SITE NAME

"Brewster Well^lSl^l^illage bf^Brewster / Putriam rountyTNew "Y6rk~~J

STATEMENT OF PURPOSE !._ . ... _ ....

This decision document represents the selected remedial actionfor the treatment and disposal of a drywell, sediments and soilsthat are contaminated with volatile halogenated organic compounds(VHO's) and that are the source of contamination of the BrewsterWell Field. The selected remedial action was developed in accord-ance with the Comprehensive Environmental Response, Compensationand Liability Act of 1980, 42 USC §9601, et seq., as amendedby the Superfund Amendments and Reauthor ization Act of 1986,and to the extent practicable, the National Oil and HazardousSubstance Pollution Contingency Plan, 40 CFR Part 300.

STATEMENT OF BASIS

This decision is based on the administrative record for theBrewster Well Field site. The attached index identifies theitems that comprise the administrative record, upon which theselection of a remedial action is based.

DESCRIPTION OF SELECTED REMEDY

This Record of Decision for the Brewster Well Field site addressesthe treatment/disposal of a drywell, sediments, sludge, and soilscontaminated with VHO's. This portion of the site has beenidentified as the source of groundwater contamination that isbeing addressed under a separate operable unit.

* The drywell sediments, sludge, and soils will be excavated,containerized and transported to a permitted hazardous wastefacility where the waste will be incinerated and treatedresiduals will be disposed of.

* The concrete drywell structure and debris will similarly beremoved, decontaminated, transported to a permitted hazardouswaste facility and disposed of.

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DECLARATIONS

Consistent with the ComprehensivellEnyJronmental Jte8pohsef 'Compensation, Wd Liability Act of -1980 as-amended by -the - ——Superfund Amendments anf Reauthorizat ion Act of 198G, and theNational Oil and Hazardous Substances Pollution Contingency Plan,40 CFR Part 300, I have determined that the selected remedyis protective of human health and the environment, willattain Federal and State requirements that are applicable, orrelevant and appropriate for this remedial action, and iscost-effective. Furthermore, this remedy satisfies the statutorypreference for treatment that reduces the toxicity, mobilityor volume of hazardous substances as a principal element.Finally, this remedy utilizes permanent solutions and alternativetreatment technologies to the maximum extent practicable.

Because this remedy will not result in hazardous substancesremaining on site above health based levels, the five yearreview will not apply to this action.

The State of New York has been consulted and agrees with theapproved remedy.

Date William M MCfsz^Ski, P.E.Acting Regional Administrator

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Table of Contents ———

I. Site Location and Description...................... 1II. Site History and Enforcement Activities............ 1

III. Community Relations................................ 4IV. Scope and Role of Operable Unit

Within Site Strategy............................... 4V. Site Characteristics............................... 4

VI. Summary of Site Risks.............................. 5VII. Alternatives Evaluation............................ 6

VIII. Summary of Comparative Analysisof Alternatives.................................... 9

IX. Selected Remedy.................................... 13X. Statutory Determinations........................... 13

Figures

Figure Page

1. Regional Location Map 172. Area Map 183. Site Map 194. Contaminant Plume Map 205. Schematic - Operable Unit One (GW) Remedy 216. Unsaturated Soil Contamination Map 22

Tables

Table

1. Unsaturated Soil Data 242. Cost Estimates For Alternatives 25

Appendices

A. NYSDEC Letter of ConcurrenceB. Responsiveness SummaryC. Administrat ive Record Index

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REMEDIAL ALTERNATIVE SELECTIONBREWSTER WELL_FLELD

SITE LOCATION AND DESCRIPTION

The Brewster Well Field is located "on "the northern bank of the"East Branch Croton River, 3/4 of a mile east of the Village ofBrewster, Town of Southeast in Putnam County, New York. Thesite is approximately 3 miles west of the Connecticut/NewYork. border and approximately 47 miles north of New YorkCity. Interstate 84 passes just to the west of the site (seeFigure 1).

The land to the north of the study area, containing thecommunity of Brewster Hill, is largely residential with someagricultural use. Most of the land south of the study areais occupied by commercial or light industrial facilities. Tothe west is the residential community of the Village ofBrewster.

The 1980 Census records the population of Putnam County as77,193. Estimated population for the Town of Southeast andthe Village of Brewster are 15,500 and 1,700 respectively.The municipal water system serves the Village and severalareas in the Town of Southeast, a number of business establish-ments and the Consolidated Rail Corporation's Putnam JunctionRail Yard. Residential users alone account for an estimated2, 100 people.

Additional potential receptors are downstream users of theEast Branch Croton River which contributes to the CrotonFalls Reservoir approximately 3.5 miles downstream. The EastBranch Croton River flows adjacent to and south of the WellField. Three thousand feet to the east of the site (upstream)the River is impounded to form the East Branch Reservoir,part of New York City's Croton watershed reservoir system.Three thousand feet from the site to the northeast, Bog Brook,a tributary to the East Branch Croton River, is impounded toform Bog Brook Reservoir, also owned by New York City asshown on Figure 2.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

Beginning in 1954, when Well Field No. 1 was developed, theVillage of Brewster has used the aquifers beneath the Village-owned land, in the Town of Southeast, as a source of water forits water supply system. In 1967 Well Field No. 2 was brought online. The two well fields consist of a total of 18 shallow wells.

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_~t ion""? irst appearecTin 1978, ~and alternative water "sources were ~subsequently added to_ the water supply system,_including a deepIbedrock well ~(DW-2) emd two separate~shallow-IweTls "(SO-l -and" ~~SG-2) located as shown or Figure 3. As a result of lov yieldDW-1 was not connected to the supply system. Two new wells SG-3and SG-4 were added to the system in 1984. Prior to droughtconditions arising in 1981, East Branch Croton River surfacewater was also used at times to supplement the water supplysystem.

Since 1979, the Village has had several studies conducted toidentify potential alternative groundwater sources and to testspray aeration as a potential treatment method for VHO removal.It has since been concluded that treatment of existing sources isthe most promising of the alternatives for solving existingcontamination problems in the Well Field. Under a cooperativeagreement with the Environmental Protection Agency (EPA), Officeof Research and Development, the Village has constructed, testedand in 1984, placed on line, a full scale packed column sprayaeration system for treatment of the entire Village supply.

The Brewster Well Field was placed on the National Priorities List(NPL) in December 1982. Superfund work at the Brewster WellField has been divided into two phases or units, referred to asoperable units (OU's). The two operable units at Brewster are:0 OU One: Management of the migration of contamination throughthe groundwater.

0 OU Two: Control of the contamination source.

Under OU One, in 1985, a study (Focused Feasibility Study) wasconducted by the New York State Department of EnvironmentalConservation (NYSDEC), to investigate the feasibility of on-sitetreatment alternatives for removal of volatile halogenated organiccompounds from the Village's water supply. Considering cost,reliability, off-site releases and flexibility, the packed columnwas adjudged superior to other alternatives.

Concurrent with the Focused Feasibility Study a Remedial Investi-gation (RI) was initiated by NYSDEC, under OU One, to determinethe nature and extent of contamination at and in the vicinity ofthe site. Volatile halogenated organic compounds have been theprimary contaminants detected in the groundwater from the WellField and in the vicinity of the site. The OU One RI defined aplume of groundwater contaminated with tetrachloroethylene (PCE), wtrichloroethylene (TCE) and 1,2 dichloroethylene (DCE) (see raFigure 4) .

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liver and kidney"damage and central nervous system depressionin humans. — ——- ___-.. : ' - - - --"• - ____=__ ___

The OU Or.c Feasibility Study -{re }, which was completed by NYSDECin 1986, evaluated alternatives for remediating the contaminatedgroundwater plume and provided the basis for approval of thefirst Record of Decision (ROD) for the site/ which was signed byEPA on 'September 30, 1986.

The first ROD called for the design and construction of a ground-water management system (CMS) to extract, treat (by air strippingvia a packed tower) and reinject groundwater to expedite theremoval of VHO contaminants from the groundwater (see Figure 5).It also cited the need for a supplemental study (OU Two) toidentify and recommend remediation measures for the source of thegroundwater contamination. It is estimated that the groundwatermanagement system will reduce groundwater cleanup time from 30years (if left to naturally attenuate) to 10 years (if treated).Groundwater will be treated to meet Federal drinking waterstandards (Maximum Contaminant Levels or MCL's).

Design of the CMS proceeded under EPA lead and was completed inSeptember 1987. Construction will commence shortly.

