HRS DOCUMENTATION RECORD--REVIEW COVER SHEET

Name of Site: Dewey Loeffel Landfill

Date Prepared: March 2010

Date Revised: March 2011

Contact Persons:

Site Investigation: James Desir

U.S. Environmental Protection Agency

New York, NY

Documentation Record: Ildefonso Acosta

U.S. Environmental Protection Agency

New York, NY

Pathways, Components, or Threats Not Scored

Even though evidence of ground water contamination exists (see below), the Ground Water Migration, Soil Exposure, 

and Air Migration Pathways are not scored because the listing decision is not significantly affected by those pathways. 

The site score based solely on the Surface Water Migration Pathway is sufficient to list the site.

Some hazardous substances, in particular PCBs, have migrated from the facility to underlying aquifers, resulting in 

contamination of ground water [Ref. 6, pp. 7; 9, pp. 6, 15-17]. New York State Department of Health (NYSDOH) has 

conducted residential well monitoring in the vicinity of the facility since 1979 [Ref. 9, p. 10]. There is evidence of 

historical and current continued ground water contamination at the Dewey Loeffel Landfill site [Ref. 49, pp. 22-25]. 

New York State Department of Environmental Conservation (NYSDEC) designated ground water contamination

associated with the disposal facility as Operable Unit 2 (OU2) [Ref. 6, pp. 7, 10]. General Electric Company (GE) has 

conducted remedial investigations and remedial actions associated with OU2 since 1992, and has reported that Aroclor1260 exists as a dense non-aqueous phase liquid (DNAPL) [Ref. 9, pp. 10-15; 10, pp. 9-10, 23]. In January 2001, 

NYSDEC issued a Record of Decision (ROD) for OU2 [Ref. 9, p. 1].

 
This page has been left blank intentionally.
1

HRS DOCUMENTATION RECORD

Name of Site: Dewey Loeffel Landfill Date Prepared: March 2010

Date Revised: March 2011

EPA ID No.: NYD000512335

EPA Region: 2

Street Address of Site*: Mead Road, Nassau, NY 12123

County and State: Rensselaer County, New York

General Location in the State: Capital District (eastern portion of state)

Topographic Map: Nassau, NY

Latitude*: 42° 33′ 39.44” North (42.560957°) Longitude*: 73° 33′ 37.78′′ West (-73.560496°)

Site Reference Point: Facility entrance

[Figure 1; Ref. 3, p. 1; 4, p. 1; 5, pp. 1-2]

* The street address, coordinates, and contaminant locations presented in this Hazard Ranking System (HRS)

documentation record identify the general area where the site is located. They represent one or more locations EPA 

considers to be part of the site based on the screening information EPA used to evaluate the site for NPL listing. EPA 

lists national priorities among the known "releases or threatened releases" of hazardous substances; thus, the focus is on 

the release, not precisely delineated boundaries. A site is defined as where a hazardous substance has been "deposited, 

stored, placed, or otherwise come to be located." Generally, HRS scoring and the subsequent listing of a release merely 

represent the initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EPA 

contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more 

information is developed as to where the contamination has come to be located.

Scores

Ground Water Pathway Not Scored

Surface Water Pathway 100.00

Soil Exposure Pathway Not Scored

Air Pathway Not Scored

HRS SITE SCORE 50.00
2

WORKSHEET FOR COMPUTING HRS SITE SCORE

DEWEY LOEFFEL LANDFILL

 S S2

 

1. Ground Water Migration Pathway Score (Sgw) Not Scored

(from Table 3-1, line 13)

2a. Surface Water Overland/Flood Migration Component 100.00 10,000.00

(from Table 4-1, line 30)

2b. Ground Water to Surface Water Migration Component Not Scored

(from Table 4-25, line 28)

2c. Surface Water Migration Pathway Score (Ssw) 100.00 10,000.00

Enter the larger of lines 2a and 2b as the pathway score.

3. Soil Exposure Pathway Score (Ss) Not Scored

(from Table 5-1, line 22)

4. Air Migration Pathway Score (Sa) Not Scored

(from Table 6-1, line 12)

5. Total of Sgw2 + Ssw2 + Ss

2 + Sa2 10,000.00

6. HRS Site Score Divide the value on line 5

 by 4 and take the square root 50.00
3

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

DEWEY LOEFFEL LANDFILL

SURFACE WATER OVERLAND/FLOOD 

MIGRATION COMPONENT

Factor Categories & Factors

DRINKING WATER THREAT

MAXIMUM

VALUE

VALUE

ASSIGNED

Likelihood of Release

1. Observed Release

2. Potential to Release by Overland Flow

 2a. Containment

 2b. Runoff

 2c. Distance to Surface Water

 2d. Potential to Release by Overland Flow

 (lines 2a [2b + 2c])

3. Potential to Release by Flood

 3a. Containment (Flood)

 3b. Flood Frequency

 3c. Potential to Release by Flood

 (lines 3a x 3b)

4. Potential to Release (lines 2d + 3c)

5. Likelihood of Release (higher of lines 1 and 4)

550

10

25

25

500

10

50

500

500

550

550

not scored

not scored

not scored

not scored

not scored

not scored

not scored

not scored

550

Waste Characteristics

6. Toxicity/Persistence

7. Hazardous Waste Quantity

8. Waste Characteristics

*

*

100

not scored

not scored

not scored

Targets

9. Nearest Intake

10. Population

 10a. Level I Concentrations

 10b. Level II Concentrations

 10c. Potential Contamination

 10d. Population (lines 10a + 10b + 10c)

11. Resources

12. Targets (lines 9 + 10d + 11)

50

**

**

**

**

5

**

not scored

not scored

not scored

not scored

not scored

not scored

not scored

13. DRINKING WATER THREAT SCORE

 ([lines 5 x 8 x 12]/82,500)

100 not scored

* Maximum value applies to waste characteristics category.

** Maximum value not applicable
4

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

DEWEY LOEFFEL LANDFILL

SURFACE WATER OVERLAND/FLOOD 

MIGRATION COMPONENT

Factor Categories & Factors

HUMAN FOOD CHAIN THREAT

MAXIMUM

VALUE

VALUE

ASSIGNED

Likelihood of Release

14. Likelihood of Release (same as line 5) 550 550

Waste Characteristics

15. Toxicity/Persistence/Bioaccumulation

16. Hazardous Waste Quantity

17. Waste Characteristics

*

*

1,000

5.00E+08

100

320

Targets

18. Food Chain Individual

19. Population

 19a. Level I Concentrations

 19b. Level II Concentrations

 19c. Potential Human Food Chain Contamination

 19d. Population (lines 19a + 19b + 19c)

20. Targets (lines 18 + 19d)

50

**

**

**

**

**

45

0

0.03

0.0003

0.0303

45.0303

21. HUMAN FOOD CHAIN THREAT SCORE

 ([lines 14 x 17 x 20]/82,500)

100 96.06

* Maximum value applies to waste characteristics category.

** Maximum value not applicable
5

SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

DEWEY LOEFFEL LANDFILL

SURFACE WATER OVERLAND/FLOOD 

MIGRATION COMPONENT

Factor Categories & Factors

ENVIRONMENTAL THREAT

MAXIMUM

VALUE

VALUE

ASSIGNED

Likelihood of Release

22. Likelihood of Release (same as line 5) 550 550

Waste Characteristics

23. Ecosystem Toxicity/Persistence/Bioaccumulation

24. Hazardous Waste Quantity

25. Waste Characteristics

*

*

1,000

5.00E+08

100

320

Targets

26. Sensitive Environments

 26a. Level I Concentrations

 26b. Level II Concentrations

 26c. Potential Contamination

 26d. Sensitive Environments (lines 26a + 26b + 26c)

27. Targets (line 26d)

**

**

**

**

**

0

75

not scored

75

75

28. ENVIRONMENTAL THREAT SCORE

 ([lines 22 x 25 x 27]/82,500)

60 60.00

29. WATERSHED SCORE (lines 13 + 21 + 28) 100 100.00

30. SURFACE WATER OVERLAND/FLOOD

 MIGRATION COMPONENT SCORE (Sof)

100 100.00

SURFACE WATER MIGRATION PATHWAY 

SCORE (Ssw)

100 100.00

* Maximum value applies to waste characteristics category.

** Maximum value not applicable
6

REFERENCES

Reference

Number Description of the Reference

1. U.S. Environmental Protection Agency (EPA). Hazard Ranking System, Final Rule. Federal Register, 

Volume 55, No. 241, pp. 51532-51667. December 14, 1990. [138 pages]

2. EPA. Superfund Chemical Data Matrix, SCDM Data Version: 1/27/2004, Appendices B-I (Hazardous 

Substances Factor Values) and B-II (Hazardous Substance Benchmarks); excerpts downloaded on March 

30, 2009. A complete copy of SCDM is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. [8 pages]

3. EPA. Superfund Information Systems, CERCLIS Database, Dewey Loeffel Landfill: Site Information and 

Actions. Downloaded from http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0201218 on 

September 16, 2009. [2 pages]

4. U.S. Department of the Interior Geological Survey (USGS). Nassau Quadrangle, New York, 7.5-Minute 

Series (Topographic). 1978. [1 page]

5. Gilliland, Gerry, Region 2 Site Assessment Team 2 (SAT 2), Weston Solutions, Inc. (WESTON). Project 

Note to Dewey Loeffel Landfill site file, Subject: Geographic Coordinates – Dewey Loeffel Landfill site; 

with Google Earth map attached. September 28, 2009. [2 pages]

6. New York State Department of Environmental Conservation (NYSDEC). Record of Decision, Dewey 

Loeffel Inactive Hazardous Waste Disposal Site, Operable Unit 3, Towns of Nassau and Schodack, 

Rensselaer County, New York, Site No. 442006. January 2002. [129 pages]

7. O’Brien & Gere Engineers, Inc. (OBG). Loeffel Site Engineering Report. Prepared for General Electric 

Company (GE). October 1981. [153 pages]

8. Blasland, Bouck & Lee, Inc. (BBL). Loeffel Site Environs, Feasibility Study Report: Nassau lake Drainage 

Basin. Prepared for GE. May 13, 1998. [285 pages]

9. NYSDEC. Record of Decision, Dewey Loeffel Site, Operable Unit 2, Town of Nassau, Rensselaer County, 

Site No. 4-42-006. January 2001. [87 pages]

10. HSI GeoTrans. Phase II Hydrogeologic Report, Loeffel Site Environs Remedial Investigation. Prepared 

for GE. May 8, 1997. [496 pages]

11. Brown, Mark P., BBL. Letter Report to James N. Ludlam, NYSDEC, Re: Post-Remedial Monitoring and 

Long-Term Monitoring Plan, Operable Unit 3, Loeffel Site Environs, Nassau, New York, 2004 Surface 

Water and Suspended Monitoring, 2004 Biota Sampling, Proposed 2005 Monitoring, BBl Project #: 

10073.900. Prepared on behalf of GE. October 19, 2004. [151 pages] 

12. NYSDEC. Dewey Loeffel Landfill Fish Monitoring Update; with attached database from NYSDEC. 

February 2009. [646 pages]

13. WESTON Region 2 SAT 2. Field Logbook, Dewey Loeffel Landfill, DCN # SAT2.20113.119.001; with 

Photo Logs attached. May 14, 2009 to August 10, 2009. [66 pages]

14. Lucarino, Kelli, WESTON Region 2 SAT 2. Letter to James Desir, EPA, Subject: Sampling Trip Report, 

Work Assignment No.: 0119 Dewey Loeffel Landfill, Contract No.: EP-W-05-048, Document Control No. 

