and wash water; and in-situ treatment of the contaminated groundwater in the upper aquifer in the source area with an oxidizing agent.
The excavation and groundwater remedies have been completed. Newly identified residual vadose zone contamination is being addressed by an enhancement of the ISVE system. Indoor air and subslab monitoring continues for those buildings with vapor mitigation systems.
Since the groundwater cleanup goals have been met, residual vadose zone contamination is being adequately addressed by the ISVE system, and the operating vapor mitigation systems are effectively addressing indoor air concerns, the remedies are functioning as intended.
Question B: Are the exposure assumptions, toxicity data, cleanup levels and remedial action objectives used at the time of the remedy still valid?
Although the ecological risk assessment screening values used to support the ROD may not necessarily reflect the current values, the exposure assumptions remain appropriate and thus the remedy remains protective of ecological resources. The terrestrial exposure pathway has been addressed by the removal of contaminated surface soil. Although the contamination in the Upper Glacial Aquifer has also been addressed, since this aquifer does not discharge into any water bodies in the vicinity of the site, it never posed an ecological risk.
The remedial action objectives noted above in Section IV are still valid.
There have been no changes in the physical conditions of the site over the past five years that would change the protectiveness of the remedy. Soil and groundwater use at the site are not expected to change during the next five years, the period of time considered in this review.
The human health risk assessment was included in the Rl report and a supplement to the risk assessment for indoor air titled "Indoor Air Risk Assessment at Tutor Time." Routes of exposure and media included ingestion and dermal exposure to the building floor based on wipe sample results; ingestion, dermal and inhalation exposures to surface and subsurface soil; and contact with groundwater, as well as inhalation of groundwater vapors while showering. Although the groundwater is not currently being used on-property for drinking, it is designated a potable water supply, or Class GA, by the State
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of New York. Based on the groundwater classification, it was included as a potential future exposure pathway. I
The remedy required building decontamination including the floor; soil excavation of surface and building sump and trench and dry wells; installation of a vapor mitigation system to address elevated concentrations in the subslab; and remediation of the groundwater in the Upper Glacial Aquifer. The remedial actions have reduced contaminants concentrations to within the risk range or^have interrupted exposures. The remedy remains protective.
The risk assessment considered the current commercial and future residential land use. The current and anticipated future use of this property is not expected to change in the next five years. Direct contact exposures at the site were addressed through the remedial actions described above which meet appropriate standards. .
Soil
Contaminated soil exceeding TAGM objectives in soil were excavated and no longer serve as a source of exposure. In order to determine if the remedy is currently protective of human health, the cleanup goals established for the chemicals of concern were compared to their respective NYSDEC Soil Cleanup Objectives (6 NYCRR Part 375) and EPA Regional Screening Levels to determine if the remedy remains protective of human health (see Table 4) . Based on this analysis, the remedy is considered to be protective of human health.
. Groundwater
The cleanup goals established for the site-related groundwater contamination are EPA's MCLs or New York State Groundwater Criteria (the lower of the two criteria). The groundwater is currently meets MCLs/NYSDEC Groundwater Criteria. Table 5 summarizes the relevant groundwater MCL and risk information.
Vapor Intrusion
Vapor intrusion into indoor air has been identified as a potentially important route of exposure at sites that contain VOCs. Soil vapor intrusion was evaluated by conducting indoor air and subslab sampling. As discussed in the "Initial Response" section, vapor mitigation systems were installed to address the vapor intrusion at the daycare center and retail store. The systems are periodically inspected and subslab and indoor air are sampled.
EPA evaluated recent indoor air sample results in comparison to indoor air concentrations associated with a risk to a resident at concentrations of 10"̂ (one in a million) and a noncancer Hazard Index (HI) of 1. The results of this comparison indicate that the indoor air concentrations for both chemicals are within the risk range and below an HI of 1.
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Toxicity Values I •
The toxicity values for several chemicals have changed since the ROD. During this time frame, toxicity values were updated to the Integrated Risk Information System (IRIS), EPA's consensus toxicity values, for cis- and trans-1,2-DCE, TCE, PCE, and 1,1,1 -TCA. In addition, the toxicity values under review by the IRIS program are arsenic and benzo(a)pyrene and these chemicals will need to be evaluated in the next five-year review.
Overall, based on the past remedial actions, ongoing monitoring, and maintenance of the property, the remedy remains protective.
Question C: Has other information come to light which could affect protectiveness of remedy?
No information has come to light that would call into question the protectiveness of the remedy.
Technical Assessment Summary
The soil and groundwater remedies have been fully implemented. Since elevated soil gas concentrations persist under the subslab of the building, following an investigation which located previously unidentified sources under the slab, the ISVE system was expanded in early June 2012 to address this source material. The ISVE system will continue to operate until the vapors are reduced to levels that achieve the remedial objective of minimizing or eliminating migration to indoor air
I VII. Recommendations and Follow-Up Actions
There are no recommendations or follow-up actions stemming from this five-year review.
