sdms document 112250 racii

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SDMS Document

112250

viSISl Contract No. 68-W-98-210

RACII

Remedial Response, Enforcement Oversight and Non-time Critical Removal Activities a t Sites of Release or Threatened Release of Hazardous Substances in EPA Region II

O D I v l Federal Programs Corporation A Subsidiary of Camp Dresser & McKee Inc.

in association with TAMS

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RESPONSE ACTION CONTRACT FOR REMEDIAL RESPONSE, ENFORCEMENT OVERSIGHT,

CRITICAL REMOVAL ACTIVITIES AT SITES OF RELEASE OR THREATENED RELEASE OF HAZARDOUS SUBSTANCES

IN EPA REGION II

FINAL WORK PLAN VOLUME I

HITEMAN LEATHER CO. REMEDIAL INVESTIGATION /

FEASIBILITY STUDY WEST WINFIELD, NEW YORK

Work Assignment No. 032-RICO-02CG

U.S. EPA CONTRACT NO. 68-VV-98-210 Document Control No.: 3220-032-PP-WKPN-01454

September 11, 2000

Prepared for: U.S. Environmental Protection Agency

290 Broadway New York, New York 10007-1866

Prepared by: CDM Federal Programs Corporation

125 Maiden Lane, 5th Floor New York, New York 10038

This document has been prepared for the U.S. Environmental Protection Agency under w Contract No. 68-W-98-210. The material contained herein is not to be disclosed to, discussed o with, or,made available to any person or persons for any reason without prior expressed Q approval of a responsible official of the U.S. Environmental Protection Agency. '^

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" w m V I Federal Programs Corporation A subsidiary of Camp Dresser d McKee Inc.

I I I I I I

I I I I I I I I I

consulting

engineering

construction

operations

125 Maiden Lane

5th Floor

New York, New York 10038

Tel: 212 785-9123 Fax:212 785-6114

September 11,2000

Mr. Fernando Rosado Project Officer U.S. Environmental Protection Agency 290 Broadway-18* Floor New York, NY 10007-1866

Mr. Jack O'Dell Remedial Project Manager U.S. Environmental Protection Agency 290 Broadway - 20* Floor New York, NY 10007-1866

PROJECT: RAC II Contract No.: 68-W-98-210 Work Assignment No.: 032-RICO-02CG

DOC. CONTROL NO.: 3220-032-PP-WKPN-01454

SUBJECT: Final Work Plan, Volume I & Negotiated Work Plan, Volume II Hiteman Leather Co. Remedial Investigation/Feasibility Study West Winfield, New York

Dear Mr. Rosado and Mr. O'Dell:

CDM Federal Programs Corporation (CDM Federal), on behalf of our entire RAC II Team, is pleased to submit this Final Work Plan, Volume I & Negotiated Work Plan Volume II, for the Remedial Investigation/Feasibility Study the Hiteman Leather Co. Site in West Winfield, New York. The Negotiated Work Plan, Volume II is based on a negotiation meeting conducted with EPA on August 15, 2000.

If you have any questions regarding these work plans, please contact me at your earliest convenience at (212) 785-9123.

Very truly yours,

CDM FEDERAL PROGRAMS CORPORATION

Robert D. Goltz, P.E. RAC II Program Manager

RDG/md Enclosure

cc: D.Butler, EPA Region II J. Litwin, CDM Federal B. Irons, CDM Federal

p. Philip, CDM Federal RAC II Document Control

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RESPONSE ACTION CONTRACT FOR REMEDIAL RESPONSE, ENFORCEMENT OVERSIGHT,

CRITICAL REMOVAL ACTIVITIES AT SITES OF RELEASE OR THREATENED RELEASE OF HAZARDOUS SUBSTANCES

IN EPA REGION II

REMEDIAL INVESTIGATION / FEASIBILITY STUDY

HITEMAN LEATHER CO. WEST WINFIELD, NEW YORK

Work Assignment No. 032-RICO-02CG

FINAL WORK PLAN VOLUME I

1 U.S. EPA CONTRACT NO. 68-W-98-210

Document Control No.: 3220-032-PP-WKPN-01454 September 11, 2000

Prepared by:

Site Manager

Date: ^ i / \ i U o

Reviewed by: %\Wiiy

JeaMe Litwin, REM RAC n Technical Operations Manager

Date: ^ I l l l o O

Approved by:

i Date: . ^ [ 4 . f ? ^

Robert D. Goltz, P.E. RAC n Program Manager

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HITEMAN LEATHER Remedial Investigation/Feasibility Study

Draft Work Plan Volume I

Table of Contents

1.0 Introduction 1-1 1.1 Overview of the Problem 1-1 1.2 Approach to the Development of the Work Plan 1-2 1.3 Work Plan Content 1-3

2.0 Site Background and Setting 2-1 2.1 Site Location 2-1 2.2 Site History 2-1 2.3 Current Conditions 2-4

3.0 Initial Evaluation 3-1 3.1 Review of Existing Data 3-1

3.1.1 Topography, Drainage, and Surface Water Quahty 3-1 3.1.2 Geology and Hydrogeology 3-3

3.1.2.1 Regional Geology and Hydrogeology 3-3 3.1.2.2 Site-specific Geology and Hydrogeology . . 3-5

3.1.3 Climate 3-10 3.1.4 Population and Land Use 3-10 3.1.5 Characteristics of Chemical Contaminants 3-11

3.1.5.1 Summary of Soil and Sediment Samphng 3-11 3.1.5.2 Summary of Surface Water Sampling 3-14 3.1.5.3 Summary of Groundwater Samphng 3-15

3.2 . Preliminary Identification of Apphcable or Relevant and Appropriate Requirements (ARARs) 3-16 3.2.1 Definition of ARARs 3-17 3.2.2 Consideration of ARARs During the RI/FS 3-18 3.2.3 Preliminary Identification of ARARs andTBCs . . . . 3-19

3.2.3.1 Chemical-specific ARARs ' : . . . 3-20 3.2.3.2 Location-specific ARARs 3-20 3.2.3.3 Action-specific ARARs 3-21 3.2.3.4 To Be Considered Cntena . . . 3-23

3.3 PreHnunary Human Health Risk Assessment 3-24 3.3.1 Potential Chemicals of Concern 3-24 3.3.2 Potential Source Areas and Release Mechanisms 3-25

3.3.2.1 Surface Soil Pathway 3-25 3.3.2.2 Subsurface Soil Pathway 3-25 3.3.2.3 Groundwater Pathway ' 3-25 3.3.2.4 Surface Water/sediment Path.way 3-26

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Table of Contents

3.3.3 Summary of Additional Data Needs 3-26 3.4 Preliminary Ecological Risk Assessment 3-26 3.5 Preliminary Identification of Remedial Action Alternatives 3-26 3.6 Need for Treatability Studies 3-26

4.0 Work Plan Rationale 4-1 4.1 Data Quahty Objectives 4-1 4.2 Work Plan Approach 4-1

5.0 Task Plans 5-1 5.1 Task 1 - Project Planning and Support 5-1

5.1.1 Project Administration 5-1 5.1.2 Attend Scoping Meeting 5-2 5.1.3 Conduct Site Visit 5-2 5.1.4 Develop Draft Work Plan and Associated Cost Estimate 5-2 5.1.5 Negotiate and Revise Draft Work Plan/budget 5-3 5.1.6 Evaluate Existing Data and Documents 5-3 5.1.7 Quahty Assurance Project Plan 5-3 5.1.8 Health and Safety Plan 5-4 5.1.9 Non-RAS, Analyses 5-4 5.1.10 Meetings : . . . 5-5 5.1.11 Subcontract Procurement 5-5 5.1.12 Perform Subcontract Management.- 5-6 5.1.13 Pathway Analysis Report . 5-6

5.2 Task 2 - Community Relations 5-7 5.2.1 Community Interviews 5-7 5.2.2 Community Relations Plan 5-7 5.2.3 Pubhc Meeting Support 5-8 5.2.4 Fact Sheet Preparation 5-8 5.2.5 " Proposed Plan Support 5-8 5.2.6 Public Notices 5-8 5.2.7 Information Repositories 5-9 5.2.8 Site Mailing List 5-9 5.2.9 Responsiveness Summary Support 5-9

5.3 Task 3 - Field Investigation 5-9 5.3.1 Site Reconnaissance 5-11 5.3.2 Mobilization and Demobilization '. 5-12

. 5.3.3 Hydrogeological Assessment ' 5-13 5.3.3.1 Momtonng Well Installation 5-13

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Table of Contents

5.3.3.2 Groundwater Elevation Measurements 5-14 5.3.3.3 Slug Testing 5-14 5.3.3.4 HydrauHc Testing 5-14

5.3.4 Soil Boring, DriUing, and Testing 5-15 5.3.4.1 Soil Bonngs 5-15 5.3.4.2 Lagoon Soil Borings 5-16 5.3.4.3 Building Borings 5-17 5.3.4.4 Test Pit Program 5-18 5.3.4.5 Unadilla River Geotechnical Borings 5-18

5.3.5 Environmental Sampling 5-19 5.3.5.1 Surface Water and Sediment Sampling 5-19 5.3.5.2 Wetland Sediment Soil Samphng 5-21 5.3.5.3 Surface Spil Sampling 5-22 5.3.5.4 Groundwater Sampling 5-22 5.3.5.5 Fish Collection .. . .- 5-23

5.3.6 Ecological Characterization . ; 5-24 5.3.6.1 Characterization of Wildhfe Habitat/usage 5-24 5.3.6.2 Wetland Delineation 5-25 5.3.6.3 Assessment of Wetland Functions and Values 5-25 5.3.6.4 Identification of Endangered and Special Concern Species . . . 5-25

5.3.7 Geotechnical Survey 5-25 5.3.8 Disposal of Field Generated Waste 5-25

5.4 Task 4 - Sample Analysis 5-26 5.4.1 Innovative Methods/field Screening Sample Analysis 5-26 5.4.2 Analytical Services Provided via CLP, DES A or EPA-ERT 5-26 5.4.3 Subcontractor Laboratory for Non-RAS Analyses 5-26

5.5 Task 5 - Analytical Support and Data Validation 5-26 5.5.1 Collect, Prepare and Ship Samples 5-26 5.5.2 Sample Management 5-27 5.5.3 Data VaUdation 5-27

5.6 Task 6 - Data Evaluation 5-27 5.6.1 Data Usability Evaluation '. 5-28 5.6.2 Data Reduction, Tabulation and Evaluation 5-28 5.6.3 Modeling , 5-29 5.6.4 Technical Memorandum 5-30^

5.7 Task 7. - Assessment of Risk 5-30 5.7.1 Baseline Risk Assessment (Human Health) 5-30

5.7.1.1 Draft HLiman Health Risk Assessment Report 5-31 5.7.1.2 Final Human Health Risk Assessment 5-38

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Table of Contents Section Page

5.7.2 Ecological Risk Assessment 5-38 5.7.2.1 Draft Screening Level Ecological Risk Assessment Report . . 5-38 5.7.2.2 Final Ecological Risk Assessment Report 5-40

5.8 Task 8 - Treatabihty Studies/Pilot Testing 5-41 5.9 Task 9 - Remedial Investigation Report . 5-41

5.9.1 Draft Remedial Investigation Report 5-41 5.9.2 Final Remedial Investigation Report 5-41

5.10 Task 10 - Remedial Alternatives Screening - FS 5-41 5.10.1 Technical Memorandum 5-44 5.10.2 Final Technical Memorandum 5-44

5.11 Task 11 - Remedial Alternatives Evaluation 5-44 5.11.1 Draft Technical Memorandum 5-46 5.11.2 Final Technical Memorandum 5-46

5.12 Task 12-Feasibility Study Report 5-46 5.12.1 Draft FS Report 5-46 5.12.2 Final FS Reports 5-47

5.13 Task 13 - Post RI/FS Support 5-47 5.14 Task 14 - Negotiation Support 5-48 5.15 Task 15 - Administrative Record 5-48 5.16 Task 16 - Project Closeout 5-48

5.16.1 Work Assignment Closeout Report 5-48 5.16.2 Document Indexing 5-48 5.16.3 Document Retention/Conversion 5-48

6.0 Costs and Key Assumptions 6-1

7.0 Schedule 7-1

8.0 Project Management Approach 8-1 8.1 Organization and Approach 8-1 8.2 Quality Assurance and Document Conlro) 8-2 8.3 Project Coordination 8-3

9.0 References 9-1

10.0 Glossary of Abbreviations 10-1

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HITEVL^N LEATHER Remedial Investigation/Feasibility Study


Table of Contents

LIST OF TABLES

2-1 Chronology of Events

2-2 Tannery Process Chemicals

3-1 Analytical Results of Soil and Sediment Samples with Chromium X-ray Fluorescence Concentrations Greater than 10,000 mg/kg and Laboratory Concentrations Greater than 1,000 mg/kg

3-2 Summary of Analytical Results of Target Analyte List Metals in Soil and Sediment

3-3 Summary of Analytical Results of VOCs in Soil

3-4 Summary of Analytical Results of SVOCs in Soil and Sediment

3-5 Analytical Results of Target Analyte List Metals in Water Samples

3-6 Analytical Results of Chromium in Groundwater

3-7 Summary of Anaytical Results of VOCs in Groundwater

3-8 Potential Chemicals of Concerns

4-1 Summary of Data Quality Levels Appropriate to Rf/FS Uses

5-1 Summary of Sampling and Analysis Program

5-2 Summary of Fish Sampling and Analysis Program

5-3 Proposed RI Report Format

5-4 Proposed FS Report Format

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Table of Contents

LIST OF FIGURES

1-1 Site Location Map

1-2 Site Features Map

3-1 General Glacial Stratigraphy

3-2 Existing Monitoring Well Locations

3-3 Groundwater Flow Map

3-4 Previous Soil and Sediment Sampling Locations

5-1 Proposed Sampling Locations

7-1 Project Schedule

8-1 Project Organization

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1.0 INTRODUCTION

CDM FEDERAL PROGRAMS CORPORATION (CDM Federal) and TAMS Consultants (the RAC n Team) received work assignment number 032-RICO-02CG under the United States Environmental Protection Agency (EPA) Response Action Contract (RAC H) program to perform a Remedial Investigation/Feasibility Study (RI/FS) for the Hiteman Leather Company Site in West Winfield, Herkimer County, New York. The overall purpose of this work assignment is to investigate the nature and extent of contamination of site-related contamination and develop and evaluate remedial alternatives.

1.1 OVERVIEW OF THE PROBLEM

The Hiteman Leather Company Site is a former leather tanning facility located in West Winfield, Herkimer County, New York. Figures 1-1 and 1-2 provide site location and site maps, respectively. The site is approximately 14 acres and consists of the foundations of fonner factory buildings, a former wastewater lagoon area, a two-acre wetland, and a section of the Unadilla River. Two small buildings still remain on site, one of which is utilized by the Village of West Winfield Department of Public Works.

The Hiteman Leather Company operated at the site from 1820 until the plant closed in 1968. During the time the tannery operated, the leather manufacturing process underwent several major changes. The raw ingredients used during the tanning process evolved from vegetable-based (tree bark) products to mineral-based products (chromium salts) and acid solutions. However, during this time no significant changes were made in the on-site treatment and disposal of the process wastewater (tannery and beam house waste).

Prior to 1959, the tannery wastewater flowed sequentially through two unlined settling lagoons, with the final effluent flowing into the Unadilla River or into the adjacent wetlands and then into the river. The settled solids in the lagoons were periodically excavated and deposited as bank material surrounding the lagoons.

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In August 1959, a fish kill occurred in the Unadilla River near the site. This was attributed to the overflow of toxic substances from the two site lagoons. Following the incident, the lagoons were dredged and a third lagoon was added.

Historical records indicate that in 1964 the tannery was discharging daily as much as 180,000 gallons of wastewater. The tannery closed in 196,8 because of its inability to cost-effectively upgrade wastewater treatment. The lagoons were backfilled at that time and the site has been inactive since, with the exception of the intermittent use of the remaining two small building, as mentioned above.

In 1983, hmi ted soil and sediment sampling within the lagoon areaat the rear of the facility buildings and along the river was conducted by the New York State Department of Environmental Conservation (NYSDEC). Analytical data revealed elevated levels of 15 heavy metals including

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chromium, copper, lead, mercury, nickel, arsenic, and cadmium. In 1985, the site was added to the New York Slate (NYS) List of Inactive Hazardous Waste Disposal Sites. Subsequently, an RI/FS was conducted by NYSDEC from 1988 to 1992 (NYSDEC, 1992). NYSDEC subsequently referred the site to the EPA in 1993 for a possible removal action.

A Site Investigation (SI) was conducted by the EPA Environmental Response Team (ERT) in 1996 that documented the presence of high-levels of chromium in the lagoon area and other site media including groundwater and Unadilla River surface water and sediment (EPA, 1997).

The Site was proposed for the National priorities List (NPL) in September, 1998 and was subsequently listed on the NPL on January 19, 1999.

1.2 APPROACH TO THE DEVELOPMENT OF THE WORK PLAN

The RAC 11 Team has reviewed all available information on the site (provided by EPA) prior to formulating the scope of work presented in this work plan. Section 9.0 provides a list of all documents reviewed and referenced in the development of this work plan. The RI/FS for Hiteman Leather will be completed in three phases: a remedial investigation (RI); a risk assessment (RA); and a feasibihty study (FS).

The RI will focus on collecting adequate soil, groundwater, surface water, and sediment data to fully characterize the nature and extent of site-related contamination and to identify potential areas of contamination. The sampling approach is discussed in Section 5.0. A Quality Assurance Project Plan (QAPP) detailing sample and analysis requirements for the field investigation program and a Health and Safety Plan will be submitted separately. The RI report will provide a complete evaluation of sampling results.

A RA will be completed for the Site that will evaluate the public health and ecological risk from exposure to contaminated groundwater, surface water, sediment, and soil. The RA will be conducted according to EPA's "Risk Assessment Guidance for Superfund" (Part A 1989 and Part D, 1998a) or according to the most recent EPA guidance and requirements. The risk assessment also will include a list of contaminants of concern (COC); human toxicology of COCs; transport, degradation, and fate analysis of COCs; comparison of COCs found in the various media to Applicable or Relevant and Appropriate Requirements (ARARs); and determination of risk.

A FS will be completed in accordance with EPA guidance under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). "Interim Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA" (EPA, 1988), or the most recent EPA FS,guidance docufnent will be used as guidelines. The FS will develop and screen remedial alternatives and provide detailed,analysis of selected alternatives, including the "No Action", alternative. The remedial alternatives will be evaluated against the nine criteria required by EPA guidance documents: (1) overall protection of human health and the environment; (2) compliance with ARARs; (3) long term effectiveness and permanence; (4) reduction of toxicity, mobility, or

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volume through treatment; (5) short term effectiveness; (6) implementability; (7) cost; (8) state acceptance; and (9) community acceptance.

Data already exists for the Hiteman Leather Company Site. The RAC II Team has reviewed and evaluated the quality and completeness of the existing data and intends to use these data where appropnate. Data collection activities identified in this work plan are directed toward verification of existing data (when necessary); collection of new data to fill gaps in the existing data; and collection of data of sufficient quality and quantity to support Human Health and Ecological Risk Assessments and the FS.

1.3 WORK PLAN CONTENT

This work plan contains ten sections: -

• Sectionl.O provides an introduction to the site. • Section 2.0 describes the site background including the current understanding of the

location, history, and existing conditions of the site. • Section 3.0 presents the initial evaluation of existing data and includes a description

of the types and quantities of waste present, site hydrogeology, contaminant migration and exposure pathways, a preliminary assessment of public health and environmental impacts, and a preliminary identification of ARARs and remedial action objectives.

• Section 4.0 presents the work plan rationale including the Data Quality Objectives (DQOs) for RI sampling activities and the approach for preparing the work plan. The work plan approach also describes how Rl activities will satisfy data needs.

• Section 5.0 provides a discussion of each task of the RI/FS in accordance with the Hiteman Leather Company Site RAC II Statement of Work and the "Interim Guidance for Conducting Remedial Investigations and Feasibihty Studies under CERCLA," (EPA, 1988).

• Section 6.0 presents costs and key assumptions^ • Section 7.0 presents the anticipated schedule for the RI/FS tasks. • Section 8.0 presents project management considerations that define relationships and

responsibilities for selected tasks and project management teams. • Section 9.0 provides a list of references used to develop the material presented in this

work plan. • Section 10.0 provides a glossary of acronyms and abbreviations used in this work

plan.

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O U IVI Federal Programs Corporation A subsidiary of Camp Dresser & McKee Inc.

HITEMAN LEATHER COMPANY HERKIMER COUNTY. NEW YORK

FIGURE 1-1

SITE LOCATION MAP

PROJECT No. 3 2 2 0 - 0 3 2

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HITEMAN LEATHER COMPANY HERKIMER COUNTY, NEW YORK

FIGURE 1-2

SITE FEATURES

PROJECT No. 3 2 2 0 - 0 3 2

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2.0 SITE BACKGROUND AND SETTING

2.1 SITE LOCATION

The site, approximately 14 acres in area, is a former tannery and leather manufacturing facility located on the banks of the Unadilla River in the Village of West Winfield, Herkimer County, New York. Figures 1-1 and 1-2 show the site location and site plan, respectively. The Hiteman property includes approximately 1.8 acres of open area and wetlands to the west of the former factory; a section of the Unadilla River to the south of the former factory; and a two- acre lot south of the river. The site is bordered to the south by a small stream channel with a wetland beyond, to the east by Route 51, and to the west by the West Winfield Cemetery. Residential areas are located north of the site. '

2.2 SITE HISTORY

According to local historical documents, the West Winfield tannery (the precursor to Hiteman Leather Company) was established on the northern bank of the Unadilla River in 1820 (Smith, 1979). The first recorded owner was a Mr. Adsit who later sold the company to Rufus Wheeler in 1823. By 1884, ownership of the tannery had been transferred to C. J. Wheeler, who sold the business to Henry and John Hiteman. The leather company continued to operate and expand under the name Beckwith-Hiteman Brothers. In 1913, the name changed to Hiteman Leather Company, Inc., and remained as such until its closing in 1968. The tannery underwent several changes over the years which included the addition of a factory building in 1946. The property to the west and rear of the factory was also subsequently procured by the tannery. This area was ultimately utilized as settling basins for the tannery wastewater. Table 2-1 shows the chronology of events at the site upuntil the RI/FS in 1988.

During the mid-twentieth century, the tanning process, consisting of soaking, liming, and tanning, evolved from the use of vegetable-based (tree bark) products to the. use of mineral-based products (chromium salts) and acid solutions (EPA, 1997). In the rnodem chromium tanning processes, hides are cleaned of any remaining fatty substances prior to being soaked in a lime and sulfide solution to dissolve hair; after dissolution of the hair, the wastewater is discharged. After hair removal, hides are placed into large rotating drums and treated with ammonium salt and an enzyme followed by an acid-salt solution bath (steps known as bating and pickling, respectively). Tanning is achieved by adding chromium sulfate solution to the drums followed by mixing and soaking for up to 24 hours. Coloring of the hides may take place by transferring them to another drum containing a re-tanning solution (not chromium contaming) and a pigment dye. The coloring solution is discharged and oils are added to condition the hides prior to removal, wringing, and drying.

The change to the chromium-based process at the Hiteman Site reduced the amount of time needed to process leather, from two years to a number of weeks; however, a consequence was to produce greater volumes of process waste that was discharged to the on-site lagoons. In addition, the waste

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tanning solutions and rinse waters had become much more toxic, containing metals and acids. Table 2-2 lists common process chemicals used in mineral-based tanning.

On November 11, 1953, the Water Pollution Control Section of the New York State Department of Health (NYSDOH) completed an Industrial Waste Survey of the Hiteman Leather Company site. At this time, one-third of tanning production was vegetable-based and two-thirds of production was chrome-based. Wastewater effluent samples collected from two settling tanks (derived from the coloring process) and two settling lagoons (derived from the tan and beam houses) were collected during the inspection. Laboratory analyses of the samples indicated chromium at 23.0 parts per million (ppm) in effluent from the coloring process and chromium at 6.0 ppm in the settling lagoon overflow effluent. In addition, two water samples from the adjacent Unadilla River were collected and analyzed. A sample collected upstream of the facility did not detect chromium; however, a downstream sample detected chromium at 0.3 ppm.

Prior to 1959, the wastewater flowed sequentially through two unlined settling lagoons, with the final effluent flowing into the Unadilla River or into the adjacent wetlands and then into the river. The settled solids in the lagoons were periodically excavated and deposited as bank material surrounding the lagoons. • ' o ^

In August 1959, a fish kill occurred in the Unadilla River near the site. The fish kill was subsequently attributed to the overflow of toxic substances from the two site lagoons. Following the incident the lagoons were dredged and a third lagoon was added.

On October 11, 1960, the NYSDOH - Syracuse Regional Office, conducted an inspection of the Hiteman Leather Company facihty. According to the inspection report, a whitish discoloration was observed in the Unadilla River surface water and sludge deposits were noted in the streambed. It was also noted that odors were detected when the streambed was disturbed.

In 1964, the tannery discharged as much as 180,000 gallons of wastewater daily. The following volumes of process materials were being used daily: salt-1,930 pounds/day (Ib/d), lime-1,260 Ib/d, chrome oxide - 1,000 Ib/d,. sodium sulfide - 520 Ib/d, sulfuric acid - 1501b/d, caustic soda - 54 Ib/d, and dyes - 25 Ib/d (EPA, 1998).

In 1968, the facihty closed because of its inability to cost-effectively upgrade wastewater treatment after the NYSDOH had determined that the company was responsible for the p.ollution. The facility was abandoned, the settling lagoons were filled in, and the property was sold (NYSDEC, 1987).

On October 24, 1983, NYSDEC (Region 6) collected samples from the former Hiteman Leather Company plant for laboratory analysis. The analytical results were compared to referenced background concentrations (Smith, 1984). The results indicated that soil samples taken from the bank of the Unadilla River directly below the former lagoon area contained elevated concentrations of chromium and nickel and soil samples taken from the "disposal area" contained arsenic, cadmium, chromium, and lead at concentrations at least ten times greater than the background concentrations.

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A Phase I investigation of the Hiteman Leather Company was conducted by Recra Research, Inc. (1985), under contract to NYSDEC, to provide the information necessary to establish a potential risk score using the Hazard Ranking System (HRS). In 1985, the site was added to the New York State (NYS) List of Inactive Hazardous Waste Disposal Sites.

A RI/FS was conducted from 1988 to 1992 prepared by SAIC Engineering Inc., under contract to NYSDEC. The RI/FS included the installation and sampling of 24 monitoring wells, 10 piezometers, and 13 soil borings, and the collection of four surface water, 20 surface soil, eight wetland sediment, and 12 river sediment samples (NYSDEC, 1992).

The subsurface investigation revealed that the site is underlain by unconsohdated Recent fluvial deposits and Pleistocene glacial deposits of variable thickness. Beneath the glacial deposits, a thinly interbedded limestone and shale bedrock is encountered, likely part of the Middle Devonian Onondaga Formation. The glacial deposits consist of a sandy surficial outwash deposit, ranging in thickness from 1.5 feet (ft) on the northern edge of the site to 22 ft in the former lagoon area underlain by a fine-grained glacio-lacustrine deposit, ranging in thickness from nine feet on the southwestern side of the site to 30 ft on the northeastern portion of the site.

Fifteen "shallow" monitoring wells were installed within the surficial glacial outwash deposits screened at the water table. Seven "deep" wells were screened at unknown depths in the underlying glacio-lacustrine unit and two "bedrock" wells were installed in the underlying Onondaga Formation to monitor the bedrock aquifer. After installation, groundwater began flowing from the two bedrock wells installed south of the Unadilla River indicating they were screened in an aquifer under flowing artesian conditions. The hydrostatic head in these wells was measured at more than 11 feet above ground surface. Based on these extreme conditions, SAIC concluded that site contaminants could not have migrated into the bedrock aquifer; as such, no further bedrock monitoring well installation was proposed.

Study results documented the presence of high levels of chromium in the lagoon area soils and indicated contamination throughout the site. Hexavalent chromium was also found in the soil at low concentrations (maximum concentration detected was 4.2 ppm). Other heavy metals, pesticides, polychlorinated biphenyls (PCBs), volatile organic compounds (VOCs) and semivolatile organic compounds (SVOCs) were also detected, at lower concentrations, throughout the site in various environmental media. Based on the results of the RI/FS, NYSDEC subsequently referred the site to EPA for possible removal action.

Dunng the 1996 EPA-ERT SI, soil samples were collected from 50 on-site locations and three off-site locations (EPA, 1997). Three surface water and sediment samples were collected from one upstream and two downstream locations on the Unadilla River. The existing monitoring wells at the site were redeveloped and sampled by the EPA.

The SI results confirmed the presence of high levels of chromium in the lagoon area, in surface soils (up to 75,000 miligrams per kilogram [mg/kg]) and subsurface soils (up to 72,000 mg/kg), as well

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as in the soils in other parts of the site and in the wetlands. Elevated concentrations of chromium also were detected in surface water (33 micrograms per Liter [lJ.g/L] unfiltered; 5.7 [ig/1 filtered) and groundwater (1,000 ^ig/L). Hexavalent chromium was detected sporadically in the soil and groundwater samples. Other heavy metals, pesticides, PCBs, VOCs, and SVOCs also were detected at the site. Refer to Section 3.1.5 for presentation and discussion of the SI analytical data.

During the SI, asbestos sampling and a structural evaluafion of the facility buildings also was performed. It concluded that the main tannery building and stack were structurally unsound and that asbestos pipe covering was found throughout the buildings. At the time of the study, visible signs of erosion along the northern bank of the Unadilla were noted. It was recommended that the river bank be stabilized with rip-rap.

In 1996, an asbestos removal was conducted at the site by EPA and in 1998 the tannery building and stack were demolished by EPA. At that time, in an effort to stabilize the Unadilla River, approximately 500 ft of rip-rap was installed along the north bank.

A HRS Evaluation was conducted for the site in August 1998. Based on the 1996 SI, the site was assigned a HRS, score of 50. The Hiteman Leather Site was proposed:for NPL in September, 1998 and was subsequently listed on the NPL on January 19, 1999. -

2.3 CURRENT CONDITIONS

A site visit was conducted by RAC 11 Team personnel on March 2, 2000. Debns from the building demolition remain on site. Two buildings sfill exist at the site, including a storage garage that is maintained and operated by the Village of West Winfield Department of Public Works. The portion of the site fence that runs along the Unadilla River was noted to be damaged in several places, which potenfially could allow access to the site property.

At the fime of the site visit, while the site wetland appeared dry, a small stream was observed flowing through the area to the Unadilla River. The Unadilla River was noted to be at high stage and rapidly flowing. The existing site monitoring wells were noted to be secure and in good condifion. Water was noted to be, flowing from several monitoring wells located on the north side of the Unadilla River, between the former lagoon area and the river. All of these wells are screened in the glacial deposits, suggesting that artesian condifions may exist, at least seasonally,^ within the unconsolidated aquifer at the site.