SAT2.20113.119.839. June 11, 2009. [19 pages]
7

REFERENCES (continued)

Reference

Number Description of the Reference

15. Snyder, Scott T., WESTON Region 2 SAT 2. Letter to James Desir, EPA, Subject: Sampling Trip Report 

[Phase 2], Work Assignment No.: 0119 Dewey Loeffel Landfill, Contract No.: EP-W-05-048, Document 

Control No. SAT2.20113.119.867. August 12, 2009. [27 pages]

16. Desir, James, EPA. Letter to Gerry Gilliland, WESTON, Subject: [Attached] Organic Data Validation 

(Phase 1), Hazardous Ranking System (HRS), Work Assignment No. 119, Dewey Loeffel LF Site. 

September 15, 2009. [43 pages]

17. Desir, James, EPA. Letter to Gerry Gilliland, WESTON, Subject: [Attached] Organic Data Validation, 

Hazardous Ranking System (HRS), Work Assignment No. 119, Dewey Loeffel LF Site. September 10, 

2009. [84 pages]

18. Accutest Laboratories. Technical Report for: Weston Solutions, Inc., Dewey Loeffel Landfill, Mead Road, 

Nassau, NY, Project # 20113.111.00.0119.00, Accutest Job Number: JA20530, Sampling Dates: 06/08/09 

– 06/09/09. June 23, 2009. [225 pages]

19. Accutest Laboratories. Technical Report for: Weston Solutions, Inc., Dewey Loeffel Landfill, Mead Road, 

Nassau, NY, Project # 20113.111.002.0119.00, Accutest Job Number: JA25102, Sampling Dates: 08/05/09 

– 08/06/09. August 25, 2009. [108 pages]

20. Accutest Laboratories. Technical Report for: Weston Solutions, Inc., Dewey Loeffel Landfill, Mead Road, 

Nassau, NY, Project # 20113.111.00.0119.00, Accutest Job Number: JA25103, Sampling Date: 08/06/09. 

August 25, 2009. [95 pages]

21. Accutest Laboratories. Technical Report for: Weston Solutions, Inc., Dewey Loeffel Landfill, Mead Road, 

Nassau, NY, Project # 20113.111.00.0119.00, Accutest Job Number: JA25211, Sampling Date: 08/07/09. 

August 24, 2009. [103 pages]

22. Accutest Laboratories. Technical Report for: Weston Solutions, Inc., Dewey Loeffel Landfill, Mead Road, 

Nassau, NY, Project # 20113.111.00.0119.00, Accutest Job Number: JA25223, Sampling Dates: 08/07/09 

– 08/08/09. August 26, 2009. [128 pages]

23. New York State Department of Health (NYSDOH). Chemicals in Sportfish and Game, 2008-2009 Health 

Advisories. May 21, 2008. [30 pages]

24. NYSDEC. NYSDEC Questionnaires for Fish Consumption from the Valatie Kill and Nassau Lake, 

Rensselaer County; completed by local residents. September 2009. [50 pages]

25. WESTON. 15-Mile Surface Water Pathway Map, Dewey Loeffel Landfill, Town of Nassau, Rensselaer 

County, NY. October 1, 2009. [1 page]

26. EPA. Quick Reference Fact Sheet EPA 540-F-94-028: Using Qualified Data to Document an Observed 

Release and Observed Contamination. Office of Emergency and Remedial Response. November 1996. 

[18 pages]

27. EPA. Basic Information: Polychlorinated Biphenyl (PCB). Downloaded from 

http://www.epa.gov/waste/hazard/tsd/pcbs/pubs/about.htm, on July 13, 2009. [2 pages]
8

REFERENCES (continued)

Reference

Number Description of the Reference

28. Environmental Data Resources, Inc. (EDR). EDR Radius MapTM Report with GeoCheck®, Dewey Loeffel 

Landfill, Mead Road, Nassau, NY 12123, Inquiry Number: 2593233.1s. September 16, 2009. [69 pages]

29. NYSDEC and General Electric Company (GE). Administrative Consent Order (“Seven Sites Agreement”). 

September 1980. [34 pages]

30. U.S. District Court, Northern District of New York. Stipulation and Order of Partial Settlement, Civil 

Action No. 89-CV-1135 (McAvoy), State of New York et al., Plaintiff, v. General Electric Company, 

Defendant. September 3, 1992. [29 pages]

31. Armstrong, Shirley, Times-Union. Waste Lagoon to be Burned. May 21, 1970. [2 pages]

32. Rensselaer County Health Department (RCHD). Memoranda from Mr. Furlong to File via Mr. Stefanik, 

Subject: Loeffel’s Waste Oil, Town of Nassau, Restricted Burning and Inspection. May 25, 1970. [3 

pages]

33. C.T. Male Associates. Engineer’s Report on Waste Water Disposal, Loeffel Refining Products, Inc., Town 

of Nassau, Rensselaer County, New York. October 26, 1970. [13 pages]

34. Loeffel, Dewey, Loeffel Refining Products Inc. Letter to Andrew Weist, Water Pollution Control Eng., 

RE: Receipt of Letter and Agreement to Terms. August 5, 1970. [1 page]

35. Camp Dresser & McKee (CDM). Final Engineering Report, Implementation of a Remedial Program at the 

Dewey Loeffel Hazardous Waste Site, Town of Nassau, Rensselaer County, New York. December 1985. 

[237 pages]

36. Munro, David A., New York State Department of Law. Letter to James R. Bieke, Shea & Gardner, Re: 

New York v. General Electric Company; with attached Sampling and Analysis Plan, Volumes 1 and 2, 

Remedial Investigation, Loeffel Site Environs, Nassau, New York. June 24, 1992. [324 pages]

37. Gilliland, Gerry, WESTON Region 2 SAT 2. Project Note to Dewey Loeffel Landfill site file, Subject: 

Sample Quantitation Limits – Dewey Loeffel Landfill site; with attached spreadsheets. December 29, 

2009. [28 pages]

38. Reference Removed

39. EPA. Envirofacts Warehouse, RCRAinfo Query Results, Handler Name: Dewey Loeffel Landfill. 

Downloaded from http://oaspub.epa.gov/enviro/rcris_web.report?pgm_sys_id=NYD000512335 on January 

7, 2010. [2 pages]

40. Torell, Christopher, BBL. Completion Report, Mead Road Pond Area Interim Remedial Measures, Loeffel 

Site Environs, Nassau, New York. Prepared for GE. February 2002. [230 pages]

41. Torell, Christopher, BBL. Tributary T11A Completion Report, Loeffel Site Environs, Operable Unit 3, 

Nassau, New York. Prepared for GE. March 2003. [364 pages]

42. KAP Technologies, Inc. Laboratory Data Package for Sample Delivery Group B5PD5. June 17, 2009. 

[240 pages]
9 

43. KAP Technologies, Inc. Revised Pages from the Laboratory Data Package for Sample Delivery Group 

B5PD5. December 20, 2010. [5 pages]

44. Mitkem Laboratories. Laboratory Data Package for Sample Delivery Group B5Q40. August 17, 2009. 

[386 pages]

45. Weston Solutions, Inc. Wetlands Measurement Trip Report. January 25, 2011. [192 pages]

46. Sauda, Donald, P.E., ARCADIS. Letter to Michael Komoroske, NYSDEC Division of Hazardous Waste 

Remediation. Subject: Supplemental Investigation of Tributary T11A, Loeffel Site Environs, Nassau, New 

York. June 14, 2010. [642 pages]

47. Sauda, Donald, P.E., ARCADIS. Letter to Paul Wm Hare, Manager, Notheast/Midwest Region, 

Environmental Remediation Programs, General Electric Company. Subject: Supplemental Investigation of 

Tributary T11A – Phase 2, Loeffel Site Environs, Nassau, New York. October 14, 2010. [79 pages]

48. Blasband and Bouck Engineers, P.C. Loeffel Site Environs, Remedial Investigation, Interim Phase I 

Report, Draft. October 1993. Excerpt. [26 pages]

49. GeoTrans, Inc. Loeffel Environs October 2010 Groundwater Sampling Event Monitoring Report, Dewey 

Loeffel Site. December 13, 2010. [227 pages]

50. New York State Department of Health (NYSDOH). Chemicals in Sportfish and Game, 2010-2011 Health 

Advisories. May 21, 2008. [30 pages]

51. Kane, Michael W, Biologist, NYSDEC, Division of Fish, Wildlife & Marine Resources - Bureau of 

Habitat. Presentation Slides: Valatie Kill and Nassau Lake PCBs 2009 Data and Trends in Fish. March 4, 

2010. [53 pages]

52. Rigg, David, Principle Scientist, ARCADIS. Letter to Michael Kane, NYSDEC, Division of Fish, Wildlife 

& Marine Resources - Bureau of Habitat. Subject: Loeffel Site Environs Operable Unit 3 2009 Biological 

Monitoring Data Summary. December 15, 2009. [10014 pages]

53. NYSDEC. Dewey Loeffel Landfill (NYSDEC I.D. # 4-42-006), Project Update – December 2010. 

December 2010. [6 pages]
1 0

SS-Site Summary

SITE SUMMARY

The Dewey Loeffel Landfill (DLL) site (CERCLIS ID No. NYD000512335) is composed of an inactive hazardous waste disposal 

area and the releases from it into the former Mead Road Pond, Tributary T11A, Valatie Kill, Valley Stream, Smith Pond, and 

Nassau Lake (Mead Road Pond is referred to as “former” due to remediation and excavation of Mead Road Pond in 2001[Ref. 40, 

p 25]). The DLL facility is located in southern Rensselaer County, New York and is located within a low-lying, 19.6-acre 

easement between two wooded hills [Ref. 3, p. 1; 4, p. 1; 6, pp. 5-6; 9, p. 7]. In the 1950s and 1960s, the property was used as a 

disposal facility for more than 46,000 tons of industrial hazardous wastes, including solvents, waste oils, polychlorinated biphenyls 

(PCB), scrap materials, sludges, and solids [Ref. 6, pp. 5, 8; 7, p. 7; 29, pp. 1, 28-30]. Some hazardous substances, in particular 

PCBs, have migrated from the facility to underlying aquifers and downstream surface water bodies, resulting in contamination of 

ground water, surface water, sediments, and several species of fish [Ref. 6, pp. 5-7, 12-17; 8, pp. 18-21; 9, pp. 6, 15-17]. The 

geographic coordinates of the DLL facility are 42° 33′ 39.44” north latitude (42.560957°) and 73° 33′ 37.78′′ west longitude (-

73.560496°) [Ref. 4, p. 1; 5, pp. 1-2]. Figure 1 presents the site location, and Figure 2 shows the extent of documented PCB 

contamination along the surface water migration pathway.

