Record of DecisionRemedial Alternative Selection

Site;

Sinclair Refinery Bite, Village of Wellsville, Mew York« ' •

Documents Reviewed;

I an basing my decision primarily on the following documentsdescribing the analysis of the cost-effectiveness of remedialalternatives at the Sinclair Refinery site:

•

Remedial Action Master Plan, CH2M Bill, April 27, 1983.

Phase Z Remedial Investigation Sinclair Refinery Site,SNC Martin, March 14, 1985.

Fast-Track Feasibility Study of Initial Remedial Measuresfor Wellsville Water Supply, SMC Martin Inc., May 1985.

Feasibility Study fo^ the Sinclair Refinery Site Landfill,SMC Martin, August 1985.

Staff summaries, memoranda, letters, and recommendations.

Summary of Remedial Action Alternative Selection - SinclairRefinery Site.

Description of Selected Remedy;

Removal and off-site disposal of approximately 300 drumson the surface of the Central Elevated Landfill Area.

Excavation of the wastes from the 2.3-acre South LandfillArea.

Filling of the excavated area with clean fill.

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- Consolidation of the excavated South Landfill Areaf wastes onto the Central Elevated Landfill Area.

RCRA capping of the consolidated wastes on the CentralElevated Landfill Area.

Partial Genesee River Channelization to protect the landfillfrom erosion and flood inundation from the Genesee River.

•Erection of a fence to secure the entire Landfill site.

Declarations;

Consistent with the Comprehensive Environmental Response,Compensation and Liability Act of 1980 (CERCLA), and the NationalContingency Plan (40 CPR Part 300), I have determined that theselected strategy for the Sinclair Refinery site landfill is acost-effective remedy, and that it effectively mitigates andminimizes existing and potential damage to, and provides adequateprotection of public health, welfare and the environment.

I have also determined that the action being taken is appropriatewhen balanced against the availability of Trust Fund monies foruse at other sites.

The Region has consulted with the State of New York in selecting"'~ the recommended remedial action for this site. The State concurs

that this is the most appropriate remedial measure for theSinclair Refinery site landfill.

•71 v I iU

Summary of Remedial Alternatives SelectionSinclair Refinery Site

Site Location and Description

'Site Location

The former 103-acre Sinclair Oil Refinery, located in AlleganyCounty, New York in the Town of Wellsville', southeast of theVillage of Wellsville, is bounded on the west by Brooklyn Street,on the north by a residential area, and on the south and east bythe Genesee River. The population of Wellsville, estimated tobe 6,000 residents, is served by an aging water treatment plantbuilt in 1921. The intake of the treatment plant is locatedapproximately one-half mile downstream of the northern-mostextremity of the Sinclair Refinery site (see "Figures 1 and- 2).

'Site Description

For the purposes of this project, the Sinclair Refinery site isconsidered as two sub-sites: the refinery portion of the site,consisting of approximately 90 acres where the original refineryoperations took place, now utilized as a light industrial park andagricultural and technical college campus; and the 12.5-acrelandfill portion, which accepted wastes from the refinery operation.

The fenced landfill is located along the Genesee River in thesoutheastern part of the site. The landfill sub-site consistsof the "Central Elevated Landfill Area" ( CELA ) , a 9.2-acre landfilledarea to the north, the 2.3-acre "South Landfill Area" (SLA) to thesouth, and a 1-acre sand and gravel borrow area between the twolandfilled areas (see Figure 3). The 12.5 acre landfill sub-siteis considered in this Record of Decision (ROD). Upon completionof a Feasibility Study for the refinery portion of the site, aseparate ROD will be prepared.

Layers of fill and black-stained material are visible in the 10foot high, several hundred foot long segment of the landfill thatwas subjected to erosion by the Genesee River (see Site Historysection of this ROD). Standing water between the landfill andthe protective dike constructed in 1983 often has an oily sheenon the surface.

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The landfill, wooded and covered with vegetation, has approxiaately300 rusted and corroding 55-gallon drums located in severallocations on the surface. The majority of these drums are empty.It is believed that hundreds of drums are buried in the landfill.A small pool of oil, probably the remains of a lagoon, is locatedon the top of the landfill. A chainlinJc fence partiallyrestricts access to the landfill from the roadway. Access fromthe river bank is unrestricted.

The Village of Wellsville lies within the Genesee River Basinnear the headwaters of the Genesee River. The river follows anorthern path across the entire Southwestern Plateau and the Erie-Ontario Plain before it empties into Lake Ontario at Rochester,New York. The Sinclair Refinery site, located on the floodplaindeposits of the river, has the west bank of the river as itseastern boundary.

'Hydrology and Surface Drainage

The hydrology of the site is dominated by the northward-flowingGenesee River, which has been modified in this area in recentyears by flood control measures implemented by the U.S. ArmyCorps of Engineers. After severe flooding in 1972, the riverunderwent channelization, bank stabilization, and diversion.Several check dams have also been constructed. A dike built in1983 to prevent erosion of the landfill further modified streamflow patterns. Dyke Creek, a tributary, enters the GeneseeRiver approximately 1.25 miles downstream from the landfillsite.

Surface drainage in the landfill area appears to be dominated byoverland flow. The surface material on the CELA is relativelyimpermeable, indicated by standing water and marshy areas onthe top of the landfill. These conditions are the result of animpermeable material placed over the landfill.

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'Hydrelogy

Figure 4 presents a generalized geologic cross-section throughthe site. The site is directly underlain by unconsolidateddeposits consisting of sands, silts, clays, and gravels. Thenear-surface deposits are Holocene channel.and overbank depositsof the Genesee River. The coarser grained sands and gravelstend to be well-sorted and are present as lenses and thin, discon-tinuous sheets separated by layers of finer-grained deposits.Alluvial deposits are at least 10 to 25 feet thick over much ofthe site.

Beneath the alluvial sediments lie glacial deposits of thePleistocene age. Although the glacial and al'lnvial deposits aredifficult to distinguish from one another, based on fieldobservations, it is believed that the clay unit encountered inseveral boreholes represents a glacio-lacustrine deposit. Thethickness of the clay substratum appears to pinch out to thewest ranging from at least 35 feet along South Brooklyn Avenueto over 60 feet along the Genesee River.

During the deglaciation of the northward-sloping Genesee RiverValley, northward-receding ice masses blocked the drainage ofmeltwater, forming large lakes. These lakes were the sites foraccumulations of great thicknesses of fine grained (clay andsilt) lacustrine deposits. A general upward decreasing grainsize at this location suggests that an ancient or buried riverchannel once existed west of the Genesee River (SMC Martin).

The glacial deposits are underlain by bedrock of Devonian age.Although no site-specific data has been acquired on the nature ofthis bedrock, regional data indicate that it is composed ofsandstones, shales, and conglomerates. Seismic data collected forthis investigation indicate that the depth to bedrock varies fromapproximately 70 feet near South Brooklyn Avenue to over 250 feetin the southeastern corner of the site. This slope in the bedrocksurface reflects either a deeper pre-glacial Genesee River or adeepening of the valley by advancing glaciers (SMC Martin).

Geomorphologically, this area is within the Allegany PlateauPhysiographic Province, characterized by a deeply incised dendriticdrainage pattern and broad, flat discontinuous ridges.

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The uppermost aquifer, an unconfirmed water table aquifer, isfound at relatively shallow depths beneath the site. IB thelandfill area, the depths to the water table surface were measuredin the range of 3 to 17 feet, with the depth-to-water at nostlocations in the elevated portions of the landfill greater than10 feet. Water from this aquifer discharges into the GeneseeRiver. The average ground-water flow velocity in the uppermostaquifer is approximately 0.91 ft/day. Velocities tend to belower in the central portion of the site and higher at wellsadjacent to the Genesee River. At this rate, it is estimatedthat it would take about 1.2 years for ground water flowing fromthe central portion of the landfill to reach the Genesee River.Fluctuations in the water levels observed over a three and one-halfmonth period averaged 1.14 feet. Fluctuation's were observed tobe greater in those wells installed closest to the river,particularly in the landfill area where maximum fluctuation wereobserved on the north side. These fluctuations are apparentlyrelated to river stage, with high water tables corresponding tohigh river stages, and with low water levels occurring togetherin the river and the aquifer, illustrating that the GeneseeRiver is a significant hydrologic boundary (SMC Martin).Figure 5 illustrates water level elevations and ground waterflow direction.