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TABLE 2-1

CHRONOLOGY OF EVENTS HITEMAN LEATHER SITE

WEST WINFIELD, NEW YORK

Year

1820

1823

1884

1913

1946

1953

1958

1964

1967

1968

Event

First record of tannery owned by Mr. Adsit

Rufus Wheeler purchased tannery; the tannery remained in the Wheeler family for 60 years

Tannery bought by Henry and John Hiteman together with partner Ezra D. Beckwith; they expand the leather business, calling it Beckwith-Hiteman Brothers

Became known as Hiteman Leather Company, Inc.

Modem factory building added to join the old plant along the north side at a cost of about $200,000

The area to the rear (few acres) has been used for various purposes, including pasture, meadow, ball park, and a settling basin for tannery refuse water

New York State Department of Health, Industrial Waste Survey

May - Meeting with Water Pollution Control Board; Hiteman agrees to retain the services of an engineer for the purpose of upgrading waste treatment facilities

July - Permission given to postpone action until Village of West Winfield could decide on actions relative to village water pollution control; joint project with village was to be undertaken

Morell Vrooman Engineers submit preliminary report on village sewer system and sewage treatment plant

State Health officers conduct sampling for pollution by property owners of village; village judged not to be a polluter of area surface waters

Hiteman Leather terminated operations after receiving citation from the New York Department of Health as a contributor of pollution to the Unadilla River; economics prevent Hiteman Leather from construction of an adequate waste treatment facility

Earl Davis of Clinton, New York, purchased the property of Hiteman Leather

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CHRONOLOGY OF EVENTS HITEMAN LEATHER SITE


Year

1983

1984

1985

1986

1987

1988

Event

New York State Department of Environmental Conservation collected water and sediment samples from the Unadilla River; analytical results indicated elevated levels of chromium, copper, lead, mercury, nickel, selenium, silver, zinc, beryllium, antimony, arsenic, and cadmium

Proposal to construct a senior citizens housing project was abandoned due to concerns regarding potential environmental and human health hazards associated with the site

Engineering investigations at inactive hazardous waste sites in the State of New York; Hiteman Leather Company, Village of West Winfield, Herkimer County, New York, site no. 622007, prepared for New York State Department of Conservation by Recra Research, Inc.

The site is receives a hazard ranking system score of 43.98

New York State Department of Environmental Conservation conducted analysis of groundwater samples from the three village wells; analytical results do not indicate the presence of organics or metals except one sample that shows zinc at a concentration of 0.02 milligrams per liter

The New York State Department of Environmental Conservation, Division of Solid and Hazardous Waste invited five firms to submit proposals for a remedial investigation and feasibility study for the Hiteman Leather Site

GHR Engineering Associates, Inc., approved to conduct investigation

Source: SAIC Engineering, Inc., 1992. Remedial Investigation Report, Hiteman Leather Company, prepared for the New York State Department of Environmental Conservation, February.

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I TABLE 2-2

TANNERY PROCESS CHEMICALS HITEMAN LEATHER SITE


P

i

Process Chemical

Diethylamine Sulfate

Leukanol HPS

OrotanTV

Tamol N

Tamol L concentrate

Indulin A

Sodium citrate

Oxalic acid

Sodium thiosulfate

Betasol Wetting Agent OT

OroponFS

Oropon AB-SP

Sodium sulfide

Sulfide ion

Tanolin R

Hydroxyacetic acid

Sodium fiilmate

Sodium acetate

Purex Quebracho

Chemical Composition

(CH3)2NH H2S O4 (3 5 to 40%)

Napthalene sulfonic acid - formaldehyde condensate

—

Neutral naphthalene sulfonic acid -formaldehyde condensate

—

Alkaline lignin compound

Na3C6H50,.5/2H20

(COOH)2.2H20

Na^S^Oj

Sodium dioctyl sulfo succinate (75% Aguaeous)

95% (HNJ2SO + 5% enzymes

(HN4)2S04 + enzymes

62%Na2S

s -Basic chromic sulfate

CH2OHCOOH

HCOONa

CHjCOONa •

Tannin

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TABLE 2-2



Process Chemical

Slaked lime

Calcium foiniate

D-1 Oil

Quebracho

Lactic Acid (30%)

Gambade

Koreon M

Tanbark H

Upper Tan

Triton 770 concentrate

Stoddard Solvent No. 510

Kerosene

Tergitol Anionic 4

Tergitol Nonionic 7

Tergitol Anionic 08

Tergitol Anionic NP14

Tergitol Nonionic NP27

Tergitol Anionic P28

Tergitol Nonionic TMN

Tergitol Nonionic NP3 5

Tergitol Nonionic NPX

Methocel


Ca(0H)2

Ca(HC00)2

Oil

Tannin

CH3CHOHCOOH

~

Chromic sulfate

Tannin

Tannin

Alkylaryl polyether sulfate

Hydrocarbon

Hydrocarbon

—

—

C4H9CHC2H5CH2S04Na

—

~

(CsH,,)2NaP04

—

—

Methyl cellulose

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TABLE 2-2



Process Chemical

G-942

Quilon M

EmulphorEL719

SolidigenLT13

Tanigan DNLA

Blancol

Maraton H •

Maraton B

Tanak AA

TanakCNS

Tanak A

Tanak DN

Tanak MRX

Suprak 57

Suprak 58

Suprak 59

Sodium chloride

Sterizol

Sulfuric Acid

Soda Ash

Ammonium chloride


Syntan

Organic chrome, complex in isopropanol

Polyeoxyethylated vegetable oil

Cationic resinous fixing agent

Sulfonated dihydroxy diaryl sulfone -diphenoyl propane

Sodium nahthalene sulfonate - formaldehyde

~

—

Naphthalene sytan.

Naphthalene sytan

Naphthalene sytan

Naphthalene sytan

Naphthalene sytan

Phenolic syntan

Phenolic syntan

Phenolic syntan

— •

—

— •

—

Page 3 of 4

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I TABLE 2-2

TANNERY PROCESS CHEMICALS HITEIVIAN LEATHER SITE

WEST WEVFIELD, NEW YORK

Process Chemical

Titanium dioxide

Soyarich flour

Semi-sol glue


—

—

—

Source: Maselli, J.W., et. al.. Tannery Wastes, Pollution Sources and Methods of Treatinent, New England Interstate Water Pollution Control Commision, June 1958.

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3.0 INITIAL EVALUATION

This chapter presents an inifial evaluation of site condifions, and is based largely on the reports from two previous invesfigafions; specifically, the 1992 Remedial Invesfigafion Report (prepared for NYSDEC by SAIC), and the 1997 EPA ERT SI Report.

3.1 REVIEW OF EXISTING DATA

3.1.1 TOPOGRAPHY, DRAINAGE, AND SURFACE WATER QUALITY

Topography

The site is located within the Unadilla River valley, the floor of which has relafi vely low topographic, relief. West Winfield is located on the northern edge of the approximately one and one-half-mile wide Unadilla River valley which is oriented west southwest-east northeast and slopes slightly (approximately 0.28 percent slope) to the southwest in the vicinity of the Site. The river valley is bounded abrupfiy to the north and south by rolling hills with elevafions between three and five hundred feet above that of the river yalley.

In general, the topography of the Hiteman Site is flat, with a gentle southwestern slope from the northern and northeastern portions of the site on the northern bank of the river toward the on-site wetland and Unadilla River. The southern portion of the site south of the river is level. Ground surface elevafions range from approximately 1,170 to 1,180 feet above mean sea level (MSL). The site is located within a 500-year flood plain (EPA 1998).

North of the river, the site slopes gently from the northern portion of the site towards the southwestern wetland area. However, a slightly steeper grade is observed at the location of the former tannery buildings on the eastern portion of the site due to mounts of demolifion debris resfing above the original grade. The northern river bank drops steeply (between 6 to 8 ft) down to the river from grade; rip-rap has been placed along the river bank as a erosion control measure which obscures this abrupt.drop in elevafion. The area once occupied by the wastewater lagoons has no topographic expression other than small mounds and hummocks. A surface expression of a former channel leading from the northern lagoon to the wefiands, observed in historical aerial photographs, can be idenfified visually. • • '

Drainage

The Unadilla River is one of several tributaries within the Susquehanna River Basin, a major drainage basin located within the Southern Tier of New York State and eastern Pennsylvania, the Susquehanna River eventually discharges into Chesapeake Bay. The headwaters of the Unadilla River originate approximately five miles northeast of the Site in Herkimer County, at the drainage basin watershed, the groundwater divide between the Susquehanna and Mohawk river basins. The

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3.0 INITIAL EVALUATION

This chapter presents an inifial evaluafion of site condifions, and is based largely on the reports from two previous investigafions; specifically, the 1992 Remedial Invesfigation Report (prepared for NYSDEC by SAIC),'and the 1997 EPA ERT SI Report.

3.1 REVIEW OF EXISTING DATA

3.1.1 TOPOGRAPHY, DRAINAGE, AND SURFACE WATER QUALITY

Topography

The site is located within the Unadilla River valley, the floor of which has relafi vely low topographic relief. West Winfield is located on the northern edge of the approximately one and one-half-mile wide Unadilla River valley which is oriented west southwest-east northeast and slopes slightly (approximately 0.28 percent slope) to the southwest in the vicinity of the Site. The river valley is bounded abrupfiy to the north and south by rolling hills with elevations between three and five hundred feet above that of the river valley.

In general, the topography of the Hiteman Site is flat, with a gentle southwestern slope from the northern and northeastern portions of the site on the northern bank of the river toward the on-site wefiand and Unadilla River. The southern portion of the site south of the river is level. Ground surface elevafions range from approximately 1,170 to 1,180 feet above mean sea level (MSL). The site is located within a 500-year flood plain (EPA 1998).

North of the river, the site slopes gently from the northern portion of the site towards the •southwestern wefiand area. However, a slighUy steeper grade is observed at the location of the former tannery buildings on the eastern portion of the site due to mounts of demolition debris resfing above the original grade. The northern river bank drops steeply (between 6 to 8 ft) down to the river from grade; rip-rap has been placed along the river bank as a erosion control measure which obscures this abrupt drop in elevafion. The area once occupied by the wastewater lagoons has no topographic expression other than small mounds and hummocks. A surface expression of a former channel leading from the northern lagoon to the wefiands, observed in historical aerial photographs, can be idenfified visually.

Drainage t)*-

The Unadilla River is one of several tributaries within the Susquehanna River Basin, a major drainage basin located within the Southern Tier of New York State and eastern Pennsylvania, the Susquehanna River eventually discharges into Chesapeake Bay. The headwaters of the Unadilla River originate approximately five miles northeast of the Site in Herkimer County, at the drainage basin watershed, the groundwater divide between the Susquehanna and Mohawk river basins. The

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Unadilla River flows to the south-southwest through Herkimer, Madison, Otsego, and Chenango Counfies unfil its confluence with the Susquehanna River, approximately 50 miles south of the site.

Within the Unadilla River drainage basin in the vicinity of the Site, surface drainage is charactenzed by a combinafion of trellis and dendrific drainage patterns. Tributary strearris generally flow from the topographically high areas north and south of the valley towards the northeast to southwest -flowing Unadilla River. •

Local surface water runoff flows towards the North Winfield Creek and Unadilla River. The Unadilla River traverses the Hiteman Leather Company site from the Route 51 bridge at the eastern edge of the site to the outflow of the wetland area on the western side of the property. The river, at this point, turns and flows in a southerly direcfion towards the Erie-Lackawanna railroad tracks at the southern boundary of the Site. The river measures up to 50 ft wide and is of shallow depth (typically less than 3 ft). Southwest of the Hiteman property, the Unadilla River branches into several stream channels characterized by a series of meanders (NYSDEC, 1992).

In general, the river morphology is characterized by segmented riffle runs, quiescent runs, and pools. The bottom is generally characterized by large cobbles, gravels with silt, and detritus. A sediment shelf composed of gray silty material exists within the northern river bank in the western portion of the site. This shelf extends approximately 12-18 inches horizontally from the river bank into the river, then drops abruptly to the river bottom (approximately 3 ft). Rip-rap has been placed on the bank to curb erosion.

The majortributary to the Unadilla River in the vicinity of the Site is the North Winfield Creek. The North Winfield Creek, which originates in the Town of Litchfield approximately seven miles north of West Winfield, flows in a southerly direcfion towards the Unadilla River. The Unadilla River also receives recharge from the wetland area along the western portion of the Hiteman property and from' drainage from Route 51 and the area north and east of the Unadilla River. Flow data for the Unadilla River at West Winfield are not available.

Surface Water Quality

The surface water of the Unadilla River adjacent to the Hiteman property does not exhibit discolorafion other than that associated with normal biologic and sedimentologic processes. Crayfish

"and trout have been observed in the river adjacent to the property.

The nearest gaging stafion is about 19.5 miles southwest of the site, at West Berlin, New York. Average discharge at this stafion is 317 cubic feet per second (cfs) (NYSEDEC, 1992).

The Unadilla River in the Site area is classified as a "Class C(Ty' stream (6 NYCRR 17, Ch 10, Secfion 931.4 §1006). This classificafion indicates that waters are suitable for fishing and all other uses except as a source of water supply for drinking, culinary, and food processing puiposes, or for pnmary contact recreafion. The (T) represents suitable condifions for trout propagafion and fishing.

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The RAC 11 Team will obtain addifional drainage and surface water quality data during the course • of the field invesfigafion and will incorporate those data into the RI report.

3.1.2 GEOLOGY AND HYDROGEOLOGY

Regional and site-specific geologic and hydrogeologic condifions are discussed in this subsecfion.

3.1.2.1 Regional Geology and Hvdrogeoloev

Regional Geology

The Hiteman site lies within the northern portion of the Appalachian Upland physiographic province, near the bedrock divide between the Appalachian Upland and the Mohawk Lowland physiographic provinces. The site is located within a relafively thin outcrop belt of the Middle Devonian Onondaga Formafion. The formation, deposited approximately 385 to 405 million years ago, consists-of a limestone-dominated succession which is approximately 60 feet thick at its type locafion in Onondaga County, approximately 50 miles west of the Site, and up to approximately 150 feet thick in eastern and western parts of the state (Friedman, 1985). In general, the formafion has a shallow strafigraphic dip of less than 10° towards the south. The limestones of the Onondaga Formafion have been studied widely, especially by paleontologists'. The limestones are particularly well-known for coral-crinoidal reef structures that occur within the outcrop belt from Albany to the Niagara Peninsula, Ontario, as well as in the subsurface of western and Central New York and northwestern Pennsylvania (Oliver, 1954, 1976; Turner, 1977; Mesolella, 1978; Lindemann, 1979; Williams, 1980; Friedman, 1985; Brett and Ver Straeten, 1994; and Wolosz and Paquette, 1995).

The limestones of the Onondaga Formafion were deposited in a westward-transgressing, shallow enclosed northeast-trending sea which had a major connecfion to the open ocean to the southwest and a minor connecfion to the east (Lindemann and Friedman, 1987). Coral-rich limestones were deposited in shallow water along the eastern and western margins of the sea, now exposed near Albany and along the Niagara Peninsula, respecfively, where reefs flourished and thicker accumulafions of Onondaga sediments took place. The sparcity of reefal limestone accumulations in central New York, observed in outcrops (Oliver, 1976) and on Onondaga formafion thickness maps, suggest'that the water was deeper in central New York than in eastern and western parts of the state. The Onondaga Formafion deposited in central New York consists of a higher proportion fine-grained clastic sediments, such as shales and fine sandstones, that commonly are interbedded with thinner fine-grained limestone beds.

o '

The site has been subject to several periods of glaciafion during the Pleistocene, with each succeeding glacial event destroying evidence of the previous one. As a result, most of the glacial sediments that cover the site were derived almost enfirely from the last southward advance and, northward retreat of the ice sheet during the Late Wisconsin-age glacial event, which began approximately 30,000 years ago and reached its maximum southerly extent approximately 20,000

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years ago on Long Island (Caldwell and Dineen, 1987). The retreafing ice sheet deposited a series of recessional moraines, preglacial lake sediments, and outwash deposits within the valleys.

The Late Wisconsin deposits in the Upper Susquehanna River drainage basin and eastern Appalachian Plateau (in which the site is located) consist generally of lodgement fill on the valley walls and valley divides and thick stratified drift (glacial outwash deposits) along the valley floors (MacNish and Randall, 1982). Kame and kame moraines have been mapped along the valley walls in the area of the site (Cadwell and Dineen, 1987). Ice-contact or pro-glacial lakes formed in some valleys (especially in north-south trending valleys) where glacial meltwaters collected behind moraine deposits or ice dams during the northward retreat andablafion of glacier ice. These lakes created basins for the accumulafion of fine-grained glacio-lacustrine deposits. In east-west trending valleys, valley-fill deposits were composed predominantly of coarse-grained sediments commonly underlain by fine-grained lacustrine deposits. Figure 3-1 shows the generalized glacial strafigraphy of a typical east-west trending valley-fill deposits in the Upper Susquehanna River Basin, (from Reynolds and Wilhams, 1987).

Since the Pleistocene, glacial deposits have been moderately reworked and reshaped by streams to form the Recent fluvial valley floor deposits (Cadwell and Dineen, 1987). In general, the fill consists of highly compact, poorly sorted, clay to boulder size sediments deposited sub-glacially as the ice-sheet advanced across the region. The kame and kame moraine deposits consist of coarse- to finegrained gravel and sand that were deposited by meltwater adjacent to the ice margin during deglaciafion. Large volumes of sediment laden water from the melting ice were generated and created the outwash deposits which consist of well strafified fine- to coarse-grained sand and gravel. The outwash deposits tend to become finer with distance from the ice border. The glacio-lacustrine deposits that formed in the ice-contact or pro-glacial lakes generally consist of laminated siR and clay. Post-glacial streams reworked the sediments in the low-lying areas,.deposifing sediments such as channel and overbank floodplain sand, gravels and clays.

Regional Hydrogeology

The Onondaga Formafion in central New York consists of interbedded limestones, shales, and to a lesser extent sandstones. Groundwater in the bedrock aquifer occurs primarily along fractures and. joints (secondary porosity features). Joints tend to be wider and more numerous near the bedrock surface. In sandstone and shale units, the widths of the fractures and joints are typically 0.01 inch. In the lirnestone beds, which are slighfiy soluble in water, the joints and fractures may be enlarged to widths of 0.1 inch to several inches. Joints and fractures tend to become progressively narrower and more widely spaced with depth. In shale units, few openings exist at depths greater than 100 to 200 ft below ground surface (bgs); however, in sandstone and limestone units, fractures capable of yielding significant volumes of water may exist to depths of more than 500 ft bgs. The average yield of wells installed in the bedrock aquifers of the Onondaga Formafion in'the Susquehanna River basin is approximately 8 gallons per minute (gpm) (MacNish and Randall, 1982).

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Recharge to the bedrock aquifer occurs in the upland areas where little or no overburden deposits exist. Recharge can also occur from the overlying saturated deposits. The direcfion of groundwater flow in the bedrock aquifer is controlled by the orientafion of the interconnected, water-bearing joints and fractures. As a result, it is difficult to infer the direcfion of groundwater flow within the bedrock aquifer without conducting a detailed fracture orientafion study.

Valleys of the Susquehanna River Basin contain confined and unconfined strafified drift aquifers which have the potential for large temporary withdrawals of water and have been described by numerous authors, notably Hollyday (1969), Bntievetal. (1978), Randall (1977), Miller era/. (1981), MacNish and Randall (1982), VanAlstyne era/. (1982), Waller and Finch (1982), Reynolds (1987), Reynolds and Wilhams (1987), and Ballaron (1988).

Glacial deposits are variable in grain size, from silt and clay in glacio-lacustrine deposits; sand, gravel, cobbles, and boulders in glacial outwash; and clay to boulder-size particles within glacial till deposits. Storage and transmission of groundwater in the unconsolidated deposits is dependent in part on the distribufion of grain sizes. Hydraulic conducfivity values (a coefficient of proportionality describing the rate that water can move through a permeable medium) are generally greatest in the coarser-grained, well-sorted glacial outwash deposits and recently-deposited fluvial sediments.

The regional direcfion of groundwater flow in the unconsolidated aquifer, based on topography and surface water elevafions, is most likely towards the Unadilla River Valley, then southwest through the valley towards the Susquehanna River (NYSDEC, 1992)-

3.1.2.2 Site-Specific Geology and Hydrogeology

Site-Specific Geology

Bedrock Geology

Bedrock was encountered at eight locafions during the RI drilling program (NYSDEC, 1992); bedrock cores were retrieved from four borings (MW-6D, MW-lOB, MW-13D, and MW-15B). Refer to Figure 3-2 for monitoring well locafions. The depth to the bedrock ranged from approximately 43 ft at monitoring well MW-13B, at the.northern edge of the site, to 50 ft at MW-15B, one of the two abandoned bedrock wells located on the southern bank of the Unadilla River. There are not sufficient data points to adequately determine the bedrock topography, but based on the data available, it appears as if the bedrock surface slopes slighUy to the south.

The bedrock samples recovered from the cores indicate that the bedrock underlying the Hiteman property consists of a thin- to medium-bedded, dark-gray, fine-grained micritic limestone with abundant chert nodules and some bryozoan and brachiopod fossils. Minor shale partings and thin, nearly vertical fractures also were apparent in the core samples collected at the Hiteman property. Based on available published descnpfions (Ohver, 1954) and the core descripfions, the bedrock underlying the Hiteman property has been assigned to the Moorehouse Member of the Onondaga

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Formafion. The.Moorehouse Member is restricted mainly to central New York. The Moorehouse Memberis underlain by the Nedrow Lirnestone, a thinly bedded, fine-grained argillaceous limestone containing brachiopods, gastropods, and a few corals. Underlying the Nedrow Limestone is the Edgecliff Member, a limestone consisfing pnmarily of skeletal calcarenites, dominated by rugose and tabulate corals in the upper part and by brachiopods and crinoids in the lower part (Oliver, 1954). In central New York, the Edgecliff Limestone unconformably over lies the sand-dominated Lower Devonian Tristates Group, the Helderberg Limestone Group, and the Upper Silurian Salina Group, a succession of evaporific salt deposits.

Unconsolidated Surficial Deposits

Four types of unconsolidated deposits have been idenfified at the Hiteman property. The four units were idenfified following the evaluafion of soil samples collected from borings and test pits dunng the RI and include glacio-lacustrine sediments, glacial outwash sediments, fluvial sediments and artificialfill. A brief descripfion of each unit is presented below, as presented in the RI (NYSDEC, 1992).

Artificial Fill: Artificial fill extends along the western margin of the Hiteman Leather Company parking lot and the margins of the public parking area north of the property. The fill consists of concrete, wood debris, and varying amounts of glass, bricks, ashes, tile flooring and other assorted matenals.

The fill in the vicinity of the former lagoon area was of a relatively uniform consistency. In general, the lagoon fill consisted of fine- to medium-grained sand and silt with lesser amounts of clay and fine- to medium-grained gravel. Varying amounts of blue-black sludge were observed approximately four to five feet below the existing grade; A trace of boiler slag was observed in the fill overlying the sludge.at soil boring SB-3, on the western side of the lagoon area. •

Recent Fluvial Deposits : Recent fluvial sediments were idenfified near the ground surface at all locafions except where artificial fill was encountered at monitoring wells MW-3S, MW-4 (S and D) and MW-12S. The fluvial,deposits range in thickness from 3.5 feet at monitoring well MW-5D, at the southwest comer of the settling lagoons, to 10 feet at MW-IS, at the northeast comer of the former facility building. The composifion of these deposits is variable, but commonly is described as light-brown clayey-silt with some medium to fine sand and a trace of fine gravel. The main disfinguishing feature between the fluvial deposits and the fine-grained portions of the outwash deposits is that the outwash tends to contain cobbles and the fluvial deposits do not.

Glacial Outwash Deposits: Glacial outwash deposits were observed underlying the recent fluvial deposits-throughout the Hiteman property. The thickness of these deposits ranges from 1.5 feet at soil boring SB-12, at the northem edge of the site, to 22 ft at monitoring well MW-4D, at the center of the area formerly occupied by the setUing lagoons. The

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outwash is variable in cornposifion but commonly is described as light brown, coarse- to fine-grained gravel, some coarse to fine-grained sand, little silt and cobbles. In the vicinity

• . of the former lagoons the outwash consists of black, medium- to coarse-grained gravel with varying amounts of cobbles and lesser amounts of fine to coarse sand.

Giacio-Lacustrine Deposits: Glacio-lacustrine deposits were observed underlying the glacial outwash deposits in all the deep borings advanced executed on-site. These deposits, range in thickness from nine feet at monitoring well MW-1 ID, located near the south west comer of the site, to 30 ft at MW-13D, on the northeastem portion of the site, and consist of gray silty-clay with abundant darkgray clay seams and light gray silt seams. A thin layer of gray silt and sand mantles the bedrock over the northem portions of the Hiteman property. This unit is beheved to be related to the finer-grained glacio-lactistrine sediments observed in the area.

Site-Specific Hydrogeology

MacNish and Randall (1982) describe the aquifers in the vicinity of the Site. The aquifer underlying the Site is a northeast-southwest trending unconfined aquifer within the Unadilla River Valley. The aquifer is comprised of strafified outwash deposits greater than 40 ft in thickness. In the vicinity of the site, the Unadilla River is primarily a 'gaining' surface water body; that is, the vertical direcfion of groundwater flow in the shallow aquifer is upward into the river. The Unadilla River is also fed by surface water runoff and tributaries. The northem extent of this aquifer underlies the southern portion of North Winfield Creek. The unconfined valley fill aquifer becomes a buried aquifer system approximately 4,000 ft southwest of the Site. Depth to the top of this buried aquifer is reported to be greater than 200 ft bgs and underlies a fine sand, silt, and/or clay confining unit.

MacNish and Randall (1982) provide the following hydrologic data for the aquifer system in the site's vicinity:

for the unconfined aquifer underlying the Site: Aquifer Length: 12,000 ft • , Aquifer Area: 2.15 square miles Volume of Water in Storage: 17.51 billion gallons Potenfial Induced Infiltration: 10.0 million gallons per day Horizontal Hydraulic Conductivity: 100 gallons/day/square foot (4.72 x lO'^cenfimeter

per second [cm/sec])

for the buried aquifer southwest of the Site: Aquifer Length: 37500 ft Aquifer Area: 8.07 square miles Volume of Water in Storage: 4.03 billion gallons Potenfial Induced Infiltrafion: 0.0 Honzontal Hydraulic Conducfivity: 1000 gallons/day/square foot (4.72 x 10""cm/sec)

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A total of 24 monitoring wells, 10 piezometers, and three surface water stafions were established during both phases of the RI in order to determine groundwater and surface water elevations in the vicinity of the Hiteman property (NYSDEC, 1992). Fifteen, monitoring wells were installed in the shallow unconsolidated overburden aquifer (glacial outwash). Seven monitoring wells were installed in the glacio-lacustrinedeposits between the shallow unconsolidated aquifer and the bedrock aquifer.

The hydrogeologic condifions at the Hiteman Leather Company site are characterized by the existence of three hydrologic units: outwash unconfined aquifei unit, glacio-lacustrine leaky aquitard, and bedrock aquifer unit.

Outwash Aquifer

The outwash aquifer unit is an unconsolidated overburden sand and gravel aquifer which consists mainly of glacial outwash sediments overlain in some locafions by a thin veneer of recenfiy deposited fluvial sediments and artificial fill. The horizontal direction of groundwater flow in this aquifer north of the Unadilla River is generally in a southwesterly direcfion, towards the Unadilla River (NYSDEC, 1992).

Periodic water level measurements were taken from the on-site monitoring wells screened in the unconfined aquifer unit during the RI and SI field activifies. The final round of measurements were taken on June 14, 1996 (EPA, 1998). Groundwater elevafion data collected from the shallow monitoring wells and surface water level data were used to construct a water table contour map. Contours were established by interpolafion between data points assuming homogeneous and isotropic aquifer condifions (aquifer properties do not vary with location or direcfion). Figure 3-3 depicts groundwater contours derived from measurements taken on June,14, 1996. The direcfion of horizontal groundwater flow on the Hiteman property north of the river is generally from northeast to southwest, and indicates groundwater in this area discharges into the river.

The outwash aquifer groundwater elevafion data and surface water elevation data collected in November 1988, March 1989, and November 1989 from MW-8S, MW-9S, and MW-IOS (each located south of the river) indicated that the groundwater flow direcfion on the southem side of the river is to the northwest, towards the Unadilla River. However, water levels measured during an August 1991 sampling event indicated that the direcfion of groundwater flow south of the river was away from the Unadilla River towards the stream channel located along the southern boundary of the site. This may be attributed to litfie or no recharge during the dry summer months, resulfing in the lowering of the water table. Further hydrological monitoring is needed.

Giacio-Lacustrine Leaky Aquitard

The unit underlying the shallow overburden aquifer is a thin unit of fine-grained glacio-lacustrine deposits that creates a semi-confining, leaky aquitard, separating the penneable outwash aquifer deposits from the underlying bedrock aquifer. This unit is four to seven orders of magnitude less

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permeable than the shallow overburden aquifer and likely serves to confine or retard vertical flow between the bedrock aquifer and the outwash sediments. The term leaky is used to indicate that the glacio-lacustrine deposit probably transmits a small proportion of water between the aquifer units. Due to its low permeability, the leaky aquitard likely does not have a significant horizontal component of groundwater flow (NYSDEC, 1992). Instead, groundwater flow lines are more likely to be near vertical-within this semi-confining unit.

Although hydraulic conducfivity within the leaky aquitard are significanfiy lower than in the outwash aquifer unit (as described below), the glacio-lucustrine deposits are water bearing, such that the deeper overburden monitoring wells screened in the leaky aquitard are water producing. Water level measurements presented in the 1992 RI indicate the potenfiometric elevafion measured within the leaky aquitard is higher than the water table elevafion measured in the wells screened in the overlying outwash aquifer This artesian condifion suggests an upward movement of water through this unit.

Bedrock Aquifer

The bedrock aquifer below the leaky aquitard is composed of thin- to medium-bedded, dark gray, fine-grained limestone with shale partings and thin, nearly vertical fractures and joints. This aquifer is a semi-confined bedrock aquifer. During the RI, well casings were temporarily installed in two of the bedrock boreholes MW-lOB and MW-15B, located south of the river; however, artesian condifions were observed (water levels rose to approximately 11 ft above the ground surface). Cores obtained during the RI indicate that at least the upper five feet of the bedrock has a well-cemented matrix with litfie primary porosity. The occurrence of joints and fractures in the cores collected from below the cemented zone suggests that secondary porosity (porosity produced by fractures, joints and other post-diagenefic processes) most likely controls flow within the bedrock aquifer. Artesian condifions occurred in most of the wells screened in the bedrock.