OU One essentially addresses contamination in the saturated soilzone. OU Two has therefore been designed to address the unsaturatedzone. OU Two is intended to identify and remediate any continuingsource for groundwater contamination and eliminate any directcontact health threats.

The OU Two Remedial Investigation (conducted under EPA lead) wascompleted in March 1988 and has identified a drywell adjacentto Alben Cleaners as the source of the groundwater contamination.It is estimated that 100 cubic yards -of material (drywell liquids,sediment, and soil) is contaminated with VHO's to the extent thatrequires remediation. Based on interviews with the cleaningoperator, dry cleaning wastes were disposed of in the drywell,via a floor drain, up until 1983. The principal VHO's, PCE andTCE, are No. F002 listed wastes under 40 CFR 261.31, regulationspromulgated under the Resource Conservation and Recovery Act (RCRA).

The OU Two Feasibility Study (also under EPA lead) was completedin July 1988. The FS looked at alternatives for dealing with thesource of contamination. The evaluation of those alternativesis discussed in subsequent sections of this ROD.

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as the source of contaminations -Information request-letterssubsequent .general notice letters have been sent to.the prpperty'f±r.Isvmers and cleanlrig _6perator7~ZRemedial flesighTand jremedi~al'=1 — ...action will proceed under 5uperr"vnd. Enforcement activitiescontinuing in an attempt to identify and locate additionalpotentially responsible parties' (PRP's). •--=•• ----- ^= ---

COMMUNITY RELATIONS

An extensive community relations plan was developed under OU Oneand updated under OU Two. Community relations activities haveincluded fact sheets, interviews with local citizens and officials,and public meetings. A public-meeting was held on August 21,1986to discuss the findings and alternatives for remediating the ^groundwater contamination studied under OU One. Subsequent factsheets have announced progress on design and construction underOU One as well the RI/FS under OU Two. Additional interviewswith local citizens and officials were conducted and a publicmeeting was held on August 31, 1988 to discuss the findings and 'alternatives for remediating the source identified under OU Two.A copy of the responsiveness summary is attached.

SCOPE AND ROLE OF OPERABLE UNIT TWO WITHIN SITE STRATEGY

The objective of OU Two is to identify and, as necessary, remediatethe source of the well field contamination. The identificationof the source will aid enforcement and cost recovery activities.Remediation of the source will remove any health risks due todirect contact and will ensure the viability of the groundwaterclean-up efforts under OU One by eliminating any continuingcontribution of contaminants to the aquifer. OU Two is the finaloperable unit of the overall remediation strategy for this site.

SITE CHARACTERISTICS

The results of the OU One RI can be broken down into six areas:1) groundwater, 2) water in drainlines in the vicinity of the Site,3) surface water, 4) private water wells, 5) soil and, 6) air.The results of the investigation are discussed in detail in theOU One RI/FS which includes a discussion of the nature and extentof contamination and potential risks from contaminated media.

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The priniclpal findings of the^LFOne stu'dy are that:

- -There is a plume, of groundwatcr contaminated with -VHO'B ——— ~ ----- - -(maximum concentrations of =up~to 6000 parts per billion

~~ ~~~~~ ~ (ppbH -extending -f rom the vicinirty of ±he Alben Cleaners • --- -- - ——parking lot to the Brewster Well Field.

-The Alben Cleaners dry we 11 is the source ofsite contamination.

The primary contaminants of concern are PCE and TCE which areNo. F002 RCRA listed wastes under 40 CFR 261.31.

The analytical results from the OU Two RI , the objectives ofwhich were to confirm the source of site contamination and investi-gate soil contamination in the unsaturated zone, can be found inthe OU Two RI report dated March 1988, and Risk Assessment (RA)report dated July 1988. The OU Two site investigation includedover 100 soil gas probes in the vicinity of Alben Cleaners andother possible source areas; 16 soil borings at suspected sourcelocations, soil gas "hot spots" and the Alben Cleaners dry well;and an additional round of groundwater samples. The RI and RAreports indicate elevated levels of organics in the Alben Cleanersdrywell sediments and sludges (at up to 620,000 parts permillion (ppm) PCE). Additionally, mildly elevated concentrations(up to 4ppm PCE) of organics were found in soil samples from twoother isolated locations in the Alben Cleaners parking lot (seeFigure 6 and Table 1). A risk baseline assessment has determinedthat the incremental cancer risk posed by soils at 4ppm is lessthan lxlO~6. These areas were therefore not considered in thealternatives evaluation phase.

SUMMARY OF SITE RISKS

The primary contaminant used in the baseline risk assessment isPCE as the principal contaminant found at the site. The primaryhealth threat posed by contaminated site soils is from directcontact by ingestion of soils or inhalation of dust. Although thesite is currently used for light commerce, anticipating that thesite might be rezoned for residential use in the future, a baselinerisk assessment conservatively calculated that soils containing upto 4ppm of PCE would present excess carcinogenic risks of no morethan lxlO~6 (or one person in a million) for a 17 kg childconsuming 50 mg of soil per day over 70 years.

Contaminated soils present a secondary threat as contaminantsleach into the groundwater. A groundwater management systemwhich is being constructed under OU One will address this secondary crthreat by treating the groundwater to safe drinking water standards *(MCL's) under the Safe Drinking Water Act.

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The major objective of the OU Two FS was to evaluate alternatives __for addressing the source of groundwater contamination at thesite. Alternatives were formvlated to achieve the followinggoals:

- Ensure the viability of the groundwater management system to beconstructed under OU One by removing any continuing source ofcontamination.

- Minimize any potential risks associated with direct contactwith contaminated residual site soils by removing any soilsposing unacceptable health risks.

A comprehensive list of appropriate remedial technologies wasidentified for source control. These technologies were screenedbased on the characteristics of the site and the characteristicsof the contaminants. The technologies which survived the initialscreening were further screened based on effectiveness, implement-ability and cost. Cost was only used to differentiate betweenalternative technologies providing similar degrees of overallprotectiveness .

Technologies which satisfied the screening requirements werecombined to form remedial action alternatives. Containmentalternatives were dropped from consideration at this point ofthe evaluation process. Given the relatively minor volume ofreadily treatable, highly concentrated waste, the treatmentalternatives are clearly more practicable than the non-treatment alternatives. The remaining alternatives included noaction and treatment. The alternatives developed are detailedbelow and are numbered to correspond with the FS report.

Alternative 1 - No Action

The no-action alternative is required by the National ContingencyPlan (NCP) to be considered through the detailed analysis. Itprovides a baseline for comparison of other alternatives. Underthe no-action alternative, no source control remedial measureswould be undertaken at the Brewster site at the present time.

Although no action would entail no operation or maintenance (O&M)and require no time to implement, unremediated soils wouldcontinue to release contaminants into this Class IIA aquifer,thereby extending the period of time over which the drinking andgroundwater treatment systems will be required to operate. s?

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-Alternative 3 - Cn^Site

The aajor features of this alternative include pumping the poolof liquid waste (sediment and sludge) from the dry we 11, removal -of the concrete drywell structure and removal of contiguous soilswith volatile organic concentrations of greater than 4ppm PCE.It is estimated that approximately 100 cubic yards (cy) of wasteand debris requires remediation. Waste and soils would be treatedon-site in accordance with RCRA by a thermal process to vaporizecontaminants from the waste and soils, after which the vaporizedcontaminants would be destroyed by incineration in an afterburner.The treated soils would be used as backfill. The concrete drywellstructure would be decontaminated by steam blasting and disposedof off site at a RCRA Subtitle C facility.

Estimated capital costs for this alternative are $244,420. Thisalternative will result in the remediation of site soils tohealth based levels. This remedy could be implemented in amatter of months from the start of remedial action.

Inasmuch as the PCE and TCE wastes were discharged to the drywellby the dry cleaner, reportedly until 1983, the drywell, itscontents and contiguous contaminated soils are RCRA wastes under40 CFR 261. The following standards are applicable to theremoval, transport, treatment and disposition of those wastes,and closure of the site.

' 40 CFR 262 - Standards Applicable to Generatorsof Hazardous Waste

* 40 CFR 263 - Standards Applicable to Transportersof Hazardous Waste

0 40 CFR 264 - Standards of Owners/Operators of Hazardous WasteTreatment, Storage and Disposal Facilities

0 40 CFR 268 - Land Disposal Restrictions

At the completion of remedial action, direct contact health risksposed by residual site soils (at less than 4ppm PCE) would be nogreater than lxlO~6. RCRA regulations, 40 CFR Subpart N (Landfills),Subpart G (Closure and Post Closure Care), and Subpart F (Releases)are applicable to the closure and post closure care of residual sitesoils contiguous to the drywell excavation. The details ofproposed remedial actions for complying with RCRA closure andpost closure regulations would be developed as part of remedialdesign activities.