Topography at the site is relatively flat, with a steep drop tothe river on the east, and a steep climb into the hills to thewest. The local relief ranges from approximately 1,500 to 2,100feet above mean sea level. The landfill exhibits greater topographicdiversity where the topography has been altered by landfillingand earthmoving operations.

The water table in the landfill area is significantly influencedby the I seal topography and the nature of the landfilled material.The variable thicknesses and permeabilities of the wastes depositedin this area have apparently altered the natural ground-waterflow patterns. Ground water in the southern part of the landfillarea flows in a northerly-easterly direction towards the river.

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Zn the northern portion of the landfill area, there appears to beperched water or Bounding of the ground water at a topographichigh. The water observed at this location may not be directlyconnected hydraulically to the uppermost aquifer. Instead, it Bayrepresent water pooled in a basin with a relatively laperaeablebottom of oil- or sludge-infiltrated soil,. A depressed watertable is indicated south of this area and* west of the dike pool.This area lies in a topographic low between landfilled areas tothe north and south. Ground water in this area apparently flowsfrom the topographically high landfilled areas into the depression.(SMC Martin).

'Landfilled Waste Characteristics

Seismic and resistivity surveys conducted in the landfill areaidentified geophysically anomalous rones which were most likelyrelated to surface and subsurface contamination. Seismic velocitiesof the surface material in the landfill ranged from about 700 to2,300 ft/sec. The wide velocity range for this layer is apparentlydue to the variation of the fill material. Velocity inversionacross the center of the landfill, and the presence of a nearsurface layer with a seismic .velocity of 2,000 to 3,000 ft/secare considered anomalies. A possible interpretation of theseconditions is that the water table is significantly displaced.Water level observations indicate that this is probably thecondition across a portion of the landfill. The anomaly of theseismic inversion may have resulted from localized cementing ofthe overburden material. Subsurface drilling and test pit excava-tions suggest this inversion is caused by sludgy or tarry materialdeposited in the landfill, which may have permeated the naturalsoils (SMC Martin).

A magnetometric survey conducted in the landfill area locatedseveral zones of anomalous magnetic conditions. The magneticanomalies coincided well with areas where waste drums were exposedat the surface, and indicated locations where other drums may havebeen buried. Text pit excavations performed at several of thesemagnetic anomaly locations uncovered buried metallic debris and drums

Pill in the landfill is highly variable and encountered at varyingdepths down to about 20 feet (see Figure 6). This fill isgenerically described as "variable petrochemical waste materialintermixed with soil,' including oil, tars, sludges, and hazardous wwaste-containing drums. While the chemical nature of the waste £material has not been estimated in the field descriptions of thematerial, it is estimated from visual observation that the fill 0material in the landfill is about 50 percent soil and 50 percent °waste material (SMC Martin).

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Site History

The site, originally developed as an oil refinery during the late1800s, was operated by the Wellsville Refining Company. Productsmanufactured by refinement of Pennsylvania "sweet* (low sulfurcontent) crude oil included lubricating oils and grease, fueloil, naptha, gasoline, lighter fluid, and paraffin. In 1924,the Wellsville Refining Company sold the property and plant tothe Sinclair Refining Company which maintained and operated therefinery until 1958, when operations ceased as a result of afire. Following the fire, Sinclair transferred the bulk of theproperty to the Village of Wellsville, reserving to itself someportions of real property and improvements, materials and otherassets on the property, which were separately disposed of bycontract with the New York Refinery Project. The Village ofWellsville subsequently disposed of its parcels to variousinterests after the transfer. An agricultural and technicalcollege and an industrial park have since been developed by thedispensing of some of the parcels. All of the oil tanks fromthe refinery operation and a number of the original buildingshave been removed. Several -structures have been renovated;several remain vacant.

While the refinery was in operation, the southernmost portion ofthe property was used as a landfill. The landfill, locatedalong the Genesee River, was used to dispose of approximately230,000 yd3 of wastes (see Table 1) during its 60 years of use. Ithas been estimated that 206,500 yd3 of this waste was disposed ofin the CELA; the remaining volume being disposed of in the SLA.

The working face of the landfill was accessed by roads traversingthe landfill, ending its southernmost extremity. These roadsended in areas where mounded material and debris were deposited.

An extensive fill mound in the central portion of the landfillis composed of soil-like material and unidentifiable debris.The center of this mound was hollowed out to form a lagoon, usedto contain dark liquids. A channel to the east allowed lagoonoverflow to be diverted to the Genesee River. Trenches and pitsfor burial of either solids or liquids were present in the northernportion of the landfill.

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TYPES OF WASTES DEPOSITED IN THE SINCLAIR REFINERY LANDFILL

* Cloth filters used for straining oil from the contact plant

" Sludges from an oil separator emanating from the light oil andfuels plant (disposed of in a pond within the landfill site)

* Tank sludges from the solvent plant ,

* "Off-specification" products

* Sludge dumptruck loads of oil-soaked soil and sludges (daily)

* Fullers Earth (used for filtering) burned and then disposed

* Approximately 500 gallons of tank sludges ("weekly)

* Acid spills (disposed of in pond within the landfill site)

* Cinders and ash from the coal-fired boiler plant

* Tetraethyl lead

* Pesticides

* Waste oil

* Heavy metals

Table 1

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By 1958, when the refinery terminated its operations/ the lagoonconsisted of only • small pool of standing liquid in the center,surrounded by the drier, dark stained surface of the basin.Portions of the northern and eastern edges of the lagoon,trenches and pits were filled in.

Activities on the landfill continued long after the closure ofrefinery operations. Evidence from 1964, 1970, 1974, and 1982aerial photographs indicate that lagoon dredging, trench back-filling, additional landfilling, and general regrading occurredthroughout this period. Additional landfilling appears to bemost extensive in the 2.3-acre SLA between the years 1970 and1974. By 1982, the landfill had been graded almost flat, and asurficial covering of clay or tilt covered po'rtions of it. Atthat time, the lagoon had been largely filled, a linear area ofdark standing liquid in the center of the landfill being theonly remnant of the lagoon.

Damaging Genesee River floods have occurred in the Village oftfellsville five times since 1913. The most recent flood, causedby Tropical Storm Agnes in 1972, damaged and destroyed bridgescrossing the Genesee River in the Village and caused over $12million damage, overall.

Prom 1973 to 1976, the 0.5. Army Corps of Engineers (COE) undertooka flood control project in the Village, constructing levees alongboth banks of the Genesee River through the Village to a pointimmediately north of the CZLA. This flood control work wasintended to rectify deficiencies in initial flood protection workundertaken in the 1950s.

As can be seen by Figure 7, the Genesee River has had a historyof systemically meandering in the vicinity of the landfill,shifting as much as several hundred feet in some places from1958-1982. As the meanders migrated further downstream, theincreasing meandor amplitude resulted in increased river bankerosion.

The Genesee River began eroding a portion of the landfill as aresult of this lateral movement of the river-bed and heavy rainsin October 1981. Analytical results from the site indicated the 'presence of PCBs , arsenic, mercury, and lead. In association withthe period of high water in the river, organic taste and odorproblems were observed with the drinking water. Test resultsfrom the Village of Wellsville's water treatment plant, theintake of which is located approximately 1 mile downstream of thelandfill, indicated low levels of aliphatic hydrocarbons (10 ug/1as carbon; EPA's limit is 1000 ug/1 as carbon).

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Pollowing the landfill bank erosion and citizen water" taste andodor conplaints, the Allegany County Health Department and NewYork State Department of Transportation investigated the site inconjunction with an investigation by the New York State Departmentof Environmental Conservation (NYSDEC), in the fall of 1981. InJune 1982, the EPA Field Investigation Team visited the site andcollected samples.