From 1952 to 1968, Loeffel Waste Oil Removal and Service Company (“Loeffel”) operated the DLL property as a disposal facility 

for waste materials generated by several industries [Ref. 6, pp. 5, 8; 7, p. 7; 8, p. 16]. The General Electric Company (GE)

reported that approximately 37,530 tons of waste materials from GE manufacturing facilities were deposited at the facility [Ref. 7, 

p. 7; 29, pp. 28-30]. New York State Department of Environmental Conservation (NYSDEC) reported that at least 8,790 tons of 

waste materials were deposited at the facility from other industrial sources, including Bendix Corporation and Schenectady 

Chemicals, Inc. [Ref. 6, p. 8; 7, p. 7; 8, p. 16; 29, p. 30; 30, pp. 4-5; 31, p. 2]. Waste materials were dumped into a lagoon area, 

oil pit, and drum burial area [Ref. 7, p. 8; 8, pp. 16, 17]. Some drum contents were pumped onto the ground surface, and waste 

materials were also burned during facility operations [Ref. 6, p. 8; 8, p. 16].

In 1968, after several years of citizen complaints, documented downstream fish and cattle kills, and uncontrolled fires at the 

facility, the State of New York ordered Loeffel to stop discharges from the disposal facility and perform remedial activities [Ref. 6, 

p. 8; 7, p. 7]. By 1974, Loeffel had covered and graded the disposal areas with soil and constructed drainage channels to control 

runoff [Ref. 6, p. 8; 7, pp. 7-8]. From 1974 to 1980, Loeffel continued to use four 30,000-gallon aboveground storage tanks

(AST) at the facility for waste oil transfer [Ref. 6, p. 9; 7, p. 8]. In 1980, GE entered into an agreement with NYSDEC to perform 

additional investigation and remediation at the facility [Ref. 6, p. 9; 7, pp. 9-10; 29, pp. 1, 13-27]. From 1982 to 1984, 

approximately 500 surface drums and the 30,000-gallon ASTs were removed from the property, and a NYSDEC-approved slurry 

wall, clay cap, and leachate collection system were installed [Ref. 6, pp. 9-10; 8, p. 17; 35, pp. 10, 14, 17-22]. The encapsulated 

disposal area (i.e., landfill) is evaluated as the source for HRS scoring purposes [Ref. 1, pp. 51591]. The facility is not classified 

as a treatment, storage, or disposal facility (TSDF) under the Resource Conservation and Recovery Act (RCRA) and is not subject 

to RCRA Subtitle C corrective action authority [Ref. 39, p. 1]

Since 1985, NYSDEC has overseen operation, maintenance, and monitoring activities at the DLL facility [Ref. 6, p. 9]. NYSDEC 

designated three operable units (OU) at the facility: OU1, the encapsulated disposal area; OU2, ground water contamination

associated with the facility; and OU3, surface water releases downgradient of the facility [Ref. 6, pp. 5-7, 10, 13]. In January 

2001, NYSDEC issued a Record of Decision (ROD) for OU2, and in January 2002, NYSDEC issued a ROD for OU3. No ROD 

for OU1 was issued [Ref. 6, p. 1; 9, p. 1]. GE has conducted remedial investigations and remedial actions associated with OU2 

and OU3 since 1992 [Ref. 8, pp. 7, 17-21; 9, pp. 10-15; 10, pp. 9-10; 11, pp. 1-2]. The January 2001 NYSDEC ROD concerning 

OU2 recommended several elements to eliminate or mitigate all significant threats to human health and/or the environment. 

However, two of these elements—an upgraded leachate collection system and a new water treatment facility to manage leachate—

have not yet been implemented [Ref. 9, pp. 6-7; 53, p. 2]. With respect to OU3, from 2001 to 2004, GE removed approximately 

15,000 tons of PCB-contaminated soil and sediments from the drainage-way between the facility and Nassau Lake, including the 

area immediately adjacent to the disposal facility, Mead Road Pond, Tributary T11A, and Valatie Kill [Ref. 12, pp. 5-7; 40, p. 7; 

41, p. 9].

In June and August 2009, EPA conducted sediment sampling along the surface water migration pathway downstream of the 

facility, including the former Mead Road Pond, Tributary T11A, Valatie Kill, Valley Stream, Smith Pond, and Nassau Lake [Ref. 

13, pp. 8-48; 14, pp. 3-6, 9; 15, pp. 3-8, 11]. Samples were analyzed for Target Compound List (TCL) Aroclors, total organic 

carbon (TOC), and grain size [Ref. 16 through 22]. The analytical results indicated the continuing presence of PCBsin sediment 
1 1

samples from the former Mead Road Pond, Tributary T11A, Valatie Kill, and Nassau Lake [Ref. 16, pp. 30-32; 17, pp. 3-5, 17, 

20-22, 24, 31-32, 45, 74]. Nassau Lake and the Valatie Kill between County Route 18 and Nassau Lake are fisheries that have 

been closed due to the site-related PCB contamination, and there are 2.83 miles of wetland frontage located within the zone of 

contamination [Figure 2; Ref. 8, pp. 21, 26; 23, pp. 13, 17, 21; 45, pp. 4, 6; 50, pp. 19, 20, 29].
CLIENT NAME: DATE: FIGURE #:

PROJECT:

LEGEND: TITLE:

!(

Facility Entrance

2,000 1,000 0 2,000

Feet

Facility Boundary

(11-acre encapsulated area)

 National Geographic TOPO! U.S. Geologic Survey (USGS). 7.5 Minute 

 Series (Topographic) Quadrangles: Nassau, NY 1992

EPA

Dewey Loeffel Landfill

October 2009 1

Site Location Map

Dewey Loeffel Landfill

Town of Nassau

Rensselaer County, NY

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Site Area

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KILL

DLL-SED27/27A

DLL-SED12/12A

DLL-SED11/11A

DLL-SED10/10A

DLL-SED13/13A

DLL-SED26/26A

DLL-SED25/25A

DLL-SED24/24A

DLL-SED21/21A

DLL-SED20/20A

DLL-SED19/19A

DLL-SED14/14A

DLL-SED15/15A

DLL-SED16/16A

DLL-SED17/17A

DLL-SED04/04A

DLL-SED03/03A

DLL-SED02/02A

DLL-SED22/22A

DLL-SED23/23A (Dup)

DLL-SED43A

DLL-SED45A

DLL-SED05/05A

DLL-SED18/18A

DLL-SED01/01A

DLL-SED28A DLL-SED29A

DLL-SED30A

DLL-SED31A

DLL-SED32A

DLL-SED33A

DLL-SED34A

DLL-SED35A

DLL-SED36A

DLL-SED37A

DLL-SED38A

DLL-SED39A

DLL-SED40A

DLL-SED41A DLL-SED42A

DLL-SED44A

DLL-SED46A (Dup)

Freshwater Forested/Shrub 

Wetland

Freshwater 

Emergent Wetland

Freshwater Emergent &

Forested/Shrub Wetland

Freshwater Forested/Shrub 

Wetland

Freshwater Forested/Shrub 

Wetland

Freshwater Forested/Shrub 

Wetland

DRAWING NUMBER: FIGURE #: CLIENT NAME:

PROJECT:

LEGEND: TITLE:

PROJECT MANAGER:

DATE:

DRAWN BY:

REVIEWED BY:

S. Poultney

G. Gilliland

G. Gilliland

Figure 2

Site Map

Dewey Loeffel Landfill HRS

US EPA January 2011 08829 2

.

!(

!(

!(

10 0 10 5 Feet

DLL-SED08/08A

DLL-SED06/06A

DLL-SED07/07A

 (Dup)

DLL-SED09/09A

Source:

1. Rensselaer County 2' Resolution Natural Color Ortho-imagery. NYS 

 Cyber Security & Critical Infrastructure Coordination. 

 http://www.nysgis.state.ny.us/gateway/mg/2007/rensselaer/. 11/01/2007

2. Weston Solutions, Inc. Region 2 Site Assessment Team 2, Site Logbook, 

 SAT2.20113.119.001, May-August 2009.

3. EPA CLP Data Packages, Dewey Loeffel Landfill. June-September 2009.

4. U.S Department of the Interior, Fish and Wildlife Service, St. Petersburg, 

 FL. National Wetlands Inventory, http://www.nwi.fws.gov. Date unknown; 

 downloaded April 2009.

5. NY State Department of Health, Chemicals in Sportfish and Game, 2008 

 -2009 Health Advisories. May 2008.

6. Weston Solutions, Inc. Site Logbook, DCN #1131-4E-AHLF. July 2010.

Tributary T11A

#*1

#*2

750 0 750 1,500 375

Feet

SCALE:

P:\SAT2\Dewey_Loeffel_Landfill_HRS\MXD\0710_GPS_Locs\08829_DLL_Site_Map.mxd

!( Sediment sample location with observed release concentration(s)

!( Sediment sample location with detected Aroclor concentration(s)

!( Sediment sample location with no detected Aroclors

!( Background sediment location

(! PCB analysis not completed (broken bottle during shipment)

Wetland Frontage

Zone of contamination with mile marker

Mapped Wetlands Along the Zone of Contamination

#*1

Valatie Kill

SCALE:

See Map
1 4

SD-Characterization and Containment

SOURCE DESCRIPTION

2.2 SOURCE CHARACTERIZATION

2.2.1 Source Identification

Number of the source: Source No. 1

Name and description of the source: Operable Unit 1 (OU1)

Source Type: Landfill

Source 1 consists of Operable Unit 1, the encapsulated disposal area (i.e., landfill) at the DLL facility [Ref. 6, p. 10]. 

The condition of the source changed significantly due to response actions, as described below:

Source Prior to Response Actions:

From 1952 to 1968, Loeffel operated the subject property as a disposal facility for waste materials generated by 

several industries [Ref. 6, pp. 5, 8; 7, p. 7; 8, p. 16]. GE reported that approximately 37,530 tons of waste 

materials from GE manufacturing facilities were deposited at the facility [Ref. 7, p. 7; 29, pp. 28-30]. NYSDEC 

reported that at least 8,790 tons of waste materials were deposited at the facility from other industrial sources, 

including Bendix Corporation and Schenectady Chemicals, Inc. [Ref. 6, p. 8; 7, p. 7; 8, p. 16; 29, p. 30; 30, pp. 