Hydraulic conductivity

Hydraulic conducfivity (k) values were determined during the RI by Dunn Geoscience Corp. (Dunn), from data obtained from slug and bail tests (Dunn 1988). These tests were conducted in the shallow unconfined water table aquifer wells and wells installed in the deeper semi-confining leaky aquitard. Data were analyzed using the Hvorslev (1949) method. The hydraulic conducfivity valuescalculated from the slug test data ranged from 3.27 x 10"* to 3.56 x 10"* cm/sec (0.927 to 1010 feet per day [ft/day], respecfively). Although, the RI does not specify whether the k values are for the shallow aquifer or the leaky aquitard, the range in hydraulic conducfivifies is consistent with the variability of soil types encountered at the site (NYSDEC, 1992).

Laboratory triaxial tesfing of samples from the leaky aquitard indicates a hydraulic conducfivity of approximately 4.4 x 10" cm/sec (1.25 x 10"* ft/day) for this unit. The average hydraulic gradient determined from the August 16,1991 data is 0.002 and discharge values were 720 cubic square feet per day (ftVday) or approximately 6.23 x 10"" gallons per minute. The resulfing seepage velocity for

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August 16, 1991 is 1.77 x 10"*cm/sec (0.5 ft/day). This compares to a seepage velocity of 2.65 x 10"* cm/sec (0.75 ft/day) for November 18,1991. For the shallow unconsolidated overburden aquifer, the calculated transmissivity value is 782 square feet/day (ft"/day).

The existing hydrogeologic data presented in the RI and SI do not adequately characterize the hydraulic nature of the aquifer system underlying the site. Numerous studies of glacial valley-fill aquifer systems in the Susquehanna River Basin have highlighted their often complex nature. In addifion, predicting the potenfial groundwater flow pattems in the fractured bedrock aquifer system can be equally difficult to predict. A detailed fracture orientafion study would provide valuable data in characterizing the groundwater flow; however, at best, only an esfimafion of groundwater flow may be defined. This RI will address these data gaps.

3.1.3 CLIMATE

The climate in the West Winfield central upland New York area is typical for the northeastem North American continent and can be classified as Polar Continental. This climate is typical for alteraafing air masses of cold dry polar air and moist warm tropical air. Temperatures for the area, as represented by the 10-year climatological summary in Syracuse, range from an average minimum in January of 22.8° F to an average maximum in July of 70° F. Extreme cold and warm maximums occur from the seasonal alteration of air masses which are typical for mid-latitude locations.

Winds for the area are predominanfiy from a westerly direcfion, which is typical of those in mid-lafitude northem hemisphere locafions. Wind direcfions typically change with the alterafion of air masses, changing from a west-northwest direction in winter months to a west-southwest direcfion in the summer months. The average annual wind velocity for the area is 8.3 miles per hour (mph).

Precipitation for the area is distributed evenly throughout the year with, averaging about 41 inches. Precipitation is typically snow during the winter months, averaging 111 inches a year. The Site is located approximately 100 miles south of an area of intense snow fall created by a localized "lake effect" circulafion. Occasionally, this zone of intense snow fall moves southward to the West Winfield area, adding addifional snowfall to the average amounts. -

The RAC II Team will obtain both historic and current climate data, including, but not limited to, temperature, precipitafion, and wind speed and direcfion, from local meteorological stafions. Climafic data will be collected during the course of the field invesfigafion and will be incorporated in the Rl report.

3.1.4 POPULATION AND LAND USE

Based on the esfimates of the resident populafion of NYS villages taken from the website of the New York State Data Center, the populafion of Village of West Winfield was estimated to be 998 on July 1, 1996.

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The commercial business and government center of the village of West Winfield is centered around the intersecfion of Routes 20 and 51 (approximately 0.1 miles north of .the Hiteman property). This area was comprised of retail businesses, two small restaurants, gasoline and service stations, food stores, office space, the Village office, library, post office, fire company and numerous residences and apartments. The Village of West Winfield is currently supplied with potable water from two water supply wells located/north of Route 20, but within the village limits. The wells are approximately 0.3 miles (1,700 ft) northeast of the Hiteman facility.

A park and athlefic field is located approximately 1,200 ft east of the Hiteman Leather Company Site and south of Route 20. A water supply exploratory program was conducted within this park area in 1966.

The Erie-Lackawanna railroad extends in an east-west direcfion approximately 0.15 miles (800 ft) south of the Hiteman building. Several small industrial businesses exist further south of the Agway on Route 51. Residenfial property and farm land occupies the area further to the south.

West of the Hiteman property is the West Winfield Cemetery, and beyond the cemetery is residenfial land and farm land. Southwest of the Hiteman property is a large wetland area associated with the Unadilla River. • ,

The RAC n Team will obtain addifional up-to-date demographic data during the course pf the invesfigafion and will incorporate that data in the RI report.

3.1.5 CHARACTERISTICS OF CHEMICAL CONTAMINANTS

The inifial RI was conducted to determine the sources and distribufion of contaminafion at the Hiteman Leather Company site. Although the inifial RI provided a general characterizafion of site contaminants, a large portion of the analyfical data was rejected because of quality assurance/quality control (QA/QC) protocol violafions. A subsequent SI was conducted by EPA ERT during 1996 to further define the nature and extent of contaminafion at the site. SI acfivifies included the analysis of samples ^collected from soil, sediment, groundwater, and surface water (EPA 1997). The following secfions summarize the SI results presented in the SI report dated 1997.

3.1.5.1 Summary of Soil and Sediment Sampling

During the SI, soil and sediment samples were collected from the locafions shown on Figure 3-4. , About 200 investigative samples (not including quality control [QC] samples) were field-analyzed for chromium with an X-ray fluorescence (XRF) spectrometer and for total organic carbon (TOC) by a subcontract laboratory. Approximately 10 percent of these samples were also submitted to a Contract Laboratory Program (CLP) laboratory for analysis of Target Compound List (TCL) and Target Analyte List (TAL) parameters. These samples were also analyzed for total chromium, hexavalent chromium, and Resource Conservation and Recovery Act (RCRA) metals by the toxicity characterisfic leaching procedure (TCLP). Minor variafions in the sampling scheme (for example,

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four samples were collected for analysis of total chromi,um by CLP but not for chromium analysis by XRF) will not be discussed. The secfions below present the results of these analyses.

Chromium Results

Including QC samples, 236 soil samples for XRF analysis were collected from 50 locafions at 2-foot intervals from depths ranging from the surface to 15 feet bgs; however, the majority of samples were collected fromdepths less than 8 feet bgs. This includes four sediment samples (including one QC sample) collected from three Unadilla River locafions for chromium analysis by XRF. Concentrafions ranged from not detected (at a detecfion limit of 210 milligrams per kilogram [mg/kg]) to 75,000 mg/kg in sample Q-17-0', where "Q-17" designates the sampling locafion and "0'" designates the depth bgs in feet. Of the 236 samples, 37 had chromium concentrafions greater than 10,000 mg/kg, 115 had concentrafions up to 10,000 mg/kg, and 84 had no detected chromium: Samples with chromium concentrafions greater than 10,000 mg/kg are listed in Table 3-1 and the sampling locafions are shown on Figure 3-4. As can be seen in Table 3-1, some sampling locafions had samples with chromium concentrafions greater than 10,000 mg/kg at mulfiple depths; however, only the single sampling location is shown on Figure 3-4. Of the four sediment samples, two had no detectable chromiuin, sample UR-2 had a concentrafion of 4,200 mg/kg, and UR-3 (duplicate) had a concentration of 270J mg/kg. Sediment sampling locafion UR-1 is upgradient of the site.

Thirty-one samples were collected for analysis of total chromium and 17 for analysis of hexavalent chromium by CLP., These samples include three sediment samples and three "reference" samples that, although not stafisfically suitable for use as background, can be used for semi-qualitafive comparisons. The reference sampling locafions are not shown on Figure 3-4. Concentrations of total chromium ranged from 7 mg/kg (sample C-14-2') to 50,000 mg/kg (sample T1-M20-C-5') with 12 samples, including one sediment sample, having concentrafions greater than 1,000 mg/kg. Samples with total chromium concentrations greater than 1,000 mg/kg are listed in Table 3-1 and the sampling locafion shown on Figure 3-4. The three reference samples had total chromium concentrafions of 16, 19, and 290 mg/kg. Of the 17 samples collected for analysis of hexavalent chromium, only one sample (H-16-3.5') had detectable hexavalent chromium at a concentrafion of 4.3, mg/kg.

In general, the chromium soil results indicate three'disfinct areas of chromium contaminafion:

• In the wetland area west of the former lagoons, surface and subsurface soil samples were collected from the central portion of the wetland. Suface soil samples collected from almost every sampling locafion had XRF chromium concentrations greater than 10,000 mg/kg. The fact that surface soil samples had significantly higher concentrafions than subsurface soil samples is consistent with the former facility's pracfice of discharging wastewater to this area dunng periods of low flow in the Unadilla River. Concentrafions of chromium in subsurface soil, were significanfiy less than surface soil, but sfill elevated ranging up to 8,000 mg/kg in sample 50N-75W-4.5'. In addifion, high chromium concentrations in suface soil samples do not correspond well with higher concentrafions at depth in the same sampling location.

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Because most pf the sampling locafions were in the central portion of the wetland, the lateral extent of chromium contaminafion within and potenfially outside the wefiand is not fully known.

• The second area is the former lagoon area. Suface and subsurface samples were collected primarilly around the suspected edges of the lagoon area. Consistent with the closure of the former lagoons, which simply involved filling to grade, the highest chromium concentrafions detected are in subsurface soil at depths from 2 to 6 feet. However, almost all surface soil samples, and subsurface soil samples collected from depths between 6 feet bgs andthe terminafion of the borehole (usually 8 feet bgs) also had XRF chromium concentrafions greater than 1,000 mg/kg. Because the samples collected near the suspected edges of former lagoon area had significantly elevated chromium concentrafions, it appears that the actual boundaries of the former lagoon may be farther out than previously thought.

• The third area is north of the former lagoons. In this area, the highest concentrations of chromium were found at the surface similar to the wefiand area. It is thought that chromium in this area was deposited by overland flow when the former lagoons occasionally overflowed. However, subsurface soil samples also had XRF chromium concentrafions greater than 1,000 mg/kg.

Other smaller areas of chromium contaminafion also exist on site. One of these is the sluiceway area between the former lagoon and process building. XRF and CLP samples collected at locations Sluiceway-1, Sluiceway-2, G-26, and F-28 indicate chromium contaminafion in this area which is' likely the result of leaks and spillage from the sluice that transported wastewater from the process building to the lagoons. In addition, this contaminafion appears to be rather deep extending down to the terminal samples collected from G-26 and F-28. Also, elevated total chromium in sediment samples UR-2 and UR-3, located adjacent and downgradient, respecfively, of the site indicate prior discharges to surface water from facility. Finally, soil samples collected south of the Unadilla River potenfially indicate a larger area contaminated with lower concentrafions (not detected to 1,300 mg/kg) of chromium.

TAL Inorganic and TCLP Results ' t o '

A summary of metals in soil and sediment samples is provided in Table 3-2. During the SI, 23 on site and three reference samples (including two sediment samples) were collected for analysis of TAL metals. The SI report compared samples collected on site to the reference samples collected off site and concluded that mercury and lead were found at slighfiy higher concentrafions on site. Concentrafions of mercury in the three reference samples ranged from 0.08 to 0.19 mg/kg. Of the 23 samples, only two, E-20-0' (2.1 mg/kg) and H-22-2' (1.1 mg/kg), appear elevated relafive to the reference samples. Concentrations of lead in the three reference samples ranged from 22 to 43 mg/kg. The majonty of on site samples contained less than 100 mg/kg of lead but four samples, F-28-2' (200 mg/kg), H-22-2' (210 mg/kg), T1-M20-C-5' (200), and Sluiceway-2 (280 mg/kg) exceeded

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200 mg/kg. However, other metals, including arsenic and cadmium, also appear to be elevated in some samples. '

Seventeen samples (including QC samples) were collected for analysis of RCRA metals by TCLP. None of the samples exceeded regulatory levels. Silver and mercury were not detected in any TCLP extract. Chromium concentrafions, which ranged up to 280 micrograms per liter (/xg/L) in sample M-22-2', were more than one order of magnitude below the regulatory limit of 5,000 /xg/L. All other metal concentrafions were at least two orders of magnitude lower than their respecfive regulatory limits.

TCL Organic Results

During the SI, 17 s'oil and sediment samples were collected for analysis of TCL VOC. Nineteen samples (including two sediment samples) were collected for analysis of TCL SVOC and TCL pesficides and PCB. Overall, SI results do not indicate significant, wide-spread organics contaminafion. However, several single samples didcontain relafively high concentrafions of VOCs or SVOCs.

VOCs were detected in five samples as listed in Table 3-3. In four of the samples, few VOCs were detected, the concentrafions were relatively low, and some of the VOCs detected are probably attributable to laboratory contamination. However, sample T1-M-20-C-5' contained 15 different VOCs with a total VOC concentration of 43 mg/kg. According to the SI report, there were no unusual soil characterisfics at the sampling locafion and interval which consisted of gravel and cobbles with intermixed sands. In addifion, screening for organic vapors with a flame ionization detector yielded a maximum reading of 5 ppm at a depth of 5 feet bgs.

SVOCs were detected in eight samples as listed in Table 3-4. The SVOCs consist primarily of polynuclear aromafic hydrocarbons (PAHs). In seven of the samples, individual SVOC concentrafions ranged from not detected up to l,300JjU,g/kg (chrysene) which was detected in sample Sluiceway-1. Total SVOC concentrafions range from 1,200 Mg/kg up to 8,700 /xg/kg in sample G-26-4' and,- according to the SI, none of these samples contained more than 1 mg/kg of suspected carcinogenic PAHs. However, in sample F-28-2' SVOC concentrations are relafively high with a total SVOC concentrafion of 150,000 fig/y^g. According to the SI report, sample F-28-2' contained black asphalfic material that resembled roofing shingles.

No PCBs were detected in any sample and pesticides were detected in only five samples. The highest pesficide concentrafions were found in sample M-22-2'. This sample contained alpha and gamma chlordane at concentrafions of 35 and 31/xg/kg, respecfively. Other pesficides detected were all below 10 /xg/kg.

3.1.5.2 Summary of Surface Water Sampling

As part of the 1996 SI, surface water samples were also collected ,at the same three locafions as the sediment samples as shown in Figure 3-4. All three samples were submitted for analysis of TCL

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organics and TAL metals (filtered and unffitered). Overall, sample UR-2, adjacent to the wetlands and west of the former lagoons, had the highest concentrafions of metals in the filtered and unfiltered samples as shown in Table 3-5. Chromium was not detected in samples UR-1 and UR-3 but was detected in UrR-2 at 33 pig/L(unfiltered) and 5.7 /xg/L(filtered). In addifion to chromium, eight other TAL metals were detected.in surface water samples. These include aluminum, barium, calcium, iron, magnesium, manganese, sodium, and zinc. Except for aluminum, concentrafions of metals in unfiltered and filtered samples were similar indicafing that the majonty of the analytes were in the dissolved fracfion. Conversely, aluminum was detected only in the,unfiltered samples indicafing that this analyte is associated with suspended particles.

According to the SI report, no sample exceeded federal maximum contaminant levels (MCL) or NYS surface water standards. However, it appears that inorganic contaminant loading to surface water from the site was occurring during the fime span that SI samples were collected. Evidence for this conclusion can been seen in Table 3-5. For the majority of analytes, concentrafions are higher in sample UR-2 than in the other two samples. The pattern of higher concentrafions coupled with the fact that the sediment sample collected from locafion UR-2 contained elevated chromium suggests that contaminafion from the site was potentially discharging to the Unadilla River.

No TCL VOCs, SVOCs, pesficides, or PCBs were detected in the surface water samples.

3.1.5.3 Summary of Groundwater Sampling

During the 1996 SI, groundwater samples were also collected from 21 exisfing site wells (Figure 3-2). All samples were analyzed for unfiltered and filtered total chromium and unfiltered hexavalent chromium; four samples were analyzed for unfiltered and filtered TAL metals; and five samples were analyzed for unfiltered TCL organics. The sections below present the results of these analyses. In addifion, conclusions regarding groundwater contaminafion at the Hiteman site are also discussed.

Chromium Results

Total chromium was detected in 71 percent (15 of the 22 wells) of the unfiltered groundwater samples and in none of the filtered groundwater samples collected during the SI. The unfiltered groundwater chromium concentrafions in shallow monitoring wells ranged from not detected to 1,000 /xg/L in monitoring well MW-3S and in deep monitoring wells ranged from not detected to 690 mg/L in monitoring well MW-1 ID. Hexavalent chromium was not detected in any of the groundwater samples. Analytical results for chromium in groundwater are listed in Table 3-6 and shown on Figure 3-2.

According to the SI, the distnbufion of chromium in groundwater below the site is anomalous. In summary, the highest concentrafions of chromium in shallow groundwater were detected in shallow monitoring wells that appear to be hydrogeologically upgradient of the site. The two highest chromium concentrafions in shallow monitoring wells are 210 and 1,000 mg/L in MW-12S and MW-3S, respecfively. Further, in the two deep monitoring wells that have the highest concentrafions

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of chromium, MW-4D (300/xg/L) and MW-1 ID (690,ptg/L), their respecfive shallow wells have a relafively low concentrationof chromium.

The SI report provides several connected processes that may explain the situafion including water table mounding caused by the former lagoon which could produce localized reversals of groundwater flow paths; the high density of the wastewater responsible for the contaminafion; an upward vertical gradient from the deeper aquifer to the shallow, "water table aquifer; and opposing directions of groundwater flow in the upper and lower aquifers.

TAL Metals

Filtered and unfiltered groundwater samples for analysis of TAL metals were collected from monitonng wells MW-5S,MS-6S,MW-13D, and IVfW-14S. The analytical results for these samples are presented in Table 3-5. With the excepfion of chromium, the results do not indicate inorganic contaminafion of groundwater. According to the SI report, with the exception of chromium, no analytes exceed NYS groundwater standards of federal MCLs. However, the groundwater sample collected from MW-14S has consistenfiy higher concentrafions of inorganics relafive to the other wells samples. Conversely, MW-14S is seemingly upgradient of the site and should not be affected by groundwater contaminafion from the site. In addifion, as discussed below, MW-14S is the only monitoring well sampled that contained VOCs and SVOCs.

TCL Organics to*^

Unfiltered groundwater samples were collected from monitoring wells MW-5S, MS-6S, MW-13D, and MW-14S for analysis of TCL organic parameters. No pesticides or PCBs were detected in any of the samples. Only monitoring well MW-14S contained VOCs and SVOCs. The groundwater sample collected frorn MS-14S contained 2 SVOCs at concentrations below 10 pig/Land 12 VOCs at concentrafions up to 130 ptg/L. None of the organic compounds detected exceed MCLs. The compounds detected and their concentrations are listed in Table 3-7.

Groundwater Sampling Conclusions

Considering the relafively elevated inorganics and organics detected in upgradient monitoring well MW-14S and the overall anomalous distribufion of chromium in groundwater, it is apparent that site-specific hydrogeologic and geochemical processes are acfing in ways that create an atypical hydrogelogic situafion at the Hiteman site. The SI report theorized several explanafions that alone or in concert may explain these unusual condifions and the SI report should be reviewed for further information.

3.2 PRELIMINARY IDENTIFICATION OF APPLICABLE OR RELEVANT AND APPROPRIATE REOUIREMENTS (ARARs)

This secfion provides a preliminary determinafion of the regulafions that are applicable or relevant and appropriate to the remediafion of the site. Both federal and State requirements are considered.

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In addifion, this secfion presents an idenfificafion of federal and State criteria, advisories, and guidance that may be appropriate for the development of Remedial Acfion Objectives, and development and evaluafion of remedial technologies and altemafives.

3.2.1 DEFINITION OF ARARs

The legal requirements that are relevant to the remediafion of the Hiteman Leather site are identified and discussed using the framework and.terminology of CERCLA, as amended by the Superfund Amendments and Reauthorizafion Act (SARA). These acts specify that Superfund remedial acfions must comply with the requirements and standards of both federal and state environmental laws.

The EPA defines applicable requirements as "those cleanup standards, standards of control, and other substanfive requirements, criteria, or limitafions promulgated under federal environmental or state environmental or facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, locafion, or other circumstance at a CERCLA site". An applicable requirement must directly and fully address the situafion at the site.

The EPA defines relevant and appropriate requirements as "those cleanup standards, standards of control, or other substantive requirements, criteria, or limitafions promulgated under federal environmental or state environmental or facility sifing laws that, while not "applicable" to a hazardous substance, pollutant, contaminant, remedial acfion, locafion, or other circumstance at a CERCLA site, address problems or situations sufficienfiy similar to those encountered at the CERCLA site that their use is well suited to the particular site".

Acfions must comply with state ARARs that are more stringent than federal ARARs. State ARARs are also used in the absence of a federal ARAR, or where a state ARAR is broader in scope than the federal ARAR. In order to qualify as an ARAR, state requirements must be promulgated and identified in a timely manner. Furthermore, for a state requirement to be a potenfial ARAR it must be applicable to all remedial situafions described in the requirement, not just CERCLA sites.

ARARs are not currently available for every chemical, locafion, or acfion that may be encountered. For example, there are currenfiy no ARARs which specify cleanup levels for soils. When ARARs are not available, remediation goals may be based upon other federal or state criteria, advisories and guidance, or local-ordinances. In the development of remedial acfion alternatives, the informafion derived from these sources is termed "To Be Considered" and the resulting requirements are referred to as TBCs. EPA guidance allows cleanup goals to be based upon non-promulgated criteria and advisories such as reference doses when ARARs do not exist, or when an ARAR alone would not be sufficiently protecfive in the given circumstance.

By contrast, there are six condifions under which compliance with--ARARs may be waived. Remedial acfions performed under Superfund authority must comply with ARARs except in the following circumstances:

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• the remedial acfion is an intenm measure or a portion of the total remedy which will attain' the standard upon corriplefion;

• compliance with the requirement could result in greater nsk to human health and the environment than altemafive opfions;

• compliance is,technically impracfical from an engineering perspecfive; . • the remedial acfion will attain an equivalent standard of performance; • the requirement has been promulgated by the state, but has not been consistently applied in

similar circumstances; or • • the remedial acfion would disrupt fund balancing.

Potenfial ARARs andTBCs are classified as chemical-specific, acfion-specific, or locafion-specific, as described briefly below.

Chemical-specific ARARs or TBCs are usually health or risk-based numerical values, or methodologies which when applied to site specific condifions, result in the establishment of numerical values. These values establish the acceptable amount or concentration of a chemical that may be found in, or discharged to, the ambient environment.

Location-specific ARARs or TBCs generally are restricfions imposed when remedial acfivifies are performed in an environmentally sensifive area or special locafion. Some examples of special locafions include floodplains, wefiands, historic places, and sensifive ecosystems or habitats.

Acfion-specific ARARs or TBCs are restricfions placed on particular treatment or disposal technologies. Examples of acfion-specific ARARs are effluent discharge limits and hazardous waste manifest requirements.

3.2.2 CONSIDERATION OF ARARs DURING THE RI/FS

ARARs are used to determine the necessary extent of cleanup, to scope and formulate remedial acfion altematives, and to govem the implementafion of the selected altemafive. The different ARAR classificafions are considered at various points in a RI/FS. Chemical-specific ARARs are used early in the development of specific remediafion goals. Locafion-specific ARARs may be developed throughout the study. Action-specific ARARs are addressed in the detailed evaluation of remedial altemafives and the selecfion of a preferred remedy. Specifically, ARARs (including TBCs) will be considered during the following intervals of the RI/FS process:

. Scoping of the RI/FS. Chemical and locafion-specific ARARs will be idenfified on a preliminary basis.

Site characterizafion and risk assessment phases of the RI. Chemical and locafion-specific ARARs will be identified comprehensively, and will be refined to determine site cleanup goals.

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Development pf remedial altematives in the FS report. Action-specific ARARs will be identified for each of the proposed altemafives and will be considered along with other ARARs.

• Detailed evaluafion of altemafives in the FS reports. The potenfial AR.A.Rs idenfified up to this point will be examined to specifically idenfify a suite of ARARs relevant to each altemafive. Each altemafive will be evaluated to determine what is required to achieve compliance with the ARARs.

• Selecfion of remedy. Compliance with idenfified ARARs is used as a criterion for the selecfion of a remedial altemafive. If necessary, the provisions for the waiver of ARARs will be considered.

• Remedial design. Technical specificafions of the remedial design and proposed construcfion will be evaluated for compliance with action-specific ARARs.

As the RI/FS process confinues, the list of ARARs and TBCs will be updated, particularly as new regulafions and guidance are issued by state and federal agencies. ARARs will be used as a guide to establish the appropriate extent of site remediafion; to aid in scoping, formulafing and selecfing proposed treatment technologies; and to govem the implementafion and operation of the selected remedial altemafive. Primary consideration should be given to remedial altemafives that attain or exceed the requirements of the idenfified ARARs. Throughout the RI/FS, ARARs are idenfified and ufilized by taking into account the following:

Contaminants suspected or idenfified to be at the site; Chemical analysis performed, or scheduled to be performed; Types of media (air, soil, ground water, surface water, and sediment);

, Geology and other site characterisfics; Use of site resources and media; Potenfial contaminant transport mechanisms; Purpose and applicafion of potenfial ARARs; and Remedial altemafives considered for site cleanup.

3.2.3 PRELIMINARY IDENTIFICATION OF ARARs AND TBCs

The Nafional Contingency Plan (NCP) (40 CFR 400.430 and 8666, March 8, 1990) and the S ARA/CERCLA Compliance Policy guidance define applicable requirements as the federal and state requirements for hazardous substances, which would be legally binding at the site, if site response were to be undertaken regardless of CERCLA Sections 104 or 106. Relevant and appropriate requirements are defined as those federal and state requirements that, while not directly applicable, apply to facilities or problems similar to those encountered at this site. In other words, requirements may be relevant and appropnate if they would be applicable except for jurisdicfional restricfions associated with the requirements. Relevant and appropriate requirements are afforded the same

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weight and considerafion as applicable requirements with regard to the selecfion of remedial altemafives.

A preliminary idenfification of federal and state regulatory requirements (ARARs andTBCs) which may be potenfially applicable or relevant and appropriate to the site is presented in the following

, subsecfions. This list of presenfiy identified potenfial ARARs is based on current knowledge and will be reviewed throughout the RI/FS to confirm that the ARARs idenfified at the preliminary stage are sfill applicable to potenfial remedial measures as more informafion about the site becomes available, and to idenfify addifional ARARs that may be appropriate.

3.2.3.1 Chemical-Specific ARARs

The determinafion of potenfial chemical-specific ARARs and TBC criteria for a site typically follows an examinafion of the nature and extent of contaminafion, potenfial migrafion pathways and release mechanisms for site contaminants, the presence of human receptor populafions, and the likelihood that exposure to site contaminants will occun Previous invesfigafions performed by NYSDEC and EPA Region n provide some of this basic informafion. These sampling events included the collection and analysis of surface soil, surface water, sediment, groundwater and solid waste samples.

Federal:

• Resource Conservafion and Recovery Act (RCRA) Groundwater Protection Standards and Maximum Concentration Limits (40 CFR 264, Subpart F)

• Nafional Ambient Air Quality Standards (NAAQC)(40 CFR 50) • SafeDrinkingWater Act, MCLs (40 CFR 141.11-141.16)

RCRA TCLP and Land Ban Requirements for Landfilling (40 CFR 261)

New York:

New York Ground Water Quality Regulafions (6 NYCRR Part 703) New York State Department of Health (NYSDOH), State Sanitary Code, Drinking Water Supply (10 NYCRR Part 5.1)

• New York Surface Water Quality Standards (6 NYCRR Part 702) • New York Water Supply Sources (10 NYCRR Part 170) • New York Air Quality Standards (6 NYCRR Part 257) • New York Pollufion Discharge Eliminafion Systems (6 NYCRR Part 750-758)

New York Technical and Operafions Guidance Series (TOGS), Ambient Water Quality Standards and Guidance Values (April 1, 1987)

3.2.3.2 Location-Specific ARARs

The locafion of the site is a fundamental detemiinant of its impact of human health and the environment. Locafion-specific ARARs are restncfions placed on the concentration of hazardous

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substances or the conduct of acfivifies solely because they are in a specific locafion (EPA, 1988). Some examples of these unique locafions include floodplains, wefiands, histonc places, and sensifive ecosystems or habitats.

Federal:

• Endangered Species Act of 1973 (16 USC 1531); generally, 50 CFR Parts 81, 225, and 402 Execufive Order on Wefiands Protecfion (CERCLA Wefiands Assessments) No. 11990. National Histonc Preservafion Act (16 USC 470) Secfion 106 et seq. (36 CFR 800) RCRA Locafion Requirements for 100-year Floodplains (40 CFR 264.18(b)).

• . Fish and Wildlife Coordinafion Act (16 USC 661 et seq.) Clean Water Act Secfion 404 and Rivers and Harbor Act Secfion 10 Requirements for Dredge and Fill Acfivifies (40 CFR 230) Army Corps of Engineers Regulafions for Construcfion and Discharge of Dredged or Fill Materials in Navigable Waterways (33 CFR 320-330). Wetlands Construction and Management Procedures (40 CFR 6, Appendix A)

New York:

New York Use and Protection of Waters (6 NYCRR Part 608) Freshwater Wefiands (6 NYCRR Part 662-665) Endangered and Threatened Speciesof Fish and Wildlife (6 NYCRR Part 182) Freshwater Wefiands Act (ECL article 24 and 71, Tifie 23) Flood Plain Management Regulations - development permits (6 NYCRR 500 ECL article 36)

3.2.3.3 Action-Specific ARARs

Based on the idenfificafion of remedial response objecfives and applicable general response acfions, numerous federally promulgated acfion-specific ARARs and TBCs will affect the implementafion of remedial measures and include administrafive requirements related to treatment, storage and disposal actions.

The primary federal requirements which guide remediation are those established under CERCLA as amended by SARA. Requirements outlined in the current NCP (40 CFR 300.400(g)(3)) represent TBC criteria for the site. The NCP incorporates the SARA Tifie HI requirement that altemafives must safisfy ARARs and ufilize technologies that will provide a permanent reducfion in the toxicity, mobility or volume of wastes, to the extent pracficable.

RCRA establishes both administrafive (e.g., permitfing, manifesting) requirements and substanfive {i.e., design and operafion) requirements for remedial acfions. For CERCLA acfions conducted, enfirely onsite, only the substantive requirements apply.