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-Xhe_removal =and -abandonpen17"Tlrywell^3rf" riecessary, is subject to uic Program standards under40 CFR 144 regulations for underground injection^wells.

Standards for dust, particulates and other emissions from responseactions are to be considered relative to federal and state airquality regulations (e.g. NYS Air Guide 1, 40 CFR 50).

Alternative 4 - Off-site Incineration

Under .this alternative the pool of liquid waste (sediment andsludge) would be removed from the drywell, the concrete drywellstructure would be removed, and contiguous soils with volatileorganic concentrations of greater than 4ppm PCE would be removed(approximately lOOcy). Waste and soils would be taken to a RCRASubtitle C disposal facility, incinerated and disposed of underappropriate air and land disposal regulations. The site wouldbe backfilled with clean soil from off-site sources. The concretedrywell structure would be decontaminated by steam blasting anddisposed of off site at a RCRA Subtitle C facility.

Estimated capital costs for this alternative are $241,940. Thisalternative will result in the remediation of site soils to healthbased levels. This remedy could be implemented in a matter ofweeks from the start of remedial action.

Inasmuch as the PCE and TCE wastes were discharged to the drywell bythe dry cleaner, reportedly until 1983, the drywell, its contentsand contiguous contaminated soils are RCRA wastes under 40 CFR261. The following standards are applicable to the removal,transport, treatment and disposition of those wastes, and closureof the site.

8 40 CFR 262 - Standards Applicable to Generatorsof Hazardous Waste,

0 40 CFR 263 - Standards Applicable to Transportersof Hazardous Waste

e 40 CFR 264 - Standards for Owners/Operators of HazardousWaste Treatment, Storage and DisposalFacilities

0 40 CFR 268 - Land Disposal Restrictions

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posed by re"sidual ~^ite soils (at less than 4ppm PCE) would toe nogreater than l*l°~ -_ RCRA regulations, 40 CFR Subpart N (Landfills),.._Subpart G tClosur~e~am3 1>ost"CTosur e~Care)-, anl3~~53T5partI F~TRelease?) ."are applicable to the .closure ap.d-post closure rgre of residual sitesoils contiguous to the drywell excavation. The details of -— _proposed remedial actions for complying with RCRA closure and " "post closure regulations would be developed as part-of remedialdesign activities.

The removal and abandonment, or replacement and permitting of thedrywell, if necessary, is subject to UIC Program standards under40 CFR 144 regulations for underground injection wells.

Standards for dust, particulates and other emissions from responseactions are to be considered relative to federal and state airquality regulations (e.g. NYS Air Guide 1, 40 CFR 50).

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

The retained alternatives were evaluated based on the followingnine criteria:

- Overall protection of human health and the environment;- Compliance with all federal and state applicable orrelevant and appropriate requirements (ARARs);

- Reduction of toxicity, mobility or volume;- Short term effectiveness;- Long term effectiveness;- Implementability;- Cost;- Community Acceptance; and- State Acceptance.

A summary of the relative performance of the alternatives withrespect to each of the nine criteria is provided in this section.

Protection of Human Health and the Environment

Protection of human health and the environment is the centralmandate of CERCLA as amended by SARA. Protection is achievedprimarily by reducing health and environmental threats toacceptable levels and taking appropriate action to ensure thatthere will be no unacceptable risks to human health and theenvironment through any exposure pathways. Without remediation, &contaminated soils would present unacceptable direct contact ft

health risks and continue to act as a source for groundwater

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Both Alternatives7 3 and' 4 would -eliminate these risks. "Alternative's3 and 4 are protective of human health and the environment underTthe standardslioandated by CERCLATas ametided "byTSAPA"._._ __ IL._r~~

Appropriate measures would need to be taken during excavation, _handling and transportation, and treatment of waste and soils to ~^~~protect workers and the community. In addition, prior toimplementing treatment, measures would have to be taken to assurethat implementation does not pose a threat to human health or theenvironment. A few of the potential problems are outlined below.

Workers and the residents would be protected through measuresoutlined in project specific health and safety plans and throughcontractor adherence to Occupational Safety and Health Act (OSHA)regulations.

Dust and particulate matter could be generated during materialshandling and pretreatment. The potential for air releases ofproducts of incomplete combustion also exists. Adjustments inhandling and treatment would be made to ensure that all thesepotential hazards are controlled.

Compliance with ARARs

The drywell and surrounding soils contain PCE and TCE, which areRCRA listed wastes. The wastes were discharged via a floor drainto the drywell until 1983. (They are now recovered by a licensedhauler.) Without remedial action the wastes deposited in thedrywell violate RCRA standards applicable to the disposal ofhazardous wastes and the drywell violates UIC standards applicableto underground injection wells. Without source control, theremediation of contaminated groundwater under OU One to complywith Federal and State ARARs would be prolonged.

The primary ARARs for source control under OU Two are the RCRAregulations relating to the management of hazardous wastes.Under Alternative 3 treated soils would be disposed of on siteas backfill. Under Alternative 4 soils would be removed to aSubtitle C facility, incinerated and the residue landfilled.Both options would be required to comply with RCRA regulationsunder 40 CFR 262, 263, 264, and 268 for the removal, transport,treatment and disposition (land disposal) of hazardous wastes, andclosure of the site.

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The drywell would be removed and,abandoned, or if necessary,.._-replaced and permitted ^nu»* uiw-B«.«naarQ&-under 40 C*^ 144(regulations covering underground injection wells). The drywell

.would be replaced and permitted only _if necessary—to service __the building occupied by the dry cleaner and only if~the --_-—————:replacement were paid for by the building owner/PRP's. Adecision on whether to abandon or. replace the drywell will be ' :\~:made at the time of remedial design after speaking with thebuilding owner/PRP's. "~ ~

Fugitives (i.e. dust) and emissions from remedial actions areto be considered relative to federal and state air qualityregulations (e.g. NYS Air Guide 1). Both the volatilizationalternative and incineration alternative are expected to meetthese air quality standards.

Reduction of Toxicity, Mobility or Volume

This evaluation criterion relates to the performance of a remedialalternative in terms of eliminating or controlling risks posed bythe toxicity, mobility or volume of hazardous substances.

Alternative 3 would accomplish all of these objectives by de-stroying the volatile organic contaminants by on-site volatiliza-tion. Alternative 4 would accomplish this by off-site incineration.Both alternatives would in turn reduce the volume of contaminantsleaching into the aquifer to be treated under the OU One groundwaterremedy.

Short Term Effectiveness

No action requires no time to implement, nor does it result inany short term impacts, but it provides no effectiveness inmeeting cleanup goals.

Alternatives 3 and 4 provide a high degree of effectiveness inthe short term by achieving prompt protection of human healthwith little significant adverse impact resulting from theimplementation of the remedy. Under both alternatives there issome risk of exposure during excavation of soils and decontaminationof the drywell. Under Alternative 3 risks are posed while soilsare stockpiled and treated on site and also by exposure to airemissions from afterburning of soils vapors. Measures (such asrestricting site access and adjusting the treatment process)would be taken to ensure that these potential hazards arecontrolled. Under Alternative 4 only minor additional on-siterisks are presented during transportation of contaminated materials »off site. Alternative 3 could be implemented in months. M

Alternative 4 could be implemented in weeks.

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Both Alternatives 3 and 4 are effective in providing long term --protection of human health.- Both alternatives will-remove the — dry well (and contents) that is the source of site contamination-:This will assure the viability of the groundwater managementsystem to be constructed under OU One by protecting the groundwaterfrom further contamination. The amount of contamination removeddirectly affects the length of time the OU One groundwaterremedy will take to meet clean-up standards. Both alternativeswill also remove and treat, thereby permanently destroyingcontaminants, those most heavily contaminated soils that poseunacceptable health risks.

Implementability

The implementability of alternatives is based on the technicalfeasibility, administrative feasibility and the availability ofservices and materials for the alternative. Alternative 3 issomewhat less implementable and technically feasible thanAlternative 4 in that Alternative 3 requires on-site mobilizationof innovative specialized equipment. The implementation ofAlternative 3 could be restricted by the availability of equipmentand lack of adequate site space. Incineration, as proposed underAlternative 4, is a common technology with a demonstratedperformance record, and it is expected that an off-site facilty,with adequate capacity for the relative minor quantity of wastethat will be generated, should be available.