4-5; 31, p. 2]. The waste materials dumped at the facility included chlorinated solvents, solvents, waste oils, 

PCBs, acids and bases, other scrap materials (resins, paints, solids and liquid chemicals), heavy metal sludge, 

organic chemical sludge, paint sludge, wet dust collector residue, and PCB-contaminated solids [Ref. 6, pp. 5, 

8; 7, p. 7; 29, pp. 1, 28-30]. In May 1970, Rensselaer County Health Department (RCHD) reported that 

trichloroethylene (TCE), methyl chloride, toluene, xylene, silicones, phenols, lead, and other chemicals were 

known to be present [Ref. 32, p. 2].

Before remedial action was initiated, the Loeffel disposal facility consisted of a 6-acre lagoon, a 25- by 150-foot 

oil pit, a 1- to 3-acre drum storage and disposal area, and four 30,000-gallon ASTs [Ref. 7, p. 8]. During 

disposal operations, liquid hazardous wastes were transported to the facility and emptied into the lagoon or oil 

pit, pumped onto the ground surface, or left at the facility in sealed drums[Ref. 8, p. 16; 33, p. 4]. Some wastes

were reportedly burned during facility operations [Ref. 6, p. 8; 8, p. 16]. Drums were discarded on the lagoon 

perimeter or in a drum burial area, and were later covered with soil using a bulldozer [Ref. 8, p. 16]. The 

lagoon area was a natural swamp before Loeffel used it for liquid waste disposal [Ref. 33, p. 4]. A wastewater 

sample collected from the lagoon in July 1970 reportedly contained hydrocarbons including petroleum residues, 

sulfoxide organic compounds, and substituted aromatic organic compounds [Ref. 33, p. 6]. In October 1970, 

Loeffel indicated that the discharge of liquid industrial wastes over approximately 20 years had resulted in the 

former swamp being devoid of plant and animal life [Ref. 33, p. 5].

Source After Response Actions:

In 1968, after several years of citizen complaints, documented downstream fish and cattle kills, and 

uncontrolled fires at the facility, the State of New York ordered Loeffel to stop discharges from the disposal 

facility and perform remedial activities [Ref. 6, p. 8; 7, p. 7]. Remedial activities began in the summer of 1970, 

when Loeffel divided the lagoon into upper and lower areas with a 2- to 3-foot-high earthen dike and began to

fill the lower area with gravel [Ref. 7, pp. 7-8; 33, p. 7]. The liquid wastes displaced by the filling operation 

were either pumped to the upper lagoon area or into a tank truck for salvage use [Ref. 33, p. 7]. In August 

1970, Loeffel reported that “we have completely removed floating pollutants from lower lagoon and completed 

filling in lower lagoon” [Ref. 34, p. 1]. By 1974, Loeffel had covered and graded the disposal facility with soil 

and constructed drainage channels to control runoff [Ref. 6, p. 8; 7, pp. 7-8]. From 1974 to 1980, Loeffel 

continued to use the four 30,000-gallon ASTs at the facility for waste oil transfer [Ref. 6, p. 9; 7, p. 8].
1 5

SD-Characterization and Containment

In 1980, GE entered into an agreement with NYSDEC to perform additional investigation and remediation at 

the facility [Ref. 6, p. 9; 7, pp. 9-10; 29, pp. 1, 13-27]. From 1980 to 1984, a chain-link fence around the 

facility was installed, approximately 500 surface drums and four 30,000-gallon ASTs were removed from the 

property, and a NYSDEC-approved slurry wall, clay cap, and leachate collection system were installed at the 

disposal facility [Ref. 6, pp. 9-10; 8, p. 17; 35, pp. 10, 14, 17-22]. Since 1985, NYSDEC has overseen 

operation, maintenance, and monitoring activities at the facility [Ref. 6, p. 9]. The encapsulated disposal area 

(i.e., landfill) is designated by NYSDEC as OU1 and is evaluated as the source for HRS scoring purposes [Ref. 

6, p. 10].

In addition to OU1, NYSDEC designated ground water contamination associated with the facility as OU2 and

surface water releases downgradient of the facility as OU3 [Ref. 6, pp. 5-7, 10, 13]. GE has conducted remedial 

investigations and remedial actions associated with OU2 and OU3 since 1992 [Ref. 8, pp. 7, 17-21; 9, pp. 10-

15; 10, pp. 9-10; 11, pp. 1-2]. From 2001 to 2004, GE removed approximately 15,000 tons of PCBcontaminated soil and sediments from the drainage-way between the facility and Nassau Lake, including the 

area immediately adjacent to the disposal facility, Mead Road Pond, Tributary T11A, and Valatie Kill [Ref. 12, 

pp. 5-7; 40, p. 7; 41, p. 9].

Location of the source, with reference to a map of the site:

A November 7, 2007aerial photograph showing the boundary of the landfill (i.e., Source 1) is shown in Figure 

2.

Containment

Release to surface water via overland migration and/or flood:

There is evidence that hazardous substances (i.e., PCBs) migrated from the disposal area into downstream 

surface waters [see Section 4.1.2.1]. However, NYSDEC hasindicated that the contaminants migrated into the 

surface water pathway prior to the 1983-1984 remedial actions, which included the following containment 

measures: GE removed drums and tanks and installed a NYSDEC-approved slurry wall, clay cap, and leachate 

collection system at the disposal facility [Ref. 6, pp. 1, 9-10; 8, p. 17; 35, pp. 10, 14, 17-22]. Since 1985, 

NYSDEC has overseen operation, maintenance, and monitoring activities at the facility [Ref. 6, p. 9]. As 

evidenced by the Final Engineering Report for the remedial action and confirmed by wells installed within the 

encapsulated disposal area in 1996, there is no liner associated with the leachate control system [Ref. 35, pp. 14, 

25, 71-72, 78-83].

Based on the above considerations (i.e., a maintained engineered cover and functioning, maintained run-on 

control and runoff management system are present, but a liner is not present), a surface water containment factor 

value of 7 is assigned for this source [Ref. 1, p. 51609, Table 4-2].
1 6

SD-Hazardous Substances

Source No.: 1

2.4.1 Hazardous Substances

The waste materials dumped at the facility included chlorinated solvents, solvents, waste oils, PCBs, acids and bases, 

other scrap materials (resins, paints, solids and liquid chemicals), heavy metal sludge, organic chemical sludge, paint 

sludge, wet dust collector residue, and PCB-contaminated solids[Ref. 6, pp. 5, 8; 7, p. 7; 29, pp. 1, 28-30]. GE reported 

that approximately 37,530 tons of waste materials from GE manufacturing facilities were deposited at the facility [Ref. 7, 

p. 7; 29, pp. 28-30]. NYSDEC reported that at least 8,790 tons of waste materials were deposited at the facility from 

other industrial sources, including Bendix Corporation and Schenectady Chemicals, Inc. [Ref. 6, p. 8; 7, p. 7; 8, p. 16; 29, 

p. 30; 30, p. 4; 31, p.2]. GE collected soil samples from the disposal area in 1981, prior to installation of the clay cap and 

slurry wall, and reported that concentrations of individual PCBs (Aroclor-1016, Aroclor-1254, and Aroclor-1260) ranged 

from 0.6 to 979 parts per million (ppm) [Ref. 7, pp. 37-38, 77]. GE collected landfill leachate sample PO4-1021 in 1996 

and analyzed the sample for TCL volatile organic compounds (VOC), semivolatile organic compounds (SVOC), and 

PCBs in accordance with EPA’s “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846)”, 

Third Edition, Revision 1 dated December 1987 [Ref. 10, pp. 74, 90-97; 36, pp. 27, 36, 58]. The analytical results for 

sample PO4-1021 indicated the presence of VOCs, SVOCs, and the PCB Aroclor-1260 [Ref. 10, pp. 23-24, 74, 90-97]. 

Based on the leachate results, GE reported that Aroclor-1260 exists as a dense non-aqueous phase liquid (DNAPL) at the 

site [Ref. 10, p. 23].

Hazardous

Substance Evidence Reference(s)

Aroclor-1260 Leachate sample PO4-1021, GE, Oct-1996: 10, p. 97

260,000 μg/L

Chlorobenzene Leachate sample PO4-1021, GE, Oct-1996: 10, p. 91

89 μg/L

1,2-Dichlorobenzene Leachate sample PO4-1021, GE, Oct-1996: 10, pp. 91, 95

4.7 μg/L

1,3-Dichlorobenzene Leachate sample PO4-1021, GE, Oct-1996: 10, pp. 91, 95

19 μg/L

1,4-Dichlorobenzene Leachate sample PO4-1021, GE, Oct-1996: 10, pp. 91, 95

80 μg/L

2,4-Dimethylphenol Leachate sample PO4-1021, GE, Oct-1996: 10, p. 95

14 μg/L
1 7

SD-Hazardous Waste Quantity

Source No.: 1

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity

The information available is not sufficient to evaluate Tier A source hazardous waste quantity; therefore, hazardous 

constituent quantity is not scored (NS).

Hazardous Constituent Quantity (C) Value: NS

2.4.2.1.2 Hazardous Wastestream Quantity

GE reported that approximately 37,530 tons of waste materials from GE manufacturing facilities were deposited at the 

DLL facility [Ref. 7, p. 7; 29, pp. 28-30]. NYSDEC reported that at least 8,790 tons of waste materials from other 

industrial sources, including Bendix Corporation and Schenectady Chemicals, Inc., were deposited at the DLL facility

[Ref. 6, p. 8; 7, p. 7; 8, p. 16; 29, p. 30; 30, pp. 4-5; 31, p. 2]. However, GE removed an unknown quantity of the 

hazardous materials, some of which had been stored in sealed drums and tanks, prior to the installation of the landfill cap 

[Ref. 6, pp. 9-10; 8, p. 17; 35, pp. 10, 14, 17-22]. In addition, the condition of the source changed significantly due to 

response actions [see Section 2.2.1]. Therefore, the information available is not sufficient to evaluate Tier B source 

hazardous waste quantity, and hazardous wastestream quantity is not scored (NS).

Hazardous Wastestream Quantity (W) Value: NS

2.4.2.1.3 Volume

The information available is not sufficient to evaluate Tier C source hazardous waste quantity; therefore, volume is not 

scored (NS).

Dimension of source (yd3): NS

Volume (V) Assigned Value: NS

2.4.2.1.4 Area

GE reported that the encapsulated disposal area (i.e., landfill) covers an area of approximately 11 acres [Ref. 7, p. 8; 10, 

pp. 13-14]. However, there were multiple sources originally and it is unclear how much waste was removed prior to 

encapsulation. Therefore, the area value is assigned a value of greater than zero but the specific amount is unknown [Ref. 

1, p. 51591, Section 2.4.2.1.4, Table 2-5].

Area (A) Assigned Value: > 0

2.4.2.1.5 Source Hazardous Waste Quantity Value

The source hazardous waste quantity value for Source 1 is > 0 for Tier D - Area [Ref. 1, p. 51591].