VII. Protectiveness Statement
The implemented actions at the site protect human health and the environment. Currently, there are no exposure pathways that could î esult in unacceptable risks and none are expected, as long as the site use does not change and the vapor mitigation systems continue to be properly operated, monitored, and maintained.
IX. Next Review
The next five-year review for the Jackson Steel site should be completed within five years of the date of this review.
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Table 1: Chronology of Site Events
Event
Original Jackson Steel site building constructed
New section of building constructed
Building used as "roll form metal shapes" manufacturing facility Nassau County Department of Health collects samples at property and finds contamination
Site placed on National Priorities List
Remedial investigation/feasibility study commences Subslab depressurization system installed at adjacent daycare center and billiards club (currently retail store)
Record of Decision signed
Remedial design commences and approved
Remedial actions performed
Groundwater Remedial Action Report approved
Explanation of Significant Differences issued
Preliminary Close-Out Report approved
Soil and Building Demolition Remedial Action Report approved
Enhancement of the in-situ vapor extraction system
Date(s)
1959
1963
mid-1970s-1991
early 1990s
2000
2001 2002
2004
2005
2005-2006
2006
2007
2007
2008
2012
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Table 2: Annual Operation and Maintenance Costs
Activity
Labor related to soil gas and air sampling
Soil gas and air sample analyses and ISVE system operation
Total
Cost
$7,980
$12,930
$20,910
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Table 3: Documents, Data, and Information Reviewed in Completing Five-Year Review
Document Title (Author)
Record of Decision, Jackson Steel Superfund Site, Mineola, Nassau County, New York, Environmental Protection Agency Remedial Action Construction Report Upper Glacial Aquifer for the Jackson Steel Site, Mineola, New York, CH2MHill Preliminary Close-Out Report, Environmental Protection Agency
Explanation of Significant Differences, Jackson Steel Superfund Site, Mineola, Nassau County, New York, Environmental Protection Agency Remedial Action Report for Soils and Building Floor Decontamination for the Jackson Steel Superfund Site, Mineola, New York, CH2MHill Groundwater Sampling Results, July 2002 Through July 2011, Shallow Upper Glacial Aquifer, Jackson Steel Superfund Site, Mineola, NY, Nassau County, Long Island, CH2MHill Membrane Interface Probe (MIP) and Soil Sampling Investigation at the Jackson Steel Superfund Site, January - February, 2012, CH2MHill
Summary of Analytical Results for Indoor Air Samples, Jackson Steel Superfund Site, Mineola, New York, CH2MHill Summary of Analytical Results for Soil Gas Sampling, Jackson Steel Superfund Site, Mineola, New York, CH2MHill Summary of Analytical Results for Sub Slab Vent Sampling, Jackson Steel Superfund Site, Mineola, New York, CH2MHill
EPA guidance for conducting five-year reviews and other guidance and regulations to determine if any new Applicable or Relevant and Appropriate Requirements relating to the protectiveness of the remedy have been developed since EPA issued the Record of Decision
Submittal Date
September 2004
September 2006
August 2007
August 2007
September 2008
December 2011
April 2012
July 2012
July 2012
July 2012
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Table 4: Soil Cleanup Levels and Cancer and Non-Cancer Risks
Chemical
Benzene
Arsenic
TCE
PCE
Benzo(a)pyrene
TAGM-Soil (mg/kg)
60
7.5
0.7
1.4
0.061
Part - 375 Commercial/R esidential Use (mg/kg)
44/2.9
16/16
150/10
200/5.5
1/1
Cancer Risk Associated with 10-̂ Industrial/ Commercial Exposures (mg/kg)
5.4/1.1
1.6/0.39
6.4/0.91
110/22
0.21/0.015
Non-Cancer Hazard Index Associated with Industrial/ Residential Exposures (mg/kg)
450/120
260/21
20/4.4
410/86
Comments
Within risk range Within risk range Within risk range Within risk range Within risk range
Table 5: Groundwater Cleanup Levels and Cancer and Non-Cancer Risks
Chemical
Trichloroethylene
Tetrachloroethylene
1,1-Dichloroethane
Cis-1,2-dichloroethylene
Trans-1,2-dichloroethylene
1,2-dichloroethane
1,1-dichloroethylene
1,1,1-trichloroethane
Federal MCL (ug/l)
5
5
5
5
5
5
5
5
State MCL (ug/i)
5
5
70
100
5
7
200
Risk at 10* Associated with Residential Exposures (pg/i)
0.4
9.7
2.4
0.15
Hazard at HI = 1 Associated with Residential Exposures iUQl\)
2.6
35
2,900
28
86
13
260
7,500
Comment
Within risk range Within risk range Within risk range Within risk range Within risk range Within risk range Within risk range Within risk range
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