Cost

The capital cost for Alternative 3 is $244,420 and Alternative 4is $241,940 (see Table 2). Site operation and maintenance costsare covered under the OU One groundwater response action.

Community Acceptance

The community supports Alternative 4 as the preferred alternative.Community comments can be reviewed in the public meeting transcriptwhich is included in the Administrat ive Record. A responsivenesssummary which summarizes all comments received during the publiccomment period is attached.

State Acceptance

The State of New York, through the New York State Department ofEnvironmental Conservation (NYSDEC), has been actively involvedin remedial activities at the Brewster Well Field site. NYSDECconcurs with EPA's selected alternative. A copy of NYSDEC 'sletter of concurrence is attached.

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SELECTED REMEDY

_ Based upon available data and analyses conducted to date, EPA has ._ ..- selected Alternative 4-as the most appropriate solution for meet- ~ing the goals of Operable Uni't Two at the Brewster Well Fieldsite. Alternative 4 was chosen as being more effective in theshort term and as being more readily implementable than Alternative 3.The primary elements of Alternative 4 are:

- The alternative removes the drywell (and contents) that isthe source of site contamination.

- The alternative removes and treats site soils that poseunacceptable health risks. Site soils and sediment/ in-cluding those contiguous to the drywell and site drainagesystems, will be tested during response actions, and thosematerials containing more than 4ppm PCE will be remediated.

By eliminating the source of groundwater contamination, theselected alternative ensures the viability of the groundwatermanagement system to be installed under Operable Unit One.Groundwater remediation under OU One can be expected in 10 yearsas opposed to 30 years or more if contaminant migration werenot controlled and the source not removed. It is estimated thatapproximately 100 cubic yards of contaminated debris and soilwill be excavated, decontaminated or incinerated, and disposed ofat a RCRA Subtitle C facility. This action will reduce healthrisks due to direct contact with contaminated site soils to lxlO~6and comply with RCRA regulations for the closure and postclosure care of residual site soils.

STATUTORY DETERMINATIONS

EPA believes that this remedy will satisfy the statutory require-ments of providing protection of human health and the environment,will be cost-effective, will utilize permanent solutions andalternative treatment technologies or resource recovery technologiesto the maximum extent practicable, and will satisfy the preferencefor treatment as a principal element.

Protection of Human Health and the Environment

The selected remedy eliminates all outstanding threats posed bythe site. It reduces contamination of site materials down tohealth based levels. It removes a continuing threat to groundwaterthereby ensuring the achievement of groundwater remediation underOU One in approximately 10 years as opposed to 30 years or more ^if migration and source controls were not instituted. w

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Attainment Q*-ARAR' s

j At the completion of response actions the selected remedy-will-— ^ave complied^ with-ali—of -the rf ollowing ARARs -and tronsiderations;——

0 40 CFR 262 - Standards Applicable to Generators of Hazardous-r-• Waste, Subparts A through D, for the management of RCRA

hazardous waste, are applicable.

• 40 CFR 263 - Standards Applicable to Transporters ofHazardous Waste, Subpart A (General), Subpart B (Manifestsand Recordkeeping), and Subpart C (Hazardous WasteDischarges), for handling of RCRA hazardous waste off-site, are applicable.

0 40 CFR 264 - Standards for Owners/Operators of HazardousWaste Treatment, Storage and Disposal Facilities, SubpartI (Containers) and Subpart L (Waste Piles), for storage/treatment of hazardous waste; Subpart 0 (Incinerators),for off-site incineration; Subpart F (Releases), forgroundwater monitoring; and Subpart G (Closure and Post-Closure Care), for closure and post closure care; SubpartN (Landfills); are all applicable.

* 40 CFR 268 - Land Disposal Restrictions, for treatmentstandards for land disposal of hazardous waste/ areapplicable.

0 40 CFR 144 Underground Injection Control Program, forremoval and abandonment, or replacement and permitting,of the drywell, are applicable.

0 New York State Air Guide 1 Control of Ambient AirContaminants, 40 CFR 50 Ambient Air Quality Standards, 40CFR 264 Standards for Owners/Operators of Hazardous WasteTreatment, Storage and Disposal Facilities, for control offugitives from excavation and emissions from incineration,are to be considered.

Cost Effectiveness

Selected Alternative 4 provides overall effectiveness proportionateto its cost. It is slightly less costly than Alternative 3 yetit offers comparable performance, is more implementable and ismore effective in the short-term.

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Termanenfc SOltitaona and -JUt-ernartive-Treatmeirfc-Technologies or Resource Recovery Technologies to the MaximumExtent Possible.—————~~~———-———————H——_T———Izm~L~T~ —~T~

Incineratiorf'under Alternative 4"~will completely destroy thecontaminants of concern found in the source soils and debris. -----

Alternative 4 is comparable to Alternative 3 with respect to long-term effectiveness and the degree of permanence afforded, reductionin toxicity, mobility and volume achieved, but poses fewer on-siteshort-term impacts, is more implementable, slightly less costlyand preferred by the community.

Preference for Treatment as a Principal Element

The incineration remedy satisfies the statutory preference fortreatment as a principal element in that it addresses, to healthbased levels, the principal threat posed by the site, i.e. thedrywell that is the source of site contamination.

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FIGURE 1REGIONAL LOCATION

A P P R O X I M A T E SCALE T-14 MILES

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v1 ^-rr~ \Y^I-,X' ToVk >*"{

•X Hill.

JREWSTER. N. Y. -CONN.N 4 J ? ? 5 - - W 7 3 3 0 / 7 5

1958! 'MOTO«tVlSt D 1970

MS 6266 I NE-SERIES VI2i

CONTOUR INTERVAL 10 FEETOAtUM IS. MCAN SEA LEVEL

FIGURE 2BREWSTER STUDYAREA LOCATION

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B R A O YS T A N N A R O

FIGURE 3

. SHALLOW WELLDEPTH : 20'- 2 5 ' i

o SHALLOW WELLu DEPTH : 40 ' -50*

& BEDROCK WELLDEPTH : 350'

., V ILLAGE OF BREWSTER, N.Y.T WELL FIELD AND VICINITY LOCATION MAP

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v x \SCALE IN FEET

FIGURE 4ISOCONCENTRATION MAP. TOTAL CONCENTRATION OF

VHO AT MONITORING WELL LOCATIONSBASED ON SAMPLE ROUND NO. 1 (OCTOBER. 1005)

LEGENDDOC-7 MONITORING WELLS

(10-JO) SCREENED INTERVAL TO NEAREST FOOT19 - T O T A L VMO

F - FILLT - OLACIAL TILL

OL - OLACIOLACUSTRINE0 - OLACIOFLUVIAL-DELTAIC

OW - OLACIOFLUVIAL-OUTWASHSG - SANLVSKW*:. «.UPP:Y we::,OW- P£EP SUPPLV WELl

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FIGURE 5

PRELIMINARY SCHEMATIC-ALTERNATIVE JJJAPPROX. SCALE 1':200'

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EXPLANATION:

WELL/SOIL BORING u-UNDETECTEDPCE (ppb)TCE (ppb) u'-UNDETECTEO, SEMIQUANTITATIVE

SB-1 • SOIL BORING (EBASCO 1967)MW-A$ MONITORING WELL (EBASCO 1887)

DGC-«B MONITORING WELL (GHR 1965)TP-12 EB TEST PIT (GHR 1985)

d-DETECTED.SEMIQUANTITATIVE

ENVIRONMENTALAGENCY

BREWSTER WELL FIELD

FIGURE 6

AVERAGE SOIL CONTAMINATIONABOVE THE WATERTABLE AND

IN THE DRYWELLEBASCO SERVICES INCORPORATED

TABLES

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BREWSTER WELL FIELDSELECTED VHO CONCENTRATIONS IN SOIL BORINGS NEAR ALBEN CLEANERS

PRESENT STUDY :

APPROX. VHO SB-8DEPTH Compounds SB-2 SB-7 SB-7 (VOA(feet) ppb SB-1 (VOA vial) SB-2 SB-3 SB-4 SB-5 SB-5-5a SB-6 1AUG1 (SEP1 Vial) SB-J SB-9 SB-10 SB-11 SE

-D C E - u u - u u - u - - u u u u u -

0 - 2 T C E - u u - u u - u - - u u u u u -PCE - 1.200 1.200 - u 4.100 - u - - 27 12 u u u -OCE - - - _ _ _ g 7 _ _ u u u u - i

2 - 4 T C E - - - _ _ _ u 5 J - - u u u u - iP C E - - - _ _ _ u u - - u u u u - tDCE - - - uu- u - r - - - u u - r u i

4 - 6 T C E - - - u u - u - - - - u u - u iPCE - - - u u 4.000 -- - - 79 u - u tD C E - ' - u u u - T u » - - . - - _ _ _ u

6 - 8 T C E - - u u u - u - - - _ _ _ _ u .P C E - - 9 3 u u - u - - - _ - _ _ u -O C E 8 3 0 u u u u - - - - - - - u » - - T -

8-10 T C E 1,100 u u u u - - - - - - - u - - ! .P C E 7.400 1.700 u u u - - - - - _ - u - - : -DCE - -V -» -* -r - _ u u _f 101? - - • -

10-12 T C E - - - - _ - _ _ 4.1x!0fj 3.0x10= - u - i .PCE - - - - - 2.1xl06 5.7x106 - u - - . - , ' > .O C E - - - _ - _ _ _ „ „ . . - _ . . .