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P

RCRA Subfitle C Hazardous Waste Treatment Facility Design and Operafing Standards for TreatmentandDisposal Systems {e.g.,landfill,incinerators,tanks,containers,etc.)(40CFR 264 and 265) (Minimum Technology Requirements) RCRA Subfifie C Closure and Post-Closure Standards (40 CFR 264, Subpart G) RCRA Ground Water Momtonng and Protecfion Standards (40 CFR 264, Subpart F) RCRA Manifesfing, Transport and Recordkeeping Requirements (40 CFR 262) RCRA Wastewater Treatment System Standards (40 CFR 264, Subpart X) RCRA Correcfive Acfion (40 CFR 264.101) RCRA Storage Requirements (40 CFR 264; 40 CFR 265, Subparts I and J) RCRA Subfifie D Nonhazardous Waste Management Standards (40 CFR 257) Off-Site Transport of Hazardous Waste (EPA OSWER Direcfive 9834.11) Reinjecfion Requirements (EPA OSWER Direcfi ve 9234.1-06) RCRA Excavafion and Fugifive Dust Requirements (40 CFR 264.251 and 264.254) Safe Drinking Water Act, Underground Injecfion Control Requirements (40 CFR 144 and 146) RCRA Land Disposal Restricfions (40 CFR 268) (On- and off-site disposal of excavated soil) Clean Water Act - Nafional Pollufion Discharge Elimination System (NPDES).Permitfing Requirements for Discharge of Treatment System Effluent (40 CFR 122-125) Clean Water Act Discharge,to Publicly Owned Treatment Works (POTW) (40 CFR 403) Nafional Emission Standards for Hazardous Air Pollutants (NESHAPs) (40 CFR 61) DOT Rules for Hazardous Materials Transport (49 CFR 107,171.1-171.500) Occupafional Safety and Health Standards for Hazardous Responses and General Construcfion Acfivifies (29 CFR 1904,1910,1926) Fish and Wildlife Coordination Act (16 UC 661 et seq.). (Requires acfions to protect fish or wildlife when diverting, channeling or modifying a stream).

New York:

ft

New York State Solid Waste Management Facilifies (6 NYCRR Part 360) New York State Sifing of Industrial Hazardous Waste Facilifies (6 NYCRR Part 361) New York State Waste Transporter Permits (6 NYCRR Part 364) New York State Hazardous Waste Management System (6 NYCRR Part 370) New York State Identificafion and Lisfing of Hazardous Wastes (6 NYCRR Part 371) • New York State Hazardous Waste Manifest System and related Standards for Generators, Transporters and Facilifies (6 NYCRR Part 372) New York State Hazardous Waste Treatment, Storage and Disposal Facility Permitfing Requirements (6 NYCRR Part 373-1) New York State Final Status Standard for Owners and Operators of Hazardous Waste TSD Facilifies (6 NYCRR Part 373-2) New York State Interim Status Standards for Owners and Operators of Hazardous Waste Facihfies (6 NYCRR Part 373-3) -

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New York State Standards for the Management of Specific Hazardous Wastes and Specific Types of Hazardous Management Facilifies (6 NYCRR Part 374) New York State Inacfive Hazardous Waste Disposal Sites (6'NYCRR Part 375) • hnplementafion of NPDES Program in NYS (6 NYCRR Part 750-757) Division of Air, General Provisions (6 NYCRR Part 200) Air Permits and Certificafions (6 NYCRR Part 201) General Prohibifions (6 NYCRR Part 211) General Process Emission Sources (6 NYCRR Part 212) New York Water Pollufion Control Regulations (6 NYCRR Parts 608,610-614)

3.2.3.4 To Be Considered Criteria

When ARARs do not exist for a particular chemical or remedial acfivity, other criteria, advisories and guidance (TBCs) may be useful in designing and selecfing a remedial altemafive. The following criteria, advisories and guidance were developed by EPA, other federal agencies and state agencies.

Federal TBCs (Acfion. Locafion. and Chemical-Specific):

Safe Drinking Water Act Nafional Primary Drinking Water Regulafions, Maximum Contaminant Level Goals (MCLGs) Maximum Contaminant Levels Goals (56 CFR 3256, January 30,1991.50 Federal Register 46936-47022, November 13, 1985) Proposed Requirements for Hybrid Closures (combined waste-in-place and clean closures) (52 Federal Register 8711) EPA Drinking Water Health Advisories Clean Water Act, Water Quality Cntena (Section 304) (May 1, 1987 - Gold Book) EPA Health Effects Assessment (HEAs) Toxic Substances Control Act (TSCA) Health Data Toxicological Profiles, Agency for Toxic Substances and Disease Registry, U.S. Public Health Service Policy for the Development of Water-Quality-Based Permit Limitations for Toxic Pollutants (49 Federal Register 8711) , Cancer Assessment Group (Nafional Academy of Science) Guidance Ground Water Classificafion Guidelines Ground Water Protection Strategy Waste Load Allocation Procedures Fish and Wildlife Coordinafion Act Advisories Federal Guidelines for Specificafion of Disposal Site for Dredged or Fill Material Proposed RCRA Comecfive Action Regulafions (July 27, 1991) Guidelines for the Protecfion and Management of Aquatic Sediment Quality in Ontario (D. Persaud et al , August 1993) Ontario Ministry of the Environment and Energy Lowest Effect Level (LEL) and Severe Effects Level (SEL) ~

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New York TBCs (Acfion, Locafion. and Chemical-Specific):

• Technical and Operafions Guidance Series (TOGS) - Analyfical Detectability for Toxic Pollutants, July 12, 1985 - Ambient Water Quality Standards and Guidance Values (revised June, 1998) - Toxicity Tesfing in the State Pollufion Discharge Eliminafion System (SPDES) Permit

Program, Apnl 1, 1987 - BPJ Methodologies, April 1, 1987 • " - Regional Authorizafion for Temporary Discharges, April 1, 1987

, . - Industrial SPDES Permit Drafting Strategy for Surface Waters, May 19, 1987 - Waste Assimilafi ve Capacity Analysis for Setfing Water Quality Based Effluent Limits,

May 22, 1987 • Air Guide 1 - Guidelines for the Control of Toxic Ambient Air Contaminants NYSDOH, Criteria for the development of health advisories for sport fish consumpfion NYSDEC Soil Cleanup Objecfives and Cleanup Levels (TAGM HWR 94-4046, revised January 1994) -.

• NYSDEC Technical Guidance for Screening Contaminated Sediments (NYSDEC, revised April 1996a)

3.3 PRELIMINARY HUMAN HEALTH RISK ASSESSMENT

The Preliminary Human Health Risk Assessment for the Hiteman Leather site, presented below, is based on available soil, groundwater, surface water, and sediment analyfical results, site visits, and historical site information.

COCs, source areas and release mechanisms, exposure pathways and receptors, and additional data needs are discussed in the following subsecfions.

3.3.1 POTENTIAL CHEMICALS OF CONCERN

A list of potenfial COCs has been developed based on available analyfical data from surface soil, groundwater, surface water, and sediment sampling (see Table 3-8). This list is preliminary and may change once data acquisifion for the RI has been completed. The approach for the selecfion of potential COCs will be discussed in the pathway analysis report. The list presented here is summarizing work performed by others and will be revised prior to selecting a final list of COCs. The primary considerafions for selecfion of potenfial chemicals of concem include:

frequency of detection in analyzed medium (e.g, surface soil) • histoncal site informafion/ acfivifies (i.e., site-relatedness) • chemical concentration - toxicity screen

retain Group A carcinogens • 'Chemical toxicity (potenfial carcinogenic and noncarcinogenic effects, weight of

evidence for potenfial carcinogenicity) chemical properties (mobility, persistence, and bioaccumulafion) significant exposure routes

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Potenfial COCs detected in the sampled matrices include inorganics: anfimony, arsenic, barium, beryllium, chromium, and silver; volafiles: Xylenes and methylbenzenes and pesficides: aldrin, dieldnn, and chlordane. • Previous human health eyaluafions prepared as part of the 1998 HRS invesfigation indicated potenfial non-carcinogenic risks from 0.1 to 10.0 and potenfial carcinogenic nsks between 9E-06 and 6E-04 depending on the exposure scenario examined.

3.3.2 POTENTIAL SOURCE AREAS AND RELEASE MECHANISMS

There is both residenfial and commercial development within 500 feet of the site. Based on the recent site visit in March 2000, the most hkely current receptors for site-related contaminafion are site workers/trespassers and recreafional users. Future residential development could occur and will be evaluated as one of the future exposure scenanos.

Based upon the potenfially contaminated soil, groundwater, surface water and sediment described in the preceding secfion, pathways of potential concem at the Hiteman Leather Site have been developed and are presented below.

3.3.2.1 Surface Soil Pathway

Previous sampling at the site revealed surface soil contamination. It is also likely that poor housekeeping pracfices may have caused spills on site. Therefore, area site workers/trespassers may currently be exposed to contaminated surface soil via ingesfion, dermal contact, and inhalafion of suspended soil.

3.3.2.2 Subsurface Soil Pathway

Sampling at the site revealed subsurface soil contaminafion. The potential for exposure to subsurface soil exists through future excavafion on-site due- to any re-development activifies. Therefore, direct exposure to subsurface soils will exist. Off-site subsurface soil contaminafion at two other properties may be evaluated if EPA determines that a need exists to evaluate those properties.

3.3.2.3 Groundwater Pathway

Groundwater associated with the Hiteman Leather site is of concem because available analytical data and the HRS risk assessment indicate that previous on-site disposal acfivifies have resulted in the contaminafion of surface and subsurface soils. West Winfield receives its dnnking water from a municipal water supply operated by the village located northeast of the site. While the probability of future exposure to groundwater at the site is low, the potential risks associated with this pathway are high. In such cases, the EPA's Risk Assessment Guidance for Superfund (EPA, 1989) requires that the pathway be evaluated.

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3.3.2.4 Surface Water/Sediment Pathway

Previous sampling at the' site revealed surface water and sediment contaminafion. Area residents/trespassers have the potenfial to come into contact with surface water and sediment (e.g., stream and wefiand) and associated surface water run-off Run-off from the site into the Unadilla River and potenfial groundwater discharge may pose a threat to receptors using the River for recreational purposes. The, Unadilla River is not used as a drinking water supply. The Unadilla River is a NYSDEC Class C (T) stream in which fishing is permitted. Therefore, the potenfial exists for off-site residents to be exposed to contaminated surface water and sediment during recreafional acfivities.

3.3.3 SUMMARY OF ADDITIONAL DATA NEEDS

Previous invesfigafions of the site have not provided sufficient environmental sampling data to characterize the potenfial risks to human receptors. Addifional data will be collected during the RI for use in the Baseline Human Health Risk Assessment.

3.4 PRELIMINARY ECOLOGICAL RISK ASSESSMENT

The RAC II Team has reviewed the available background data. An ecological risk assessment (ERA) was conducted by EPA Region 2 Environmental Response Team in March 1997. The field effort included on-site trapping of small mammals, collecfion of crayfish from the Unadilla River, infaunal benthic macroinvertebrate sampling, and terrestrial bioaccumulafion modeling. The calculated hazard quofients indicated three assessment endpoints being at risk due to potenfially acutely toxic levels of chromium at the site. These assessment endpoints included: protection of the structure and function of the Unadilla River, protection of waterfowl utilizing the site as a feeding area, and protection of mammals utilizing the site. The ERA concluded that since the hazard quofients were calculated using acutely toxic levels of chromium there is an imminent threat present on the site. Based on this inifial assessment, general exposure scenarios and receptor classes (terrestrial, avian, aquafic) were identified.

3.5 PRELIMINARY IDENTIFICATION OF REMEDIAL ACTION ALTERNATIVES

Since only limited hydrogeological, soil/waste, and analyfical data are available for site specific conditions, the RAC II Team believes that it is premature to identify remedial acfion altemafives at this fime.

3.6 NEED FOR TREATABILITY STUDIES

At this fime no treatability studies are anficipated for the RI/FS.

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TABLE 3-1

CHROMUIM ANALYTICAL RESULTS - SOIL AND SEDIMENT SAMPLES X-RAY FLUORESCENCE CONCENTRATIONS GREATER THAN 10,000 MG/KG

LABORATORY CONCENTRATIONS GREATER THAN 1,000 MG/KG HITEMAN LEATHER SITE


Sample Number

050N-025W-0'

050N-125W-0'

100N-025W-0'

100N-025W-0' (duplicate)

100N-075W-0'

100N-125W-0'

•150N-025W-0'

150N-125W-0'

F-28-2'

G-10-0'

G-10-2'

G-26-0'

G-26-2'

G-26-4'

G-26-6'

H-12-2'

H-14-4'

H-20-4'

H-22-2'

L-13-2'

L-13-4'

M-19-0'

M-19-2'

M-19-4'

X-rav Fluorescence

71,000

21,000

32,000

34,000

, 51,000

37,000

67,000

52,000

15,000

~

—

44,000

72,000

—

21,000

13,000

—

36,000

13,000

11,000

13,000

13,000

26.000

Laboratory

1

~

~

—

—

—

~

4,700

12,000

4,700

—

—

3,500

—

~

3,800

—

20,000

~

—

~

—

~

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TABLE 3-1 (continued)

CHROMIUM ANALYTICAL RESULTS - SOIL AND SEDIMENT SAMPLES X-RAY FLUORESCENCE CONCENTRATIONS GREATER THAN 10,000 MG/KG

LABORATORY CONCENTRATIONS GREATER THAN 1,000 MG/KG HITEMAN LEATHER SITE


Sample Number

M-22-2'

M-22-4'

M-22-6''

M-22-6' (duplicate)

P-20-0'

P-20-2.5'-A

P-20-4'

P-20-6''

Q-10-0',

Q-17-0''

Q-17-2'I

Q-17-2' (duplicate)

Q-17-4'!

Q-20-0':

Q-20-0' (duplicate)

Q-20-2',

R-14-0'

S-20-0''

T1-M20-C-5'

Sluiceway-1-0'

Sluiceway-2-0'

UR-3

X-ray Fluorescence

37,000

36,000

28,000

24,000

33,000

46.000

13,000

26,000

—

75,000

47,000 '

43,000

15,000

25,000

23,000

60,000

42,000

22,000

32,000

—

—

Laboratory

15.000

—

—

~

__

—

—

45,000

—

~

—

—

—

—

—

~

~

50,000

1,100

2,400

6.700

Notes: Reported in milligrams per kilogram (mg/kg), dry weight ~ = Not analyzed

Page 2 of 2

300058

TABLE 3-2

SUMMARY OF TARGET ANALYTE LIST METALS IN SOIL AND SEDIMENT HITEMAN LEATHER SITE


U) o o o tJi

Analyte

Aluminum

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Selenium

Silver

Sodium

Vanadium

Zinc

:'E-20-0'.

5,100

3.8

44

ND

ND

58,000

45

4.7

10

12,000

44

2,600

250

. '2.1'1',.'-

12

470

ND

ND

94

10

76

F-28-2'-"

990

' 52 f: '

240

0.46

ND

4,400

4,700

3.6

50

•Ho^ool;;

200

140

26

0.2

6.6

390

wmm ND

280

22

45

": HtM-^'- •

5,400

3.3

57

ND

" • . ' ' ' • ' ' 4 .5 . - • ' .

130,000

3,800

3.9

17

12,000

99

2,700

290

0.3

10

400

• ND

ND

490

19

68

0-23-2'

18,000

4,8

85

' f.3 .

ND

2,600

23

. t , t ' 16 # .

22 .

34,000

19

4,500

460

0.04

::-\>45;..;V.

1,100

ND

ND

140

28

88

'-U-22-2'.'

13,000

4.6

60

0.83

ND

1,400

19

'. . 16 '.J

23

30,000

18

4,000

440

0.04

39

980

ND

ND

ND

23

83

• TI-M-20-C:5'- '

4,000

2.6

47

ND

ND

200,000

50,000

ND

60

5,500

200

3,200

260

0.31

7.4

ND

ND

m- -.'"'-ir V . '>.';'', 1,500, /

*'". ' 82 - ..''

, ; w,< j j Q '• •

Sluicewayrl .

3,500

17

• 54

0.79

0.85

13,000

1,100

4.4

' • • • • 6 5 . - ••• -

12,000

78

1,200

82

0.13

14

330

0.71

ND

230

16

no

Sluiceway-2

4,400

41

390 _

1

0.98

19,000

2,400

6

34

20,000

280

1,300

250

0.22

16

700

1.1

ND

160

18

120

UR-2

7,400

3.4

130

ND

2.7

77,000

' 6,700

4.6

21

16,000

93

3,300

760

0.14

14

850

ND

ND

470

30

2 1 0 •

Page 1 of 2

TABLE 3-2

SUMMARY OF TARGET ANALYTE LIST METALS IN SOIL AND SEDIMENT HITEMAN LEATHER SITE


O o o en o

Analyte

Aluminum

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Mercur>'

Nickel

Potassium

Selenium

Silver

Sodium

Vanadium

Zinc

Building East-0'

2,300

2.3

17

ND

ND

230,000

13

0.89

9.7

5,700

37

6,800

130

ND

6.3

ND

0.75

ND

370

7.8

39

Building East-2'

15,000

4

59

0.84

ND

5,100

21 •

13

19

29,000

• 20

4,300

330

0.06

38

1,300

ND

ND

130

25

86

Building West-0' ,.

1,600

2.1

12

ND

ND

. ' '270,000- • • '• '

12

1.5

8

; 5,900 -

46

9,200

120

ND

5.8

ND

0.71

ND

380

6.9

46

,> Reference'III-1 .•

9,800

7.7

50

0.77

ND

3,100

16

9.3

13

23,000

22

2,400

640

0.08

20

110

ND

ND

ND

22 •

83

' JR^'ference 111-2

9,600

7.7

69

0.9

0.8

7,200

19

9.2

16

23,000

32

2,600

,« ii30o; '

0.13

21

1,200

ND

ND

ND

23

100

Reference II1-3

9,800

5.9

81

0.65

ND

33,000

290

7.6

70

19,000

43

3,800

480

0.19

20

1,100

0.61

ND

130

19

120

Notes: Reported in milligrams per kiogram (mg/kg), dry weight ND = Not detected Shaded and bold values represent maximum concentration for that analyte

Page 2 of 2

TABLE 3-3

SUMMARY O F ANALYTICAL RESULTS OF VOCS IN SOIL HITEMAN LEATHER SITE


u> o o o a\

Compound

Acetone

2-Butanone

Benzene

Ethylbenzene

p&m - Xylene

o-Xylene

Isopropylbenzene

n-Propylbenzene

1,3,5 - Trimethylbenzene

1,2,4 - Trimethylbenzene

sec-Butylbenzene

1,3-Dichlorobenzene

p-Isopropyltoluene

1,4 Dichlorobenzene

n-Butylbenzene

Naphthalene

F-28-2'

ND

ND

7

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

210

H-14-4'

710

JOO

ND

ND

ND

ND

ND

ND

ND

3.8

ND

ND

ND

ND

ND

3.0

H-16-3.5'

10

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

U-22-2'

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

3.7

T1-M-20-C-5'

340

81

ND

17

4,300

8.8

510

4,200

5,600

15,000

120

6.2

3,100

4.3

210

210

Notes; , Reported in micrograiTis per kilogram (jig/kg), dry weight ND = Not Detected

Page 1 of 1

TABLE 3-4

SUMMARY OF ANALYTICAL RESULTS OF SVOCS EV SOIL AND SEDIMENT HITEMAN LEATHER SITE


o o o

Compound

Naphthalene

4-chloro-3-methylphenol ,

2-methylnaphthaIene

Acenaphthylene

Dibenzofuran °

Phenanthrene

Anthracene

Carbazole

Fluoranthene

Pyrene

Benzo(a)anthracene

Chrysene

Benzo(b) fluoranthene

Benzo (k)fluoranthene

Benzo(a)pyrene

lndeno( 1,2,3-cd)pyrene

Dibenzo(a,h)anthracene

Benzo(g,h,i)perylene

Total BNAs

ySU-Tr

ND

ND

ND

ND

ND

ND

ND

ND

220 J

150 J

130 J

130 J

IIOJ

140 J

150 J

80 J

ND

80 J

1,200

E-20-0' ,

ND

ND

ND

ND

ND

ND

ND

ND

6I0J

480 J

ND

300 J

ND

ND

290 J

ND

ND

ND

1,700

•y.F-2&-2'\:

11,000

ND

2,500 J

2,600 J

3,100 J

25,000

5,300

3,600 J

21,000

17,000

10,000

9,800

8,500

9,200

8,700

6,400

1,700 J

6,000

150,000

G-26-4'

1,200

180 J

140 J

ND.

100 J

1,200

340 J

140 J

1,300

840

490 J

520

550

610

580

240 J

65 J

' 220 J

8,700

Sluiceway-1;

ND

ND

ND

ND

ND

ND

ND

ND

ND

1100 J

ND

1300 J

. 850 J

1000 J

ND

ND

ND

ND

, 4,300

Sluiceway-2

1,600 J

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

' ND

1,600

'!':Tl-M-20rC-5'

1,500 J

ND

ND

ND

ND

630 J

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

ND

2,100

; UR-I

ND

ND

ND

ND

ND

740J

ND

ND

l,300J

1,100J

ND

660J

• ND

ND

410J

ND

ND

ND

4,200

Notes: Reported in micrograms per kilogram (pg/kg), dry weight ND = Not Detected J = Estimated value

Page 1 of 1

TABLE 3-5

ANALYTICAL RESULTS O F TAl^GET ANALYTE LIST METALS IN WATER SAMPLES HITEMAN LEATHER SITE


Sampling Location

MVV-13I)

MW-13D . '

MVV-14S

MW-14S -

MW-5.S

MW-5S

N4W-r,.S

MW-6S ' - ' . ; -

UR-1

UR-1

,UR-2 -

UR-2>: . ' ' ' • * .

UR-3

UR-3 . - ' .

-Aluminum ,-

ND

" ' 3,800 ; t

ND

- --7800 }'\,

' ND

- - ND .{ .

ND

• ' • ' / I ' o ' t ^

ND

." 77 ' *

ND

• ' I60" . \ ' "

ND

*."' - 8 0 . . * - '

Arsenic ,

ND

; . ^ 2 • *'•

ND

;;:"-'-7.p"'' "

32

\y PfJ'.. 43

l.-'iV:''-}

ND

.-'' 'ND J;

ND

^ '_Np..

ND

X N D : ? .

Barium .,.

120

*.I40 •',,,

89

-•~" i3g-","'""

82

.•'5V90' - ••

60

\ \ i 5 6 , , , y

31

:-'' ^!^ ' '

54

i l53- 'S

31

. " 301 A '

~ Calcium J

70,000

88.000*;'

1 10,000

.110,000-.'

96,000

,>98;ooo?'

84,000

1 .,80;6()o}!

70.000

»• 70.000';

100.000

' • 96*000,t

71,000

•: '69.000.' .

Chromium '

ND

•• • ' , ' 5 . 3 . - ' • ; •

ND

:,«?•;'6.9 •'-£

ND

<.'if<;,Nb *•;•_,

ND

-;.-\":>ro"'ir:.

ND

{ . U N D ] , / -

5.7

ND

' j ' l 'W '..-.

Iron

ND

"3,300 ;

ND

• 9.400 •

1,300

2,300-

1,000

/.i.ioo.'J

ND

y m ^ '

32

. 210\

28

160 -

Magnesium

11,000

':•• 13,000 :.'

9,900

12,000' •'•. •

9,400

. ;-' 9_,40'0./.':, '

9,800

'J '.'9.300.'-;;;';;

6,700

>'-"* 6,700 ,

5,800

• ; .5.700^ Z-

7,300

• -7,200 . /

Manganese

39

.' . 100''

1,100

' ' • f.200

860

:i",oo6.->.'

220

; ; / - -200- '",

8.8

'. '5 '

37

' ..'51 -•; '

4.9

'' \-i35*t

Nickel

ND

-ND • '

ND

.'„• 13 •

ND

y- ND. ,

ND

,'' ND- ..'i

ND

ND-

ND

" .-.ND

ND

ND ,

Potassium

ND

2.800

2,600

4,600

ND

ND

ND

-. 'ND' .,.

ND

ND

ND

-. ' " N D ' ; • •

ND

ND

Sodium

5,000

5.100

34,000

35,000

11,000

11,000

9.000

' ,8,400

4.600

-4,400

13,000

• 14;000 •

4,600

' 4,300 '

Vanadium

ND

• 7 5

ND

16.0

ND

' ND

ND

ND

ND

ND

ND

• ' NT)

ND

ND

Zinc

ND

5.8

ND

34.0

ND

ND

ND

ND

9.2

ND

ND

ND

14

ND

U) o o o

Notes: Reported in micrograms per liter (ug/L) ND = Not Detected Shaded samples indicate unfiltered samples, unshaded samples indicate filtered samples UR samples are from the river

Page 1 of 1

I TABLE 3-6

CHROMIUM ANALYTICAL RESULTS - GROUNDWATER HITEMAN LEATHER SITE


Notes

Reported in micrograms per liter (ug/L)

Page 1 of 1

300064

I

f

TABLE 3-7

SUMMARY OF ANALYTICAL RESULTS OF VOCS IN GROUNDWATER HITEMAN LEATHER SITE

WEST WmriELD, NEW YORK

1 Compduhd, \":-'''.'. **' " - , ' • . ' : , - ' ' . / '

Acetone

Toluene

Ethylbenzene

p&m - Xylene

o-Xylene

Isopropylbenzene

n-Propylbenzene

1,3,5-Trimethlbenzene .

1,2,4-Trimethylbenzene

sec-Butylbenzene

p-Isopropyltoluene

Naphthalene

,.,, •MW^l4§-;-:,X/i%

39

2.3

39

100

3.1

15

20

43

130

1.9

2.0

9.1

Note: Reported in micrograms per liter ([Ig/L)

b Page 1 of 1

300065

I TABLE 3-8

LIST OF POTENTIAL CHEMICALS OF CONCERN (COCs) HITEMAN LEATHER SITE


Inorganics

Volatiles

Pesticides/PCBs

Antimony Arsenic Barium

Beryllium Cadmium Chromium

Lead Mercury

Silver

Xylenes Methylbenzenes

Aldrin Dieldrin

Chlordane

t

i ^00066

EXPLANATION

g l ^ j g Sand and 9r9v«l. Mturalfr wtiers shaoed

^ 5 ^ 3 Lacusiiine siK. ci»v. ii O v»ry line &tnd

I I I !

|:^:'Y;S:-) SedtmenlgfV bedrock

where gnaced and melted (From

MacNiah and Randall, 1982, fig 9B)

w D l w l Federal Programs Corporation aSubakHaiyofCampOmmeriMcKeetia

FIGURE 3-1

GENERAL GLACIAL STRATIGRAPHY


PROJECT No. ^7?n-0^7

Z.9000€

STREET

C D IVI Federal Programs Corporation 'A subsidiary of Camp Dresser & McKee Inc.


LEGEND

WETLAND BOUNDARY

APPROXIMATE BOUNDARY OF FORMER

DISCHARGE LAGOON "

FENCE

2 1 0 UNFILTERED CHROMIIUM CONCENTTRATIONS (ug/L)

N D NO CHROMIUM DETECTED

NOT SAMPLED

M W — 1 3 D - ^ DEjp MONITORING WELL

M W — 1 3 S " $ " SHALLOW MONITORING WELL

a

50 100 ISO

SCAL£

FIGURE 3 - 2

EXISTING MONITORING WELL LOCATIONS

PROJECT No. 3 2 2 0 - 0 3 2

U) o o o <y\

00

+•

I I

t I

h I

f U IVI Federal Programs Corporation subsidiary of Camp Dresser & McKee Inc.,


LEGEND

WETLAND BOUNDARY

APPROXIMATE BOUNDARY OF FORMER, DISCHARGE LAGOON

FENCE

M W — 1 3 D - © - MONITORING WELL WITH CALCULATED 1 1 7 3 . 1 1 ^ ^ " ^ ^ T^BLE ELEVATION

-1173- WATER TABLE ELEVATION CONTOUR ( f t ms l

DASHED WERE INFERRED

,a NOTE: DATA COLLECTED ON JUNE U , 1998

f t mst - FEET ABOVE MEAN SEA LEVEL

SO 100 ISO

SCALE

FIGURE 3 - 3

GROUNDWATER FLOW MAP

PROJECT No. 3 2 2 0 - 0 3 2 300069

I

I I I I

I

I I I I t

LEGEND

• WETLAND BOUNDARY

APPROXIMATE BOUNDARY OF FORMER DISCHARGE LAGOON

- . . FENCE

M-17® S a L SAMPLE

UR-if5?l UNADILLA RIVER SURFACE WATER <>' AND SEDIMENT SAMPUNG LOCATION

S0N125W^ XRF SAMPLE > 10.000 m g A g

0 - 1 0 - ^ LABORATORY SAMPLE > 1.000 m g A ?

DQ

XRF SAMPLE > 10.000 m g A g AND LABORATORY SAMPLE > 1.000 m g A g

0 so 100 ISO

SCALE

I O U IVI Federal Programs Corporation A subsidiary of Camp Dresser & McKee Inc.


FIGURE 3 - 4

PREVIOUS SOIL AND SEDIMENT SAMPLE LOCATIONS

PROJECT No. 3 2 2 0 - 0 3 2

o* 3

300071

I

r

k

4.0 WORK PLAN RATIONALE

4.1 DATA QUALITY OB.IECTIVES

Data quality objectives (DQO) are qualitative and quantitative statements which specify the quality of data required to support decisions regarding remedial response activities. DQOs are based on the end uses of the data collected. The data quality and level of analytical documentation necessary for a given set of samples will vary, depending on the intended use of the data.

As part of the work plan scoping effort, site-specific remedial action objectives were developed. Sampling data for selected parameters will be required to evaluate whether or not remedial altematives can meet the objectives. The intended uses of these data dictate the data confidence levels. The guidance document Guidance for Data Quality Objectives Process, EPA OA/G-4, (EPA QAMS, 1994) was used to determine the appropriate analytical levels necessary to obtain the required confidence levels. The three levels are screening data with definitive level data confirmation, definitive level data and measurement-specific DQO requirements (see Table 4-1).

The applicability of these levels of data will be further specified in the QAPP. Sampling and analytical data quality indicators (DQIs) such as precision, accuracy, representativeness, comparability, completeness, and sensidvity, will also be defined in the QAPP.

Most of the analytical data gathered during previous investigations at the site will be assumed to be definitive level data that has had appropriate (QA/QC) verification.

4.2 WORK PLAN APPROACH

The remedial action objecdves for the RI/FS for the Hiteman Leather site include contamination-source identification, risk assessment, and evaluation of remedial alternatives. It is anticipated that the field investigation activities will generate data to support the remedial action objectives. Screening level and definitive level data will be required for these RI activities.

The objectives to beachieved during this RI/FS are: ,

Define the nature and extent of site contamination related to the Hiteman Leather site. The sampling program to achieve this goal is described in Section 5.3, Field Invesdgation.

Identify and quantify potential human health and ecological risks, if any, posed by the exposure to site contaminants. , . - ' -

Develop and screen remedial alternatives, discussed in Section 5.10, Remedial . Alternatives Development and Screening.