Source Hazardous Waste Quantity Value: > 0
1 8

SD-Summary

SITE SUMMARY OF SOURCE DESCRIPTIONS

 Containment

Source

Source Hazardous Waste Ground Surface Air

Number Quantity Value Water Water Gas Particulate

1 > 0 NS 7 * NS NS

NS = Not Scored

* The overland flow containment factor is 7 for the source [see Section 2.2.1].

Other Possible Sources (these former sources were subject to response actions, including removal and 

encapsulation; all that remains of them is within the encapsulated disposal area [Source No. 1]):

Before remedial action was initiated, the Loeffel disposal facility consisted of a 6-acre lagoon, a 25- by 150-foot 

oil pit, a 1- to 3-acre drum storage and disposal area, and four 30,000-gallon ASTs [Ref. 7, p. 8]. Hazardous 

substances deposited in these sources included chlorinated solvents, waste oils, PCBs, petroleum products, and 

aromatic organic compounds [Ref. 6, p. 8; 7, pp. 7-8; 8, p. 16; 33, pp. 4]. During disposal operations, liquid 

hazardous wastes were transported to the facility and emptied into the lagoon or oil pit, pumped onto the ground 

surface, or left at the facility in sealed drums [Ref. 8, p. 16; 33, p. 4]. Some wastes were reportedly burned 

during facility operations [Ref. 6, p. 8; 8, p. 16]. Drums were discarded on the lagoon perimeter or in a drum 

burial area, and were later covered with soil using a bulldozer [Ref. 8, p. 16]. The lagoon area was a natural 

swamp before Loeffel used it for liquid waste disposal [Ref. 33, p. 4]. A wastewater sample collected from the 

lagoon in July 1970 reportedly contained hydrocarbons including petroleum residues, sulfoxide organic 

compounds, and substituted aromatic organic compounds [Ref. 33, p. 6]. In October 1970, Loeffel indicated 

that the discharge of liquid industrial wastes over approximately 20 years had resulted in the former swamp 

being devoid of plant and animal life [Ref. 33, p. 5].
1 9

SWOF-Surface Water Overland Flow/Flood Migration Pathway

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component

The DLL facility is located in a low-lying area (elevation approximately 620 feet) between two wooded hills with peak 

elevations of 876 and 778 feet above mean sea level (MSL) [Figure 1; Ref. 4, p. 1; 6, p. 7; 9, p. 7]. Topography in the 

area generally slopes downward from east to west [Ref. 6, p. 7]. Surface drainage at the facility is controlled by a series 

of drainage swales built into and around the vegetated landfill cap, which was constructed in 1984 [Ref. 6, pp. 7, 10]. 

From the disposal facility, surface water flows into the Valatie Kill drainage basin [Ref. 6, p. 7]. There are two probable 

points of entry (PPE) to surface water from the DLL facility: northwest toward the former Mead Road Pond (PPE1) and

southeast toward Valley Stream (PPE2) [Figure 2; Ref. 6, pp. 7, 48; Ref. 25, p. 1]. The majority of surface water drains 

northwest into an unnamed stream (the “northwest drainage ditch”; PPE1), through the former Mead Road Pond and into 

Tributary T11A, which in turn flows into Valatie Kill [Figure 2; Ref. 6, p. 7; 8, pp. 18-19, 105]. Valatie Kill flows 

southwest into Nassau Lake approximately 3.1 miles downstream of the facility, into Kinderhook Lake approximately 8.5 

miles downstream, and to the end of the target distance limit (TDL) [Ref. 25, p. 1]. The secondary drainage system flows 

southeast into an unnamed tributary (the “southeast drainage ditch”; PPE2) and into Valley Stream, which flows through 

Smith Pond on its way to Nassau Lake 3.4 miles downstream [Figure 2; Ref. 6, pp. 7, 48]. PPE2 is not used in the site 

scoring because doing so would not change the site score, but contamination migrating from this location does pose a 

threat to downstream surface waters.

The northwest drainage ditch, former Mead Road Pond, Tributary T11A, and Valatie Kill are perennial streams, as 

illustrated in GE’s Completion Report for the Mead Road Pond Area Interim Remedial Measures and confirmed by the 

presence of water at all times during the EPA investigation [Ref. 13, pp. 4-6, 10-13, 17-18, 23, 39-42, 45-46, 49-52, 55, 

59-61; 14, pp. 4-5, 9; 40, pp. 8, 25, 43-51, 67-69]. Nassau Lake and the Valatie Kill between County Route 18 and 

Nassau Lake are fisheries that have been closed due to the site-related PCB contamination, and there are 2.83 miles of 

wetland frontage located within the zone of contamination [Figure 2; Ref. 8, pp. 21, 26; 23, pp. 13, 17, 21; 45, pp. 4, 6; 

50, pp. 19, 20, 29].

The Dewey Loeffel Landfill site is scored by the following approach:

The threats being evaluated are the Surface Water Pathway Human Food Chain and Environmental Threats.

An observed release by chemical analysis is documented, and the hazardous substances present are PCBs [see 

Section 4.1.2.1].

The known zone of contamination extends from PPE1 at the northwest corner of the facility into Nassau Lake 

(sample DLL-SD34A), approximately 3.4 miles downstream [see Figure 2].

Targets subject to actual contamination include the Valatie Kill and Nassau Lake fisheries [see Section 4.1.3.3] 

and approximately 2.83 miles of wetland frontage [see Section 4.1.4.3].

As mentioned above, PPE2 is not used in the site scoring because it does not contribute to the site score, but it 

does pose a threat to downstream surface waters.
20

SWOF-Observed Release

4.1.2.1 Likelihood of Release

4.1.2.1.1 Observed Release

Sampling and analysis by EPA in June and August 2009 showed the presence of PCBs at concentrations significantly 

above background concentrations in several sediment samples collected downstream of the DLL facility. Tables 1 and 2 

present the background and observed release concentrations. Additionally, new and historical data indicate elevated 

levels of PCBs downstream of the DLL facility [Ref. 46, pp. 1-4; 47, pp. 1-6; 48, pp. 25-26].

NYSDEC has designated surface water releases downgradient of the DLL facility as operable unit OU3 [Ref. 6, pp. 5-7, 

13]. GE has conducted remedial investigations and remedial actions associated with OU3 since 1992, and NYSDEC 

issued its ROD for OU3 in January 2002 [Ref. 6, p. 1; 8, pp. 7, 17-21; 11, pp. 1-2]. From 2001 to 2004, GE removed

approximately 15,000 tons of PCB-contaminated soil and sediments from the drainage-way between the facility and

Nassau Lake, including the area immediately adjacent to the disposal facility, Mead Road Pond, Tributary T11A, and

Valatie Kill [Ref. 12, pp. 5-7; 40, p. 7; 41, p. 9]. However, recent fish tissue data (2008) indicate that PCBs still affect 

several species in surface waters downstream of the facility [Ref. 12, pp. 20-91].

Direct Observation

An observed release by direct observation is not being scored.

Chemical Analysis

An observed release by chemical analysis is documented along the surface water migration pathway downstream of the 

Dewey Loeffel Landfill facility, between sample location DLL-SED12 in the former Mead Road Pond and sample 

location DLL-SED34A in Nassau Lake, approximately 3.4 miles downstream [Figure 2].

In June and August 2009, EPA conducted sediment sampling along the surface water migration pathway downstream of 

the facility, including the former Mead Road Pond, Tributary T11A, Valatie Kill, Valley Stream, Smith Pond, and Nassau

Lake [Ref. 13, pp. 8-48; 14, pp. 3-6, 9; 15, pp. 3-8, 11]. Samples were analyzed for TCL Aroclors (i.e., PCBs), TOC,

and grain size [Ref. 16 through 22]. The validated analytical results indicated the continuing presence of PCBs at 

concentrations significantly above background in sediment samplesfrom the former Mead Road Pond, Tributary T11A, 

Valatie Kill, and Nassau Lake [See Tables 1 and 2; Ref. 16, pp. 17, 28, 30-32, 38; 17, pp. 3-5, 7, 17, 20-24, 31-32, 45, 

50, 74]. The June and August 2009 sediment data document the observed release by chemical analysis to the surface 

water pathway. The background sample locations were chosen because they are representative of upgradient locations 

unaffected by site contamination [Ref. 14, pp. 4-6, 9; 15, pp. 5-8, 11].

Notes on Sample Similarity:

Figure 2 (Sample Location Map) shows the background and release sample locations for the DLL site. Background 

samples were collected upstream from influence by the source [Figure 2]. The release sample data from three different 

water body types (stream, lake, spring) were compared to samplesfrom the only usable upgradient background locations, 

which came from stream samples [Tables 1 and 2] (i.e., there were no lakes or springs immediately upgradient of the 

release sample locations). The background and release samples were handled the same procedurally and were similar 

physically, as follows:

• Sampling Methods: The background and release sediment samples were all collected by EPA, using Standard 

Operating Procedures (SOP), during the June and August 2009 sampling events [Ref. 14, pp. 2-6; 15, pp. 2-8].

• Analytical Procedures: The background and release samples were all analyzed for TCL Aroclors through the 

Contract Laboratory Program (CLP) [Ref. 16, pp. 1-43; 17, pp. 1-84]. The samples were also analyzed for 

grain-size distribution according to Method ASTM D422-63 and for TOC according to Method CORP ENG 

81M/SW9060M by Accutest Laboratories of Dayton, New Jersey [Ref. 18 through 22].

• Data Validation: The PCB analytical data were reviewed independently by EPA according to “SOP HW-37 

(Revision 1), USEPA Region II Data Validation SOP for Statement of Work SOM01.2” dated August 2007 
21

[Ref. 16, pp. 2-9; 17, pp. 8-11, 41-44, 69-72, 81-84]. The data reviewers found the results to be valid and 

acceptable with the following exception:

o The non-detect results for background samples DLL-SED43A, DLL-SED44A, DLL-SED45A, and 

DLL-SED46A, collected in August 2009, were found to be unusable because percent moisture content 

exceeded 90% [Ref. 15, pp. 7-8; 17, pp. 33-35, 41, 44, 73, 81, 84].

• Water Body Type: Background and release samples presented in Tables 1 and 2 were all collected from small 

streams, with the exception of sample DLL-SED34A, which was collected from Nassau Lake in August 2009. 

EPA collected background lake samples DLL-SED43A, DLL-SED44A, DLL-SED45A, and DLL-SED46A

from Lyons Lake [see Figure 2] in August 2009, and Aroclors were not detected. However, the non-detect 

results for the Lyons Lake samples were found to be unusable because percent moisture content exceeded 90%. 

The percent moisture values ranged from 91% to 93%, whereas the percent moisture value for sample DLLSED34A was 78% [Ref. 14, pp. 4-6, 9; 15, pp. 5-8, 11; 17, pp. 33-35, 41, 44, 73, 81, 84]. Based on these 

considerations, the results for sample DLL-SED34A are compared to the highest usable background value for 

significance above background [Table 2].