12-14 T C E - - - _ _ _ _ _ 7.2x10* 3.2x10? - - - ; •PCE - - - . . _ . - 1.9x10' 6.2xl08 - - - ' .•

u = undetected ;

J = estimated value, detected below contract required detection limits ; '- s no sample collected :y = water-table

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TABLE 2*

CAPITAL CpST ESTIMATES (1988 Dollars)ALTERNATIVE 3 - QN-SITE ENHANCED VOLATILIZATION

Material Installation DirectEstimated Unit Unit Construction

Facilitv/Construction Quantities Price Cost Price Cost Cost

1 . Site Preparation & Sample Monitoring

a. Site Preparation $ 6.000

b. Field Portable GS (Lease) 1 1.000/wk 4,000 500/day 15,000 $ 19.000

2. Removal of Asohalt Pavement & 42 cv 33.4 cy $ 1.400Excavation Around Dry Well

3. Sheet Piles

a. Lease of Sheet Piles 32 ton 200/ton 6,400 $ 6,400

b. Installation of Sheet Piles 1,200 sf 8.83/Sf 10.600 $ 10,600

4. Removal of Drv Well

a. Saw Cut 2,270 $ 2,270

b. Removal 15 cy 1,520 $ 1,520

5. Decontamination of Dry Well

a. Steamblasting 800 sf 740 $ 740

6. Off-Site RCRA Disoosal of DecontaminatedConcrete Debris

a. Hauling & Transportation 15 cy 4,300 $ 4,300 j

b. RCRA Landfill Disposal < - . -22. 5 ton - . - 350/ton v .-7,880. -. ,.$ 7.880. !

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TABLE 2 (Cont'd) ;:

CAPITAL COST ESTIMATES (1988 Dollars) 'ALTERNATIVE 3 - QN-SITE ENHANCED VOLATILIZATION

Materials Installation DirectEstimated Unit Unit Construction ; ;

Facility/Construction Quantities Price Cost Price Cost Cost•*

7. Removal of Liquid Waste and Sludge

a. Settling Tank (Lease 2 weeks) 3,000 gal $ 3,000 •

b. Pumping 1,000 $ 1,000

c. Settled Wastewater Hauling 3,000 gal 3,200 $ 3.200Tanker Truck (Lease 1 Week) '

8. Excavation of Contaminated Soil 63 cy 29.60 cy 1.870 $ 1,870 !

9. On-Site Enhanced Volatilization <

a. Mobilization & Demobilization $ 60,000 :

b. Low Temperature Thermal Stripping 135 ton 300/ton 40,500 $ 40,500

10. Site Restoration > , ii

a. Backfill & Compaction of 90 cy 10/cy 900 $ 900 iTreated Soil

b. Borrowed Fill & Compaction 15 cy 15/cy 225 5/cy 75 $ 300

c. Asphalt Pavement 250 sf 2/sf 500 3/sf 750 S 1.250 ',

Total Construction Cost (TDCC) % 172,130Contingency 9 25% of TDCC $ 43.030Engineering 9 15X of TDCC $ 25.820Leaal & Administrative £ 2% of TDCC S 3.440 .,

Total Construction Cost $ 244.420 ' :

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CAPITAL COST ESTIMATES (1988 Dollars)ALTERNATIVE 4 - OFF-SITE INCINERATION

EstimatedQuantitiesFaci1i ty/Construction

1. Site Preparation & Sample Monitoring

a. Site Preparation

b. Field Portable GS (Lease) 1

1. Removal of Aspha.lt Pavement &Excavation Around Dry Well (See Table B-l)

2. Sheet Piles

a. Lease of Sheet Piles (See Table B-l)

b. Installation of Sheet Piles (See Table B-l)

3. Removal of Drv Hell

a. Saw Cut (See Table B-l)

b. Removal (See Table B-l)

4. Decontamination of Dry Well

a. Steamfalasting (See Table B-l)

5. Off-Site Dispoal of DecontaminatedConcrete Debris

a. Hauling & Transportation (See Table B-l)

b. Municipal Landfill Disposal (See Table B-l)

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' Cost

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InstallationUnitPrice CftSi

500/day 5.000

DirectConstruction

Cost

$ 3.000

$ 7.000

$ 1.400

$ 6,400

$ 10.600

$ 2,270

$ 1,520

$ 740

$ 4.300

$ 7,880

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TABLE 2 (Cont'd) '

CAPITAL COST ESTIMATES (1988 Dollars)ALTERNATIVE 4 - OFF-SITE INCINERATION ' i

Materials Installation . Direct 'Estimated Unit Unit Construction

Facilitv/Construction Quantities P_rice Cost Price Cost Cost ' 1

6. Removal of Liquid Waste and Sludge:' ' j 1

a. Settling Tank (See Table B-l) $ 3.000 j

b. Pumping (See Table B-l) $ 1.000

c. Settled Wastewater Hauling (See Table B-l) $ 3.200

7. Excavation of Contaminated Soil (See Table B-l) $ 1.870 1 ;

8. Contaminated Soils Containerization. iHauling and Transportation

a. Drumming and Hauling 135 tons 30/drum 11,300 33.5/ton 4,520 $ 15.8201 i'b. Transportation . 7 load 3.5/mile/load 12,250 i $ 12.250 i .

500 mi 1 e 1 • '

9. Off-Site Incineration 130 ton 700/ton 130.000 S 91.000

10. Site Restoration j

a. Borrowed Fill 4 Compaction 105 cy 15/cy 1,580 5 cy 525 $ 2.100

b. Asphalt Pavement 250 Sf 2/sf 500 3/sf 750 * 1.250

Total Direct Construction Cost (TDCC) $ 176.600Contingency 9 20X of TOCCC) $ 35,320 ; • !Engineering 0 15% of TDCC $ 26.490 :' !Leaal & Adminsitration 9 27. of TDCC $ 3.530 > '

Total Construction Cost $ 241,940 jj ! j• - • • • . - -:' • • • • • • - . - • , • . / - . - • ........ . . . . •, , . . . . •-....-.-••—•. . .• . . - « • • - . . . • . j . if '• '.••],

(*) A 20% contingency factor is assumed for this case as compared to 25X for the on-site mobile enhanced volatilization :operation because of the higher potential for operation problems and down time associated with a mobile unit as compared to 'a stationary unit. ' ;

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Ntw York Statt Dtpar1m*n| of Envlronrnfjt^Constrvatlon-K WoJf ~

Thorn*» C.Commliilontr

1988

_ ... f „ "25'-•3 -~C^

Mr. Stephen D. Luftlg, P.E. - t-o -^Director • ~° "Office of Emergency and Remedial Response . —U. S. Environmental Protection Agency "^Region II26 Federal PlazaNew York, NY 10278

Dear Mr. Luftlg:

The New York State Department of Environmental Conservation(NYSDEC) reviewed the Remedial Investigation (RI) report and thtFeasibility Study (FS) for the Second Operable Unit of the Brtwsttr NellField site. Wt concur with tht U. S. Envlronmtntal Protection Agency'sselection of Alternative 4, off-site Incineration of contaminated soilsand off-site landfill Ing of dtcontamlnattd concrete, as tht prtftrredremediation alternative.

The draft Record of Decision (ROD) states, "Site soils andstdlments, Including those contiguous to tht drywtll and site dralnagtsystems, will be tested during response actions, and those materialscontaining more than 4 ppm PCE (tttrachlorotthyltnt) will btremediated." Please bt awart that NYSDEC and tht Ntw York StattDepartment of Health (NYSDOH) define this "drainage system" as ont thatbag1ns at the catch-basins on site and continues through tht culvertout-wash to the northeast of Alben Cleaners (see enclosure).