Conduct detailed analysis of appropnate remedial altematives, discussed in Sec'tion 5.11, Remedial Altematives Evaluation.

4-1

3 0 0 0 7 2

I

f

The RAC II field team personnel will collect environmental samples in accordance with the EPA-approved rationale, procedures, and protocols provided in the project specific QAPP. Samples for Routine Analytical Services (RAS) TCL organic compounds, TAL inorganics (metals and cyanide), and for low detection level volatile organic compounds in groundwater will be analyzed through the EPA CLP to meet the necessary quality assurance (QA) data requirements.

The following non-RAS parameters will be analyzed during this work assignment:

Subsurface Soil Samples- TOC, pH, hexavalent chromium, grain size distnbution, and RCRA toxicity characteristics, as defined in 40CFR 261.24, following extraction by the TCLP (lagoon soil samples only).

-Sediment Samples -TOC, pH, hexavalent chromium, and grain size distribution.

Surface Water Samples- Total dissolved solids (TDS), alkalinity, hardness, hexavalent chromium, and total suspended solids (TSS).

Groundwater Samples- TDS, alkalinity, TSS, total Kjeldahl nitrogen (TKN), hardness, ammonia, hexavalent chromium, nitrate-nitrite, TOC, Chemical Oxygen Demand (COD), Biochemical Oxygen Demand (BOD), sulfate, and chloride.

Fish Tissue Samples- TCL VOCs, TCL SVOCs, TCL pesticides/PCBs, TAL metals, and percent lipids.

The non-RAS parameters will be analyzed by EPA's Department of Environmental Science and Assessment (DES A) laboratory in Edison, New Jersey. If DES A does not have sufficient laboratory capacity at the time of sampling, then the non-RAS parameters will be submitted to the analytical laboratory under subcontract to CDM Federal.

i 4-2 • :

3 0 0 0 7 3

I TABLE 4-1

SUMMARY OF DATA QUALITY LEVELS APPROPRIATE TO RI/FS USES

IIITEMAN L E A T m R S r r ? WEST WINFIELD, NEWJYORK^ - \

DATA USES ANALYTICAL TFVEL TYPE OF .ANALYSIS

Site Characterization Monitoring During Implementation Evaluation of Altematives Engineering Design

SCREENING LEVEL WITH DEFINITIVE LEVEL CONFIRMATION

Total Organic/Inorganic Vapor Detection Using Portable Instruments

Water Quality Field Measurements using Portable Instruments

Risk Assessment Site Characterization Monitoring During Implementation Evaluation of Alternatives Engineering Design

DEFINITIVE LEVEL

Organics/Inorganics using EPA-approved methods. Includes CLP SOWs in addition to standard solid waste and water analyses. Analyses performed by laboratory.

Site Characterization Engineering Design Evaluation of Altematives

DQO LEVEL Field Instrument (see Note 1)

Measurements from field equipment

Qualitative measurements

,. DQO . Mea3ure.e„..specif,e DQO requirement as defined in the QAPP and teehnieal .peeifica.ions.

i 300074

RACS II WA 005 Disk l/4-l_DQ0.wpd

CO

o o" 3

300075

f

I I

5.0 TASK PLANS

The tasks identified in this section correspond directly to those in EPA's Statement of Work (SOW) for the Hiteman Leather Company Site dated September 30, 1999: Of these sixteen tasks, the tasks for the RI/FS presented below correspond to the twelve tasks presented in the Interim Final Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (EPA, 1988). Of these twelve RI/FS tasks, nine are considered part of theRI, and three are part of the FS. In addition, EPA's SOW include tasks for post RI/FS support and project closeout. The order in which these tasks are presented and the task numbering scheme correspond to the work breakdown structure provided in the EPA's SOW.

5.1 TASK 1 - PRO.TECT PLANNING AND SUPPORT

The project planning task generally involves several subtasks that must be performed in order to develop the plans and the corresponding schedule necessary to execute the RI/FS. These subtasks include project administration, conducting a site visit, performing a review and detailed analysis of existing data, attending technical meetings with EPA and other'support agencies (NYSDEC, NYSDOH), preparing this RI/FS Work Plan, preparing the QAPP and Health and Safety Plan (HSP), and procuring and managing subcontractors.

5.1.1 PROJECT ADMINISTRATION

The project administration activity involves regular duties performed by the CDM Federal Site Manager (SM) and the Program Support Office throughout the duration of this work assignment. CDM Federal will provide the following project administration support in the performance of this work assimment: ' t > '

The Site Manager will a ^

Prepare the technical monthly report Review weekly financial reports Review and update the project schedule Attend quarterly internal RAC II meetings Communicate regularly (at least weekly) with the EPA Remedial Project Manager (RPM)

• Prepare staffing plans

The Program Support Office personnel will:

, •• Review the Work. Assignment Technical and Financial Status • Prepare reports for the Monthly Progress Report • Provide technical resource management • Review the work assignment budget

• Respond to questions from the EPA Project Officer and Contracting Officer

• Prepare and submit invoices.

5-1

3 0 0 0 7 6

I

f

k

5.1.2 ATTEND SCOPING MEETING

Following the receipt of this work assignment the RAC II Team SM, the RAC II Program Manager, and the RAC II Team RI/FS Task Leader participated in a conference call kickoff meeting with the EPA Contracting Officer, the EPA Project Officer and the EPA RPM on February 9, 2000.

5.1.3 CONDUCT SITE VISIT

From March 6 through March 7, 2000, the RAC II Team SM , RAC E Team Senior Geologist, and the RAC n Team RI/FS Task Manager conducted an initial site visit to develop a conceptual understanding of local and site-specific conditions within the ai"ea of the Hiteman Leather Site.

5.1.4 DEVELOP DRAFT WORK PLAN AND ASSOCIATED COST ESTIMATE

The RAC II Team has prepared this RI/FS Work Plan in accordance with the contract terms and conditions. The RAC II Team used information from EPA guidance documents (as appropriate) and technical direction provided by the EPA RPM as the b'asis for preparing this RI/FS work plan.

This work plan includes a comprehensive description of project tasks, project documentation, and project schedule. The RAC II Team uses internal QA/QC systems and procedures to assure that this work plan and other deliverables are of professional quality requiring only minor revisions (to the extent that the scope is defined and is not modified). Specifically, the work plan includes the following:

•a-

Identification of RI/FS project elements including planning and activity reporting documentation. A detailed work breakdown structure of the RI/FS that corresponds to the work breakdown structure that was provided in the EPA SOW dated September 30, 1999.

The RAC II Team's approach for each task to be performed, including a detailed description of each task; the assumptions used; any information to be produced during and at the conclusion of each task; and a description of the work products that will be submitted to EPA. Issues relating to management responsibilities, site access, site security, contingency procedures and storage and disposal of investigation derived wastes will also be addressed.

A schedule with dates for completion of each required activity, cntical path milestones and submission of each deliverable required by the SOW and the anticipated review time for EPA (Section 7). A list of key RAC n Team personnel that will support the project (see Section 8.0) and the subcontractor services required to complete the field investigation (see Section 5.1.11).

5-2

300077

I

t

i

5.1.5 NEGOTIATE AND REVISE DRAFT WORK PLAN/BUDGET

RAC n Team personnel attended a work plan fact finding/negotiation meeting with EPA via teleconference on August 15,2000. EPA and the RAC II Team personnel discussed and agreed upon the final technical approach and costs required to accomplish the tasks detailed in this work plan. The RAC II Team will submit this Final Work Plan and budget that incorporates the agreements made in the negotiation meeting. The RAC II Team will submit this Final Work Plan and budget in both hard copy and electronic formats.

5.1.6 EVALUATE EXISTING DATA AND DOCUMENTS

As part of the preparation of this work plan, the RAC II Team obtained information from the EPA RPM and NYSDEC. The background docum'ents were copied, reviewed, and incorporated, where applicable, in this planning document. The RAC II Team has prepared summary tables for use in this work plan. The RAC II Team will obtain and review additional documents as part of the project planning process.

5.1.7 QUALITY ASSURANCE PROJECT PLAN

Quality Assurance Project Plan

The RAC n Team will prepare a QAPP in accordance with the current revision of EPA QA/R-5 and the approved EPA Region n QAPP guidance and/or procedures. The RAC II Team will describe the project objectives and organization, functional activities, and QA/QC protocols that will be used to achieve the required DQOs. The DQOs will, at a minimum, reflect the use of analytical methods foridentifyingandaddressin'gcontaminatioiiconsistent with the levels for remedial action objectives identified in the National Contingency Plan.

The QAPP will include sample locations and sampling frequency; a list of sampling equipment; personnel and equipment decontamination procedures; sample handling and analysis; and a breakdown of samples to be analyzed through the CLP and through other laboratory sources.

The QAPP will also consist of sections addressing site management including site control and site operations. The site control section describes how approval to enter the areas of investigation will be obtained, along with the site security control measures, and the field office/command post for the field investigation. The logistics of all field investigation activities will also be described.

^a^

The site operations section will include a project organization chart and will delineate the responsibilities of key field and office team members. A schedule will be included that shows the proposed scheduling of each major field activity.

Other Quality Assurance/Quality Control Activities

Quality assurance activities to be performed during this project may also include intemal office and field or laboratory technical systems audits, field planning meetings, and quality assurance reviews

5-3

300078

f

I

I • of all project plans, measurement reports, and subcontractor procurement packages. The quality ^ ^ " assurance requirements are further discussed in Section 8.2 of this work plan.

5.1.8 HEALTH AND SAFETY PLAN

The RAC H Team will prepare a HSP in accordance with 40 CFR 300.150 of the NCP and 29 CFR 1910.120 (1).(1) and (1)(2). The HSP includes the following site-specific information:

a hazard assessment training requirements definition of exclusion, contaminant reduction, and other work zones monitoring procedures for site operations safety procedures personal protective clothing and equipment requirements for various field operations disposal and decontamination procedures , other sections required by EPA. The HSP also includes a contingency plan which addresses site specific conditions .which may be encountered.

The site HSP will address field activities conducted during the RI, which at present includes but are not hmited to, site activities conducted by the RAC n Team (Sections 5.3.3 and 5.3.4)

In addition to the preparation of the HSP, health and safety activities will be monitored throughout the field investigation. The CDM Federal Regional Health and Safety Coordinator, or designated representative will attend the initial field planning meeting and may perform a site visit to ensure that all health and safety requirements are being adhered to. The RAC II Team will designate a member of the field team to serve as the onsite health and safety coordinator throughout the field program. During the field investigation, this person will report directly to both the Field Team Leader and the Regional Health and Safety Coordinator. The Health and Safety Plan will be subject to revision as necessary based on new information that is discovered during the field investigation.

5.1.9 NON-RAS ANALYSES

The following non-RAS parameters will be analyzed during this work assignment:

Subsurface Soil Samples- TOC, pH, hexavalent chromium, grain size distribution, and RCRA toxicity characteristics, as defined in 40CFR 261.24, following TCLP extraction (lagoon soil samples only). -

Sediment Samples -TOC, pH, hexavalent chromium, and grain size distribution.

Surface Water- TDS, alkalinity, hardness, hexavalent chromium, and TSS.

Groundwater Samples- TDS, alkalinity, TSS, TKN, hexavalent chromium, hardness, ammonia, nitrate-nitnte, TOC, COD, BOD, sulfate, and chloride.

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plan that all that concrete rubble and debris to be disposed of by the subcontractor will be classified by EPA as non-hazardous.

• a subcontractor that will be responsible for the removal and proper disposal of all RI generated waste soils, liquids, solids, and personal protective equipment, a subcontractor to haul and dispose of investigation derived waste. It has been assumed for this work plan that all that groundwater extracted dunng well development and sample purge water will be contained and disposed of by the subcontractor.

All subcontractor procurement packages will be subject to CDM Federal's technical and quality assurance reviews.

5.1.12 PERFORM SUBCONTRACT MANAGEMENT

The CDM Federal SM and the CDM Federal Subcontracts Manager will perform the necessary management and oversight of the subcontractors (identified under Section 5.1.11) needed for the perfomiance of this RI/FS. CDM Federal will institute procedures to monitor progress, and maintain systems and records to ensure that the work proceeds according to subcontract and RAC EI contract requirements. CDM Federal will review and approve subcontractor invoices and issue any necessary subcontract modifications.

5.1.13 PATHWAY ANALYSIS REPORT

The RAC II Team will prepare a Pathways Analysis Report (PAR) in accordance with OSWER Directive 9285.7-OlD-l dated December 17, 1997, entitied Risic Assessment Guidelines for Superfund - Part D.

. Prior to the risk assessment process, the RAC II Team will coordinate with the EPA RPM to define potential exposure pathways and human receptors. To accomplish this, the RAC II Team will review all available information obtained from EPA pertaining to the Hiteman Leather site, including data generated during previous investigations. Background information on the site will be summarized, and samples collected and the chemicals analyzed for, by media will be discussed. The treatment of data sets {e.g., duplicates, splits, blanks (trip, field, and laboratory), multiple rounds, and qualified and rejected data) will be discussed. Present and future-use exposure pathways and receptors will be tentatively identified in the PAR and finalized in Task 7.0 based on site data generated by the site investigation. Based on cuirent knowledge the potential exposure scenarios include: future residential exposures, future construction workers, cument and future site workers, recreational exposures, and trespassers. Exposure variables to be used for the calculation of daily intakes will be presented. Carcinogenic and noncarcinogenic toxicity values for contaminants of concem and the sources of these values will be presented in the PAR. The exposure pathways and receptors, exposure variables, and toxicity values will be presented in tabular form in accordance with the Standard Tables of RAGS Part D. These tables and supporting text will be submitted in the Pathways Analysis. Report.

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I Upon EPA's approval of the Work Plan and the Pathways Analysis Report, the RAC II Team will

^ ^ - initiate the risk assessment process which is comprised of the components defined in Section 3.7.

5.2 TASK 2 - COMMUNITY RELATIONS

This task covers technical and other community relations support to be provided by the RAC II Team under this work assignment. The RAC II Team will provide community relations support to EPA throughout the human health risk assessment in accordance with Community Relations in Superfimd -A Handbook (EPA, lune 1988a).

5.2.1 COMMUNITY INTERVIEWS

Communitv Interviews Preparation - The RAC II Team Community Relations Speciahst (CRS) and Community Relations Technical Assistance team will review relevant background documents as provided by the EPA RPM or public affairs specialist. The CRS will then prepare a list of potential interviewees for EPA's review and final selection. The EPA RPM will conduct interviews with the appropriate government officials (federal, state, county, borough), environmental groups, local broadcast and print media and any other relevant individuals or groups, either in person or via a telephone call. The CRS will accompany the EPA RPM and public affairs specialist on the interviews and will provide logistical support and function as directed by the EPA RPM.

Communitv Interviews Questions - The RAC II Team will prepare draft interview questions for EPA's review and approval. The RAC II Team will then prepare final interview questions incorporating all EPA comments.

5.2.2 COMMUNITY RELATIONS PLAN

The RAC n Team will develop a draft Community Relations Plan (CRP) which presents an overview of the community's concerns and includes the following elements:

1) site background including site location, site description and site history; 2) community overview including a community profile, community concerns and

community involvement; 3) community involvement objectives and planned activities with a schedule to

accomplish those objectives; 4) mailing list of contacts and interested parties; 5) name and address of the infonnation repositories and public meeting facility

locations; 6) list of acronyms; and 7) a glossary.

The RAC II Team prepare and submit the final CRP after incorporating comments from EPA.

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5.2.7 INFORMATION REPOSITORIES

In accordance with the SOW, this task is cumently not applicable to this work assignment.

5.2.8 SITE MAILING LIST

The RAC n Team will prepare the site mailing list with two updates dunng the work assignment's penod of performance. This mailing list is assumed to contain 50 names and addresses. A copy of the mailing list on diskette and mailing labels will be provided to EPA upon request. EPA will do the actual mailing of any information to the community.

5.2.9 RESPONSIVENESS SUMMARY SUPPORT

The RAC D Team will provide administrative and technical support,for the site responsiveness summary. The RAC II Team will provide assistance in compiling, summarizing and responding to comments received during the public commehf period on the Proposed Plan and Feasibility Study. For budget purposes, the RAC II Team assumes 30 separate comments (including duplicates).

5.3 TASK 3 - FIELD INVESTIGATION

This task includes all activities related to implementing field investigations at the Hiteman Leather Company Site. The task descriptions have been developed after review and evaluation of the site background data currenUy available to the RAC II Team.

The RAC II team has evaluated the existing hydrogeological and geological data and has identified several data gaps. The following data gaps remain that concem the hydrogeologic framework of the site and the nature and extent of site related groundwater contamination:

• Hydrogeologic connection/gradient between the bedrock, the overburden aquifer and the lagoon materials on the north side of the Unadilla River;

• Depth and degree of weathering of the bedrock and its relation to contaminant migration, north of the Unadilla River; .

• Vertical and horizontal extent of lagoon boundaries and the subsequent volume of lagoon waste materials . .

• Lack of records that indicate past spills or wastewater overflow at the site, specially around the sluiceway between the lagoons and the loading dock.

• Extent of contamination beneath the buildings.

The proposed field program has been designed to address the gaps in existing data; to verify existing data (when necessary); to minimize the duplication of previously collected data; and to provide sufficient infonnation to complete the RI, FS, and risk assessment.

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The field investigation has been'divided into two phases. Field Activity 1 andField Activity 2. Field Activity 1 is designed to characterize existing conditions at the site. Aspartof the first phase of field activities, all the elevations and locations of existing monitoring wells will be surveyed as part of the site wide-topographic survey. The wells will subsequently be redeveloped and resampled by the RAC nTeam. Synoptic water level measurements will also be collected from the newly redeveloped wells. Non-intrusive sampling activities will also be performedin Field Activity 1 to confirm contaminant concentrations in the Unadilla River and site wetiand areas.

The RAC II Team will evaluate the newly collected hydrogeological information including groundwater flow direction and contaminant migration data to determine if additional monitonng wells are necessary to complete the characterization of site groundwater conditions. Analytical data from the wetiand and river sampling will also be reviewed to determine if additional activities are necessary to characterize the nature and extent of contamination in the site's environmental media. The results from Field Activity 1 will be summarized in a technical memorandum to EPA. The technical memorandum will also propose the locations and depths of additional monitoring wells as well as the locations of additional environmental samples and off-site sampling activities.

Field Activity 2 will be initiated upon EPA approval of the technical memorandum and will include soil boring sampling, monitoring well installation, test pit activities, hydraulic testing, groundwater sampling from existing and newly installed wells, and, if directed by EPA, additional environmental sampling in the Unadilla River and site wetlands.

Field Activity 1

During the Field Activity 1, the following activities will be performed:

• . Topographic survey of the site. Mapping of the location and elevations of existing wells

(5.3.r) Collection of synpotic water levels (5.3.3.2) Redevelopment/resampling of existing wells (5.3.1) Collection of wetland sediment samples (5.3.5.2) Collection of Unadilla River surface water samples/sediment samples (5.3.5.1) Collection of groundwater samples from the two Municipal Wells (5.3.5.4)

Field Activity 2

During the Field Activity 2, the following activities will be performed:

• Soil Bonngs - to charactenze potential hot spots outside of the lagoon includes 10 contingency bonngs to charactenze two offsite properties (5.3.4.1) Lagoon Soil Borings- to charactenze depth of waste in lagoons (5.3.4.2) Surface Soil Samples- collected at all soil boring locations (5.3.5.3) Geotechnical borings - installed along the northem bank of the Unadilla River 5.3.4.5) Ecological characterization and wetland delineation (5.3.6) Fish Tissue Sampling (5.3.5.5) Building bonngs- to charactenze soil quality under buildings 5.3.4.3)

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Existing Monitoring Well Redevelopemeht

All existing site monitoring wells will be redeveloped and will subsequently be resampled two weeks after redevelopment. Redevelopment procedures will be fully detailed in the QAPP.

Cultural Resources Survey

In accordance with Section 106 of the National Historic Preservation Act, as amended, and the EPA's CERCLA Compliance with Other Laws Manual: Part II, a Stage 1 Cultural Resources Survey will be conducted to locate and identify cultural resources within and near the Hiteman Leather Company Site. Initially, a Stage IA survey will be conducted.to develop a sensitivity model for cultural resources in order to focus any future investigation. A Stage IB Survey, which includes field research, may be conducted based on the predictions of the Stage IA sensitivity model.

5.3.2 MOBILIZATION AND DEMOBILIZATION

Mobilization and Demobilization

This subtask will consist of property access, field personnel orientation", field trailer and equipment mobilization, and demobilization. Prior to field activities, each field team member will review all project plans and participate in a field planning meeting to become familiar with the history of the Site, health and safety requirements, field procedures, and related QC requirements. Field personnel also will attend an on-site tailgate kick-off meeting immediately prior to the commencement of field activities. All new field personnel will receive a comparable briefing if they did not attend the initial field planning meeting and/or the tailgate kick-off meeting. Supplemental meetings may be conducted as required by any changes in site conditions or to review field operation procedures.

Equipment mobilization will entail the ordering, rental, and purchasing of all equipment needed for each part of the field investigation. The field equipment will be inspected for acceptability and instruments calibrated as required prior to use. This task also involves the construction of a decontamination area for decontamination of sampling equipment and personnel. A separate decontamination pad will be constructed by the drilling subcontractor for drilling equipment.

Health and safety work zones, including personnel decontamination areas, will be established. Local authorities such as the police and fire departments will be notified prior to the start of field activities. Equipment will be demobilized at the completion of each field event, as necessary. Demobilized equipment will include sampling equipment, .drilling subcontractor equipment, health and safety equipment, decontamination equipment, and field screening laboratory equipment.

5.3.3 HYDROGEOLOGICAL ASSESSMENT

5.3.3.1 Monitoring Well Installation

The purpose of the monitonng well installation program is to gather subsurface soil data for lithological logging; to gather information on both the vertical and horizontal groundwater hydraulic gradients; and to more accurately define the groundwater flow direction. Previous data collection

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All new overburden wells will be constructed of 4-inch diameter PVC casing with 10-foot 0.010 inch slot screens. The overburden wells will be developed by the drilling subcontractor following installation. It should be noted that the RAC II Team has proposed the use of PVC casing, instead of stainless steel, since chromium and other inorganics are groundwater contaminants of concem at

. the Hiteman Leather site.

5.3.3.2 Groundwater Elevation Measurements

Synoptic Groundwater Level Measurements -During Field Activity 1, the RAC II Team will collect synoptic water level measurements from all existing site monitonng wells. During Field Activity 2, synoptic water level measurements will be collected from all existing and newly installed monitoring wells. Groundwater contour maps will be constructed for each of the groundwater monitoring zones (e.g., in the overburden and in the bedrock) and will be included in the technical memorandum and in the RI Report. '~ .

Synoptic water level measurement procedures will be fully described in the QAPP.

Continuous Water Level Measurements - To obtain data to support the proposed hydraulic testing, the RAC n Team will collect continuous water levels from selected wells (anticipated'to include two bedrock wells, four shallow, and four deepoverburden wells) over a two week period. This activity will only be conducted if the RAC II team is directed by EPA to conduct an aquifer test. Continuous water level measurement procedures will be fully described in the QAPP.

5.3.3.3 Slug Testing

In-situ hydraulic conductivity testing will be performed in selected site monitoring wells to provide hydraulic conductivity data to support evaluation of remedial altematives in the FS. A standard slug test consists of an instantaneous injection (a stainless steel slug) that causes immediate change of . water level in a well. The subsequent amount of rise or decline of water levels within the well with re.spect to time is recorded and used to calculate hydraulic conductivities of the in-situ materials in the screen interval.

The data obtained during the slug test will be used to estimate the hydraulic conductivity within the localized aquifer zone surrounding the monitoring welk Slug tests are performed as a first estimate of aquifer hydraulic conductivity because they:

• Are low in cost, simple and relatively rapid to perform;

• Do not produce water wastes; and

• Provide information on spatial variations in hydraulic properties (Butier, 1997).

The hydraulic conductivity data combined with hydraulic head gradients will be used to estimate a site wide groundwater flow velocity.

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The slug tests will be performed during Field Activity 2. For cost estimation purposes, it has been assumed that slug tests will be performed in the four newly installed overburden wells and in eight existing overburden monitonng wells. ' D

The methods, equipment, and measurement parameters required to conduct conductivity testing will be fully described in the QAPP.

5.3.3.4 Hydraulic Testing

If directed by the EPA, the RAC n Team will conduct a 72-hour aquifer test. The aquifer tests will monitor the actual response to pumping of select wells by monitoring drawdown in surrounding observation wells. It is anticipated that the design of the test, including selection of the test wells and observation wells and pumping rates, will be determined once specific information is obtained.

The aquifer test will begin with the collection of continuous water levels from selected wells (anticipated to include two bedrock wells, four shallow, and four deep overburden wells) over a two week penod. A step-drawdown test and a constant-rate test will then be conducted in the extraction well. The tests will be performed to determine well yields (Q), aquifer transmissivity (T), and to refine estimates of influent concentrations to be delivered to the proposed groundwater treatment system.

Each selected well will be pumped at a constant rate for a penod of up to 72 hours. It is assumed that the water levels in observation wells of varying distances and directions from the pumping well will be monitored by data loggers and checked manually by RAC II Team field personnel.

It is anticipated that the drilling subcontractor will be required to perform the pump testing at the selected site well. All procedures and protocols for the 72-hour aquifer test wifl be provided in the QAPP.

It should be noted that due to the large volume of water generated during aquifer testing, CDM Federal has assumed that the groundwater extracted by the drilling subcontractor will subsequentiy be discharged. ' -

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5.3.4 SOIL BORING, DRILLING, AND TESTING

5.3.4.1 Soil Borings

The RAC II Team will collect samples from 27 soil borings located outside the wastewater lagoons to obtain data to characterize both the nature and extent and spatial distnbution of subsurface contamination. Previous subsurface soil sampling activities indicate potentially significant contamination outside of the former lagoons that has not been adequately characterized. In addition, the most recent analytical results available for chromium in soil are primarily field testing by XRF, which has a data quality level not entirely adequate for risk assessment purposes and remedial altemative selection. Figure 5-1 illustrates the proposed soil bonng locations. It should be noted

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that sampling locations may be refined at the time of the investigation to more closely reflect field conditions.

It is anticipated that 27 soil borings will be dnlled to characterize potential hot spots outside of the lagoon area. One bonng will be drilled near underground storage tank (RSB-OI), one bonng will be dnlled adjacent to the sluiceway (RSB-02), one adjacent to the settling tank (RSB-03), three borings (RSB-04 to RSB-06) wilFalso be drilled between the lagoon and the loading dock to ascertain that no spills or wastewater overflow occurred along the sluiceway, one adjacent to the weir box in the wetland area (RSB-07), one boring will be adjacent to the former location of SB-10, where elevated chromium concentrations were detected during the NYSDEC Rl (RSB-08), three bonngs (RSB-09, RSB-10, RSB-11) will be drilled to charactenze the matenal that has been landfilled along the site's eastern embankment area, and one will be drilled adjacent to MW-IS (RSB-12).

In addition, five contingency borings have been proposed to characterize any areas, identified during Field Activity 1, that could serve as potential contamination sources. In addition, if directed by EPA, the RAC n Team will install 10 borings in offsite properties that may have been used by Hiteman Leather as depot and storage areas. The 5 contingecy soil borings and 10 offsite soil borings are not shown on Figure 5-1.

Subsurface soil samples will be collected via the hollow stem auger method. Continuous split-spoon samples will be collected from the two-foot interval in advance of the augers to a total depth of 10 feet bgs. Each split spoon will be immediately screened with an organic vapor analyzer (OVA) and/or a photoionization detector (PED), upon being opened, and will be logged by the RACH Team field geologist. A minimum of two samples will be collected from each boring location. One sample will be collected from the two to four-foot depth interval and a second sample will be collected at the boring's terminal depth (8-10 feet bgs). A third contingency soil sample will be collected from depth intervals where visual contamination or elevated organic vapors are noted.

Subsurface soil samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP. All soil samples will be analyzed for TCL/TAL parameters through the EPA CLP. In addition, all of the soil samples will be analyzed for hexavalent chromium, TOC, grain size, and pH by EPA's DESA laboraotory (if available) or ' the RAC II Team laboratory subcontractor. All samples will be analyzed using the most current EPA-approved methods that will be detailed in the QAPP.

For cost estimation puiposes, it has been determined that a maximum of 81 subsurface samples will. be collected from 27 soil bonng locations.

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5.3.4.2 Lagoon Soil Borings

The RAC H Team will collect samples from three soil bonngs (LSB-01, LSB-02, LSB-03) to confirm both the nature and extent and spatial distribution of subsurface contamination within the wastewater lagoons. In addition, the most recent analytical results available for chromium in soil are pnmanly field testing by XRF, which has a data quality level not entirely adequate for risk

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assessment purposes and remedial altemative selection. Figure 5-1 illustrates the proposed soil boring locations. It should be noted that sampling locations may be refined at the time of the investigation to more closely reflect field conditions.

Subsurface soil samples will be collected via the hollow stem auger method. Continuous split-spoon samples will be collected from the two-foot interval in advance of the augers to a total depth of 20 feet bgs. Each split spoon will be immediately screened with an OVA and/or a PID, upon being opened, and will be logged by the RAC n Team field geologist^ A minimum- of two samples will be collected from each bonng location. One sample will be collected from the depth interval that corresponds to the water table and a second sample will be collected at the boring's terminal depth (18-20 feet bgs). A third contingency soil sample will be collected from depth intervals where visual contamination or elevated organic vapors are noted.

Subsurface soil samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP. All soil samples will be analyzed for TCL/TAL parameters through the EPA CLP. In addition, all of the soil samples will be analyzed for hexavalent chromium, TOC, grain size, pH, and RCRA toxicity characteristics following TCLP extraction by EPA's DESA laboratory (if available) or the RAC II Team laboratory subcontractor. All samples will be analyzed using the most current EPA-approved methods that will be detailed in the QAPP.

For cost estimation purposes, it has been determined that a maximum of 9 subsurface samples will be collected from three soil boring locations.

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5.3.4.3 Building Borings

The RAC D Team will collect samples from five soil borings (BB-1 to BB-5) to characterize the nature and extent of contamination beneath the facility buildings. The locations of the boring will be based on a review of locations of former pits, vats, tanks, and production areas. Figure 5-1 illustrates the proposed soil boring locations. It should be noted that sampling locations may be refined at the time of the investigation to more closely reflect field conditions.

Subsurface soil samples will be collected via the hollow stem auger method, which will be advanced through the existing floor slab. Continuous split-spoon samples will be collected from the two-foot interval in advance of the augers to a total depth of 10 feet bgs. Each split spoon will be immediately screened with an OVA and/or PID upon being opened, and will be logged by the RAC n Team field

' geologist. A maximum of two samples will be collected from each boring location. One sample will be collected immediately underneath the concrete and a second sample will be collected at the boring's terminal depth (8-10 feet bgs).