• Sampling Depth: Background and release samples were all collected from the 0-to 6-inch interval below top of 

sediment [Ref. 13, pp. 10-19, 21-47].

• Percent Moisture: The percent moisture in the background samples ranged from approximately 17% to 62%, 

while percent moisture in the release samples ranged from approximately 15% to 78% [Ref. 16, pp. 17, 28, 30-

32, 38; 17, pp. 3-5, 7, 17, 20-24, 31-32, 44-45, 50, 74].

• Total Organic Carbon: The TOC levels in the background samples ranged from less than 1,300 milligrams per 

kilogram (mg/kg) to 33,000 mg/kg, while TOC levelsin the release samples ranged from less than 1,200 mg/kg 

to 53,300 mg/kg [Ref. 18, pp. 14, 16-18, 24, 32; 20, p. 8, 15, 17; 21, pp. 6, 9, 12-15; 22, pp. 12-15, 17].

• Grain Size: The amount of fine-grained materials (silt, clay, and colloids) in the solid portion of the background 

samples ranged from 4.9% to 39.7%, with an average of 17.2%. The amount of fine-grained materials in the 

solid portion of the release samples ranged from 0.74% to 90.4%, with an average of 16.5% [Ref. 18, pp. 14, 

16-18, 24, 32; 20, p. 8, 15, 17; 21, pp. 6, 9, 12-15; 22, pp. 12-15, 17].

Due to the similarities (i.e., same time frames, sampling and analytical methods, and sampling depths; overlapping ranges 

[except for Nassau Lake sample DLL-SED34A] of percent moisture, TOC, and grain-size) among the background and 

release samples, the background and release analytical results are considered to be comparable.

Notes on significance above background:

EPA evaluated Phase 1 (June 2009) and Phase 2 (August 2009) samples separately, comparing observed release 

concentrations to the highest usable background values (i.e., highest SQLs) within each data set. Results for two of the 

June 2009 background samples—DLL-SED08 and DLL-SED18—originally determined to be not detected and marked 

with a “U” flag by the laboratory, were initially flagged “UJ” during data validation because the samples were associated 

with a continuing calibration verification (CCV) quality control sample %difference that exceeded criteria [Table 1; Ref. 

16, pp. 8, 28, 38]. However, it was subsequently determined that the “UJ” qualifiers were incorrectly applied due to a 

peak identification error occurring in instrument software at the laboratory, and therefore no quality control issue 

occurred [see Ref. 42, pp. 86, 94, 169, 170 for the related original CCV laboratory data sheets, and Ref. 43, pp. 86, 94, 

169, 170 for those data sheets corrected by the laboratory]. The Aroclor results for samples DLL-SED08 and DLLSED18 thus appear below in Table 1 with their original “U” flag.

The following criteria from the HRS were used to evaluate significance above background (i.e., observed release):

• If the maximum background concentration is not detected or is less than the detection limit, an observed release 

is established when the sample measurement equals or exceeds the SQL [Ref. 1, p. 51589].

• If the maximum background concentration equals or exceeds the detection limit, an observed release is 

established when the sample measurement equals or exceeds the SQL and is three times or more above the 

background concentration [Ref. 1, p. 51589, Table 2-3].

• The Aroclor-1260 result for sample DLL-SED34A (B5Q64) is qualified as positively identified but 

approximate (“J”) because the percent moisture content is greater than 70% but less than or equal to 90%, 

which indicates an associated low bias [Table 2; Ref. 17, pp. 32, 41, 44]. Therefore, this result is considered 

usable without any adjustment, because the true value, had there been no moisture-related interference in the 

extraction, would only be greater than 1,700 μg/kg. .
22

Notes on Tables 1 and 2:

Italics denote the highest usable background value (i.e., highest SQL) for each hazardous substance.

Bold shaded indicates concentrations that meet the criteria for observed release.

Blank spaces indicate that the results do not meet observed release criteria.

Explanation of the Comments Row: “Background Sample” indicates a sample collected upstream from 

influence by the source. “Dup.” means duplicate of the sample specified.
23

Table 1

Background and Observed Release Concentrations

Phase I Sediment Sampling - June 2009

Dewey Loeffel Landfill, Nassau, NY

Background Concentrations Observed Release Concentrations

Field Sample No. DLL-SED08 DLL-SED18 DLL-SED27 DLL-SED10 DLL-SED11 DLL-SED12

EPA Sample No. B5PE2 B5PF2 B5PG2 B5PE4 B5PE5 B5PE6

Date 6/8/2009 6/8/2009 6/9/2009 6/9/2009 6/9/2009 6/9/2009

Depth (inches) 0-6 0-6 0-6 0-6 0-6 0-6

Comment Background 

Sample - stream

Background 

Sample - stream

Background 

Sample - stream

stream stream stream

References Ref. 13, pp. 10-11; 

14, pp. 4, 9, 11, 17

Ref. 13, pp. 10-11; 

14, pp. 5, 9, 12, 18

Ref. 13, pp. 11, 19; 

14, pp. 6, 9, 15, 19

Ref. 13, pp. 11, 17; 

14, pp. 4, 9, 14, 17

Ref. 13, pp. 11, 17-

18; 14, pp. 4, 9, 14, 

17

Ref. 13, pp. 11, 17-

18; 14, pp. 5, 9, 14, 

17

PCBs (μg/kg) Result SQL Result SQL Result SQL Result SQL Result SQL Result SQL

Aroclor-1260 42 U 42 44 U 44 87 U 87 340 41 190 45 170 59

% Moisture 22 25 62 19 27 44

Reference Ref. 16, pp. 6-9, 

28; 37, p. 8

Ref. 16, pp. 6-9, 

38; 37, p. 10

Ref. 16, pp. 2-5, 

17; 37, p. 4

Ref. 16, pp. 6-9, 

30; 37, p. 8

Ref. 16, pp. 6-9, 31; 

37, p. 8

Ref. 16, pp. 6-9, 32; 

37, p. 9

Total Organic Carbon (mg/kg) <1,300 5,430 33,000 1,620 8,190 10,800

% Gravel 24.2 23.2 3.5 16.2 52.3 14.7

% Sand 70.9 49.2 56.8 80.7 43 80.8

% Silt, Clay, Colloids 4.9 27.7 39.7 3.1 4.8 4.6

Reference Ref. 18, p. 14 Ref. 18, p. 24 Ref. 18, p. 32 Ref. 18, p. 16 Ref. 18, p. 17 Ref. 18, p. 18

μg/kg - micrograms per kilogram

mg/kg - milligrams per kilogram

SQL - Sample quantitation limit

U - The substance was analyzed for, but no quantifiable concentration was found at or above the Contract Required Quantitation Limit (CRQL) [Ref. 26, p. 6].

Notes: 

* Maximum values (italicized) were used for determination of observed release.

Highlighted results indicate observed release concentrations.
24

Table 2

Background and Observed Release Concentrations

Phase II Sediment Sampling - August 2009

Dewey Loeffel Landfill, Nassau, NY

Background Concentrations Observed Release Concentrations

Field Sample No. DLL-SED08A DLL-SED18A DLL-SED27A DLL-SED01A DLL-SED02A DLL-SED05A DLL-SED06A DLL-SED07A

EPA Sample No. B5Q38 B5Q48 B5Q57 B5Q31 B5Q32 B5Q35 B5Q36 B5Q37

Date 8/7/2009 8/6/2009 8/8/2009 8/6/2009 8/7/2009 8/7/2009 8/7/2009 8/7/2009

Depth (inches) 0-6 0-6 0-6 0-6 0-6 0-6 0-6 0-6

Comment Background 

Sample -

stream

Background 

Sample -

stream

Background 

Sample -

stream

stream stream stream stream Dup. of DLLSED06A

References Ref. 13, pp. 21, 

41; 15, pp. 5, 

11, 21, 23

Ref. 13, pp. 21, 

33; 15, pp. 6, 

11, 15, 17

Ref. 13, pp. 21, 

47; 15, pp. 7, 

11, 25, 27

Ref. 13, pp. 21, 

29; 15, pp. 5, 

11, 15, 17

Ref. 13, pp. 21, 

36; 15, pp. 5, 

11, 21, 23

Ref. 13, pp. 21,

40; 15, pp. 5, 

11, 21, 23

Ref. 13, pp. 21, 

40; 15, pp. 5, 

11, 21, 23

Ref. 13, pp. 21, 

40; 15, pp. 5, 

11, 21

PCBs (μg/kg) Result SQL Result SQL Result SQL Result SQL Result SQL Result SQL Result SQL Result SQL

Aroclor-1232 47 U 47 43 U 43 40 U 40

Aroclor-1260 47 U 47 43 U 43 40 U 40 65 44 280 49 940 40 1,000 40 1,300 40

% Moisture 30 24 17 26 33 19 18 18

Reference Ref. 17, pp. 23, 

41-44; 37, p. 

17

Ref. 17, pp. 50, 

69-72; 37, p. 

22

Ref. 17, pp. 7-

11; 37, p. 13

Ref. 17, pp. 45, 

69-72; 37, p. 

21

Ref. 17, pp. 17, 

41-44; 37, p. 

14

Ref. 17, pp. 20, 

41-44; 37, p. 

15

Ref. 17, pp. 21, 

41-44; 37, p. 

16

Ref. 17, pp. 22, 

41-44; 37, p. 

16

Total Organic Carbon (mg/kg) 11,600 3,350 2,000 5,540 15,700 24,100 <1200 Duplicate 

sample not 

analyzed for 

TOC or Grain 

Size

% Gravel 0.16 9.2 14.4 0.42 0.19 11.2 23.1

% Sand 87 78.3 79.8 88.7 73.8 78.2 75.3

% Silt, Clay, Colloids 12.9 12.5 5.7 10.9 26 10.6 1.5

Reference Ref. 21, p. 14 Ref. 20, p. 17 Ref. 22, p. 17 Ref. 20, p. 15 Ref. 21, p. 6 Ref. 21, p. 15 Ref. 21, p. 12

μg/kg - micrograms per kilogram

mg/kg - milligrams per kilogram

SQL - Sample quantitation limit

CRQL - Contract required quantitation limit

U - The substance was analyzed for, but no quantifiable

 concentration was found at or above the CRQL [Ref. 26, p. 6].

C - Result confirmed by gas chromatography/mass spectrometry (GC/MS)

J - The substance was positively identified; the associated numerical value

 is the approximate concentration of the analyte in the sample [Ref. 26, p. 6].

Notes: 

* Maximum values (italicized) were used for determination of observed release.