Also, please be advised that A1r Guide I Is not in Applicable orRtltvant and Appropriate Requirement (ARAR). Rather, U 1s a tool to btused while examining the NYSDEC air regulations which must bt consideredARARs for all remedial programs. The NYSDEC regulations relating to air £quality which art eonsldtrtd ARARs Include: 6 NYCRR, Parts 200.6, 201, '-211.2, 212, and 257. oo

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.Stephen D. Luftlg,

--^ --An^«st1mate t>f -emissions from the remedial ictlvltUs mus~t "be made"during the desljn phase of this project.. During these Vtivlti.smonitoring of off-site emissions shall be conducted. Any in ss"nsdeemed unacceptable by NYSDEC win be cause for Wi1*s1on contro Jnecessary to bring these emissions to an acceptable level?

If you have any questions, please call me at (518) 457-5861 orJames Qulnn, of my staff, at (518) 457-1708.

Sincerely,

J. O'Toole, Jr., P.E.DirectorDivision of Hazardous Waste

Remediation

Enclosure

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_ _.__. -APPENDIX _B. —^

- RESPONSTVENESS

A public comment period was held from August 18, 1988 throughSeptember T.2, 1988 to receive comments'.from the publicTon the _T.draft FS and EPA's preferred remedial alternative for theBrewster Well Field site. A public meeting for the site washeld on August 31, 1988 at 7:00 p.m. at the Brewster, N.Y.Village Hall. The meeting was attended by EPA officials, arepresentative of EPA's consultant engineer, state, countyand local officials, media representatives, and a limitednumber of local citizens. The purpose of the meeting was topresent and discuss the draft FS for the site, to appriselocal officials and residents of the agency's preferredalternative for remediating the site, and to provide anopportunity for interested parties to present oral commentsand questions to EPA. Comments received during the commentperiod are categorized below by topic.

A. Liability of potentially responsible parties (PRP's).B. Origin, nature and extent of contamination.C. Other concerns.

A. LIABILITY OF POTENTIALLY RESPONSIBLE PARTIES

1. Comment: A local official wanted to know if past andpresent property owners and tenants at the source locationwere notified of the site contamination and their potentialliability.

EPA Re'sponse: Site contamination and response actionshave been widely publicized in public fact sheets andpress releases. Notice letters have been mailed to PRP'sincluding the property owner and Alben Cleaners. Enforcementefforts are continuing. If identified, additional PRP'swill be notified.

2. Comment: The site owner asked whether, as a buyer of theproperty, he was liable for waste disposal practices ofpast owners or tenants.

EPA Response: Innocent property owners are not normallyliable for disposal practices of past owners or tenants.A determination as to his innocence will be made in the future.Also see comment 4 below.

so3. Comment: A local official asked whether the village is *

considered a PRP.o

EPA Response: We presently have no reason to believe that 3the village is a PRP.

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rule~be~explalned

EPA Response! V^^rT~pracTicable~and in the"pub"irc"~inteFest ~settlements can be reached with PRPs if the settlementinvolves a minor portion of the response cost, and the —-amount and toxicity is minimal, or the PRP is the owner ofthe site but did not conduct or permit the generation,transportation, storage, treatment or disposal of hazardoussubstances and did not contribute to the release.

5. Comment: The site owner asked whether Alben Cleaners, asthe operator, is solely responsible.

EPA Response: Not necessarily. Costs may also be recoveredfrom past and present site owners and, possibly, othertenants (e.g. under subleasing arrangements.)

6. Comment: A local official asked whether New York City(NYC) or the New York State Department of Transportation(DOT) are considered PRPs since the contaminated groundwaterplume is located under NYC and DOT property.

EPA Response: No; not by virtue of the location of theplume.. The plume represents the migration, but not thesource, of contamination.

B. ORIGIN, NATURE AND EXTENT OF CONTAMINATION

1. Comment: A local official questioned whether the contaminatedsource materials (i.e. drywell and contents) pose anydangers to the building occupants.

EPA Response: The source is presently effectively buriedand presents no direct contact danger but would be adanger if left in place and accidently exposed (e.g. as aresult of excavation) in the future.

2. Comment: The site owner asked when the drywell was installed.

EPA Response: We don't know for certain. Records indicatethat an adjacent septic tank was installed in 1949. Thedrywell may have been installed at that same time.