A Technical Assistance Team investigation performed in October1982 resulted in the Region's request for an immediate removalaction to stabilize the eroding bank of the landfill. Fundingfor this action was denied by the Assistant Administrator forSolid Watte and Emergency Response in January 1983. At thattime, the potentially responsible party indic'ated a willingnessto remove drums from the Genesee River that had washed from theeroding landfill, and to stabilize the bank. Although in January1983, the PRP removed approximately 10 drums from the river, itchanged its positon regarding stabilizing the eroding landfill.To prevent the imminent threat of further erosion of the landfillduring potential high water conditions that Spring, in March1983, the State used its own funds to construct a temporarydiversion of the Genesee River by excavating a channel that couldaccommodate a two-year frequency flood.

In July 1983, EPA and NYSDEC entered into a a Cooperative Agreementto undertake a Remedial Investigation (RI) and Feasibility Study (75)at the Sinclair Refinery site. SMC Martin was selected by NYSDECto perform the required work.

The RI was broken into two phases. Phase I was performed toprovide a detailed characterization of the landfill portion ofthe site and reconnaissance assessment of the refinery portionof the site. The ongoing Phase II RI provided additional dataon the landfill portion of the site, and will provide a morefocused investigation of those areas on the refinery portion ofthe site where additional data requirements were identified.Originally, only an FS for the landfill portion of the site wascovered by the Cooperative Agreement. Because of the petroleumexclusion provision contained in CERCLA, the FS for the 90-acrerefinery portion of the site could not be performed unless•hazardous substances" were found on this segment of the site.Since hazardous substances were detected at the refinery portionof the site during the Phase I RI, upon completion of the PhaseII RI, an FS will be conducted at the refinery portion of thesite.

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In an action funded by the Potentially Responsible Party inNovember 1983, the height of the dike constructed in March 19B3was raised and it was strengthened with rip-rap.

In December 1983, partial fencing was constructed to limit accessto the landfill from the roadway.

« •

In March 1985, the Cooperative Agreement was amended to performthe Phase II RI and an PS for the refinery portion of the site.

In May 1985, ^ased upon the data collected at the Village's WaterTreatment Plant as part of the RI, and in response to concernsregarding the threat to the water supply from the Sinclair Refinerysite, SMC Martin completed a focused PS evaluating initialremedial measures to protect the Hellsville Water TreatmentPlant. The recommended measure involves relocating the watersupply's intake to a point upstream of the site (see "Authorizationto Proceed with an Initial Remedial Measure at the SinclairRefinery Site, Wellsville, MY - Action Memorandum" for specificdetails).

In August 1985, SMC Martin completed a draft PS for the landfillportion of the site.

Current Site Status

There are seven potential routes of exposure associated with thelandfill portion of the Sinclair Refinery site, includingsubsurface and surface soil, surfical drums, pools and surfacewater, river sediments, and flora and fauna. Pigure 8 indicatesthe sampling locations for all media from the Phase I and II Rls.

'Soil

As can be seen from Tables 2 and 3, the landfill soil samples, aswell as soil samples from the bottom of shallow pools adjacentto the Genesee River, exhibit high levels of base neutrals andvolatile organics, most notably 10,000,000 ppb docosane, 1,400,000ppb 1,3,5 trimethylbenzene, and 870,000 ppb heptadecane. Metalsare also present, but at considerably lower concentrations. Themost noteworthy concentrations are 1670 ppm lead and1020 ppm copper.

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VOLATILE ORGANICCOMPOUNDS tpPb)

1,1,3-Tr iHiethy IbenzeneCyclohexaneHe thy cyclohexane4-Methyl-l-Pentanol2-Hethyl-l-Pentene3,4,4-Trlmethyl-4-PenteneMethyl Ethyl Ketone (HEK)1,2,3-TriMethyIcyclohexanel-Ethyl-4-Methylcyclohexane1,1,3-Tr imethy Icy cl ohexane2,2,-Dl*ethyl-3-Hexene

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HASTE

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2-Pentanone

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VOLATILE ORGANICCOMPOUNDS (ppb)

1,1 , 3-Trimethy IbenzeneCycl ohexaneHe thy cycl ohexane4-Methyl-l-Pentanol2-Methyl-l-Pentene3,4,4-Trimethy1-4-PenteneMethyl Ethyl Ketone (NEK)1,2,3-TrinethyIcyclohexanel-Ethyl-4-Me thy Icycl ohexane1,1,3-Triwethy Icycl ohexane2,2,-Di*ethyl-3-Hexene

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ND14,00034,000

4,90023,000

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3,600

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Do co saneEi co saneHeptadecaneHexadecane4-HethylbenzaldhydeOctadecanePentadecane1,3,5-Tr1MethyIbenzene4-Hethyl-4-Hydroxyl-

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81,00034,000

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'Ground vater

Baaed upon an interpretation of ground-water elevations in theCELA, it appears that nost of the landfilled waste Bight beabove the water table, though it is probable that the wasteitself has displaced the water table. *This is attributable to arelatively iaperaeable sludge layer at the base of the waste.As a result, the waste is not water-saturated and does notgenerate excessive amounts of leachate. At the SLA, a sludgybarrier layer does not exist as in the case of the CELA. As aresult, the waste is considerably closer to the ground water atthe SLA, as compared to the CELA.

Infiltration rates were observed to be highest in the SLA ataverage rates of 0.223 in/hr (falling head conditions) and 1.06in/hr (constant head conditions). Significantly lowerinfiltration capacities were observed in the CELA, with averageinfiltration rates of 0.26 in/hr (falling head conditions) and0.17 in/hr (constant head conditions), suggesting a relativelyimpermeable landfill cover. As a result, rather than percolatingthrough the waste to yield .contaminated ground water, most of therainwater falling on top of the CELA travels over the surface ofthe landfill either pooling in depressions atop the landfill orinfiltrating the surface elsewhere. Given the low infiltrationcapacities and the relatively impermeable nature of the CELAcover, it seems likely that pooled water in these depressionsmore likely evaporates than infiltrates the surface. Because ofthe low permeability of the CELA, significnt levels of contaminationwere not found in the ground water. Zn the SLA, because of thehigher permeability of the cover material and the buried wastes,as compared to the CELA, more precipitation passes through thelandfill, however, overall leachate generation associated withthe landfill appears to be low, as well. Table 4 summarizes therange of contaminants found in the ground water. The most notableconcentrations found include 23,000 ppb 4-methy-4-hydroxyl-2-pentanone,6,000 ppb bis (2-ethyl hexyl) phthalate, and 3,000 ppb fluorenebeneath the Landfill site. Insignificant levels of contaminationwere found in landfill perimeter wells.

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VOLftTILB OPCMIC

1.1.1-TrlcMotoelbaneBenteneChloiobelttenoI. J-OlehlofOpTOpan*1.1.2.2-TetiachloioetliaiieetbylbenieneToluenevinyl ChlorideBfModlrhlOfMetheneChlotoloiaNethylene CMotldeB*n«o|M»nlhieceneTetfachlotoethylenaPyrene •PhcnanthreneI,l.)-Tf iMtnylbeitieneCycloheiane

4-Hethyl-l-rcntanel1-Nethrl-l-Pcntvn*J.«.4-TilB«thrl-4-P*l*«l*«Hctkfl Ethyl Kctonc (NCR)l.2.1-TrlB»tky IcycloKf ••••)-etny l-4-Mcthy IcycloheiAiMI.I.J-Tt IK* thy Icyclohcianal>2t-OI««thyl-l-Nei*n«

TOTAL ITLENES

174.5

11

-25-

Thc "Hydrologic Evaluation of Landfill Performance" 4HELP)computer program, a two-dimensional hydrologic model of^ watermovement across, into, through, and out of landfills, provided arough approximation of the leachate which may be generated atthe Landfill site under average conditions. The model predictedthat for conditions present in the CELA, less than one percentof the annual precipitation (50 gallons' per day (gpd)), willleach through the waste and upper aquifer, and through the claysubstratum, with virtually none leaching through the waste andlaterally draining from the aquifer into the Genesee River.Eighty-nine percent of the annual precipitation will be consumedas evapotranspiration and runoff, with the remaining 10 percentaccumulating in the CELA soil/waste matrix. Tor the SLA, theHELP model predicted that roughly 2 percent MOO gpd) of theannual precipitation will percolate from the surface, throughthe waste and upper aquifer, and through the clay substratum.Roughly 66 percent of the annual precipitation will be lost toevapotranspiration and runoff. Thirty-one percent will laterallydrain to the Genesee River via the upper aquifer, with verylittle being stored in the SLA.