Subsurface soil samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP. All soil samples will be analyzed for TCL/TAL parameters through the EPA CLP. In addition, all of the soil samples will be analyzed for hexavalent chromium, TOC, grain size, by EPA's DESA laboratory (if available) or the RAC II Team laboratory subcontractor. All samples will be analyzed using the most cument EPA-approved methods that will be detailed in the QAPP.

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5.3.4.4 Test Pit Program

The RAC II Team will conduct a test pit investigation to accurately delineate the horizontal extent of the lagoon boundanes. Although the approximate boundanes of the former lagoon have been established, it is necessary to delineate and survey the exact boundaries of the former lagoon to provide data required to support the selection of a remedial altemative. The approximate locations of the test pits are shown in Figure 5-1. It should be noted that test pit locations may be refined at the time of the investigation to more closely reflect field conditions.

Two test pits will be excavated out laterally from both the east and west sides of the lagoon (RTP-01, RTP-02, RTP-06, RTP-07) and three test pits will be excavated on the north side of the lagoon (RTP-03, RTP-04, and RTP-05).

Prior to the test pit investigation, aerial photographs and historical records will be reviewed. In addition, the NYSDEC RI geophysical data will be reviewed to determine the approximate limit of waste materials. Based on the review information, the field team will locate and stake the approximate boundary of the waste/fill material and identify test pit locations. No analytical samples will be collected from the test pits because it is believed that the chemical characteristics of the former lagoons has been sufficiently characterized.

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Digging of test pits will commence from the inner portion of the estimated lagoon boundary, and proceed outward toward the estimated lagoon boundary to the point where waste materials are no longer observed. Excavated material will be placed on plastic sheeting adjacent to the test pit. The excavated material will be retumed to the test pit in the order that it was removed.

. The test pits will be logged by the RAC II field geologist and will include the following information: surface features before excavation; depth of the test pit; all relevant soil horizons and soil features including desiccation cracks (if any); moisture content of the soil and waste material; and soil classification using the Unified Soil Classification System. Each test pit will be sketched, showing pertinent geologic and waste matenal features. A photo of each test pit location and excavation will be included with the test pit log. All test pit locations will be surveyed at the completion of the test pit program.

5.3.4.5 Unadilla River Geotechnical Borings

Geotechnical borings will be drilled at three locations along the northem bank of the Unadilla River (GTB-01, GTB-02, and GTB-03). The purpose of the geotechnical borings is to provide information on the physical and mechanical engineering properties of the material, stratification, and thickness for use in evaluating remedial altematives for the area, particularly the eroded slopes along the Unadilla River. Because the banks of any river are a constantly changing and shifting environment, the most recent available data is required.

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The borings will be drilled with hollow stem augers, and will be sampled continuously through the overburden and ten feet into the shale bedrock. Soil structure and lithology will also be characterized dunng split spoon sampling and coring of the geotechnical borings. After completion of drilling, the borings will be backfilled with a cement and bentonite grouted to within two feet below the ground surface. Native surface soils will be placed in the remaining portion of the borehole.

Geotechnical soil samples will be collected from these borings to further characterize the geologic environment. Subsurface soil samples will be submitted for geotechnical analysis from various depths from the three geotechnical bonngs to provide sufficient data for the FS. The depth of soil samples submitted from each bonng will be determined by the field geologist overseeing the drilling operations. The sampling depths will be selected based on the physical and mechanical charactenstics of the subsurface materials encountered,(i-e., soft clay or silts that may be relevant to the stability). It is anticipated that up to 4 subsurface soil samples will be collected from each boring location. Depending on the stiffness of the material, one Shelby tube (undisturbed soil sample) will be collected from each of the three geotechnical borings.

Shelby tube samples will be analyzed for Atterberg limits or gradation distribution, permeability, shear strength,, and visual descriptions of undisturbed (if possible) soil structures. The remaining subsurface soil samples will be analyzed for grain size distribution.

Rock core will be obtained from each of the geotechnical borings for engineering classification. For estimation purposes, the rock cores are assumed to be 10 feet in length. The rock core will be inspected and the following information will be recorded on the rock core logs: hthology; mineralogy; degree of cementation; color; grain size; percent recovery; bedding character (e.g., cross bedding); rock quality designation (RQD); fracture density; and any other pertinent data or observations (e.g., water loss). This information is necessary to determine the suitability of potential remedial altematives, such as reactive barriers or pressure grouting, that may be evaluated. A photograph of all labeled cores will be taken and submitted with the logs.

5.3.5 ENVIRONMENTAL SAMPLING

This section summarizes the number of samples and associated analytical parameters for the various environmental media that will be sampled during this RI. A summary of the numbers of samples-for each media and the associated sample analysis parameters is provided in Tables 5-1 and 5-2. Analyses will be performed in accordance with the most current EPA methods.

5.3.5.1 Surface Water and Sediment Sampling

The RAC II Team will collect collocated surface water and sediment samples from the Unadilla River to determine the impact of the site contamination on the river, and to define the nature and extent of contamination potentially migrating off-site. Previous surface water and sediment sampling efforts appear to indicate that contamination was migrating from the'site to the Unadilla River at the time of the prior sampling. Therefore, it is necessary to detennine if contaminant.

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migration to the Unadilla River potentially continues and subsequentiy, determine any associated risks to human health and the environment.

In order to provide background data for use in the RI and RA, the RAC II Team will collect a surface water and sediment sample from one location that is anticipated to be free from site impacts and site-specific contamination. The proposed Field Activity 1 surface water and sediment sample locations are shown in Figure 5-1. It should be noted that final sampling locations may be refined at the time of the investigation to more closely reflect field conditions.

Dunng Field Activity 1, surface water and sediment samples will be collected at the following locations:

One surface water and one sediment sample pair will be collected to define background conditions in the Unadilla River (UR-l). The exact location of the background samples will be determined based on visual observation of the streamflow and sediment characteristics. The samples will be collected from locations where the stream flow and sediment characteristics are similar to those at the downstream sampling locations.

One surface water/sediment pair will be collected adjacent to the to the building area where the water from the seuling tank flowed into the stream (lJR-2). One sample pair will be collected at the point of discharge of lagoon into the river (UR-3). The other sample pair will be collected adjacent to the wetland discharge area (UR-4). The stream bed in this area is composed primarily of bedrock and weathered bedrock fragments. As such, it may be difficult to collect useful sediment samples in this stretch of the river. In the event that it is not possible to collect useful sediment samples, the field team will collect sediment samples at likely sediment depositional areas downstream. The locations of these samples will be determined based on the judgement of the field team leader and the characteristics of the sediment at the sampling location.

The final two surface water/sediment pairs will be collected at locations further downstream in the Unadilla River (up to one mile downstream) (UR-5 and UR-6) to delineate the extent of downstream contamination. The exact locations of these sample pairs will be determined in the field using visual observation in conjunction with a USGS topographic map. It should be noted that downstream location UR-6 is not shown on Figure 5-1.

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The depth and flow velocity of the stream as well as dissolved oxygen (DO), pH, temperature, conductivity, and oxidation-reduction potential (Eh) of the surface water will be measured at each of the sampling locations. These data will be used in determining the fate and transport characteristics of site-related contaminants. Surface water flow measurement procedures will be fully detailed in the QAPP.

If directed by EPA, the RAC II Team will collect surface water and sediment samples from four additional locations to further delineate the downstream extent of site- related contamination in the Unadilla River. The Field Activity 2 sample locations will be proposed in the technical memorandum submitted to EPA after the evaluation of Field 1 Activity data.

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Surface water samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP. All surface water samples will be analyzed for TCL/TAL parameters through the EPA CLP. All surface water samples will also be analyzed for hexavalent chromium, TDS, TSS, alkalinity and hardness by EPA DESA's laboratory (if available) or by the RAC IITeam laboratory subcontractor. All samples will be analyzed using the most current EPA-approved methods, which will be detailed in the QAPP.

Sediment samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP. All sediment samples will be analyzed for TCL/TAL parameters through the EPA CLP. All sediment samples will also be analyzed for hexavalent chromium, TOC, pH, and particle size by EPA DESA's laboratory (if available) or by the RAC II Team laboratory subcontractor. All samples will be analyzed using the most current EPA-approved methods, which will be detailed in the QAPP.

For cost estimation purposes, it has been assumed six surface water and sediment samples will be collected during Field Activity 1 and an addition four surface water and sediment samples will be collected during Field Activity 2. A total of 10 surface water and sediment samples will be collected.

5.3.5.2 Wetland Sediment Soil Sampling

During Field Activity 1, the RAC II Team will collect sediment samples from 10 locations in the site wetiands areas. Previous sampling indicates wide-spread contamination in the wetiand. However, the contaminant distribution was so substantial, an accurate delineation of the contamination was not obtained. In addition, the most recent analytical results available for chromium in soil are primarily field testing by XRF, which has a data quality level not entirely adequate for risk assessment purposes and remedial altemative selection. Therefore, additional wetiand sediment sampling to accurately determine the nature and extent of the contaminated wetland sediment is necessary.

In order to provide background data for use in the RIandRA, the RACH Team will collect sediment samples from two locations that are anticipated to be free from site impacts and site-specific contamination. An off site wetiand search will be conducted to locate a wetland with similar characteristics as the one on-site. Figure 5-1 illustrates the proposed Field Activity 1 wetland sediment sample locations. It should be noted that sampling locations may be refined at the time of the investigation to more closely reflect field conditions.

If directed by EPA, the RAC II Team will collect sediment samples from five locations to further delineate the nature and extent of site related contamination in the site wetiand areas. The Field Activity 2 sample locations will be proposed in the technical memorandum submitted to EPA after the evaluation of Field 1 data.

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To provide data on the vertical extent of contamination, sediment samples will be collected from two depth intervals, 0-6 inches bgs and 18- 24 inches bgs. Sediment samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP.

All sediment samples, will be analyzed for TCL/TAL parameters through the EPA CLP. All sediment samples will also be analyzed for hexavalent chromium, TOC, pH, and particle size by EPA's-DESA laboratory (if available) or by the RAC II Team laboratory subcontractor. All samples will be analyzed using the most current EPA-approved methods. The analytical methods will be detailed in the QAPP.

For cost estimation purposes, it has been determined that 24 sediment samples will be collected from 12 locations during Field Activity 1 and 10 sediment samples will be collected from five locations during Field Activity 2. A total of 34 sediment samples will be collected.

5.3.5.3 Surface Soil Sampling

The RAC II Team will collect surface soil samples to obtain data for the site risk assessment and to characterize both the nature and extent and spatial distribution of surficial soil contamination. Surface soil samples will be collected from all of the boring locations throughout the site. Figure 5-1 illustrates the proposed soil boring locations. It should be noted that sampling locations may be refined at the time of the investigation to more closely reflect field conditions.

Surface soil samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP. All soil samples will be analyzed for TCL/TAL parameters through the EPA CLP. Samples will also be analyzed for hexavalent chromium, TOC, grain size, pH, and RCRA toxicity characteristics following extraction by TCLP (lagoon surface soil samples only) by EPA's DESA laboratory (if available) or by the RAC II Team laboratory subcontractor. All samples will be analyzed using the most current EPA-approved methods. The analytical methods will be detailed in the QAPP.

For cost estimation purposes, it has been detemiined that 22 surface soil samples will be collected from soil boring locations throughout the site.

5.3.5.4 Groundwater Sampling

The RAC II Team will collect two rounds of groundwater samples to define the nature and extent of site related contamination in the underlying groundwater. During Field Activity 1, groundwater samples will be collected from the 21 existing site monitoring wells and from the two municipal production wells. Data from Field Activity 1 will be used to characterize current contaminant concentrations and assist the RAC II Team develop a better understanding of the complex hydrogeological conditions at the site.

Dunng Field Activity 2, a round of groundwater samples will be collected from the 21 existing site wells and the seven newly installed monitonng wells to confiiTn contaminant concentrations.

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Synoptic water level measurements will be collected from all wells prior to sampling. Monitoring wells will be purged and sampled following an EPA-approved low flow procedure and other EPA-approved sampling methodologies which will be fully detailed in the QAPP. DO, oxidation-reduction potential, pH, temperature, conductivity, and turbidity measurements will be collected in the field at the time of sampling.

Groundwater samples will be collected following EPA-approved methodologies which will be fully detailed in the QAPP. All groundwater samples will be analyzed for low detection level VOCs, TCL SVOCs and pesticides/PCBs, and TAL metals and cyanide through the EPA CLP. Groundwater samples will also be analyzed for hexavalent chromium, nitrate-nitrite, TKN, ammonia, BOD, COD, TSS, TOC, TDS, alkalinity, sulfate, and chlonde by EPA's DESA laboratory (if available) or by the RAC n Team laboratory subcontractor. All samples will be analyzed using the most current EPA-approved methods that will be detailed in the QAPP.

For cost estimation purposes, it has been determined that 23 groundwater samples will be collected from 21 existing wells and the two municipal wells during Field Activity 1 and that 28 groundwater samples will be collected from the 21 existing wells and seven newly installed wells during Field Activity 2. A total of 51 groundwater samples will be collected.

5.3.5.5 Fish Collection

If directed by EPA, during Field Activity 2 fish will be collected at five locations along the Unadilla River for use in the Human Health and Screening Level Ecological Risk Assessments. As cumentiy proposed, one sampling location will be upstream of the site, three along the site (specifically, one near the suspected sump discharge, one near the center of the site, and one near the wetland discharge), and one downstream of the site. It is anticipated that for these collections, based on the limited available habitat in the Unadilla River, a maximum of two composite forage and two sport fish samples will be collected at each of the five locations resulting in the collection often forage and ten standard filet samples. If analytical results indicate potential impacts farther downstream, additional downstream locations may be investigated.

For the Screening Level Eecological Risk Assessment, the samples will be whole-body forage fish composited from a single species. Because a survey offish species inhabiting the Unadilla River near the site has not been conducted recentiy, the actual species to be collected is not known and will be determined in the field based on the most available fish species present. However, likely species include: Spottail shiner (Notropis hudsonius); Pumpkinseed (Lepomis gibbosus); Bluegill (Lepomis macrochirus); Emerald shiner (Notropis atherinoides); Tessellated darter (Etheostoma nigrum); bluntnose minnow (Pimephales notatus); and Fathead Minnow (Pimephales promelas).

For the Human Health Risk Assessment, standard filets of normally consumed sport fish will be analyzed. Likely species to be collected include Carp(Cyprinus carpio). Yellow Perch(Perca flavescens), and Brook Trout (Salvelinus fontinalis). However, the actual species to be collected will be deteiTnined in the field based on the most available fish species present.

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Fish will be collected using a backpack electroshocker. All fish tissue samples will be analyzed for TAL/TCL parameters and percent lipids using the most recent EPA-approved methods. Tissue analyses will be performed by a laboratory under subcontract to CDM Federal. Tissue preparation, sample analysis, and QA/QC procedures will be described in the QAPP, Addendum.

5.3.6 ECOLOGICAL CHARACTERIZATION

An ecological assessment of the Hiteman Leather site will be conducted during Phase II to charactenze existing site -conditions relative to the vegetation community structure, wildlife utilization and sensitive ecological resources such as surface water and wetiands. This assessment will obtain sufficient information to characterize ecological conditions at and in the immediate vicinity of the site boundanes to support the remedial investigation and ecological risk assessment. The ecological assessment consists of a characterization of wildlife habitat/usage, a wetland delineation, an assessment of wetland functions and values, and an identification of endangered/special concem species.

The areas to be investigated include the site wetiands area and the Unadilla River.

5.3.6.1 Characterization of Wildlife Habitat/Usage

The purpose of this field characterization is to identify and map ecological conditions at and in areas near the site that are potentially affected by the migration of site contaminants. Conditions at the site and in the adjacent areas will be visually inspected. Observations on habitat conditions, wildlife utilization, and contaminant exposure pathways will be made and will include the following types of ecological information:

• Vegetation community/cover types (including size and location) at and in areas immediately adjacent to the site;

• Dominant vegetation species and general observations of abundance/diversity within each cover type;

• Topographic features (i.e., drainages and general conditions of surficial soil);

• Location of surface waters and their general aquatic habitat characteristics (i.e., approximate size and shape, flow and direction, bottom substrate, and plant coverage);

• Observations of wildlife habitat, including species identification and use activity; and

• Indications of environmental stress that could be related to site contaminants.

Observations from this field survey will be recorded in a field logbook and photo documented. A cover type/habitat map of the site will be prepared, noting locations of aquatic habitats and

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5.4 TASK 4 - SAMPLE ANALYSIS

All RAS samples will be analyzed by an EPA CLP laboratory for TCL/TAL parameters using methods specified in the most current and applicable Statements of Work. The analysis of samples for non-RAS parameters will be performed by EPA's DESA laboratory in Edison, New lersey. If DESA does not have sufficient laboratory capacity at the time of sampling, then the non-RAS parameters will be submitted to the analyticaMaboratory under subcontract to CDM Federal. The RAC n Team's laboratory subcontractor will be selected by EPA-approved critena and will follow the most current CLP protocol and Region II QA requirements. The CDM Federal Regional Quality Assurance Coordinator (RQAC) will ensure that the laboratory meets all EPA requirements for laboratory services. The samples to be collected and the parameters to be analyzed for each sample are described in this work plan. The number of samples, analytical test methods, levels of detection, holding times, parameters, field sample preservation and QC sample protocols will be listed in the QAPP.

5.4.1 INNOVATIVE METHODS/FIELD SCREENING SAMPLE ANALYSIS

Split spoon samples will be scanned with a PID to field screen samples for potential organic contaminants. No other field screening is anticipated at this time.

5.4.2 ANALYTICAL SERVICES PROVIDED VIA CLP, DESA OR EPA-ERT

Section 5.3.5 presents the sampling program including those samples to be submitted for analysis by the EPA CLP. Tables 5-1 and 5-2 summarize the sampling program. All required paperwork will be completed and the samples packaged and shipped in accordance with CLP requirements. Whenever possible, the RAC El Team will attempt to use analytical services provided by the EPA CLP or by EPA's DESA laboratory in Edison, New lersey.

5.4.3 SUBCONTRACTOR LABORATORY FOR NON-RAS ANALYSES

See Section 5.1.9 for a complete description of the non-RAS parameters that will be analyzed, if required, by the RAC II Team subcontractor.

5.5 TASK 5 - ANALYTICAL SUPPORT AND DATA VALIDATION

CDM Federal will validate the non-RAS environmental samples (except samples analyzed by EPA's DESA laboratory) collected under Task 3; EPA will validate all other RAS analytical data generated under the other tasks of the RI. '

5.5.1 COLLECT, PREPARE AND SHIP SAMPLES

The RAC II Team will collect, prepare, and ship the analytical samples collected during the tield activities in accordance with the EPA-approved QAPP.

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5.5.2 SAMPLE MANAGEMENT

The CDM Federal Analytical Services Coordinator will be responsible for all RAS CLP laboratory bookings and coordination with the Regional Sample Control Center (RSCC) for sample tracking pnor to and after sampling events.

For all RAS activities, the RAC II Team will notify the Contract Laboratory Analytical Support Services (CLASS) to enable them to track the shipment of samples from the field to the laboratories and to ensure timely laboratory receipt of samples. Sampling Trip Reports will be sent directiy to the s e c and the EPA Remedial Project Manager within ten working days of final sample shipment, with a copy sent to the CDM Federal Analytical Services Coordinator.

The CLP laboratories will be responsible for providing organic and inorganic analytical data packages to the Region EI shipping coordinator for data validation by EPA.

Samples analyzed by the DESA laboratory will be coordinated by the ASC. For samples analyzed by the laboratory under subcontract to the RAC EI Team, all analytical data packages will be sent directiy to CDM Federal for data validation. If requested, CDM Federal will send these validated data packages to EPA for QA review purposes. 'The CDM Federal SM will be responsible for subcontractor laboratory bookings and sample tracking prior to, and after, sampling events.

5.5.3 DATA VALIDATION

All RAS samples will be analyzed by a laboratory participating in the CLP and all analytical data will be validated by EPA. EPA Region EI DESA laboratory samples will be validated as per DESA protocol. The non-RAS data will be.validated by CDM Federal validators who will use the requirements and the quality control procedures outiined in the associated methods and as per the analytical statement of work for the laboratory subcontractor.

All CDM Federal data validators will be certified by Region EI for the parameters of interest. Data vahdated by experienced but non-certified validation staff will go through a second review process with a certified validator. All validated data results will be presented to EPA as an Appendix to the RI report.

The data validation portion of the program will verify that the analytical results were obtained following the protocols specified,in the CLP statement of work, and are of sufficient quahty to be relied upon to prepare a human health nsk assessment, to prepare the RI and FS, to develop and screen remedial altematives, and to support a record of decision (ROD). The appropriate validation SOWs and guidelines will provided as an attachment to the QAPP.

5.6 TASK 6 - DATA EVALUATION

The RAC EI Team will organize and evaluate existing data and data gathered during the field investigation that will be used in the RI/FS effort. Data evaluation begins with the receipt of

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analytical data from the data validation task and ends with the submittal of the Data Evaluation Summary Report. All validated data will be entered into a computer database and tabulated for use in the RI and RA. The data from previous sampling efforts and data from the RI will be reviewed and carefully evaluated to identify the nature and extent of site-related contamination.

5.6.1 DATA USABILITY EVALUATION

The RAC II Team will evaluate the usability of the field investigation data including any uncertainties associated with the data. The data will be checked against the DQOs identified in the QAPP. Any qualifications to the data usability will be discussed in the quality assurance section of any reports presenting data.

5.6.2 DATA REDUCTION, TABULATION AND EVALUATION

The RAC n Team will evaluate, interpret, and tabulate data in an appropriate presentation format for final data tables. In accordance with.the EPA SOW, the following will be used as general guidelines in the preparation of data for the RI report:

• Tables of analytical results will be organized in a logical manner such as by sample location number, sampling zone, or some other logical format. The RAC II Team will coordinate the table organization with the EPA RPM.

• Analytical results will not be organized by laboratory identification numbers because these numbers do not correspond to those used on sample location maps. The sample location/well identification number will always be used as the primary reference for the analytical results. The sample location number will also be indicated if the laboratory sample identification number is used.

• Analytical tables will indicate the sample collection dates.

• The detection limit will be indicated in instances where a parameter was not detected.

• Analytical results will be reported in the text, tables and figures using a consistent and conventional unit of measurement such as ug/L for groundwater analyses and mg/kg for soil analyses.

• EPA's protocol for eliminating field sample analytical results based on laboratory/field blank contamination results will be clearly explained.

• ' If the reported result has passed established data validation procedures, it will be considered valid.

• Field equipment nnsate blank analyses results will be discussed in detail if decontamination solvents are believed to have contaminated field samples.

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Detailed information, conceming the hydrogeological and physical charactenstics of the site and the surrounding area, will be gathered, reviewed, and evaluated for inclusion in the RI report. The purpose of these activities will be to provide detailed descnptions of the site physical features and to assess how these features may impact interpretations regarding contaminant source areas and potential flow paths. Data Mapping

The RI data will be posted on site base maps for the RLTS. Figures will be generated in plan view and cross section to show the extent of groundwater contamination. Graphic illustrations in the RI Report will include geological profiles, cross-sections, contaminant isoconcentration maps, and longitudinal and cross-sectional profiles of groundwater contamination.

Database Management

The RAC It Team will use an appropriate database program and standard industry spreadsheet software programs for managing all data related to the RI sampling programs. This software will assist in managing large volumes of data. The system will provide data storage, retrieval, and analysis capabilities, and be able to interface with a variety of spreadsheet, word processing, statistical, and graphics software packages to meet the full range of site and media sampling requirements for an RI/FS. Analytical data results will interface with graphics packages to illustrate contaminants detected.

Data collected during all field activities will be organized, formatted, and input into the database for use in the data evaluation phase. All data entry will be checked for quality control. Data tables comparing the results of the various phases of sampling efforts will be prepared and evaluated. Data tables will also be prepared that compare analytical results with both state and federal ARARs.

5.6.3 MODELING

Per EPA direction, the RAC EI team will evaluate all existing data, including groundwater data collected during Field Activity 1, and will assess if modeling for the site is necessary. As additional data are collected over the course of the investigation, the need for groundwater modeling at the site will be evaluated and, if deemed necessary, a recommendation will be made to conduct groundwater modeling. Groundwater modeling may be necessary to define groundwater flow scenarios and contaminant transport in the bedrock and overburden aquifers to support evaluation of remedial measures such as groundwater extraction and treatment and permeable reactive barrier. If it is determined that modeling is necessary, the RAC II Team will prepare a work plan letter that will specify the scope of the required modeling effort and the costs associated with it. Hours have been included in the cost estimate to assess the need for groundwater modeling and to prepare the work plan letter.

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5.6.4 TECHNICAL MEMORANDUTvI

Following the completion of the Field Activity 1 investigation, and prior to the mobilization for the Field Investigation Activity 2, the RAC II Team will prepare a technical memorandum that will present the data gathered dunng the Field Activity 1 investigation including information regarding groundwater flow and contaminant distribution. The Technical Memorandum will also present a preliminary delineation of site related contamination in the surface water,.sediment, and wetiand sediment and will also include a review of off site information for locations of off site samphng activities. Recommendations for the location and depths of additional monitonng wells and environmental samples will also be presented in the memorandum.

The memorandum will be submitted for review and approval by the EPA RPM and will be finahzed upon receipt of EPA comments. It is anticipated that this report will include data results and will therefore require technical and QA review prior to submittal to EPA.

5.7 TASK 7 - ASSESSMENT OF RISK

The RAC EI Team will conduct a Human Health Risk Assessment (HHRA) for the Hiteman Leather site. The HHRA will determine whether site contaminants pose a current or potential risk to human health in the absence of any remedial action, and will be used to determine whether remediation is necessary at the site and deteiTnine what exposure pathways need to be remediated. Furthermore, it provides a method for comparing the potential health impacts of various remedial altematives and a consistent process for evaluating and documenting potential public health threats at hazardous waste sites. The objective ofthe Hiteman Leather site HHRA is to provide a quantitative assessment of the probabilities and types of potential adverse health effects that may result from exposure to chemical contaminants at the site.

The RAC EI Team will use EPA's standardized planning and reporting methods as outlined in EPA's Risk Assessment Guidance for Superfund (RAGS Part D) (Interim), Standard Planning, Reporting,

• and Reviewing of Risk Assessments. RAGS Part D provides guidance on standardized risk assessment planning, reporting, and review throughout the CERCLA remedial process, from scoping through remedy selection and completion and periodic review of the remedial action.

5.7.1 BASELINE RISK ASSESSMENT (HUMAN HEALTH)

The Human Health Risk Assessment will be performed in accordance with EPA guidance set forth in the following documents:

• Risk Assessment Guidance for Superfund: Human Health Evaluation Manual, Part A {EPA, 1989).

• Risk Assessment Guidance for Superfund: Human Hecdth Evaluation Manual, Part B, Development of Risk Based Preliminary Remediation Goals (EPA, 1991).

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Risk Assessment Guidance for Superfund: Human Health Evaluation Manual, Part D. (EPA, 1998a).

Risk Assessment Guidance for Superfund: Volume I: Human Hecdth Evaluation Manual, Supplemented Guidance, Dermal Risk Assessment Interim Final (EPA, 1999a)

Exposure Factors Handbook, Vol I, II and III (EPA, 1997a). Human Health Evaluation Manual, Supplemental Guidance: Standard Default Exposure Factors (EPA, 1991a). • • " • •

Guidance for Data Usability in Risk Assessment (EPA, 1992).

Dermal Exposure Assessment: Principals and Applications (EPA, 1992a).

Health Effects Assessment Summary Tables FY-1997 Annual (EPA, 1997a).

Integrated Risk Information System (on-line data base of toxicity measures) (EPA, 2000).

EPA Region IX Risk-Based Criteria (October 1999).

Final Soil Screening Guidance (EPA, 1996).

Additional guidance which addresses site-specific issues and chemical contaminants will also be consulted.

The RAC II Team will prepare a Human Health Risk Assessment Report that accurately establishes the site characteristics of the contaminated media, extent of contamination, and the physical boundaries of the contamination. Key contaminants will be selected based on persistence and mobility in the environment and the degree of hazard. The RAC II Team will evaluate key contaminants identified in the HHRA for receptor exposure and perform an estimate of the level of key contaminants reaching human receptors.

The RAC n Team will evaluate and assess the risk to humans posed by exposure to site contaminants. The RAC II Team will.perform the following activities under this subtask which will form the basis for the FIHRA.

5.7.1.1 Draft Human Health Risk Assessment Report

The draft report will cover the following:

• Hazard Identification (sources) - The RAC II Team will review available sample

information on the hazardous substances based on all analysis from the site, and identify the

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major contaminants of concem. The final set of chemicals of potential concem to be used in the risk assessment will be selected in accordance with EPA Region II procedures as presented in RAGS Part A. Additional selection criteria that will be used to identify the chemicals of potential concem (COPCs) at the site include the following: '

• Frequency of detection in analyzed medium {e.g., subsurface soil);-•- • Historical site information/activities (i.e., site-related); •• Sample chemical detections relative to blank chemical detections; •• Chemical concentration relative to up gradient and background concentrations; •• Chemical toxicity (potential carcinogenic and noncarcinogenic effects, weight of

evidence for potential carcinogenicity); •- Retain all Group A Carcinogens: •• Concentration toxicity screen; *• Chemical properties (i.e., mobility, persistence and bioaccumulation); and •- Significant exposure routes.

. •• Risk-based concentration screen using EPA Region IX Risk Based Concentrations and media specific chemical concentrations {i.e., maximum concentrations) to aid in the identification ofthe chemical contaminants in each medium that may have been inappropriately removed from the list of contaminants of concem.

In general, nutrients such as calcium, magnesium, potassium, and sodium are not quantitatively evaluated in the risk assessment as the potential toxicities of these minerals is significantiy lower than other inorganics detected at the site and more data are available with respect to identifying dietary intake rather than toxicity. .

Statistical analysis of the data will be performed {i.e., tests for normal distribution, calculation of upper confidence levels [UCLs]).

Dose-Response Assessment - The dose-response assessment will present the general toxicological properties of the selected COPCs using the most current toxicological human health effects data. Those chemicals which cannot be quantitatively evaluated due to a lack of toxicity factors will not be eliminated as COPCs on this basis. These chemicals will instead be qualitatively addressed for consideration in risk management decisions for the site.

Toxicological values and information regarding the potential for carcinogens and noncarcinogens to cause adverse health effects in humans will be obtained from a hierarchy of EPA sources including Integrated Risk Information System (IRIS) on-line data base. IRIS, which is updated monthly, provides chemical-specific risk data that represent an EPA scientific consensus. The quantitative risk values and supporting explanations in IRIS have been reviewed and agreed upon by EPA using available studies on a chemical.