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6. -Com * ; ~ K«>— *»«»w*— gak»^ whefher-^^hp ^"vwel 1 systemtested when instafled. ~

~~~* EPA Ttespdhse:~I~We"iadrr' t~Tcnbw~.Typically", cbunty~Qr~Tocal ~~- - agencies run percolation^££rt: on septic enn drywell _.__

systems.

9. Comment: A local official asked how much waste would beexcavated at the source and how long it would take.

EPA Response: We expect that approximately 100 cubicyards (cy) of wastes will be removed and that the responseaction will take a matter of weeks from the start ofexcavation. ~

10. Comment: A local official asked whether the adjacent EastBranch "River is being contaminated.

EPA Response: No. Only one surface water sample at thedischarge from the culvert from the Alben parking lotshowed trace amounts (4ppb) of PCE.

11. Comment: The site owner questioned whether a large (4-8ft. )culvert from the interstates ran under the site and whethera highway spill, via the culvert, could have been thecause of site contamination.

EPA Response: A culvert that large would terminate in anendwall at the river or large drainage basin and none isevident at the site. Such a culvert would probably havebeen constructed by DOT. We have coordinated our remedialefforts with DOT and are not aware of any large culvert.Finally, in the absence of a drainage basin, a spill to astorm drain would discharge to the river, and not thegroundwater aquifer.

12. Comment: The owner asked where the drywell is physicallylocated.

EPA Response: Records indicated that the drywell islocated approximately 25 feet east of the southeast cornerof the Alben building. A soil boring taken during theremedial investigation confirms this.

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13. Comment:the contamiiiattOTTiras "be B AflCaffllllAtTiS5~lir Ee~raryWe 1TT

;—_--fiPA Response^ There are tpo~roany variable : fe:rgrr-groundwaterflow, gepiog/, rate of discharge) to determine, _from data,just how long the discharge took place or has beenaccumulating, with any meaningful accuracy. - " ~- ,...-..,,-

14. Comment: The owner asked whether relatively recent highwayconstruction could have affected groundwater conditions inthe area since 1960. _

EPA Response: Construction may have mildly affected thelocal recharge of surface -water to groundwater but wouldhave substantially affected pre-existing groundwaterconditions.

15. Comment: One commenter asked how many gallons of contaminantsit took to contaminate the site.

EPA Response: Theoretically five gallons of a purecontaminant, such as the volatile organic compounds foundat the Brewster site, could contaminate one billion gallonsof water to maximum contaminant levels (MCLs) under theSafe Drinking Water Act (e.g. 5ppb for TCE). It is unlikelythat the contaminants were disposed of in pure form, butrather as an unknown part of a total waste. As a resultof pumping and natural attenuation some unknown part ofthe contamination has been removed or lost. Therefore wecould not, with any reasonable accuracy, estimate thequantity of waste that was disposed of at the site.

C. OTHER CONCERNS

1. Comment: A local official asked who will pay for andoperate the groundwater management system.

EPA Response: EPA will pay for 90% and the State will payfor 10% of the costs of construction and the ten yearremediation effort. The State will pay for operation andmaintenance after ten years if it is necessary. The Stateis also responsible for physically running the system butmay arrange for local authorities to do so.

Comment: The site OWPPFin place in the late"1970"'s that regul'at'ed the disposalof hazardous wastes such as those _Jrom a dry cleaner. _

EPA Response: The Resource Conservation and Recovery Act(RCRA) of 1976 typically regulates the discharge ofhazardous waste depending on the quantity generated. "^There may also be State, local, and industry regulationsor guidelines that have application to dry cleaning wastedisposal.

3. Comment: A local official asked why the effluent from thegroundwater management system is going to be reinjectedinto the groundwater rather than be pumped into the distri-bution system.

EPA Response: Pumping to distribution would have requiredthat the discharge be piped across the river and wouldhave been more difficult to implement and more costly.Reinjection of the effluent dilutes the groundwatercontamination and creates a barrier to the migration offurther contamination.

4. Comment: A local official asked when the groundwatermanagement system will be built.

EPA Response: Funding for construction is shared 90% byEPA and 10% by the State. Federal funding has beenobligated. It is expected that the State cost share willbe approved shortly. Construction should take approximatelysix to nine months.

5. Comment: A local engineer asked what the groundwatermanagement system well construction will be.

EPA Response: The groundwater management wells will begravel packed wells.

6. Comment: The engineer asked what the groundwater managementsystem capacity will be.

EPA Response: The system is designed to operate at 50gallons per minute (gpm).

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7. XZominent:_The engineer asked how oeep the groundwater ;_— management wells—wi-11 be.rrr-—-'" '" ~—:— - -———~management

-EPA Response: -The groundwater-Baanagementj_wells will vary -_~ from 20 to 40 leet deep." _ """" -—-------.

8. Comment: A local official asked whether town permissionwas necessary to construct the groundwater managementsystem.

EEA Response: With regard to property access, the systemis to be constructed on DOT, NYC, and Brady Stannardproperty, from whom we have permission or conditionalpermission to construct the system. Local constructionpermits, if necessary, will be obtained by the constructioncontractor.

9. Comment: A local official asked whether NYC was apprisedof the construction of the groundwater management system.

EPA Response: NYC has been so advised and supports EPA'sremedial efforts.

10. Comment: A local official asked whether health risks dueto emissions from the groundwater management system packedtower air stripper were re-evaluated as part of the mostrecent study.

EPA Response: Data from the most recent study indicatesthat calculated air pathway health risks have decreased.This is due to a corresponding decrease found in groundwatercontamination.

11. Comment: The site owner asked whether any other localproperties were listed on any Superfund type lists.

EPA Response: The commenter was advised to call bothState and Federal environmental offices for a list ofsites.

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APPENDIX C

«/23/6a —-——"' Draft Index Chronological Drdef~=—'—————=———r~~— "Page: TBREHSTER flELLFIELJ) Documents -• -

Document Number: BRE-«i-874fl To 1823 Parent: 8RE-88I-8&88 Date: / 7

Title: Feasibility Study Report Brewster Uell Field Site Voluoe II: Appendices

Type: PLANAuthor: none: 6HR Engineering

Recipient: none: NY Dept of Environmental Conservation

Document Number: BRE-W1-1383 To IW5 Date: / /

Title: Conr.T.ity Relations Plan Brewster Well Field Site

Type: P-JWIPut^.or; ncrie: none

Recipient: nore: none

DocuMnt Naber: BRE-8C1-1792 To 1732 Parent: BRE-W1-1KA Date: 01/25/79

Title: (Letter regarding required cleanup of oil coritaiinated soil and Hater at the facili ty)

Type: CORRESPONDENCEAuthor: Kanfredi, Cesare J: NY Dept of Envirorwental Conservation

Recipient: toesch, Donald: Brady-Stannard fluto Coipany

Docuaent Nuaber: BRE-OC1-1793 To 1793 Parent: BRE-«1-1924 Date: 81/26/79

Title: (Letter regarding waste disposal operations at the facility)

Type: CORRESPONDENCECondition: INCOMPLETE

f iuthor: fcnfredi, Cesare J: NY Dept of Environmental CorservationRecipient: Hoesch, Donald: Brady-Stannard Auto Company

Document Number: BRE-W1-1794 To 1795 Parent: BRE-88H824 Date: 81/38/79

Title: (Letter regarding steps to be taken to improve waste disposal operations at the facility)

Type: CORRESPONDENCEAuthor: Prentiss, John H: Brady-Stannard Auto Company

Recipient: Kanfredi, Cesare J: NY Dept of Environmental ConservationCo

: Bflf-«:-17% Pare t: Dare: 82/21/73

Title: (Letter regarding steps taken to improve waste disposal operations and requesting officialclearance)

Type: CORRESPONDENCECondition: HISSING ATTAWOT

Author: Prgr.tiss, John H: Brady-Stannard Auto CompanyRecipient: fcr.fredi, Cesare J: NY Dept of Environmental Corservation _

DocuKnt Nuiber: BRE-W1-1796 To 1738 Parent: HE-Ml-lttA

Title: (Letter acknowledging corrective action taken at the facility)

Type: CORRESPONDENCEAuthor: Mar.fredi, Cesare J: NY Dept of Environmental Conservation

Recipient: Noesch, Donald: Brady-Stannard Auto Coipany

Date: 83/23/79

Document Nuiber: BRE-98I-W22 To 8628 Date: el/el/el

'itle: Village of Brenster Water Supply Investigation and Spray Aeration Tests Progress Report -Review of Existing Water Quality Data

Type: PLANCondition: INCOMPLETE

Author: re'*: Nathan L Jacobson ( AssociatesRecipient: ncr*: nor*

Date: 86/23/81DocuKnt Kuaber: m-m-WH To 8036

Title: K^i!t^ Center Final Reports (for lab saiples)

Type: DCTfiCorxJition: ILLEGIBLE

Author: Knapp, D: NY Dept of HealthRecipient: nor«: NY Dept of Environmental Conservation