As predicted by the HELP model and confirmed by the failure tofind contamination in perimeter wells and wells in the claybeneath the landfill, overall leachate generation appears to beextremely low at this time.

'Drums

Buried drums may also be potential sources of ground-watercontamination at the Landfill site. A variety of hazardouswaste compounds, including metals and volatile organics, wereobserved in samples from exposed drums on the landfill surface.Table 5 describes the condition and contents of campled drums.Table 6, summarizing the levels of contamination found, shows5,700 ppb methylene chloride, 7,300 ppb nitrobenzene, 31,500 ppbchromium, and 35,900 ppb zinc.

'Pools

Elevated levels of lead and arsenic in the pools atop the landfilland in the main drainage swale (see Table 7) suggest that surfacewater runoff may transport the metals to these local depressionsand possibly to the Genesee River. A significant rise in riverstage or a severe storm event would conceivably transport suchpooled contaminants into the Genesee River.

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DRUM WASTE SAMPLE DESCRIPTIONS AND DRUM CONDITION NOTES

DCscription/Notes

D-l Drum is completely crushed and about 50% exposedat the surface. The area appears to be regr.aded.The drum material appears to be intermixed toiland orange, black and gray waste. The orange *discoloration may be from rusting. The wasteappears to be weathered.

D-2 D r u m . i s completely crushed and»exposed at thesurface. The waste material consisted of blacksolids, gray f ibrous solids, and discolored soillike material.

D-3 Drum is partially exposed at the surface, com-pletely rusted and somewhat crushed. Both ends ofthe drum are open. The material inside the drumis dark brown in color with a waxy texture. Thematerial is homogeneous in both texture andcolor.

D-4 Drum is 60% exposed at the surface, rusted andruptured on both ends. The material insideconsists of two phases; the first phase is adiscolored soil-like material while the second islight brown in color with a waxy texture.

D-5 Drum is 60% exposed at the surface, rusted andopen on one end. The dominant material inside isbrown in color with a soil-like texture. A largecloth rag covered with a bright red resin materialis also in the drum.

D-6 Drum is lying on surface and intact except for asmall six-inch diameter hole in one side. Thematerial inside consists of a homogeneous blackcrystalline solid.

D-7 Drum is piled among other drums and is 50% rustedthrough. Material inside is hard and white incolor with a fluffy porous texture.

D-8 The bucket is 50% exposed to the surface with theopen end facing up. Material in bucket is hard •.-and homogeneous with a gray graphite like color.

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D-9 Drum is 60% exposed on surface and partiallycrushed with one end open. Material is 0grayish-white in color with a dry, f l u f fy ' £powder-like texture. Material contains many small mseptum like plugs.

D-lO Drum is lying on surface, rusted throughout andruptured. Materie-I -inside is blackish brown incolor with a crvstalline solid texture similar tothat found in D-6, perhaps in a di f ferent state ofweathering. Table 5

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*Surfaee Water

As can be seen by Table 8, only low levels of contamination havebeen detected in the Genesee River. Table 9 shows that theredoes not appear to be significant levels of contamination in theGenesee River sediments. With the exception of low levels ofnon-priority pollutant base/neutral extractables, all of theaverage concentrations of detected pollutants found in thesediments are fairly consistent with the average backgroundlevels.

'Air

The only compound detected from the chemical'analyses ofair samples was methylene chloride at 3.6 mg/m-* (see Table 10).Because this volatile organic compound is used widely in analyticallaboratories, because it was the only compound reported, andbecause of the low levels detected, it is deemed insignificant interms of characterizing air contamination at the site.

'Public Health Threat

The 1.2 million gallon per'day Village of Wellsville Water TreatmentPlant, the intake of which is located less than a mile downstreamof the Sinclair Refinery site landfill, is the primary drinkingwater source for the 6,000 residents of the Village. The plant'sexisting facilities, while functional, are greatly in need ofrehabilitation, and are not capable of completely removing theorganic and inorganic compounds potentially discharging into theGenesee River from the Sinclair Refinery site.

Samples taken from the water treatment plant's finished water(see Table 11) through November 1984 have, on occasion, shown lowlevels of trihalomethanes, heavy metals, and base/neutralextractables, all within acceptable criteria levels. Phenol wasalso found on several occasions above the New York State Departmentof Health's (HYSDOH's) aesthetic guidelines. In December 1964,samples showed previously undetected compounds: 6.4 ppb benzene(above NYSDOH's 5 ppb chronic exposure criteria) and 4.8 ppbtetrachloroethylene (below KYSDOH's 50 ppb chronic exposurecriteria).

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NON-PRIORITY POLLUTANTSLandfill

VOLATILE ORGANICCOMPOUNDS ippb>

1,1,3-TriMethylbenzeneCyclohexaneHe thy cy cl ohexa ne4-Hethyl-l-Pentanol2-Hethyl-l-Pentene3,4,4-Trimethy1-4-PenteneMethyl Ethyl Ketone (HER)1,2,3-TrimethyIcyclohexanel-Ethyl-4-HethyIcycl ohexa nel f1,3-TrimethyIcyclohexane2,2,-Diftethyl'3-Hexene

TOTAL XYLENES

SURFACEHATER

NO2537ND28NDNDNDNDNDND100

BASE/NEUTRAL EXTRACTABLE3 (pPbl

Do co vaneEl co saneHeptadecaneHexadecane4-MethylbenxaldhydeOctadecanePentadecane1»3,S-Trinethylbenzene4-M«thyl-4-Hydroiyl-

2-Pentanone

9.8ND3319ND227.115ND

ND - Not Detected

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While the trihalomethanes found in the plant's finished water arelikely to be the result of chlorination of natural organic! inthe raw water, and several of the heavy metals appear to beartifacts of the treatment system, the benzene, nitrobenzene,trans-1,2-dichlorethylene, and possibly the phenol, Bight beattributable to releases from the Sinclair Refinery site.

Although levels of contamination found in the water supply do notindicate gross contamination, because of the presence of hazardoussubstances in the landfill, possibly disposed of in an nnsecuremanner, and because a possible link between the site and the downstreamwater supply's low level of contamination might exist, it wasdetermined that the implementation of an initi-al remedial protectivemeasure to protect the public until the implementation of along-term remedial measure, would be prudent. The initial remedialmeasure, although protecting public health, will not protect theenvironment from releases from the landfill.

"Biota Threat

Chemical analyses performed on species most likely to be consumedby humans, fish, have not indicated any potential threats.Biological screening has indicated potential bioaccumulation ofat least two priority pollutant metals in tissue from otheranimals analyzed (see Table 12). The animal population in thelandfill area, therefore, is considered a potential receptor byvirtue of direct contact and/or ingestion of the hazardous wasteconstituents. Predators of these lower species should also beconsidered potential receptors, by virtue of the potential forbioconcentration.

Several bare spots exist on top of the landfill area where surfacecontamination has apparently prevented vegetative growth. Areview of color infrared photographs of the entire site, however,do not reveal overall stressed vegetation as would be indicatedby relative loss of infrared reflectance.

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-37-

*0verall Threat Potential

With substance! deposited in the landfill consisting .of drummedwaste, oily and tarry sludges, and hazardous waste compounds inother forms, the landfilled areas of the site are potentialsources of contamination. Although the landfill as a whole mustbe considered as a potential source of contamination by virtueof its contents, the landfill may be only a "passive" source ofcontamination in that it does not appear to be generating asubstantial volume of leachate.

Although the subsurface and surface soils and waste are highlycontaminated, ground-water analyses suggest these contaminantsare not extremely mobile and are not migrating readily from thelandfill area. Also, river water samples collected adjacent tothe landfill do not reveal gross degradation of water quality.