The most current Health Effects Assessment Summary Tables (HEAST) will also be used to select toxicity values after IRIS data base has been searched. Additional sources of toxicological values may include the National Center for Environmental Assessment (NCEA).

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A slope factor is a plausible upper-bound estimate of the probability of a response per unit intake of a chemical over a lifetime and is usually the upper 95 percent confidence limit of. the slope of the dose-response curve expressed in (mg/kg/day)''. In risk assessment, a slope factor is used to estimate an upper-bound probability of an individual developing cancer as a result of a lifetime of exposure to a particular level of a potential carcinogen.

For the evaluation of non-cancer effects in the risk assessment, chronic and subchronic reference doses are used. A chronic reference dose is an estimate of a daily exposure level for the human population, including sensitive subpopulations, that is likely to be without appreciable risk of deleterious effects during a lifetime. Chronic reference doses are generally used to evaluate the potential noncancer effects associated with exposure periods between six years and a lifetime. Subchronic reference doses aid in the characterization of potential non-cancer effects associated with shorter-term exposure (i.e., less than six years).

Toxicity endpoints/target organs for noncarcinogenic COPCs will be presented for those chemicals showing hazard quotients greater than one. If the hazard index is greater than one due to the summing of hazard quotients, segregation ofthe hazard index by critical effect and mechanism of action will be performed as appropriate.

Toxicological Profiles - Toxicological profiles of the site contaminants of concem will be developed. The profile will summarize data from the Integrated Risk Information System and other appropriate scientific information.

Pathways Analysis Report - (see subtask 1.13)

Characterization of Site and Potential Receptors - The RAC II Team will identify and characterize human populations in the exposure pathways.

Site Conceptual Model - The RAC II Team will develop a conceptual model for the site. The conceptual model will be based on current and potential future uses of the island, contaminant identification, exposure assessment, dose-response assessment, and risk characterization.. The model will be used to identify potential or suspected sources of contarnination, types and concentrations of contaminants detected at the site, potentially contaminated media, release mechanisms, and potential exposure pathways, including receptors.

When preparing the site conceptual model, the following factors will be considered:

•• Sensitive populations, including but not limited to the elderly, pregnant or nursing women, infants and children, and people suffenng from chronic illness;

•• People exposed to particularly high levels of contaminants; *• Circumstances where a disadvantaged population is exposed to hazardous materials

{i.e., Environmental lustice situations); •• Significant contamination sources;

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*- Potential contaminant release mechanisms {e.g., volatilization, fugitive dust emissions, surface runoff/overland flow, tracking by humans, animals, soil gas generation, and biodegradation);

•• Contaminant transport pathways such as direct air transport downwind, soil gas migration, and biomagnification in the food chain; and

•• Cross media transfer effects, such as volatilization to air, wet deposition, dry deposition, and bioaccumulation in-home grown vegetables.

Exposure Assessment - Exposure assessment involves the identification of the potential human exposure pathways-at the site for present and potential future-use scenarios. Present conditions are as they exist today and future conditions are based on potential future land uses of the site. Potential release and transport mechanisms will be identified for contaminated source media. Exposure pathways identified in the PAR will be finalized by assessing information gathered in the sampling effort. The exposure pathway links the sources, locations, types of environmental releases, and environmental fate with receptor locations and activity pattems. Generally, an exposure pathway is considered complete if it consists of the following elements:

• A source and mechanism of release; • A transport medium; • an exposure point {i.e., point of potential contact with a contaminated medium); and • An exposure route (e.g., ingestion) at the exposure point.

All present and future-use scenarios considered will be presented; however, only some may be selected for quantitative analysis. lustifications will be provided for those exposure pathways retained and for those eliminated.

Based on the initial site visit current and future land use, the potential pathways of concem include:

PRESENT USE

• Site Workers

Surface Soil - ingestion - inhalation of fugitive dust (wind blown) -dermal

Sediment - ingestion (incidental) -dermal

• Site Trespassers (Adolescents)

Surface Soil - ingestion ' . - inhalation of fugitive dust (wind blown)

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- dermal Sediment

- ingestion (incidental) - dermal

Surface Water -- ingestion (incidental) - dermal

• S\teRecTtat]ona\ Users (Adolescents and Adults)

Fish • - ingestion of recreational caught fish

FUTURE USE

• Resident (Adults and Children)

Surface Soil - ingestion - inhalation of fugitive dust (wind blown) - dermal ' - home grown vegetable consumption

Subsurface Soil - ingestion - inhalation of fugitive dust (wind blown)

- - dermal - home grown vegetable consumption

Groundwater - ingestion - inhalation of volatiles - dermal

Sediment - ingestion (incidental) -dermal

Surface Water - ingestion (incidental) - dermal

• Construction Worker (Adults)

Surface Soil/Subsurface Soil - ingestion - inhalation of fugitive dust (wind blown or construction related) - dermal

Surface Water - ingestion (incidental) - dermal

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Sediment - ingestion (incidental)

. -deiTnal

Site Recreational Users of redeveloped property (Young Children, Adolescents and Adults)

Surface Soil - ingestion - inhalation of fugitive - dermal

Sediment - ingestion - dermal

Surface Water - ingestion - dermal

(incidental)

(incidental)

dust (wind blown)

Exposure point concentrations will be developed for each COPC in the risk assessment for use in the calculation of daily intakes. The concentration is the 95 percent UCL on the arithmetic mean, or the maximum detected value (which ever is lower).

Daily intakes will be calculated for both chronic and subchronic exposures. These daily intakes will be used in conjunction with toxicity data to provide quantitative estimates of carcinogenic risk and non-cancer effects.

Exposure assumptions used in daily intake calculations will be based on information contained in EPA guidance, site-specific information, and professional judgement. These assumptions are generally 90th and 95th percentile parameters, which represent the reasonable maximum exposure (RME). The RME is the highest exposure that is reasonably expected to occur at a site. If potential risks and hazards exceed EPA target levels then Central Tendency Exposures (CTE) will be evaluated using 50th percentile exposure variables.

The exposure assessment will identify the magnitude of actual or potential human exposures, the frequency and duration of these exposures, and the routes by which receptors are exposed. The assumptions will include information from the Standard Default Assumptions Guidance and the updated Exposure Factors Handbook. Site specific information will be used where appropriate to verify these assumptions. In developing the exposure assessment, the RAC II Team will develop reasonable maximum estimates of exposure for both current land use conditions and potential land use conditions at the site. Residential exposure will be for a duration of 30 years with separate presentations for children (0 to 6 years) and adults (24 years) with carcinogenic risks totaled for the entire 30 year penod.

Risk Characterization - In this section of the risk assessment, toxicity and exposure assessments will be integrated into quantitative and qualitative expressions of carcinogenic

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risk and non-eancer hazards. The estimates of risk and hazard will be presented numerically in spreadsheets contained in an appendix.

Carcinogenic risks are estimated as the incremental probability of an individual developing cancer over a hfe time as a result of exposure to a potential carcinogen. Per RAGS, the slope factor converts estimated daily intakes averaged over a lifetime of exposure directly to incremental risk of an individual developing cancer. This carcinogenic risk estimate is generally an upper-bound value since the slope factor is often an upper 95th percentile confidence limit of probability of response based on experimental animal data used in the multistage model

The potential for non-cancer effects will be evaluated by comparing an exposure level over a specified time period with a reference dose derived for a similar exposure period. This ratio of exposure tp toxicity is referred to as a hazard quotient. This hazard quotient assumes that there is a level of exposure below which it is unlikely even for sensitive populations to experience adverse health effects; however, this value should not be interpreted as a probability. Generally, the greater the hazard quotient is above unity, the greater the level of concem.

In general, EPA recommends a target value or risk range (i.e., hazard index [HI] = 1 or risk = 1x10'* to lxlO"'')as threshold values for potential human health impacts. The results presented in the spreadsheet calculations will be compared to these target levels and discussed. These levels aid in determining the objectives of the baseline risk assessment, which include determining whether additional response action is necessary at the site, by providing a basis for determining residual chemical levels that are adequately protective of human health, by providing a basis for comparing potential health impacts of various remedial altematives, and to help support selection ofthe no-action remedial altemative, where appropriate.

Carcinogenic risks and non-cancer HI values will be combined across pathways as appropriate. Applicable or Relevant and Appropriate Requirements will be presented for the appropriate chemicals and will be compared to site concentrations detected at and around the site.

Identification of Limitations/Uncertainties - In any risk assessment, estimates of potential carcinogenic risk and non-cancer health effects have numerous associated uncertainties. The primary areas of uncertainty and limitations will be qualitatively discussed. Quantitative measures of uncertainty will involve the calculation of central tendencies. Central tendency evaluation involves the use of 50th percentile input parameters in risk and hazard estimates as opposed to 90th percentile parameters used in the RME calculations. The 50th percentile parameters are considered representative of the general receptor population, but may underestimate the true health risk to sensitive receptors. The chemicals driving the nsk assessment will be evaluated using these average exposure assumptions and the 95 percent UCL concentration to derive risk. The central tendency risks will be discussed in relation to RME nsks. Central tendency analyses will only be calculated for pathways in which RME risks are considered unacceptable (carcinogenic risk above IxlO"* and HI above 1.0).

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The RAC II Team site manager will coordinate with the EPA RPM and submit draft/interim dehverables as outlined in the Risk Assessment Guidance for Superfund - Part D. All data will be presented in RAGS Part D Format.

The risk assessment will provide adequate details of the activities,and be presented so that individuals not famihar with risk assessment can easily follow the procedures.

5.7.1.2 Final Human Health Risk Assessment

The RAC H Team will submit the final Human-Health Risk Assessment Report, incorporating EPA review comments.

5.7.2 ECOLOGICAL RISK ASSESSMENT

A Screening Level Ecological Risk Assessment will be performed in accordance with Ecological Risk Assessment Guidance for Superfimd: Process for Designing and Conducting Ecological Risk Assessments (EPA/540-R-97-006). This Screening Level Ecological Risk Assessment will be performed to: 1) evaluate any changes in contaminant concentrations in site media which may have occurred since the last sampling effort inT992 and 1997, 2) examine all potential contaminants of concem at the site not previously evaluated in site reports, and 3) examine the bioaccumulation of contaminants in fish tissue. This Screening Level Ecological Risk Assessment will in incorporate all previous data including the extensive work performed by the EPA Emergency Response Team's 1997 site evaluation report (e.g.,the small mammal trapping, benthic macroinvertebrate analyses, crayfish bioaccumulation, and food chain modeling). The results ofthe EPA evaluation indicated a potential risk'to site receptors from chromium contamination in site media. Once this screening level risk assessment is completed, the need for additional data collection and the need to proceed to a Baseline Ecological Risk Assessment will be determined.

5.7.2.1 Draft Screening Level Ecological Risk Assessment Report

The draft Screening Level Ecological Risk Assessment Report will address the following items. As described in the primary EPA ecological risk assessment guidance documents, the key components of an ecological risk assessment include:

Problem Formulation (Hazard Identification) Exposure Assessment Toxicity Assessment (Ecological Effects Assessment) Risk Charactenzation Uncertainties and Limitations

The Screening Level Ecological Risk Assessment will be composed of these five components, in order.

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• Definition of Objectives

This section will define the objectives and scope of the ecological risk assessment. Descnptions of site history, environmental setting, nature and extent of contamination, habitat characterization, and potential ecological receptors will be included.

A selection of chemical contaminants of concem will be performed. This selection process is used to namow the focus ofthe ecological risk assessment and serves to identify dominant site risk and to guide future remediation selection decisions. The selection process to be used is based upon methodology present in EPA's Risk Assessment Guidance for Superfund, Volume II: Ecological Evaluation Manual (EPA/540/1-89/001) and in EPA's Ecological Assessment of Superfund Sites: An Overview (ECO Update Volume 1, Number 2; December 1991). The selection process for each chemical of potential concem will take into consideration the following:

• Environmental concentration in media (soils, surface water, groundwater, sediments, air, and, if available, biota);

• Physical/chemical properties, including bioavailability or presence of chemical form that can affect organisms;

• Potential for bioaccumulation or bioconcentration; -Toxicity characteristics and potency (amount of toxicant capable of producing adverse effects; and). Comparison to ARARs and applicable TBCs.

It should be noted that it is current policy of Region II EPA's Biological Technical Assistance Group (BTAG) that chemicals cannot be ehminated as COCs due to the frequency of occumence or by comparison to background reference condition concentrations, thus, frequency of detections and reference condition levels will not be factors in the selection of COCs for this ecological risk assessment.

Site-related receptor species will be chosen as ecological representatives ofthe trophic levels and habitats on and surrounding the Site. Selection will be based on an integration of the types and distribution of COCs, habitats, range and feeding habits of the potential ecological receptors, and relationships between the observed/expected species in the area(s) of concem. Other considerations include species that may have beneficial uses to humans and species that are Trustee or regulatory concems.

The assessment endpoint for the ecological risk assessment is the disruption of ecological community structure viareduction of ecological populations. It will be assumed that a reduction of an ecological population may occur through the loss of normally-functioning individuals of the population. In this ecological risk assessment, the assessment endpoint is evaluated through wildlife measurement endpoints. The measurement endpoints to be used to evaluate potential ecological impacts are benchmark toxicity endpoints from the literature. Individual toxicity endpoints such as survival, reproductive effects, and growth impacts will be considered.

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• Exposure Assessment

The purpose of the exposure assessment section is to evaluate the potential for receptor exposure to chemical constituents at the Site. This evaluation involves identification of contaminant exposure pathways that may be of concern for ecological receptors and detennination ofthe magnitude of

-exposure to the selected ecological receptors. A conceptual site model (simphfied food web noting expected contaminant transfer pathways) will be included this section of the report.

• Toxicity Assessment

The toxicity assessment will link potential contaminant exposure point concentrations to adverse effects in the selected ecological receptors. The goal of the toxicity assessment is to allow for the determination of toxic effects of the Hiteman Leather COCs on selected receptors.

Benchmark toxicity values will be sought and utilized in this assessment. A database search was performed to identify benchmark toxicity values for COCs. Data sources to be reviewed may include:

• Hazardous Substance Database (HSD) Registry of Toxic Effects of Chemical Substances (RTECS) Integrated Risk Information System (IRIS)

Benchmark toxicity values may also be obtained from the open literature sources. Additionally, site-related ecological effects information will be discussed in the toxicity assessment, if available.

• Risk Characterization

Risk characterization will evaluate the evidence linking site contamination with adverse ecological effects. Risk characterization will integrate the exposure assessment with the toxicity assessment. Characterization of risk to site ecological receptors will be determined on the basis of comparison of ecotoxicological benchmark values from the literature with exposure doses. Risks to ecological receptors indicated by site-specific ecotoxicological information will also be discussed.

• Uncertainties and Limitations

For any risk assessment, it is necessary to make assumptions. Assumptions camy with them associated unceitaindes which must be identified so'that risk estimates can be put into perspective. Uncertainties and limitations associated with the ecological risk assessment will be discussed.

5.7.2.2 Final Ecological Risk Assessment Report

The RAC 11 Team will submit the final Ecological Risk Assessment Report addressing'EPA review comments.

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5.8 TASK 8 - TREATABILITY STUDIES/PILOT TESTING

The treatment technologies for the contaminant of concem at site are well established. Therefore, at this point treatability study/pilot testing is not anticipated.

5.9 TASK 9 - REMEDIAL INVESTIGATION REPORT

The RAC II Team will develop and submit a Remedial Investigation report that accurately establishes site conditions including the identification of contaminated media, definition of the extent of contamination, and the delineation ofthe physical boundaries of contamination. The RAC II Team will obtain detailed data to identify key contaminants and to determine the movement and the extent of contamination in the environment. Key contaminants will be identified in the report and will be selected based on toxicity, persistence, and mobility in the environment. An estimate of key contaminant concentrations that are reaching both human and ecological receptors will be made and the effects on receptors will be evaluated.

5.9.1 DRAFT REMEDIAL INVESTIGATION REPORT

A draft RI report will be prepared in accordance with the format described in EPA guidance documents such as the "Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA". A draft outiine ofthe report, adapted from the 1988 guidance, is shown in Table 5-3. This outhne should be considered a draft and subject to revision, based on the data obtained. EPA's SOW for this work assignment has provided a detailed description of the types of information, maps and figures to be included in the RI report. The RAC II Team will incorporate such information to the fullest extent practicable.

.Upon completion, the RI report will be submitted for intemal technical and quality assurance reviews. It will then be submitted to EPA for formal review and comment.

5.9.2 FINAL REMEDIAL INVESTIGATION REPORT

Upon receipt of all EPA and other Federal and State Agency written comments, the RAC II Team will revise the report and submit the amended report to EPA. When the EPA determines that the report is acceptable, the report will be deemed the Final RI Report.

5.10 TASK 10 - REMEDIAL ALTERNATIVES SCREENING - FS

After data from the existing data base and those collected during the RI are evaluated, the preliminary remedial action objectives will be refined and developed or, if appropriate, eliminated. Based on the established remedial response objectives and the results of the risk assessment (Task 7), the initial screening of remedial altematives will be perfonned according to the procedures recommended in "Interim. Final Guidance for Conducting RI/FS under CERCLA" (EPA, 1988). -

This work plan does not include a preliminary identification and discussion of altematives since only limited hydrogeological and analytical data is available for site-specific conditions. The process of

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identifying and screening potential altematives will be ongoing throughout the RI, as new technological and/or site-specific data emerge.

The subtasks comprising this task (described below in detail) will accomplish the objectives for the FS. The following-paragraphs provide the approach for the remedial altematives screening for the Hiteman Leather Company Site.

Development of Remedial Action Objectives and General Response Actions

Based on the data collected in the RI along with other existing data, the remedial action objectives will be developed. Prior to the development of these objectives, any significant site problems and contaminant pathways will be identified. Considering these problems and pathways, the remedial response objectives that eliminate or minimize substantial risks to pubhc health and the environment will be developed further. ARARs will be refined by considering site-specific conditions. Based on the response objectives, general response actions will be delineated to address each ofthe site problem areas. These response actions will form the foundation for the screening of remedial technologies. General response actions considered will include the No-Action altemative as a baseline against which all other altematives can be compared.

Identification of Applicable Technologies/Process Options and Development of Alternatives

Based on the remedial action objectives and each identified general response action, potential treatment technologies and their associated containment or treatment and disposal requirements will be identified. A pre-screening of these potential treatment technologies for suitability as part pf a remedial altemative will be conducted. Where several process options exist for a particular technology (e.g., rotary kiln, infrared or circulating bed combustion), the process option for which most data exist and whose capacities/constraints most closely match site conditions will be selected for further detailed evaluation.

Technologies that could prove extremely difficult to implement might not achieve the remedial objective in a reasonable time, or might not be apphcable or feasible based on the site-specific conditions and will be eliminated from further consideration. The list of potential remedial technologies/alternatives will be developed. The development of altematives requires combining appropriate remedial technologies in a manner that will satisfy the established response objectives and refining them according to the results of the RL

As required by SARA, altematives will be developed in each of the following categories:

• An altemati ve for treatment that would eliminate, or minimize to the extent feasible, the need for long-term management (including monitoring) at the site

Altematives that would use treatment as a primary component of an altemative to address the principal threats at the site

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An altemative that relies on containment with little or no treatment, but is protective of human health and the environment by preventing potential exposure and/or by reducing mobility - ' - '"

• A No-Action altemative

Screening of Remedial Alternatives 'to

The list of potential remedial altematives^developed above will be screened. .The objective of this effort is to reduce the number of technologies and altematives for further analysis while preserving a range of options. This screening will be accomplished by evaluating altematives on the basis of effectiveness, implementability, and cost as specified in the most recent EPA guidance document (EPA, 1988). These screening criteria are briefly described below:

Effectiveness Evaluation

The effectiveness evaluation will consider the capabihty of each remedial altemative to protect human health and the environment. Each altemative will be evaluated as to the protection it would provide, and the reductions in toxicity, mobility or volume of contaminants it would achieve.

Implementability Evaluation

The implementability evaluation will be used to measure both the technical and administrative, feasibility of constructing, operating and maintaining a remedial action altemative. In addition, the availability of the technologies involved in a remedial altemative will be considered.

Innovative technologies will be considered throughout the screening process if there is a reasonable belief that they offer potential for better treatment performance or implementability, few or lesser

• adverse impacts than other available approaches, or lower costs than demonstrated technologies.

Cost Evaluation -

Cost evaluation will include estimates of capital costs, annual operation and maintenance (O&M) cost, and present worth analysis. These conceptual cost estimates are order-of-magnitude estimates, and will be prepared based on:

• Preliminary conceptual engineering for major construction components

• Unit costs of capital investment and general annual operation and maintenance costs available from EPA documents (EPA,T985c and EPA, 1985d) and from contractor

- , in-house files.

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5.10.1 TECHNICAL MEMORANDUM

A draft remedial altematives screening memorandum for the FS will be prepared that will document all of the subtasks described above. This draft memorandum will be submitted to EPA for formal review and comment. . -

5.10.2 FINAL TECHNICAL MEMORANDUM

After EPA's review of the draft Technical Memorandum, RAC II Team will incorporate EPA comments and submit the final Technical Memorandum.

5.11 TASK 11 - REMEDIAL ALTERNATIVES EVALUATION

The remedial altematives that pass the initial screening will be further evaluated. The evaluation will conform to the requirements of the NCP and will consist of a technical, environmental and-cost evaluation, as well as an analysis of other factors, as appropriate. The subtasks comprising this task are described below.

The detailed evaluation will follow the process specified in the "Interim Guidance for Conducting RI/FS under CERCLA" (EPA, 1988). In the guidance, a set of nine evaluation criteria have been developed that are to be applied inthe evaluation of each Remedial Altemative. A brief description of each criterion is provided:

Short-Term Effectiveness

This criterion addresses the effects of the altemative during the construction and implementation phase until the remedial actions have been completed and the selected level of protection has been achieved. Each altemative is evaluated with respect to its effects on the community and onsite workers during the remedial action, environmental impacts resulting from implementation, and the amount of time until protection is achieved.

Long-Term Effectiveness

This criterion addresses the results of a remedial action in terms of the risk remaining at the site after the response objectives have been met. The primary focus of this evaluation is to determine the extent and effectiveness of the controls that may be required to manage the risk posed by treatment residuals and/or untreated wastes. The factors to be evaluated include the magnitude of remaining risk (measured by numencal standards such as cancer risk levels), and the adequacy, suitability and long-term reliability of management controls for providing continued protection from residuals (i.e., assessment of potential failure of the technical components).

Reduction of Toxicity. Mobility, or Volume

This criterion addresses the statutory preference for selecting remedial actions that employ treatment technologies that pennanentiy and significantly reduce toxicity, mobility or volume of the contaminants. The factors to be evaluated include the treatment process employed, the amount of

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hazardous matenal destroyed or treated, the degree of reduction expected in toxicity, mobility or volume, and the type aiid quantity of treatment residuals.

Implementability

This criterion addresses the technical and administrative feasibility of implementing an altemative and the availability of various services and materials required during its implementation. Technical feasibility considers construction and operational difficulties, reliability, ease of undertaking additional remedial action (if required), and the ability to monitor its effectiveness. Administrative feasibility considers activities needed to coordinate with other agencies (e.g., state and local) in regard to obtaining permits or approvals for implementing remedial actions.

Cost \ '

This criterion addresses the capital costs, annual operation and maintenance costs, and present worth analysis.

Capital costs consist of direct (construction) and indirect (non-construction and overhead) costs. Direct costs include expenditures for the equipment, labor and material necessary to perform remedial actions. Indirect costs include expenditures for engineering, financial and other services that are not part of actual installation activities but are required to complete the installation of remedial altematives.

Annual operation and maintenance costs are post-construction costs necessary to ensure the continued effectiveness of a remedial action. These costs will be estimated to provide an accuracy of-i-50 percent to-30 percent.

A present worth analysis is used to evaluate expenditures that occur over different time periods by discounting all future costs to a common base year, usually the current year. This allows the cost •of remedial action altematives to be compared on the basis of a single figure representing the arnount of money that would be sufficient to cover all costs associated with the remedial action over its planned life.

Compliance With ARARs

This criterion is used to determine how each altemative complies with applicable or relevant and appropriate Federal and State requirements, as defined in CERCLA Section l2l.

Overall Protection of Human Health and the Environment

This criterion provides a final check to assess whether each altemative meets the requirement that it is protective of human health and the environment. The overall assessment of protection is based on a composite of factors assessed under the evaluation criteria, especially long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs.

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State Acceptance

This criterion evaluates the technical and administrative issues and concems the state may have regarding each ofthe altematives. The factors to be evaluated include those features of altematives that the state supports, reservations of the state, and opposition of the state.

Community Acceptance

This criterion incorporates public concems into the evaluation of the remedial altematives. Often, community (and also state) acceptance cannot be determined during development of the RI/FS. Evaluation of these criteria is postponed until the RI/FS report has been released for state and public review. These criteria are then addressed in the ROD and the responsiveness summary.

After each of the remedial altematives has been assessed against the evaluation criteria, a comparative analysis will be performed. This analysis will compare all ofthe remedial altematives against each other for each of the evaluation criteria.

5.11.1 DRAFT TECHNICAL MEMORANDUM

A draft remedial altematives evaluation memorandum that will document all of the analysis and evaluation described above. This draft memorandum will include : 1) the technical description of each altemative that outiines the waste management strategy involved and identifies the key ARARs associated with each alteimative; and 2) a discussion that describes the performance of that altematives with respect to each ofthe evaluation criteria. A summary table will be prepared and used to conduct comparison of each altemative with respect to the evaluation criteria. The draft technical memorandum will be submitted to EPA for formal review and comment.

5.11.2 FINAL TECHNICAL MEMORANDUM

After EPA's review of the draft Technical Memorandum, the RAC II Team will incorporate EPA comments and submit the final Technical Memorandum.

5.12 TASK 12-FEASIBILITY STUDY REPORT

5.12.1 DRAFT FS REPORT

A Draft FS Report will be prepared to summarize the activities performed and to present the results and associated conclusions for Tasks 1 through 11. The report will include a summary of the initial screening study process and the detailed evaluations ofthe remedial action altematives studied. The FS Report will be prepared and presented in the format specified in "Interim Final Guidance for Conducting RI/FS wider CERCLA" (EPA, 1988). This FS report fonnat is shown on Table 5-4.

The FS Report will be compnsed of an executive summary and five sections. The executive summary will be a brief overview ofthe FS and the analysis underiying the remedial actions that were evaluated.

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The FS will contain the following five sections:

• Introduction and Site Background • Identification and Screening of Remedial Technologies • Development and Initial Screening of Remedial Altematives • Descnption and Detailed Analysis of Altematives • Comparative Analysis of Altematives

The introduction will provide background information regarding site location and facility history and operation. The nature of the problem, as identified through the vanous studies, will be presented. A summary of hydrogeological conditions, remedial action objectives, nature and extent of contamination, and risk assessment addressed in the RI Report will also be provided. -

The feasible technologies and process options for site remediation will beidentified'foreach general response action, and the results of the remedial technologies screening will be described. Remedial altematives will be developed by combining the technologies identified in the previous screening process. The results ofthe initial screening of remedial altematives, with respect to effectiveness, implementability and cost, will be described.

A detailed description of the cost and non-cost features of each remedial action altemative passing the initial screening ofthe previous section will be presented. A detailed evaluation of each remedial altemative with respect to each of the evaluation criteria will be presented. A comparison of these altematives will also be presented.

5.12.2 FINAL FS REPORTS

Upon receipt of all EPA and other Federal and State Agency written comments, the RAC EI Team will revise the FS report and submit the amended report to EPA. When the EPA determines that the report is acceptable, it will be deemed the Final FS Reports.

5.13 TASK 13 - POST RI/FS SUPPORT

The RAC II Team will provide technical support required for the preparation of the record of decision (ROD) for the site, excluding community relations activities already addressed under Task 2. The RAC n Team's support activities include:

• Attendance at. public meetings, briefings, and technical meetings to provide site updates;

• Review of presentation materials; • Technical supportfor the preparation ofthe draft and final Responsiveness Summary,

Proposed Plan, and Record of Decision;

In addition, the RAC II Team may be required to prepare draft and final addenda to the FS based upon the final ROD adopted for this site.

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5.14 TASK 14 - NEGOTIATION SUPPORT

Per EPA direction at the February 9"" scoping meeting, this task will not be performed.

5.15 TASK 15 - ADMINISTRATIVE RECORD

This task is currentiy not required by EPA at this time.

5.16 TASK 16 - PRO.TECT CLOSEOUT

Upon notification from EPA that the technical work is complete, the RAC II Team will close-out the work assignment in accordance with the requirements of the contract.

5.16.1 WORK ASSIGNMENT CLOSEOUT REPORT

The RAC E Team will prepare a Work Assignment Closeout.Report (WACR). The WACR will include a breakdown of professional level of effort hours by P-level and costs.

5.16.2 DOCUMENT INDEXING

The RAC II Team will organize the work assignment files in its possession in accordance with the currentiy approved file index structure.

5.16.3 DOCUMENT RETENTION/CONVERSION

The RAC II Team will convert all pertinent paper files into an appropriate long-term storage form such as microfiche. If it is determined that microfiche will be used for the long term storage, then the,following distribution will be adhered to:

Silver Halide Original Set-EPA Region n Diazo Duplicate - EPA Region El Hard Copies - EPA Region n Silver Hahde Original Set - CDM Federal

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TABLE 5-1 SUMMARY OF SAMPLING AND ANALYSIS PROGRAM

HITEMAN LEATHER SITE WEST WINFIELD, NEW YORK

.Sampling Locations

Groundwater Sampling Field Activity f-21 Existing Monitoring Wells and 2 -Municipal Wells Field Activity 2- 28 Monitoring Wells and 2 Municipal Wells

Surface Water Sampling Field Activity 1- 6 locations Field Activity 2*- 4 locations

*(IfdirectedbyEPA) '

Sediment Sampling

Field Activity 1- 6 locations , Field Activity 2*- 4 locations

*(IfdirectedbyEPA)

.Sample Type

Groundwater

Surface water

Sediment

r . , , ! o •• r , I otal Number , ,. , „ , Field 1 .Samplmi; hrcquciicv/ , , - ,. ,.

Analytical Parameter „ , „. , ° , ' ' orini'cstigative 1 Painmctcrs"' Interval (s) ., f , 1 1 1 Samples

Low detection level VOCs, TCL SVOCs and pesticides/PCBs, TAL inorganics, Cr(VI), alkalinity, BOD, COD, ammonia, hardness, TOC, TDS, TKN, TSS, nitrate-nitrite, sulfate, and chloride.,

TAL/TCL parameters, Cr (VI), alkalinity, hardness, TDS, and TSS.

TAL/TCL parameters, Cr (VI) grain size; TOC, and pH.

DO, Eh, Turb., pH, T", Cond.

DO, pH, T-, Cond.

NA

Maximum of 1 per well.

Maximum of 1 per location.

Maximum of 1 per location.