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Title: (Site s^mary and) Documentation Records for Hazard Ranking Systw

Type: PLANAuthor: none: US EPfl

Recipient: none: none

Date: 07/81/83

DocuMnt Nuiber: BRE-WJ-1229 To 127S

Title: Reuedial Investigation/Feasibility Study Quality Assurance Project Plan

Type: PLflNAuthor: Sushue, John J: GHR Engineering

Recipient: none: NY Dept of Environmental Conservation

Date: 85/89/85

Dccuoent Nusber: BRE-8C1-1W7 To 1466 Parent: BRE-W1-1406

Title: Detailed Work ard Site Operations Plan Remedial Investigation

Type: PUWAuthor: none: 6HR Engineering

Recipient: none: NY Dept of Envircnaental Conservation

Date: 87/81/85

Docuoent Nuiber: BRE-W1-87&5 To 8S45 Parent: BRE-481-8688

Title: Focused Exposure and Risk Assesswnt for the Well Fields in Brewster NY

Type: PLflNAuthor; rcrc: Eradient Corporation

Recipient: ncre: GHR Er.girteering

Date: 85/38/86

Document Nuaber: BRE-091-8847 To 8879 Parent: BRE-081-8688 Date: 86/81/86

Title: Brewster Well Field Siwary of Health and Environwntal Effects for Thirteen Compounds

Type: PLflNAuthor: nor*: Szepatowski Associates (SAD

Recipient: none: none5

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"xumer.t Nuiber: BRE-«i-i£7£ To 1382 —- — ~ —~ -=ar>--- Date: 66/01/86

Title: Final Focused Feasibility Study - Air Stripping and Alternatives for VHC Removal

Type: PLANAuthor: nor*: 6HR Engineering

Recipient: none: NY Dept of Environmental Conservation

Document Number: BRE-W1-6608 To 6747

Title: Final Feasibility Study Report Brewster Uell Field Site Volume I

Type: PLANAuthor: none: 6HR Engir«eririg

Recipient: ncne: NY Dept of Environmental ConservationAttached: BRE-OC1-8748 BRE-W1-&765 BRE-W1-0847 BRE-«61-«882

Date: 67/81/88

Document Number: BRE-M1-1624 To 128

Title: Remedial Investigation Report Voluie I

Date: 67/01/86

Type: PLANAuthor: none: 6HR Engi riser ing

Recipient: ncne: NY Dipt of Environmental ConservationAttached: BRE-W1-1469 BRE-W1-1473 BRE-W1-1792 BRE-«1-1793 BRE-W1-1794 BRE-W1-1796 BRE-W1-1798

Document Nuiber: BRE-W1-1469 To 1799 Parent: BRE-WHK4

Title: Remedial Investigation Report Volume II: Appendices

Type: PLANAuthor: none: 6HR Engineering

Recipient: nor*: NY Dept of Environmental Conservation

Date: 07/01/86

Document Number: BRE-W1-1473 To 1531 Parent: BRE-W1-1K4 Date: 07/61/86

Title: Report on Preliminary Two-Dimensional 6round*ater Model ing for the Brewster Uell Field SiteNith Reconoendations

Type: PLANAuthor: Hare, Paul Uillian: Dunn Geoscience

Recipient: nor*: BUR Engir«ering

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K/23/88 _ . . _ Draft Index Chronological Order. _ _ , - _ . . _ ____ . _ PJJB; 5-.._.~ " ~ ——————— - - - _.. _ _

-- Document Norier: BRE-«ei-8882 To 18&e Parent: cR£-«i-CSW Date; 87/28/oc ~~

Title: Repeat and Mdendua on Three-Dimensional Groundwater Flow and Transport Modeling for the Brewsterfell Field Site " - . . . - — .

Type: P1J«Author: Hare, Paul Uillias: Dunn Geoscience

Recipient: none: GHR Engineering

Docunnt Number: BRE-881-8598 To 8599 Date: 88/01/86

Title: (Brewster Uellfield Superfund Site Information Sheet inviting public cownts and announcinga public Keting to be held ea/£l/8&)

Type: CORRESPONDENCEfluthor: Eberle, Uilliai F: NY Dept of Environmental Conservation

Recipient: nor>e: nor*

Document NLsber: BRE-M1-«5A3 To 8597 Date: 89/3C/86

'itle: Record of Decision Remedial Alternative Selectionr>

Type: LESflL DOCUMENTAut^or: Daggett, Christopher J: US EPS

Recipient: none: none

Docusent Nuaber: BRE-W51-K45 To 8273 Parent: BRE-881-8211 Date: 04/27/87

Title: Site-Specific Health and Safety Plan

Type: PLANAuthor: BirnbauE, Leslie: Ebasco Services

Recipient: ncre: US EPft

Docunent kumber: BRE-W1-O9 To 8469 Parent: BRE-881-8211 Date: 87/81/87

Title: Field Operations Plan - Supplenental Remedial Investigation/Feasibility Study

Type: PLANAuthor: Verdibello, Mario S: Ebasco Services

Recipient: none: US EPA

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30

J9/83/88 ._ -- -----—___JraftJatex Chronological Jfrdar

DocuBtrt Ifcsaer: BRE-W1-E14 To 8228 Parent: BRE-«l-«2ll Dates 67/81/87

Title: Site Xanagevent Plan - Supplemental Rewdial Investigation/Feasibility Study

Type: PLANAuthor: Verdibello, Mario 5: Ebasco Services

Recipient: none: US EPA

Docuier.t >U£>er: BRE-W1-K22 To 82*3 Parent: BRE-W1-K11 Date: 87/81/87

Title: Field Sampling arid Analysis Plan - Remedial Investigation/Feasibility Study

Type: P_AKAuthor: S«yres, Mindy: Ebaseo Services

Recipient: rcre: US EPA

Docuaent NuKer: BRE-W1-8A71 To 85« Parent: BRE-W1-8A73 Date: 87/81/87

Title: Final Supplemental fieoedial Investigation/Feasibility Study Uorkplan

Type: ?JWAuthoi". Verdibello, Kario S: Ebasco Services

Recipient: rcne: US EM

Docuient Niaoer: BRE-W1-K11 To 8218 Date: 87/14/87

Title: (Letter fonwrding Final Field Operations Plan)*

Type: CORRESPONDENCEAuthor: Stchdev, Dev R: Ebasco Services

Recipient: Plvi, M Shahieer: US EPAAttached: PS-Wl-teW BRE-W1-B2U BRE-W1-8222 BRE-M1-8245

Docuwnt Nut«r: BRE-W1-8473 To 8A75 Date: 87/14/67

Title: (Letter forwarding Final Uork Plan - Supplemental RI/FS)5

Type: CORRESPONDENCE ft

Author: Sachdev, Dev R: Ebasco ServicesRecipient: PIvi, M Shaheer: US EPA o

Attached: ESJE-W1-847I *""\jCo/—i

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83/23/&S . .—— Draft Index Chronological Order - - - - -——— Pays 7 -——- ~~ -——•—'" MWSTER HELLHBJ Documents ~~ -^——r^=-.—:....._. -" — —-—=——

Document Number: BRE-W1-1954 To 2283 "" ' - - - - - - - - --- Date: 88/81/87

Title: SroynoVater Management Syste* Remedial Design Specificaitons and Soil Borings

Type: PUWRuthor: Verdibello, Hario S: Ebasco Services

Recipient: none: none

Docuwnt Nuiber: BRE-M1-1486 To I486 Date: 83/23/87

Title: (Letter forwarding the first operable unit ttorkplan for the RI/FS)

Type: CORRESPONDENCERuthor: Eberle, Uilliai F: NY Dept of Environmental Conservation

Recipient: Uing, Robert: US EPRfittached: BRE-W1-1487

Docuwnt Nucber: BRE-Ki-1958 To 1953 Date: 11/81/87

Title: (EPfi Fact Shieet Superfund Update titled: EPR to Conduct Supplemental Investigation)

Type: CORRESPONDENCERuthor: Funcia, Isabel: US EPR

Recipient: none: nor*.

Document Nuaber: BRE-801-8182 To 8288 Parent: BRE-ttl-8185 Date: 82/81/88

Title: Final Comunity Relations Plan for the Brewster Uell Field Site

Type: PLPKRuthor: Verdibello, Hario S: Ebasco Services

Recipient: nor*: US EPR

Docuwnt Nuiber: BRE-QCi-1938 To 1949 Date: 82/81/88

Title: (Blueprints relating to) Reoedial design of Groundwater Nanagenent Facilities for BrewsterUell Field Site

Type: GRAPHICRuthor: Verdibello, Kario S: Ebasco Services

Recipient: none: US EPR

03/c3/S6 " Draft Index Chronological Order"" __~ j_; ___ Page: 8— - - ' " ' " ~ ~ " ~

Dacuw.. M-sser: ESE-K1H5185 Toe- i f i

Title: (Letter forwarding Final Cowunity Relations Plan)

Type: CCRRESPONDENCEflutter: Sart-.dev, Dev R: Ebasco Services

Recipient: Johnson, Lill ian D: US EPfl

Docuient Nustsr: BRE-M1-M37 To C181 Parent: BRE-801-W39 Date: 93/01/BB

Tit le: Fir*1. Supplemental Remedial Investigation Report

Type: PL*1

fluthor: Verdibello, Baric S: Ebasco ServicesRecipient: ncr.e: US EPfl

Docuaer.t Nuaber: BRE-831-2284 To 2212 Date: e3/ei/8fl

Title: Health arid Safety Requireaerits (Proposed for Contractors)

Type: CTHERflat tor: rcr*: riorii

Rscipierit: ncr*: none

DocuNnt Nuiber: BRE-W1-W39 To K48 Date: 83/21/88

Title: (Letter forwarding Fir^l Suppleaental Remedial Investigation Report)

Type: CCKRESPONDDCEf iuthor: Sachdev, Dev R: Ebasco Services

Recipient: fllvi, H Shaheer: US EPflPttachEd: BRE-W1-W27

Docuaer.t NuEber: BRE-K1-18N To 1885 Parent: BRE-W1-1801 Date: 67/81/88

Title: Final Suppleaental Feasibility Study Report

Type: PUW *Condition: DRflFT M

Ruthor: Verdibello, Kario S: Ebasco ServicesRecipient: nor*: US EPfl §

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_ K/23/8B .._.-- WtHSTER ttUJ-ltiJ

DocwK-t Kufbe-: WE-K1-1886 T? ISZ7

Title: Fir*; S^ppleeerital Risk Assessment

Type: PLANfigthor: Verdibello, Kario S: Ebasco Services

Recipient: ncrs: US EPfl

Parent: BRE-W1-1B88 Date:

Document Number: BRE-W1-1881 To 1882

Title: (Letter forMarding Final Supplemental Feasibility Study)

Type: CORRESPONDENCERatter: Sactidev, Dev R: Ebasco Services

Recipient: ftlvi, K Shaheer: US EPflattached: BRE-W1-18W

Date: 87/27/88

DocuMnt Nuiber: 8RE-M1-18&8 To 1889

Title: (Letter forMarding Final Supplemental Risk Assessment)

Type: CORRESPONDENCE-" Author: Sactidev, Dev R: Ebasco Services

Recipient: fllvi, H Shaheer: US EPfifittachetJ: BRI-W1-18K

Date: 87/27/88

Docuaent Nuiber: BRE-Ml-22% To 2381

Title: (EPS Superfund Update re Proposed Remedial Action Plan for site)

Type: CORRESPONDENCEAuthor: Uir.g, Robert: US EPA

Recipient: nor*: none

Date: 88/81/88

Docuaent Nuster: BRE-K51-2213 To 2295

Title: (Transcript of public meeting re site RI/FS)

T>pr: LEBftL DOCUMENTauthor: Levinson, Debra: AM Court Reporting

Recipient: nor*: none

Date: 88/31/88

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TITLE: SAMPLING DATA FOR BREWSTER WELL FIELD SITE-Samples taken during August and September 1987

AVAILABLE AT: EBASCO SERVICES INCORPORATED160 Chubb AvenueLyndhurst, New Jersey 07071

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