Although a relatively "passive" contaminant source, the landfillas a whole must be considered a serious potential source ofcontamination by virtue of the hazardous substances deposited inthe area. Buried drums in the landfill may be considered aspotential point sources of contamination of the ground water,the Genesee River, and other media. Chemical analyses of thedrums sampled for the Phase 1 RI reveal a variety of hazardouswaste compounds, many of which are carcinogenic. Geophysicalstudies suggest that many more drums may be buried in thelandfill. The condition and content of these buried or near-surface drums have not been ascertained.

Because the landfill area is partially fenced, direct humancontact is restricted. The most significant threat from thelandfill would be from flooding or failure of the landfill slopes.Failure of the landfill into the Genesee River would have aserious negative impact on public health and the environment.

Although gross contamination of the air medium has not occurred,the potential for localized, and perhaps harmful, organic compoundvaporization does exist. Drum waste samples and surface soil/sedimentsamples from pools atop the landfill have shown total volatileorganics concentrations exceeding 2,000 ppb at several locationsin the landfill area. Volatilisation of these compounds shouldbe considered as a potential contaminant migration mechanism, andthus a potential threat to the local population.

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-38-

Enforceaent

In 1969, the Sinclair Refining Company merged with the AtlanticRichfield Company (ARCO), identified as a potentially responsibleparty. EPA began discussions with ARCO in August 1982. OnJanuary 6, 1983, NYSDEC and EPA met with'ARCO to discuss measuresto prevent further erosion of the landfill by the Genesee River.As a result of that meeting, on January 21, 1983, ARCO removeddrums that had washed out of the landfill. EPA met with ARCOagain on January 31 and February 7, 1983 to discuss, further,erosion control remedial measures. The RZ and PS were alsodiscussed at the February 7th meeting. Because ARCO had notcommitted to further measures needed to preven't additionallandfill materials from entering the Genesee River, or to anyother cleanup activities at the site, a notice letter was senton March 7, 1983. That letter discussed NYSDEC1s and EPA'sintent to conduct the RI, FS, and initial remedial measures toprevent further erosion of the landfill. The State subsequentlyexpended its own funds to construct a dike as a temporary protectivemeasure. After further negotiations with NYSDEC, ARCO contributedthe funds to strengthen and raise the dike and to reimburse theState for its prior dike-related expenditures.

It is EPA's and NYSDEC's intention to offer the implementationof the remedy to ARCO. If it appears that ARCO is not willingto implement the remedy, or if these negotiations are fruitless,then EPA may consider the issuance of a CERCLA $106 AdministrativeOrder for the implementation of the remedial action, or EPA mayinitiate a cost recovery lawsuit at a later date.

Alternatives Evaluation

The primary objective of the FS was to evaluate remedialalternatives to identify a cost-effective approach consistentwith the goals and objectives of CERCLA. A cost-effectiveremedial alternative as defined in the NCP (40 CFR 300.68j) is•the lowest cost alternative that is technologically feasibleand reliable and which effectively mitigates and minimizes damageto and provides adequate protection of the public health, welfare,or the environment." The NCP outlines procedures and criteriato be used in selecting the most cost-effective alternative.

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-39-

The first step is to evaluate public health and environmentaleffects and welfare concerns associated with the problem. Criteriato be considered are outlined in 40 CFR Section 300.68(e) of the NCPand include such factors as actual or potential direct contactwith hazardous material, degree of contamination of drinkingwater, and extent of isolation and/or migration of the contaminant.

The next step is to develop a limited list of possible remedialalternatives which could be implemented. The no-action alternativeshould be included on the list.

The third step in the process is to provide an initial screeningof the remaining alternatives. The cost, relative effectivenessin minimizing threats, and engineering feasibility are reviewedhere. The no-action alternative should be included for furtherevaluation when response actions may cause greater environmentalor health damage than no-action responses. A no-action alternativeshould also be included if it is appropriate relative to the extentof the existing threat or if response actions provide no greaterprotection .

From the evaluation of the data and information on the nature andthe extent of the contamination associated with the SinclairRefinery site landfill, the following objectives were established:

1. maintenance of a safe, uncontaminated drinking watersupply for the Village of Wellsville

2. protection of Genesee River water quality and associateduses (potable water supply, fishing, recreation) fromcontaminant releases

3. protection of local ground water, which discharges to theGenesee River, from contaminant migration

4. prevention of direct contact between humans and animalswith contaminated site materials, including soil and leachate

5. avoidance of site inundation from increased river flowassociated with a 100-year storm event

6. avoidance of site erosion from a 100-year storm eventCOM"2!

Ooro

0103

-40-

Remedial response criteria for the landfill were divided intocriteria for ground and surface water and criteria for subsurfaceand surface soil.

Water-related remedial response criteria were based upon publishedState ground-water standards and ambient water quality criteriafor potable water supplies for the constituents found in ground-and surface-water samples at the site (see Table 13). In generalterns, contaminated ground water beneath the landfill site andsurface water within the site and the Genesee River will becontrolled such that perimeter monitoring wells or river samplesshow total organics concentrations of 100 ppb or less.

Soils criteria were calculated based upon State ambient waterquality criteria, compound solubilities in water, and soil/waterpartition coefficients. These calculations generated the soilconcentration of an organic compound causing a ground-waterconcentration meeting the ambient limit. Table 14 lists, foreach organic contaminant found in the soils medium, its watersolubility, partition coefficient, and subsurface soils criteria.Subsurface and surface soils at the site will be controlled insuch a manner that contaminant levels in excess of the listedcriteria do not runoff or otherwise contact plant or animallife.

With these objectives and response criteria in mind, a list offeasible remedial technologies was developed (see Table 15).Technologies identified as having the potential to meet theremedial response objectives were subjected to a two-stepevaluation process. The first step consisted of an initialscreening of candidate remedial technologies based upon cost,environmental impacts,, and engineering considerations. Thesecond step consisted of a more thorough evaluation of specificalternatives.

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(4)REMEDIAL CRITERIA FOR CROUHO HATER AND SURFACE HATER

Criteria'1'Compound Ippbl

Priority Volatile Organic*•benxene ND•chlorobenxene 5•tr*n*-l,2-dlchloro*thyl*n* (SO)•1,1,2.2-tetrachloroethane 0.3•toluene 10•vinyl chloride , 1•1,1,1-trlchloroethane (SO)

Priority Base/Neutral txtractablea•fluoranthene 0.2»J|•bl*-(2-ethyl mexyl) pnthalate o.»•fluorene (50)•D-n-octyl phthalate (SO)•2-methyl napthalene (SO)•napthelen* 10•phenantarene (SO) ••pyrene 0.2

MXTtllM, CXlTtJOA FOR SOILS

Solubility in PartitionM«t«r fntml Cp«ffieiant Crtt«ri« faabl

Priority Volatile Organic*bentene 700 130 24chlorobensene too 14) )(trans-l,2-dichloroethylene coo 1)0 1211.1,2.2-tetrachloroethane ISO )St Itoluene 100 14) 72vinyl ehlerid* 1.1 4,04) 107

Priority B*M/W*utr»l Kxtr*ct*blMfluerantAvta 0.2«5 •,0(2 91t

Priority Acid Drtnrtabl**2 , 4-d

Cyinidcs wid Phanolle*Total cyanid*Total r»cov«ratl» phenols 12 )I7 it

Priority Metalsar»«nie M/A V/A 15,000eopp«r K/A M/A »,700nickal M/A M/A • 2*.)00••Isniua M/A M/A WD•ilvar M/A M/A (00sine M/A M/A S),ooo

Priority Pesticide*chlordtn* 0.03* 21,)0( 4texaphsneendrinheptaehler end hoctachler

epexide4.4'-DOS O.K ll.t«0 O.t4,4'-DD£ "0.0013 1(1,714 1.4

PClS 0.04 JS,«)7 13-1

Monprierity Volatile Organic*eyelohaxane 45 1)1 l.)4!••thyleyclohexane 14 1,000 2,500••thyl-1-pentane ?• )•• •*>) , 4 , 4-tri»*Uiyl-4-pentenexylane 175 255 «)?