Field Activity 1-23 Samples

Field Activity 2

30 Samples


Field Activity 2

4 Samples


Field Activity 2

4 Samples

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Page 1 of 3



„ f ' " , ' ' '.SampliiigLocatidnsi>l'fc'/"l(': .Sample Tjpc

Wetland Sediment Sampling

Field Activity 1-12 locations -

Field Activity 2*- 4 locations

•(IfdirectedbyEPA)

Soil Boring Sampling 27 boring locations (total depth 10' bgs)

Lagoon Soil Boring Sampling 3 boring locations (total depth 20' bgs)

Building Boring Sampling 5 boring locations (total depth 10' bgs)

Sediment

Soil

Soil

Soil

Analytical Parameter



TAL/TCL parameters, Cr (VI) grain size; TOC, pH, TCLP and RCRA characteristics.


Field . Pararaeters<'>

NA

NA

NA

NA

1,. '- .^-'^7^''-l4;i-?j;j^V-"J ^" : Sampling WTequencyl-lihlJ'

0-6" 18-24"

Maximum of 3 soil samples per well bormg: 2-4'bgs; 8-10' bgs; and 1 sample based on visual contamination.

Maximum of 3 soil samples per well boring: water table; 18-20' bgs; and 1 sample based on visual contamination.

Maximum of 2 soil samples per well boring: immediately under concrete and 8-10' bgs.

' Totai Number , of Investigative "' Samples


Field Activity 2

10 Samples

81

•

9

10

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Sampling Locations-yrf',>•!•!./*i'-,; i',...

Surface Soil Sampling 22 samples at 19 soil boring locations and 3 lagoon soil boring locations.

Sample Type

Soil

, f'\- "t^tjf v|:^^i^:}^,\r*'''' • Analytical Parameter!!. \ K V "


/ ' F i e l d ' ^ ^ Parameters"}

NA

i ^ ? Sampling Fregiiency/,'J;,'1 . - -f-..-!.;-.Interyy hffMy ^-i

Maximum of 1 soil samples per boring location.

. Total Number •oflnvestigative

* ' Samples .

22

Notes:

(1) Field Parameters: DO- Dissolved Oxygen Eh- Oxidation-Reduction Potential Turb- Turbidity T°- Temperture Cond- Conductivity

(2) Following the method outlined in Methodology for the Field Extraction/Preservation of Soil Samples with Methanol for Volatile Organics (NJDEP, February 1997)

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TABLE 5-2 SUMMARY OF FISH SAMPLING AND ANALYSIS PROGRAM

HITEMAN LEATER SITE WEST WINFIELD, NEW YORK

Sampling Locations

Five sampling locations

Five sampling locations

Sample Type

Forage Fish (whole-body composite)

Sport Fish (standard fillet)

Analytical Parameter

TCL VOCs; TCL SVOCs; TCL pesticides/PCBs; TAL metals; and percent lipids

TCL VOCs; TCL SVOCs; TCL pesticides/PCBs; TAL metals; and percent lipids

Sampling Frequency per Location

Maximum of two samples per location

Maximum of two samples per location

Total Number of Investigative Samples

10 Samples

10 Samples

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: TABLE 5-3

PROPOSED RI REPORT FORM \T HITEMAN L E A T H E R SITE


1.0 Introduction 1.1 Purpose of Report 1.2 Site Background

1.2.1 Site Description 1.2.2 Site History 1.2.3 Previous Investigations

1.3 Report Organization

2.0' Study Area Investigation 2.1 Surface Features (topographic mapping, etc.) (natural and manmade

features) 2.2 Contaminant Source Investigations 2.3 Meteorological Investigations 2.4 Surface Water and Sediment Investigations 2.5 Geological Investigations 2.6 Soil and Vadose Zone Investigation „ 2.7 Groundwater Investigation 2.8 Human Population Surveys 2.9 Ecologic Investigation

3.0 Physical Characteristics of Site 3.1 Topography 3.2 Meteorology 3.3 Surface Water and Sediment 3.4 Geology 3.5 Hydrogeology 3.6 Soils 3.7 Air Quality 3.8 Demographics and Land Use -

4.0 Nature and Extent of Contamination 4.1 Sources of Contamination 4.2 Soils 4.3 Groundwater 4.4 Surface Water and Sediments

3 0 0 1 2 3 RACS II WA 005 Disk 1/ 5-3_repon_iormat.wpd

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TABLE 5-3

PROPOSED RI REPORT FORMAT HITEMAN LEATHER SITE J

WEST WINFffiLD, NEW YORK

5.0 Contaminant Fate and Transport 5.1 Routes of Migration 5.2 Contaminant Persistence 5.3 Contaminant Migration

6.0 Risk Assessment 6.1 Baseline Human Health Evaluation

6.1.1 Exposure Assessment 6.1.2 Toxicity Assessment 6.1.3 Risk Characterization

6.2 Screening Level Ecological Risk Assessment 6.2.1 Exposure Assessment 6.2.2 Toxicity Assessment 6.2.3 Risk Characterization

7.0 Summary and Conclusions 7.1 Source(s) of Contamination 7.2 Nature and Extent of Contamination 7.3 Fate and Transport 7.4 Risk Assessment 7.5 Data Limitations and Recommendations for Future Work 7.6 Recommended Remedial Action Objectives

Appendices Boring Logs. Hydrogeologic Data

Analytical Data/QA/QC Evaluation Results Risk Assessment Models Toxicity Profiles

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TABLE 5-4

HITEM.VN LEATHER SITE W EST W INFIELD, NEW YORK

PROPOSED FS REPORT FORMAT

Introduction 1.1 Purpose and Organization of Report

Site Description and History Site Source(s) of Contamination Nature and Extent of Contamination Contaminant Fate and Transport Baseline Human Health Risk Assessment Screening Level Ecological Risk Assessment

1.2 1.3 1.4 1.5 1.6 1.7 1.8

2.2

2.3

Identification and Screening of Technologies 2.1 Remedial Action Objectives for Each Medium

- Contaminants of Interest - Allowable Exposure Based on Risk Assessment - Allowable Exposure Based on ARARs - Development ofRemedial Action Objectives General Response Actions for Each Medium - Areas ofVolumes to Which Treatment - Containment - Technologies Screening of Technology and Process Option for Each Medium 2.3.1 Description of Technologies 2.3.2 Evaluation of Technologies 2.3.3 Screening of Altematives - Effectiveness • • - Implementability - Cost

Development of Altematives 3.1 Development of Altematives for Each Medium 3.2 Screening of Altematives

3.2.1 Altemative 1 3.2.2 Altemative 2' 3.2.3 Altemative 3

Detailed Analysis of Altematives 4.1 Description of Evaluation Criteria

- Short-Term Effectiveness - Long-Term Effectiveness and Permanence - Implementability - Reduction of Mobility, Toxicity, or Volume Through Treatment - Compliance with ARARs

o o H lO Ul

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TABLE 5-4


PROPOSED FS REPORT FORMAT

4.2 Individual Analysis of Altematives 4.2.1 Altemative 1 4.2.2 Altemative 2 4.2.3 Altemative 3

4.3 Summary

Comparative Analysis of Altematives 5.1 Comparison Among Altematives For Each Medium

Page 2 of 2

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LEGEND

— • — WETLAND BOUNDARY

APPR0XIMA1TE BOUNDARY OF FORMER

DISCHARGE LAGOON

RWS-01 ® PROPOSED WETLAND SAMPLING LOCATION

RSS-11 O PROPOSED SOIL BORING LOCATION RTP-05 2Z2I PROPOSED TEST PIT LOCATION

UR-4- ^ PROPOSED UNADILLA RIVER SURFACE WATER ® S. SEDIMENT SAMPUNG LOCATION

BB-2 ® PROPOSED BUILDING BORING LOCATION

LS8-03 ® PROPOSED LAGOON SOIL BORING LOCATION

GTB^OI ^ GEOTEC.".N!CAL BOP.ING LOCATION

RMW-4S <S> PROPOSED MONrrORING WELL LOCATION

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APPROVED 8T,

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O U iVI Federal Programs Corporation A subskSary oi Cam Dresssf i KfcKee Inc.

HITEMAN LEATHER COMPANY HERKIMEB COUNTY, NEW YORK

PROJECT NO. 3220-032 FILE MAkCi WPFKK-LDWe

PROPOSED SAMPLING LOCATIONS

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I 6.0 COSTS AND KEY ASSUMPTIONS

Ml The estimated costs for the RI/FS are shown separately in Volume II of the Work Plan.

The RAC II Team has made the following assumptions in estimating the costs of this project:

I I I I I I f 1 I I I I I k I I

It has been assumed that there will be no significant delays due to severe winter weather conditions.

It has been assumed that all field acdvities will be performed in modified Level D or Level C health and safety protection.

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7.0 SCHEDULE

A project schedule for the RI/FS is presented on Figure 7-1. It is anticipated that the project schedule will be based on assumptions for durations and conditions of key events occurring on the cridcal and non-critical path. These assumptions are as follows:

The schedule for the field activities is dependent on access to all properties being obtained by EPA without difficulty.

Field activities will not be significantly delayed due to severe winter weather ' conditions (snow and icing conditions).

The schedule for the field activities is dependent on timely review and approval of the Work Plan and QAPP and the provision of adequate funding by EPA.

The schedule for the field investigation is dependent all field activities being performed in Level D or Level C health and safety protection.

• The RAC 11 Team will receive validated data for analyses performed by the EPA's Contract Laboratory Program 10 weeks after sample collection.

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8.0 PROJECT MANAGEMENT APPROACH

8.1 ORGANIZATION AND APPROACH

The proposed project organization is presented on Figure 8-1.

The Hiteman Leather RI/FS is being conducted as a team effort with project responsibihties shared by CDM Federal and TAMS personnel. The SM, Pamela Philip, has primary responsibility for project administration, including the oversight of work assignment's technical tasks, and for the overall quahty of the work assignment's deliverables. She will serve as the primary point of contact for Mr. Jack O'Dell, the EPA RPM. The RI/FS Task Manager, Andrew Leung of TAMS, will be responsible for the technical coordination of the RI/FS efforts and will serve as a secondary point of contact for Mr. O'Dell.

The SM has primary responsibility for plan developrnent and implementation ofthe RI/FS, including coordination with the RI/FS Task Manager, and support staff, development of bid packages for subcontractor services, coordination with the site subcontractors, acquisition of engineering or specialized technical support, and all other aspects ofthe day-to-day activities associated with the project. The SM identifies staff requirements, directs and monitors site progress, ensures implementation of quality procedures and adherence to applicable codes and regulations, and is responsible for performance within the established budget and schedule.

The RI/FS Task Manager will be responsible for the technical support during the field investigation, the analysis, interpretation and presentation of data acquired relative to the, site, and will be responsible for the preparation of the RI report. Mr. Leung will will work closely with the SM to ensure that the field investigation generates the proper type and quantity of data for use in the initial screening of remedial technologies/alternatives, detailed evaluation of remedial altematives, development of requirements for and evaluation of treatability study/pilot testing, if required, and associated cost analysis.

Mr. John Grabs, the Field Team Leader, will be responsible for the activities conducted during the field investigation such as equipment mobilization, sampling, and the work performed by subcontractors such as surveying and drilling.

The Regional Quality Assurance Coordinator (RQAC) is Ms. Jeniffer Oxford. The RQAC is responsible for overall project quality including development of the QAPP, review of specific task QA/QC procedures, and auditing of specific tasks. The RQAC reports to the CDM Federal Quality Assurance Director (QAD). The RQAC or an approved QA staff member will review and approve the Draft Work Plan and QAPP.

The CDM Federal QAD, Ms. RoseMary Gustin, is responsible for overall project quality, and will have approved Quality Assurance Coordinators (QACs) perfonnlhe required elements ofthe RAC n QA program of specific task QA/QC procedures and auditing of specific tasks at established intervals. These QACs report to the QAD and are independent of the SM's reporting structure.

8-1 3 0 0 1 3 5

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The Analytical Services Coordinator (ASC), Mr. Scott Kirchner, will ensure that the analytical laboratones will perform analyses as described in the QAPP. The ASC provides assistance with meeting EPA sample management and paperwork requirements.

The task numbering system for the RI/FS effort is described in Section 5.0 of this work plan. Each of these tasks have been scheduled and will be tracked separately during the course of the RI/FS work. For the RAC II contract, the key elements of the Monthly Progress Report will be submitted within 20 calendar days after the end of each reporting period and will consist of a summary of work completed during that penod and associated costs.

Project progress meetings will be held, as needed, to evaluate project status, discuss current items of interest, and review major deliverables such as the work plan, QAPP, RI, and FS reports.

8.2 OUALITY ASSURANCE AND DOCUIVIENT CONTROL

All work by the RAC II Team on this work assignment will be performed in accordance with the following guidance documents or subsequent revisions:

• ' CDM Federal RAC II Quality Management Plan (QMP) May 1999, Annual Update.

- CDM Federal RAC II Quality Assurance Project Plan, September 1998.

The RQAC will maintain QA oversight of the project for the duration of the work assignment. The , RQAC will participate in the field planning meeting process. It has been determined that a QAPP that governs field sampling and analysis is required. It will be submitted to an approved QA staff member for review and approval before submittal to EPA. Any reports for this work assignment which present measurement data generated during the work assignment will include a QA section addressing the quality of the data and its limitations. Such reports are subject to Q.A review following technical review. Statements of work for subcontractor services, purchase requisitions for measurement and testing items, and subcontractor bids and proposals will receive technical and QA review.

The SM is responsible for implementing appropriate QC measures on this work assignment. Such QC responsibilities include:

• Implementing the QC requirements referenced or defined in this work plan and in the QAPP.

Adhering to the CDM Federal RAC Management Information System (RACMIS) ' document control system.

Organizing and maintaining work assignment files.

• Conducting field planning meetings, as needed, in accordance with the RAC n QMP.

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Completing measurement and test equipment forms that specify equipment requirements.

Technical and QA review requirements as stated in the QMP will be followed on this work assignment. .

The document control aspects of the program pertain to the control and filing documents. CDM Federal has developed a program filing system that conforms to the requirements of the EPA to ensure that the documents are properly stored and filed. This guideline will be implemented to control and file all documents associated with this work assignment. The system includes document receipt control procedures, a file review, an inspection system, and file security measures.

The RAC II QA program includes both self-assessments and independent assessments as checks on quality of data generated on this work assessment. Self-assessments include management system audits, trend analyses, calculation checking, data validation, and technical reviews. Independent assessments include office, field and laboratory audits and the submittal of performance evaluation samples to laboratories.

A QA intemal system audit, field technical system audit, and/or laboratory technical system audit may be conducted by the CDM Federal QA staff in accordance with QMP. Pert'ormance audits (i.e., performance evaluation samples) may be administered by CDM Federal as required for any analytical parameters. An audit report will be prepared and distributed to the audited group, to CDM Federal management, and to EPA. EPA may conduct or arrange a systern or performance audit.

8.3 PRO.TECT COORDINATION

The SM will coordinate all project activities with the EPA RPM. Regular telephone contact will be maintained to provide updates on project status. Field activities at the site will require coordination among federal, state, and local agencies and coordination with involved private organizations. Coordination of activities with these agencies is described below.

• ' & ' •

EPA is responsible for overall direction and approval of all acdvities for the Hiteman Leather Site. EPA may designate technical advisors and experts from academia or its technical support branches to assist on the site. Agency advisors could provide important sources of technical information and review, which the RAC II Team could use from initiation of RI/FS activities through final reporting.

Sources of technical information include EPA, NYSDEC, and NYSDOH. These sources can be used for background information on the site and surrounding areas.

New York State, through NYSDEC, may provide review, direction, and input during the RI/FS. EPA's RPM will.coordinate contact with NYSDEC personnel.

Local agencies that may be involved include departments such as planning boards, zoning and building commissions, police, fire, and health department, and utilities (water and sewer). Contacts with these local agencies will be coordinated through EPA.

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I Private organizations requiring coordination during the RI/FS include concerned residents in the area, and public interest groups such as environmental organizations and the press. Coordinadon with these interested parties will be performed through EPA.

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FIGURE 8-1 PROJECT ORGANIZATION

Hiteman Leather Site West Winfield, New York

CORPORATE QA DIRECTOR ROSEMARY GUSTIN (Pr4)

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PROGRAM MANAGER ROBERT D. GOLTZ, P.E. (P-4)

TECHNICAL OPERATIONS MANAGER JEANNE LITWIN (P-4)

EPA P R O J E C T OFFICER FERNANDO ROSADO

I SITE MANAGER

PAMELA PHILIP (P-3)

. EPA REMEDIAL PROJECT MANAGER v . JACK O'DELL

QUALITY ASSURANCE COORDINATOR

JENIFFER OXFORD (P-3)

HEALTH & SAFETY OFFICER

CHUCK MYERS, CIH (P-4)

SUBCONTRACTORS

^ . TOPOGRAPHIC SURVEYOR O. DRILLING SERVICES O. CULTURAL RESOURCE SPECIALISTS O. IDW DISPOSAL O. ANALYTICAL LABORATORY

REMEDIAL INVESTIGATION/FEASIBILITY ASSESSMENT TASK LEADER

ANDREW LEUNG (P-3)

w o o to

PROJECT TEAM

ANALYTICAL SERVICES

COORDINATOR SCOTT KIRCHNER (P-2)

J. Grabs, P.G., Field Team Leader (P-2) K. Larsson, P.E., Tech Engineer (P-4) H. Chemoff, Health Risk Assessor (P-3)

J. Rollino, Ecologist (P-1) A.Burton, Scientist (P-3) S. Kirchner, CHMM.Chemist (P-2)

EPA CLP

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9.0 REFERENCES

Ballaron, P.B., 1998. Groundwater Flow Model Of The Coming Area, New York, Susquehana River Basin Commission, Hansburg, Pennslyvania, Publication No. 116, p. 126.

Brett, C.E., and Ver Straeten, C.A., 1994, Stradgraphy And Facies Relationships Of The Eifelian Onondaga (Middle Devonian) In Western And West Central New York State, in Brett, C.E. And Scatterday, J. (Eds.), New York State Geological Association (NYSGA) Field Trip Guidebook, 66"' Annual Meeting, University of Rochester, pp. 221-269.

Buder, J.J., 1997. The Design, Performance, And Analysis of Slug Tests.

Butler, W., Nichols, W.J., and Harsh, J.F., 1978. Quality And Movement of Groundwater In Otter Creek - Dry Creek Basin, Cortland County, New York, United States Geologic Survey (USGS), Water-Resources Investigation Open-file Report 78-3, p. 63.

Cadwell, D.H. and Dineen, R.J., 1987. Surficial Geologic Map Of New York, New York State Museum And Science Service, Map And Chart Series #40, Hudson-Mohawk Sheet.

Dunn Geoscience Corporation, 1988. Preliminary Report - Geophysical Investigation At Hiteman Leather Company Site, Prepared For GHR Engineering Associates, Inc., July 12, 1988.

Friedman, G.M., 1985. Devonian Reefs In New York: Northeastem Geology, V.7, pp.65-73.

Hollyday, E.F., 1969. An Appraisal Of The Groundwater Resources Of The Susquehana River Basin In New York State, USGS, Open-file Report 69-128, p. 52.

Hvorslev, M. Joul, 1949. Time Lag And Soil Permeability In Groundwater Observation, Bulletin No. 36, United States Army Waterways Experiment Station.

Lindemann, R.H., 1979. Stradgraphy And Depositional History Of The Onondaga Limestone In Eastern New York, in Friedman, G.M., NYSGA, Field Trip Guidebook, 5L' Annual Meeting, Troy, pp. 351-387.

Lindemann, R.H. and Feldman, H.R., 1987. Paleography And Brachiopod Paleoecology Of The Onondaga Limestone In Eastern New York, NYSGA, Field Tnp Guidebook, 59" Annual Meeting, NewPaltz, pp. D1-D30. '

Macnish, R.D. and Randall, A.D., 1982. Stratified Drift Aquifers Jn Susquehana River Basin, New York State Department of Environmental Conservadon (NYSDEC), Bulledn 75, p. 68.

Mesolella, K.J., 1978. Paleogeography of Some Silurian and Devonian Reef Trends, Central Appalachian Basin: American Association of Professional Geologists, V. 53, pp. 1035-1042.

Miller, Brooks, T.D., Stelz, W.G., et al., 1981. Geohydrology of Valley-fill Aquifer In The

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Cortland-Homer-Preble Area, Cortland and Onodaga Counfies, New York, USGS, Open-file Report 81-1022,7 Sheets.

NYSDEC, 1987. "The New York River Study, Phase I: Recreafion (Draft)."

NYSDEC, 1992. Remedial Invesfigafion Report, Volume 1 - Text, Hiteman Leather Company Site. Prepared By SAIC Engineering, Inc., February, 1992.

Oliver, W.A., 1954. Strafigraphy Of The Onondaga Limestone (Devonian) In Central New York: Geological Society of America, V.65, pp. 621-652.

Oliver, W.A., 1976. Noncysfimorph Colonial Rugose Corals of the Onesquethaw and Lower Cazenovia Stages (Lower and Middle Devonian) in New York and Adjacent Areas: USGS Professional Paper, No. 869, p.[56.

Randall, A.D., 1977. Records Of Wells And Test Borings In The Susquehana River Basin, New York, NYSDEC, Bulletin 69, p. 92.

Recra Research, Inc., 1985. 'Engineering Invesfigations At Inacfive Hazardous Waste Sites In The State of New York Phase I Invesfigafions,Hiteman Leather Company, Village Of West Winfield, Herkimer County, New York, Site #622007." Prepared for NYSDEC Division Of Solid And Hazardous Waste.

Reynolds, R.J., 1987. Hydrogeology Of The Surficial Outwash Aquifer At Courtland County, New York, USGS Water-Resources Invesfigafion, Report 85-4090, p. 43.

Reynolds, R.J. and Williams, J.H., 1987. Continuous Seismic-reflecfion Profiling of Glacial Drift Along The Susquehana, Chemung and Channango Rivers, South-Central New York And North-Central Pennsylvania, in Randallm, A.D. and Johnson, A.I. (Eds.), Regional Aquifer Systems Of The United States, The Northeast Glacial Aquifers, American Water Resources Associafion, Monograph No. 11, pp. 83-103.

Smith, S.E., 1984. NYDEC, Memorandum to Mr. John Kenna, January 19, 1984.

Smith, T.W., 1979. Intimate History Of Winfield. Heritage Press, Richfield Springs, New York.

Turner, D.A., 1977. Diagenefic Pattems Of Surface and Subsurface Samples From The Bioherm Facies Of The Edgecliff Member Of The Onondaga Formafion (Middle Devonian) Of New York State, Unpubhshed Masters Thesis, Rensselaer Polytech Inst., Troy, New York, p. 188.

United States Environmental Protection Agency (EPA), 1985. Assessing The Superfund Remedial Invesfigafion And Feasibility Study Process, Final Report. EPA, 1988. Guidance For Conducfing Remedial Invesfigafions And Feasibility Studies Under CERCLA, Interim Final, EPA, Office of Emergency And Remedial Response, October 1988, OSWER Direcfive NO. 9355.3-01.

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EPA, 1988a. Community Relafions In'.Superfund: A Handbook, EPA, Office of Emergency And Remedial Response, June 1988, OSWER Direcfive No. 9230.0-3B.

EPA, 1989. Risk Assessment Guidance for Superfund (RAGS): Human Health Evaluation Manual, Part A. Office Of Solid Waste and Emergency Response. EPA/540/1-89/002. OSWER Direcfive 9285.701A.

EPA, 1991. RAGS: Human Health Evaluafion Manual, Part B, Development of Risk-Based Preliminary Remediation Goals. Office of Emergency and Remedial Response. EPA/540/R-92/003.

USEPA. 1991a. RAGS Volume 1: Human Health Evaluafion Manual Supplemental Guidance. Standard Default Exposure Factors. Office of Solid Waste and Emergency Response Direcfive 9285.6-03. March 25, 1991.

EPA, 1992. Final Guidance On Data Usability In Risk Assessment (Part A). Office Of Solid Waste And Emergency Response Direcfive 9285.7-09A.

EPA, 1992a. Dermal Exposure Assessment: Principals And Apphcafions. Office of Solid Waste And Emergency Response. EPA/600/8-91/01 IB.

EPA, Quality Assurance Management Staff, 1994. Guidance For The Data Quality Objectives Process, EPA GA/G-4., Washington, DC.

EPA, 1996. Final Soil Screening Guidance, May 17, 1996. Soil Screening Guidance User's Guide. EPA/540/R-96/018.

EPA, 1996a. Samplers Guide To The Contract Laboratory Program. August.

EPA, 1997. Final Report, Hiteman Leather Site Investigation, West Winfield, New York, Environmental Response Team Center, Office of Emergency and Remedial Response, March 1997.

EPA, 1997a. Exposure Factors Handbook, Volumes I, II, and EQ. Office of Research and Development. EPA/600/P-95/002Fa,-002Fb, and 002Fc.

EPA, August 1998. Final Hazard Ranking System Evaluafion, Hiteman Leather Company West Winfield, Herkrmer County, New York (Report No.: 8003-463; Contract No. 68-W9-0051).

EPA, 1998a. RAGS: Human Health Evaluation Manual, Part D. Office of Emergency and • Remedial Response. Intenm Publicafion No. 9285.7-OlD.

EPA, 1999. Region 9 Preliminary Remediafion Goals, October 1999.

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EPA, 1999. Risk Assessment Guidance For Superfund: Volume I: Human Health Evaluation Manual, Supplemental Guidance, Dermal Risk Assessment Interim Final.

EPA, Integrated Risk Informafion System (on-line database of toxicity measures).

Vanalstyne, F. et al., 1982. Groundwater Resource Evaluafion With Modeling Of Flow Condifions, Big Flats, New York, NYSDEC, p. 128.

Waller, R.M. and Finch, A.J., 1982. Atlas Of Eleven Selected Aquifers in New York, USGS Water-Resources Investments, Open-file Report 82-0553, p. 255.

Williams, L.A., 1980. Community Succession In Devonian Patch Reefs (Onodaga Formafion, New York)-Physical And Biofic Controls, Journal of Sedimentary Petrology, V.50, pp. 11169-1186.

Wolosz, T.H. and Paquette, D.E., 1995. Middle Devonian Temperate Water Bioherms Of Western New York State (Edgecliff Member, Onodaga Formation) In Garver, J.J. and Smith, J. A.(Eds.), Field Trips For The 67"" Annual Meefing of the NYSGA, pp. 227-250.

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10.0 GLOSSARY OF ABBREVIATIONS

ARAR Applicable or Relevant and Appropriate Requirements

ASC Analytical Services Coordinator

bgs Below Ground Surface .

BOD Biochemical Oxygen Demand

BTAG Biological Technical Assistance Group

CERCLA Comprehensive Environmental Response, Compensafion, and Liability Act

CFR Code of Federal Regulations

cfs Cubic Feet per Second

CLASS Contract Laboratory Analytical Support Services

CLP Contract Laboratory Program

cm/sec Cenfimeters per Second

COC Chemical of Concem

COD Chemical Oxygen Demand

COPC Chemical of Potenfial Concem

CRP Community Relations Plan

CRS Community Relafions Specialist

CTE Chemical Tendency Exposures

DESA Division of Environmental Science and Assessment

DO Dissolved Oxygen

DQI Data Quality Indicator

DQO Data Quality Objecfive

Eh Oxidafion and Reducfion Potential

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EPA United States Environmental Protecfion Agency

ERA Ecological Risk Assessment

ERT Environmental Response Team'

FS Feasibility Study

ft Feet

ft/day Feet per Day

ft'/day Square Feet per Day

ft^/day Cubic Square Feet per Day

gpm Gallons per Minute

HI Hazard Index

HEAS . Health Effects Assessment

HEAST Health Effects Assessment Summary Tables

HHRA Human Health Risk Assessment

HRS Hazardous Ranking System

HSD Hazardous Substance Database

HSP Health and Safety Plan

ID Inner Diameter -

IFB Information for Bidders

IRIS Integrated Risk Information System

lb/day Pounds per Day

LEL Lowest Effect Level

MCL Maximum Contaminant Level

MCLG Ma'ximum Contaminant Level Goal

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mg/kg Miligrams per Kilogram

mph Miles per Hour

MSL Mean Sea Level

NCEA National Center for Environmental Assessment

NCP National Confingency Plan ,

NPDES Nafional Pollufion Discharge Eliminafion System

NPL Nafional Priorides List

NYS New York State

NYSDEC New York Department of Environmental Conservafion

NYSDOH New York State Department of Health

NX Rock Coring

O&M Operation & Maintenance

OSWER Office of Solid Waste and Emergency Response

OVA Organic Vapor Analyzer

PAH

PAR

PCB

PID

ppm

PVC

QA

QAC

QC

Polycyclic Aromatic hydrocarb

Pathway Analysis Report

Polychlorinated biphenyl

Photoionizafioii Detector

Parts per Million

Polyvinyl Chlonde

Quahty Assurance

Quality Assurance Coordinator

Quality Control

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QA/QC Quality Assurance/Quality Control

QAD Quality Assurance Director

QAPP Quality Assurance Project Plan

QMP . Quality Management Plan

RA ~ Risk Assessment

RAC Response Action Contract

RACMIS RAC Management Information System

RAGS ' Risk Assessment Guidance

RAS Roufine Analyfical Service

RCRA Resource Conservafion and Recovery Act

RFP Request for Proposal

RI Remedial Invesfigafion

RI/FS Remedial Invesfigafion/Feasibility Study

RME Reasonable Maximum Exposure

ROD Record of Decision

RPM Remedial Project Manager

RQD Rock Quahty Designafion

RSCC Regional Sample Control Center

RTECS Registry of Toxic Effects of Chemical Substances

RQAC Regional Quahty Assurance Coordinator

SARA Superfund Amendments and Reauthorizafion Act

SEL Severe Effects Level

SI ' Site Invesfigation

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SM Site Manager

SOW Statement of Work

SPDES State Pollufion Discharge Eliminafion System

SVOC Semi Volatile Organic Compound

TAL Target Analyte List

TBC "To Be Considered" Material ,

TCL Target Compound List

TCLP Toxicity Characterisfics Leaching Procedure

TDS Total Dissolved Sohds

TKN Total Kjeldahl Nitrogen

TOC Total Organic Carbon

TOGS Technical & Operafions Guidance Series

TSCA Toxic Substances Control Act

TSS Total Suspended Solids

UCL Upper Confidence Limit

ug/L Micrograms Per Liter

USC United State Code

USGS United States Geological Survey

VOC , Volatile Organic Compound

WACR Work Assignment Close-Out Report

WET Wetland Evaluation Technique

XRF X-Ray Fluorescence

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CDM: Federal Programs Corporation , . y , A Subsidiary of Camp,Dresser'&Mckee Inc.-:

. 125 Maiden Lane, 5th Floor \ New York, NY 10038 .:

: • " ] ' ' • • ' •, '(212) 785-9123 '; ' " . I 3 0 0 1 5 1