Menpriority Base/neutral Zrtraetablesdoeosan*eieosaneheptadaeane 0.00* 72,710 111,150aexadecane 0.004 to.ti) 227 ,401oetad.ean* 0.007 •« ,S(5 1«7, ujpentadeeane 0.002 1)),17I ) )2 . t451 , ) , s-triMthylbensane•ilexan*4-hydroxyl-4 »ethyl-2 pentanonehexadaeanoie acid

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SUMMARY OF AVAILABLE REMEDIAL TECHNOLOGIES

A. Source Control Measures

a. No actionb. Surface grading and revegetationc. Collection and treatment of contaminated surface runoffd. Excavation and disposale. Excavation to on-site secure landfillf. In-situ treatment of wastes

1. incineration2. solidification3. biological destruction

g. Installation of impermeable barriers1. slurry walls2. surface cap3. complete encapsulation

h. Landfill bank stabilization6. Off-Site Migration Control Measures

a. No actionb. Ground-water controls

1. slurry walls2. pumping

c. Ground-water recovery and treatmentd. Dredging of contaminated river sedimentse. River rechannelization (flood protection)

Table 15

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-44-

Because of the meandering tendencies and the signifcant floodpotential of the Genesee River, any remedial containment measureimplemented at the Landfill site might be subject to floodinundation and erosion unless protected by a bank stabilizationor channelization measure. Therefore, technologies to protectthe landfill river bank from flooding were considered in thedevelopment of alternatives.

Prom the list of available remedial technologies applicable sourcecontrol and off-site migration control remedial measures wereformulated and were subjected to an initial screening in terms ofcost, environmental impacts, and engineering considerations.

Source control measures evaluated included:

1. No action2. Collection of contaminated runoff with on-site treatment3. Collection of contaminated runoff with Publically-Owned

Treatment Works (POTW) treatment4. Collection of leachate with on-site treatment5. Collection of leachate with POTW treatment€. Waste and contaminated soil excavation and disposal at

existing secure landfill7. Waste and contaminated soil excavation and disposal at a

new secure landfill8. Waste and contaminated soil excavation and on-site disposal9. Waste and contaminated soil excavation and incineration

followed by residue disposal on-site10. Waste and contaminated soil excavation, followed by

solidification and on-site disposal11. Waste and contaminated soil excavation, followed by

biological destruction and on-site disposal12. In-situ waste and contaminated soil solidification13. In-situ waste and contaminated solid biological destruction14. Surface grading and revegetation , CELA and SLA15. Surface grading and revegetation, SLA relocated to CELA16. Installation of perimeter slurry walls, CELA and SLA17. Installation of slurry walls, SLA relocated to CELA18. Installation of RCRA surface cap, CELA and SLA19. Installation of RCRA surface cap, SLA relocated to CELA20. Landfill bank stabilization with modified slopes21. Landfill bank stabilization with existing slopes22. Landfill bank stabilization with structures ™

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-45-

Off-site nitigative control* evaluated included t

1 . No action2. Installation of opgradient slurry walls3. Installation of apgradient pumping system4. Ground water recovery, on-site treatment5. Ground water recovery, treatment at POTW6. Dredging of contaminated sediment, disposal in on-site

secure landfill7. Dredging of contaminated sediment, off-site disposal at

existing secure landfill8. Dredging of contaminated sediment, off-site disposal in

new secure landfill9. River flow control with open channels10. River flow control with dikes11. River flow control with enclosed channels12. River flow controls with groins13. River flow control with check dams

Tables 16 and 17 summarize the initial screening of remedialtechnologies, listing summary conclusions of their publichealth/environmental impacts, feasibility and costs. Costs arenot listed for those technologies rejected on the basis ofinsignificant additional public health or environmental protection,poor technical executability , or poor reliability. Technologiesrejected on a strictly non-cost basis include:

'Collection of leachate/on-site treatment

"Collection of leachate/POTW treatment

'Solidification of waste/soil

'Biological destruction of waste/soil

'In-situ solidification of waste/soil

'In-situ bio-destruction of waste/soil

'Upgradient slurry walls

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'Landfill bank stabilization with existing slope

'Landfill bank stabilization with a structure

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'Dredging sediments/new off-site secure landfill

'River flow control vith enclosed channels

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'River flow control with check dams

A number of technologies were rejected because of their high cost-to-benefit ratio. That is, these technologies had costs generallyseveral times or an order-of-magnitude greater than othertechnologies (or combinations of technologies) that achievedsimilar public health and environmental protection. Technologiesrejected on this basis include:

'Collection of runoff /on-site treatment

'Collection of runoff/POTW treatment

'Excavation/of f-site secure landfill

'Excavation/new off-site secure landfill

'Excavation/incineration/on-site secure landfill for waste/soil

'Surface grading/SLA relocated to CELA

'Slurry walls/SLA relocated to CELA

'Ground water recovery/on-site treatment

'Ground water recovery/POTW treatment M2

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Collection and treatment of contaminated runoff and ground waterwere rejected since their order-of-magnitude installed costs werecomparable to that associated with surface grading, revegetation,and slurry wall installation, yet had significantly greateroperation and maintenance costs. Excavation and redisposal ofwastes in off-site secure landfills was rejected primarily dueto significant (order-of-magnitude) cost as compared to ResourceConservation and Recovery Act (RCRA) capping and slurry wallinstallation to the limiting clay aquaclude. Construction of anew off-site landfill was also rejected because siting problemswere considered to have the potential for long implementationdelays.

Zt should be noted that rejection of all off-site disposaltechnologies in the screening process makes it impossible toconsider a remediation alternative 'specifying off-site storage,destruction, treatment, or secure disposal of hazardous subtancesat a facility approved under RCRA." The screening makes it clear,however, that off-site disposal of Landfill site wastes is bothextraordinarily costly.

The RI and follow-up work indicate that leachate generation andcontaminant migration via the ground water to the Genesee Riverappear not to be a significant pathway. Thus, those technologiesremaining are not specifically related to leachate or ground-watercontrol. Furthermore, since no ground water plume of contaminationis identified at this time, it is believed that off-site contaminantmigration is primarily a function of surface runoff caused byperiodic rainfall and Genesee River flooding. Therefore,technologies that stress this pathway of contamination, such assurface treatments and river controls, appear most appropriatefor further consideration.

Table 18 provides a listing of those technologies that survivedthe screening process. These technologies were combined togenerate alternative remedial systems (see Table 19). Thesesystems were then evaluated in order to recommend a cost-effectiveremedial alternative.

The narrowed list of remedial alternative was furthered evaluatedaccording to the following criteria: feasibility to site-specific wconditions, reliability, operational requirements, implementation Mtime, and environmental and public health impacts.

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LANDFILL BANK STABILIZATION RIVER FLOW CONTROL

200 NIS

Table 17

TECHNOLOGIES SURVIVING INITIAL SCREENING

A. SOURCE CONTROL MEASURES

No action •Surface grading and revegetation, CELA andSLA

Installation of perimeter slurry vails, CELAand SLA

Installation of RCRA surface cap, CELA andSLA

Installation of RCRA surface cap, SLArelocated CELA

Landfill bank stabilization with modifiedslopes

B. MIGRATION MANAGEMENT CONTROL MEASURES

No action

River flow control with open channels

River flow control with dikes

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-54-

According to the NCP, • total coit estimate must also b» consideredfor remedial actions and must include both construction and annualoperation and maintenance costs. These costs are estimated forthe alternatives under consideration. A present worth valueanalysis was used to convert the annual, op.eration and maintenancecosts to an equivalent single value. These costs were consideredover a 20-year period at a 10 percent discount rate and 5 percentinflation.

'Alternative I

No Action, Alternative I, would involve no remedial actions onany of the affected media at the Lanfill site*, and no controls onrunoff, bank erosion, flooding, or leachate generation. Access tothe Landfill site would be completely controlled by the erectionof a chain-link fence around the landfill perimeter. Existingperimeter ground-water monitoring wells would be utilized forlong-term monitoring.

The only operation and maintenance requirements associated withthis alternative are those associated with periodic inspectionand repair of the perimeter fence and regular sampling and analysisof ground water from perimeter wells.

Because the soil cover of the landfill and the buried wastes arerelatively impermeable, rather than perolocating through the wasteto yield contaminated ground water, most rainfall travels over thesurface of the landfill, carrying surface contamination alongwith it, either running off into the Genesee River or pooling atlow points on the landfill. Under no action, a rise in riverstage or a severe storm could allow transport of these pooledcontaminants into the Genesee River. In addition, failure ofthe dike currently protecting the CELA could allow the releaseof waste materials from the landfill into the river.

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Although no action is feasible and has minimal operationalrequirements, it offers little protection to public health andthe environment. This alternative would only control directaccess to the Landfill site. It would do nothing to controlcontinued runoff of contaminated soils,'bank erosion or flooding.

•Alternative II

Alternative II, slurry walls, RCRA cap, and full riverchannelization, combines two source control measures with amigration management technology, yielding maximum public healthand environmental benefits. This alternative would eliminaterunoff of contaminated surface soils, prevent bank erosion andLandfill site flooding, and fully isolate contaminated subsurfacewaste, soils and ground water from the surrounding environment.The entire Landfill site perimeter would also be fenced.

This alternative includes the installation of low permeability3-foot wide bentonite clay/soil slurry wall around both the CELAand SLA to an average depth of 35+. feet beneath the CELA and 20+_feet beneath the SLA. The slurry wall would be cut approximatelyfive feet into the clay aquaclude so as to provide a continuousground-water containment system.

The RCRA cap, incorporating a 2-foot clay liner, geofabric,1-foot witness layer for leak detection, 1.5 feet of sandy soil,and 6 inches of top soil, would be designed to prevent essentiallyall infiltration of rainwater into the landfills. Overlayingthe perimeter slurry walls, the cap would provide continuousimpermeable barriers around all sides of the CELA and SLA. Thecover would be placed after removal of exposed drums and allvegetation, and the filling of depressions with clean soil.

Two leachate/groundwater sumps would maintain a hydraulic gradientinto the landfills, assuring the containment of contaminationwithin the slurry walls. The pumped liquid will be stored on theLandfill site until sufficient volume is collected to remove bytank truck for dispoal, or will be treated on-site or at a wastewater treatment plant.

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This alternative also includes full channelization of the GeneseeRiver from the extreme southern tip of the Landfill site, 3,000linear feet to the existing flood control structures below thenorthern tip of the Landfill site. This relocation widens andmoves the river channel away from the Landfill site, providesstable riprap banks along both sides, and eliminates the threatsof landfill erosion and flood inundation (100-year flood protection).

For full river channelization, 35 acres would be disturbed byconstruction activities, requiring temporary sedimentation anderosion control measures.

Because of the extensive channelization and the 'slurry wallconstruction requirements associated with this alternative,three construction seasons will probably be required.

Construction of shallow slurry walls and river channelization areboth feasible and reliable. Because of the full river channelizationaway from the landfill along its entire reach, and the RCRA capand slurry wall, this is the most redundant, most protectiveremedial alternative.

'Alternative III

Alternative III, clay cap*, slurry walls, and partial riverchannelization, is similar to Alternative II in that itutilizes fencing, surface grading/revegetation, slurry walls andinternal hydrualic control, however the surface regrading involvesa far less extensive capping than required by RCRA. Also, theGenesee River controls are less extensive and closer to the edgesof the CELA and SLA than full channelization. Partial channelizationof the Genesee River would extend roughly from the southern tipof the SLA to the existing flood control structures below thenorthern tip of the CELA. This relocation would widen the river

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•Generally, a clay cap utilizes 2 feet of clay and 6 inches oftop soil. But because the frost line is located 4 feet below the 0ground surface in this area, to prevent freeze-thaw heaving, °which could have a detrimental impact on the integrity of thesurface seal, 3 feet of clay, 1-foot of soil, and € laches of top 0soil were utilized for the clay cap. ^

01

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-57-

in two stages and move the river channel away from the Landfill•ite, providing stable riprap banks along both sides andeliminating the threats of landfill erosion and flood inundation(100-year flood protection). The cap, under Alternative IIIwould not provide the level of protection from rainfallinfiltration that a RCRA cap would, howevrfr, 'this alternativewould provide slurry wall protection and would severely limitrainfall infiltration, particularly in the currently uncappedSLA. The cap, overlaying the perimeter slurry walls, wouldprovide continuous, relatively impermeable barriers around allsides of the CELA and SLA.

To accommodate partial river channelization, placement of theslurry walls and cap will require relocation of waste material atsome points along the perimeter. Also, excavation and handlingof hazardous materials will be required at the northern andsouthern ends of the Landfill site.

For partial river channelization, 28 acres would be disturbed byconstruction activities, requiring temporary sedimentation anderosion control measures.

Because only partial channelization is called for, two tothree construction seasons should be sufficient to implementthis alternative.

*

This alternative addresses all aspects of the Landfill siteproblem and controls all pathways of contamination, providingsomewhat less protection to public health and the environmentthan Alternative II due to the less redundant nature of the capand the less extensive control over the Genesee River. It still,however, meets all Landfill site remediation criteria, and isfeasible and reliable.

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'Alternative IV

Alternative XV, RCRA cap and full river channelization,combines a single source control measure (RCRA cap) and a singlemigration management measure (full 100-year flood protectionriver channelization). Its significant difference fromAlternatives XI and XXX is the lack of slurry wall perimetercontrols. Elimination of slurry walls will not produce theeffectiveness of this alternative, however, since, at this time,ground water movement appears to be an insignificant pathway ofcontaminant migration. RCRA capping will eliminate any surfacewater infiltration and subsequent leachate generation, particularlyin the SLA.

The full channelization away from the landfill along its entireriver reach provides maximum protection from flooding. The RCRAcap provides maximum protection from infiltration.

Because of the extensive construction requirement associatedwith full channelization, three construction seasons will probablybe required.

This alternative attains applicable public health and environmentalcriteria, addressing the critical aspects of the Landfill siteproblem, contaminant migration via surface runoff, bank erosionand flooding, but it does not control movement of ground waterunder the Landfill site. The required technologies are both feasibleand reliable.

'Alternative V

Alterntive V, RCRA cap and partial river channelization, combinesa single source control measure and a single migration managementmeasure. Its significant difference from Alternative IV is theuse of partial river channelization instead of full riverchannelization.

Under partial river channelization, excavation and handling ofhazardous materials will be required at the northern and southernends of the Landfill site.

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Two to three construction season* would be required to implementthis alternative.

This alternative addresses the critical aspects of the Landfillsite problem, contaminant migration via surface runoff, bankerosion, and flooding. It does not, however, control the•ovement of ground water under the site, and it provides lessflood protection than full channelisation. The requiredtechnologies are both feasible and reliable.

'Alternative VI

Alternative VI, consolidations of SLA waste on the CELA,RCRA Cap, and partial river channelization, involves two sourcecontrol measures, excavation and RCRA capping, and a migrationmanagement technology, 100-year flood -protection via partial riverchannelization.

Because the SLA would be excavated and replaced with clean fillunder this alternative, partial river channelization of theGenesee River would only have to extend roughly from the borrowpit area south of the CELA to the existing flood controlstructures, requiring about 1000-linear feet less riprap thanthe partial river channeli ztion described under Alternative III.

Even though more cover material will be required to accommodatethe increased height of the CELA, resulting from the addition ofthe waste excavated from the SLA, because capping of the SLA willno longer be required, an overall savings of cover material ascompared to all the other alternatives will be realized.

Excavation of the 2.3-acre landfill to a depth of 25 feet istechnically feasible and reliable, however, it poses some riskto the on-site workers and the local population. However, withthe utilization of proper health and safety measures duringexcavatin this shortterm exposure risk will be minimized.Flooding and erosion during the operation are also of concern.Because the waste will not be removed from the site, the risk tothe public associated with hauling hazardous waste from the sitewould be eliminated.

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Because of the excavation and construction requirement! associatedwith this alternative, two to three construction seasons wouldprobably be required.

This alternative addresses the critical aspects of the Landfillsite problem, contaminant migration via surface runoff, bankerosion, and flooding. The required technologies are bothfeasible and reliable.

'Alternative VII

Alternative VII, clay cap and partial river channelization,includes one source control technology, grading* with clay capping,and one migration management technology, 100-year flood protectionvia partial river channelization.

Under partial river channelization, excavation and handling ofhazardous materials will be required at the northern andsouthern ends of the Landfill site.

Two to three construction seasons would probably be required toimplement this alternative.

This alternative addresses the critical aspects of the Landfillsite problem, contaminant migration via surface runoff, bankerosion, and flooding, but provides significantly lessprotection than the alternatives employing RCRA caps and/or fullriver channelization. It also employs feasible and reliabletechnologies.

'Alterantive VIII

Alternative VIII, clay cap and bank stabilization, involvesthe application of two source control technologies, grading withclay capping as in Alternative III, and stabilization of theexisting Landfill site banks with riprap and dikes, withoutriver channelization, but providing 100-year flood protection.

This alternative allows the Genesee River to remain in itsestablished channel. This bank stabilization and flood control Mtechnology is the least protective of the options considered. It wdoes nothing to control Genesee River flood waters other than 2protecting the Landfill site from inundation. This leaves the 0banks vulnerable to possible flood damage and erosion. °

-61-

Und«r this alternative, riprap will protect the existing dikeembankment, but not the river channel bank at all points alongthe Landfill site-river interface. This alternative has only afair potential for success since it is vulnerable to uncontrolledGenesee River flood waters.

« <

For bank stabilization, a total of 15 acres would be disturbed byconstruction activities, requiring temporary sedimentation anderosion control measures. One to two construction seasons shouldbe sufficient to implement this alternative.

This alternative provides public health and environmental protectionbut may not meet all applicable criteria. This alternativeaddresses the critical aspects of the Landfill 'Site problem:contaminant migration via surface runoff, bank erosion, andflooding, but does not effectively controlling the river sinceit includes no channelization work. The technologies employedunder this alternative are both feasible and reliable.

Tables 20 and 21 summarize the screening of alternatives. Table22 shows the various costs associated with the alternativesconsidered in the final evaluation.

Community Relations

Throughout the RI, PS, and focused PS for an initial remedialmeasure, all data and reports have been submitted to interestedcitizens, elected officials, the PRP, and the local library,which serves as a public repository.

The public has expressed significant concern regarding thepotential threat from the Sinclair Refinery site. In addition tothe potential acute effects that may be associated with floodconditions, residents are concerned with the long-term chroniceffects of exposure to chemicals that may be released from thesite. The Wellsville Rod and Gun Club has established the healthof the community as the foremost concern in their attempts toactivate the community. The first public meeting, sponsored bythe Rod and Gun Club, included a public panel discussion with EPAand NYSDEC in Pebruary 1983 to address the community's concerns.The primary concern expressed at this and subsequent meeting wasthe threat to the water supply from the site.

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Good - Alternative is well suited to meeting criteria under consideration.Fair - Alternative Is suited to meeting criteria under consideration.Poor - Alternative not well suited to meeting criteria under consideration.Beneficial - Alternative effectively contributes to health and safety or environment.Adverse - Alternative negatively Impacts health and s>fety or environment.High - Involves sophisticated mechanical equipment and logistical requirements.Moderate - Involves commonly utilized mechanical equipment and logistical requirements.Low - Little or no mechanical equipment required.

1890 200 NIS

swmt or lANDnit sin REMEDIAL ALTERNATIVES

ALTERNATIVE

I. No Act lot

II.

III.

IV.

v'

VI.

Slurry VailsRCRA Capfull Channel Itatlon

Slurry WallsSurface Grading

(Clay Cap)Partial Channel -Irattonf!CRA Cap

Channel If atton

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VIII.

KM CapPartial Channel-ization

ftelocatltn or SLAto CELA; RCRA Capon CtlA; Partialchannel I tat Ion uptoCCIA

Surface Grading(Clay Cap)

Partial Channel -Itatlon

Grading(Clay Cap)

lank SUbtll ration(Dikes)

PUBLICHEALTH CONCERNS

Continued exposure existsto ralnfall-and flood-Induced migration ofcontaminants.

ElUatnates releases viaall media. Public riskeliminated.

Eliminates releases viaall media. Public riskeliminated.

Eliminates releases vUsurface runoff and bankerosion. Public risk•Intmlted.

Eliminates releases viasur.ace runoff and bankerosion. Public riskmlnlmlied.

ENVIRONMENTALCONCERNS

TECHNICALCONCERNS

Continued migration ofcontaminants to GeneseeRiver. Not disruptive ofexisting pi and and Mild-life.Eliminates releases to Provendenese* River. Highly technologydisruptive of esta-blished plant and wild-life on landfill Site.Eliminates releases to ProvenGetes-e River. Highly technologydisruptive of esta-blished plant and wild-life on Landfill Site.No groundwater controls ProvenHighly disruptive of technologyestablished plant andwildlife on Landfill Site.

No groundwater controls ProvenHighly disruptive of technologyestablished plant andwildlife on LandfillSite.

Eliminates releases viasurface runoff and bankerosion. Public riskmlnlmlied.

Reduce the landfill Provensite by about 2 acres; technologyNo groundwater controls.Highly disruptive ofestablished plant andwildlife on Landfill Site.

Controls releases via sor- No oroundwater controls Provenface runoff and bank Highly dtsruptlve.of technologyerosion. Public risk established plant andmlnlmlied. wildlife on landfill

Site.Controls release? via No groundwater controls Provensurface runoff and hank No river flooding technologyRIs* of exposure exists controls. Highly dls-durlng severe flood events runtlve of established

plant and wildlife onlandfill Site.

2890 200 MIS Table 2l

OP ••TINATtD TOTAL PP.OJICT C08TI

CAPITAL ABHUAL H>«il»T «O«T« TOTALALTMHATIVt _£5*TJ_ 0»N COSTS OP OP OtX CO»T» « rat«ll»T BOUTI!'

I Ho Action • »0.0»e (10.000 IM4.000 I 404 ,000

II Olerry Valla III. 4»0.000 110.000 t«D,t*« 112.•!!,•••• CP.A CapPull Channel Ilatlon

III tlerry Walla |l»,T*).t»l |«*.llf fl»,«*t. 111.!>«,»••Clay Cap ""

Partial Channel IlatIon

IV nCKA Cap I *.••«,ttO •)».«•• IIM.aea | *,4t*.*t*Pell Channelltatlon

V *c«A Cap I (,)••.••• lia.eaa fle4 t* eecalate approiloately }« per yearI ( over the lenfth of the plaenlnf period.

£890 200 MIS Table 22

-65-

Due to concerns expressed, «t this meeting, the WYSDDHperformed a cancer study to determine whether there was anincreased cancer risk from consuming the Village's water. Theresults of this study indicated that the overall cancer incidencein the Village for the studied period is essentially the same asthat for other New York Villages having' similar populationdensities.

After publicly releasing the draft Phase I HI, a publicmeeting was held on May 6, 19B5. This meeting was attended byapproximately 100 people.- On April 1, 1985 a public workshopwas held to answer additional questions, and to take comments.These meetings were announced via direct Bailings and pressreleases. The public comment period ended on April 15, 1985.

After publicly releasing the draft TS for the landfill portionof the site, a September 3, 1985 meeting was held to brief thepublic on the findings and to solicit public comment. Themeeting, which was announced via press release and direct mailing,was attended by 15 people. A three week public comment periodended on September 16, 1985.

A responsiveness summary is attached (see Attachment 1). Thisdocument summarizes the comments on the 75 and includes meetingnotification documents.

Consistency With Other Environmental Laws

The recommended remedial alternative complies with all substantiverequirements of RCRA, the Clean Hater Act, and the Clean Air Act.The alternative will also comply with all app