Highlighted results indicate observed release concentrations.
25

Table 2

Background and Observed Release Concentrations

Phase II Sediment Sampling - August 2009

Dewey Loeffel Landfill, Nassau, NY

Background Concentrations Observed Release Concentrations (continued)

Field Sample No. DLL-SED08A DLL-SED18A DLL-SED27A DLL-SED09A DLL-SED10A DLL-SED11A DLL-SED12A DLL-SED26A

EPA Sample No. B5Q38 B5Q48 B5Q57 B5Q39 B5Q40 B5Q41 B5Q42 B5Q56

Date 8/7/2009 8/6/2009 8/8/2009 8/7/2009 8/8/2009 8/8/2009 8/8/2009 8/7/2009

Depth (inches) 0-6 0-6 0-6 0-6 0-6 0-6 0-6 0-6

Comment Background 

Sample - stream

Background 

Sample - stream

Background 

Sample - stream

stream stream stream stream stream

References Ref. 13, pp. 21, 

41; 15, pp. 5, 

11, 21, 23

Ref. 13, pp. 21, 

33; 15, pp. 6, 

11, 15, 17

Ref. 13, pp. 21, 

47; 15, pp. 7, 

11, 25, 27

Ref. 13, pp. 21, 

41; 15, pp. 5, 

11, 21, 23

Ref. 13, pp. 21, 

45; 15, pp. 5, 

11, 25, 27

Ref. 13, pp. 21, 

46; 15, pp. 5, 

11, 25, 27

Ref. 13, pp. 21, 

46; 15, pp. 5, 

11, 25, 27

Ref. 13, pp. 21, 

39; 15, pp. 6, 

11, 22, 27

PCBs (μg/kg) Result SQL Result SQL Result SQL Result SQL Result SQL Result SQL Result SQL Result SQL

Aroclor-1232 47 U 47 43 U 43 40 U 40 200 83

Aroclor-1260 47 U 47 43 U 43 40 U 40 680 39 700 39 560 39 3,300 C 83 740 68

% Moisture 30 24 17 16 15 15 21 52

Reference Ref. 17, pp. 23, 

41-44; 37, p. 17

Ref. 17, pp. 50, 

69-72; 37, p. 22

Ref. 17, pp. 7-

11; 37, p. 13

Ref. 17, pp. 24, 

41-44; 37, p. 17

Ref. 17, pp. 3, 

8-11; 37, p. 11

Ref. 17, pp. 4, 

8-11; 37, p. 12

Ref. 17, pp. 5, 

8-11; 37, p. 12; 

44, p. 39

Ref. 17, pp. 31, 

41-44; 37, p. 19

Total Organic Carbon (mg/kg) 11,600 3,350 2,000 1,460 <1200 <1200 <1200 35,500

% Gravel 0.16 9.2 14.4 32.7 46.7 16.8 17.5 8.9

% Sand 87 78.3 79.8 66.2 52.6 81.9 79.6 40.2

% Silt, Clay, Colloids 12.9 12.5 5.7 1.1 0.74 1.4 2.9 50.9

Reference Ref. 21, p. 14 Ref. 20, p. 17 Ref. 22, p. 17 Ref. 21, p. 13 Ref. 22, p. 13 Ref. 22, p. 14 Ref. 22, p. 15 Ref. 22, p. 12

μg/kg - micrograms per kilogram

mg/kg - milligrams per kilogram

SQL - Sample quantitation limit

CRQL - Contract required quantitation limit

U - The substance was analyzed for, but no quantifiable

 concentration was found at or above the CRQL [Ref. 26, p. 6].

C - Result confirmed by gas chromatography/mass spectrometry (GC/MS)

J - The substance was positively identified; the associated numerical value

 is the approximate concentration of the analyte in the sample [Ref. 26, p. 6].

Notes: 

* Maximum values (italicized) were used for determination of observed release.

Highlighted results indicate observed release concentrations.
Table 2 

Background and Observed Release Concentrations 

Phase II Sediment Sampling - August 2009 

Dewey Loeffel Landfill, Nassau, NY 

Background Concentrations Observed Release 

Field Sample No. DLL-SED08A DLL-SED18A DLL-SED27A DLL-SED34A 

EPA Sample No. B5Q38 B5Q48 B5Q57 B5Q64 

Date 8/7/2009 8/6/2009 8/8/2009 8/6/2009 

Depth (inches) 0-6 0-6 0-6 0-6 

Comment Background Sample -

stream 

Background Sample -

stream 

Background Sample -

stream 

lake 

References Ref. 13, pp. 21, 41; 15, 

pp. 5, 11, 21, 23 

Ref. 13, pp. 21, 33; 15, 

pp. 6, 11, 15, 17 

Ref. 13, pp. 21, 47; 15, 

pp. 7, 11, 25, 27 

Ref. 13, pp. 21, 27; 15, pp

16-17 

PCBs (μg/kg) Result SQL Result SQL Result SQL Result Bias CRQL 

Aroclor-1232 47 U 47 43 U 43 40 U 40 Aroclor-1260 47 U 47 43 U 43 40 U 40 1,700 J Low 33 

% Moisture 30 24 17 78 

Reference Ref. 17, pp. 23, 41-44; 37, 

p. 17 

Ref. 17, pp. 50, 69-72; 37, 

p. 22 

Ref. 17, pp. 7-11; 37, p. 

13 

Ref. 17, pp. 32, 41-44; 37

Total Organic Carbon (mg/kg) 11,600 3,350 2,000 53,300 

% Gravel 0.16 9.2 14.4 0 

% Sand 87 78.3 79.8 9.6 % Silt, Clay, Colloids 12.9 12.5 5.7 90.4 

Reference Ref. 21, p. 14 Ref. 20, p. 17 Ref. 22, p. 17 Ref. 20, p. 8 

μg/kg - micrograms per kilogram mg/kg - milligrams per kilogram SQL - Sample quantitation limit CRQL - Contract required quantitation limit U - The substance was analyzed for, but no quantifiable 

 concentration was found at or above the CRQL [Ref. 26, p. 6]. 

C - Result confirmed by gas chromatography/mass spectrometry (GC/MS) J - The substance was positively identified; the associated numerical value 

 is the approximate concentration of the analyte in the sample [Ref. 26, p. 6]. 

Notes: 

* Maximum values (italicized) were used for determination of observed release. Highlighted results indicate observed release concentrations. 

26 
27

SWOF-Observed Release

Attribution

From 1952 to 1968, Loeffel operated the DLL facility as a disposal facility for waste materials generated by several 

industries [Ref. 6, pp. 5, 8; 7, p. 7; 8, p. 16]. Waste materials were dumped into a lagoon area, oil pit, and drum burial 

area; drum contents were pumped onto the ground surface; and some waste materials were burned [Ref. 6, p. 8; 8, p. 16]. 

The waste materials dumped at the facility included solvents, waste oils, PCBs, scrap materials, sludges, and solids[Ref. 

6, pp. 5, 8; 7, p. 7; 29, pp. 1, 28-30]. GE reported that approximately 37,530 tons of waste materials from GE 

manufacturing facilities were deposited at the facility [Ref. 7, p. 7; 29, pp. 28-30]. NYSDEC reported that at least 8,790 

tons of waste materials were deposited at the facility from other industrial sources, including Bendix Corporation and 

Schenectady Chemicals, Inc. [Ref. 6, p. 8; 7, p. 7; 8, p. 16; 29, p. 30; 30, pp. 4-5; 31, p. 2]. 

GE collected soil samples from the disposal area in 1981, prior to installation of the clay cap and slurry wall, and 

reported that concentrations of individual PCBs (Aroclor-1016, Aroclor-1254, and Aroclor-1260) ranged from 0.6 ppm 

to 979 ppm [Ref. 7, pp. 37-38, 77]. A landfill leachate sample collected by GE in 1996 indicated the presence of the 

PCB Aroclor-1260, and GE reported that Aroclor-1260 exists as a DNAPL at the facility [Ref. 10, pp. 23-24, 74, 90-97].

From 2001 to 2004, GE removed approximately 15,000 tons of PCB-contaminated soil and sediments from the drainageway between the facility and Nassau Lake, including the area immediately adjacent to the disposal facility, Mead Road 

Pond, Tributary T11A, and Valatie Kill [Ref. 12, pp. 5-7; 40, p. 7; 41, p. 9]. However, recent fish tissue data (2008) 

indicate that PCBs still affect several species in surface waters downstream of the facility [Ref. 12, pp. 20-91].

PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons [Ref. 27, p. 1]. PCBs 

were manufactured domestically from 1929 until their manufacture was banned in 1979 [Ref. 27, p. 1]. Once released, 

PCBs do not readily break down and therefore remain in the environment for long periods of time [Ref. 27, p. 2]. There 

are no other known PCB sites within 1 mile of the facility, including along the drainage pathways [Ref. 28, pp. 2-45].

Hazardous Substances Released:

PCBs (Aroclor-1232 and Aroclor-1260)

[Tables 1 and 2]

===================================================================================

Observed Release Factor Value: 550
28

SWOF/Food Chain-Waste Characteristics

4.1.3.2 Human Food Chain Threat - Waste Characteristics

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

Hazardous Substance

Toxicity 

Factor 

Value*

Persistence 

Factor 

Value**

Food Chain 

Bioaccumulation 

Factor Value*

Toxicity/Persistence/ 

Bioaccumulation Factor 

Value (Table 4-16)

Ref. 2 

Page

PCBs[Aroclor-1232 and 

Aroclor-1260]

10,000 1 50,000 5 x 108 BI-10

* Fresh water values for toxicity and bioaccumulation are used [Ref. 2, p. BI-10].

** PCBs are assigned the same persistence factor value (i.e., 1.0000) for both water body types (river and lake) within the 

target distance limit [Ref. 2, p. BI-10].

PCBs are associated with the highest toxicity/persistence/bioaccumulation factor value of 5 x 108

.

4.1.3.2.2 Hazardous Waste Quantity

Source Hazardous Is source hazardous

Waste Quantity constituent quantity

Source Number Value (HRS Section 2.4.2.1.5) data complete? (yes/no)

1 > 0 no

Sum of Values: > 0

The sum corresponds to a hazardous waste quantity factor value of 1 in Table 2-6 of the HRS [Ref. 1, p. 51591]. 

However, based on the fact that targets are subject to Level II concentrations [see Section 4.1.3.3.2.2], a hazardous waste 

quantity factor value of 100 is assigned if it is greater than the hazardous waste quantity value from Table 2-6 (i.e., 1) 

[Ref. 1, p. 51591-51592]. Therefore, a hazardous waste quantity factor value of 100 is assigned for the surface water 

pathway [Ref. 1, p. 51591-51592]. 

4.1.3.2.3 Calculation of Human Food Chain Threat - Waste Characteristics Factor Category Value

One hazardous substance [PCBs] associated with the waste source, which has a surface water pathway containment factor 

greater than 0 for the watershed, corresponds to a Toxicity/Persistence Factor Value of 10,000 and Bioaccumulation 

Potential Factor Value of 50,000, as shown previously [Ref. 1, pp. 51618, 51620; 2, p. BI-10].

(Toxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 10,000 x 100 = 1 x 106

(Toxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value)

x (Bioaccumulation Potential Factor Value) = (1 x 106

) x (50,000) = 5 x 1010

The product of 5 x 1010 corresponds to an assigned Waste Characteristics Factor Category Value of 320 in Table 2-7 of 

the HRS [Ref. 1, p. 51592].

===================================================================================

Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108

Hazardous Waste Quantity Factor Value: 100

Waste Characteristics Factor Category Value: 320
29

SWOF/Food Chain-Targets

4.1.3.3 Human Food Chain Threat - Targets

Nassau Lake and the Valatie Kill between County Route 18 and Nassau Lake are fisheries that have been closed due to 

the site-related PCB contamination; New York State Department of Health (NYSDOH) has issued “Eat No Fish” 

advisories [Figure 2; Ref. 8, pp. 21, 26; 23, pp. 13, 17, 21; 50, pp. 19, 20, 29]. Local residents occasionally ate fish from 

both water bodies prior to implementation of the advisories, but stopped consumption due to the PCB contamination

[Ref. 24, pp. 1-50]. PCBs in fish tissue have been documented, and although some decline in fish tissue PCB levels was 

observed following cleanup efforts at the site, PCB levels in fish tissue have become more static in recent years [Ref. 51, 

pp. 50-51]1

Sediment Samples for Observed Release

Bioaccumulation

Distance Hazardous Potential

Sample ID from PPE Substance Factor Value Reference(s)

DLL-SED26A 0 feet PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED12 400 feet PCBs 50,000 Figure 2; Table 1; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED12A 400 feet PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED11 650 feet PCBs 50,000 Figure 2; Table 1; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED11A 650 feet PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED10 850 feet PCBs 50,000 Figure 2; Table 1; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED10A 850 feet PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED47A 1500 feet PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED09A 2000 feet PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED06A/7A 2000 feet PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED05A 4000 feet PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED02A 2.6 miles PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

. These fisheries are both within the zone of contamination for the Dewey Loeffel Landfill site [Figure 2]. 

The HRS says to consider a closed fishery (or portion of a fishery) within the target distance limit (TDL) of the watershed 

to be subject to actual human food chain contamination if a hazardous substance for which the fishery has been closed 

has been documented in an observed release to the watershed from the site and at least a portion of the fishery is within 

the boundaries of the observed release [Ref. 1, p. 51620, Section 4.1.3.3]. Therefore, Actual Contamination is 

documented, and the target closed fishery is evaluated for Actual Human Food Chain Contamination. Level I targets 

were not established because doing so would not change the site score, so the target fishery is subject to Level II 

concentrations [Ref. 1, pp. 51592-51593, 51620-51621].

 1 The information used to prepare this presentation in Reference 51 came largely from the 2009 letter from GE consultant 

ARCADIS to NYSDEC, Subject: Loeffel Site Environs Operable Unit 3 2009 Biological Monitoring Data Summary (included as 

Reference 52, see pages 9708, 9712, 9719, 9721, 9730, 9732, 9736, 9739, 9749, 9756, 9762, 9780, 9786, 9797, 9813, 9817, 

9821, 9861, 9869, 9877, 9883, 9885, 9933, 9935, 9937, 9945, 9949, 9959, 9965, 9967).
30

DLL-SED01A 3.1 miles PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10

DLL-SED34A 3.4 miles PCBs 50,000 Figure 2; Table 2; Ref. 1, p. 

51620; 2, p. BI-10
31

SWOF/Food Chain-Targets/Food Chain Individual

4.1.3.3.1 Food Chain Individual

Sample ID: NC-SD34A

Hazardous Substance: PCBs

Bioaccumulation Potential: 50,000

References: Figure 2; Ref. 1, p. 51620; 2, p. BI-10

Type of Dilution

Identity of Fishery Surface Water Body Weight Reference(s)

Valatie Kill/Nassau Lake Small to moderate stream 0.1 1, p. 51613; 8, p. 19

There is an observed release of a hazardous substance (i.e., PCBs) with a Bioaccumulation Potential Factor Value of 500 

or greater and there is Level II Actual Contamination of the Valatie Kill and Nassau Lake closed fisheries [Figure 2, 

Tables 1 and 2; Ref. 1, pp. 51592-51593, 51620; 2, p. BI-10]. Therefore, a Food Chain Individual Factor Value of 45 is 

assigned [Ref. 1, p. 51620].

===================================================================================

Food Chain Individual Factor Value: 45
32

SWOF/Food Chain-Level I/Level II Concentrations/Potential Contamination

4.1.3.3.2 Population

4.1.3.3.2.1 Level I Concentrations

There are no fisheries subject to Level I concentrations and the Level I Concentrations Factor Value is 0 [Ref. 1, pp. 

51592-51593, 51620-51621].

=====================================================================================

Level I Concentrations Factor Value: 0

4.1.3.3.2.2 Level II Concentrations

Nassau Lake and the Valatie Kill between County Route 18 and Nassau Lake are fisheries that have been closed due to 

the site-related PCB contamination; New York State Department of Health (NYSDOH) has issued “Eat No Fish” 

advisories [8, pp. 21, 26; 23, pp. 13, 17, 21; 50, pp. 19, 20, 29]. Local residents occasionally ate fish from both water 

bodies prior to implementation of the advisories, but stopped consumption due to the PCB contamination [Ref. 24, pp. 1-

50]. These fisheries are both within the zone of contamination for the Dewey Loeffel Landfill site [Figure 2]. Level I 

targets were not established because doing so would not change the site score, so the target fishery is subject to Level II 

concentrations [Ref. 1, pp. 51592-51593, 51620-51621]. The fish consumption rate for the Valatie Kill and Nassau Lake

fishery is not well-documented, so the fishery is assigned to the category “Greater than 0 to 100 pounds per year” [Ref. 1, 

p. 51621; 24, pp. 1-50]. The category corresponds to the assigned Human Food Chain Population Value of 0.03 in Table 

4-18 of the HRS, which is assigned as the Level II Concentrations Factor Value [Ref. 1, p. 51621].

=====================================================================================

Level II Concentrations Factor Value: 0.03

4.1.3.3.2.3 Potential Human Food Chain Contamination

The water bodies along the remainder of the 15-mile TDL (Valatie Kill downstream of Nassau Lake; Kinderhook Lake) 

are suitable for some fish consumption according to NYSDOH [Ref. 23, pp. 11, 17; 50, 19-20]. Local residents mention 

Kinderhook Lake as a fishing location [Ref. 24, pp. 1-50]. The fish consumption rate for the downstream fishery is not 

well-documented, so the fishery is assigned to the category “Greater than 0 to 100 pounds per year” , which corresponds 

to the assigned Human Food Chain Population Value of 0.03 in Table 4-18 of the HRS [Ref. 1, p. 51621].

Type of Average

Annual Surface Annual

Identity of Production Water Flow Population Dilution

Fishery (pounds) Body (cfs) Value (Pi) Weight (Di) Pi x Di

Valatie Kill 0-100 Small to mod. stream 11 0.03 0.1 0.003

Sum of Pi x Di: 0.003

(Sum of Pi x Di)/10: 0.0003

[Ref. 1, pp. 51613, 51621; 8, p. 19]

====================================================================================

Potential Human Food Chain Contamination Factor Value: 0.0003
33

SWOF/Environment-Waste Characteristics

4.1.4.2 Environmental Threat - Waste Characteristics

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

Hazardous Substance

Ecotoxicity

Factor 

Value*

Persistence 

Factor 

Value**

Environment 

Bioaccumulation 

Factor Value*

Ecotoxicity/Persistence/ 

Bioaccumulation Factor 

Value (Table 4-21)

Ref. 2 

Page

PCBs [Aroclor-1232 and 

Aroclor-1260]

10,000 1 50,000 5 x 108 BI-10

* Fresh water values for ecotoxicity and bioaccumulation are used [Ref. 2, p. BI-10].

** PCBs are assigned the same persistence factor value (i.e., 1.0000) for both water body types (river and lake) within the 

target distance limit [Ref. 2, p. BI-10].

PCBs are the hazardous substances associated with the highest ecotoxicity/persistence/ bioaccumulation factor value of 5 

x 108

.

=====================================================================================

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 108

4.1.4.2.2 Hazardous Waste Quantity

Source Hazardous Is source hazardous

Waste Quantity constituent quantity

Source Number Value (HRS Section 2.4.2.1.5) data complete? (yes/no)

1 > 0 no

Sum of Values: > 0

The sum corresponds to a hazardous waste quantity factor value of 1 in Table 2-6 of the HRS [Ref. 1, p. 51591]. 

However, based on the fact that targets are subject to Level II concentrations [see Section 4.1.4.3.1.2], a hazardous waste 

quantity factor value of 100 is assigned if it is greater than the hazardous waste quantity value from Table 2-6 (i.e., 1) 

[Ref. 1, p. 51591-51592]. Therefore, a hazardous waste quantity factor value of 100 is assigned for the surface water 

pathway [Ref. 1, p. 51591-51592].

4.1.4.2.3 Calculation of Environmental Threat - Waste Characteristics Factor Category Value

A hazardous substance (i.e., PCBs) associated with the waste source, which has a surface water pathway containment 

factor greater than 0 for the watershed, corresponds to an Ecotoxicity/Persistence Factor Value of 10,000 and 

Bioaccumulation Potential Factor Value of 50,000, as shown previously [Ref. 1, pp. 51618, 51620, 51624; 2, p. BI-10].

(Ecotoxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 10,000 x 100 = 1 x 106

(Ecotoxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value)

x (Bioaccumulation Potential Factor Value) = (1 x 108

) x (50,000) = 5 x 1010

The product of 5 x 1010 corresponds to an assigned Waste Characteristics Factor Category Value of 320 in Table 2-7 of 

the HRS [Ref. 1, p. 51592].

=====================================================================================

Hazardous Waste Quantity Factor Value: 100

Waste Characteristics Factor Category Value: 320
34

SWOF/Environment-Targets

4.1.4.3 Environmental Threat - Targets

There are 2.83 miles of wetland frontage located within the zone of contamination [Figure 2; 45, pp. 4, 6]. Therefore, 

Actual Contamination is documented, and the target sensitive environment is evaluated for ActualContamination. There 

are no media-specific benchmarks for sediment, so the target sensitive environment is subject to Level II concentrations 

[Ref. 1, pp. 51592-51593, 51624-51625].

4.1.4.3.1 Sensitive Environments

4.1.4.3.1.1 Level I Concentrations

There are no media-specific benchmarks for sediment. Therefore, there are no sensitive environmentssubject to Level I 

concentrations and the Level I Concentrations Factor Value is 0 [Ref. 1, pp. 51592-51593, 51624-51625].

======================================================================================

Level I Concentrations Factor Value: 0

4.1.4.3.1.2 Level II Concentrations

Sensitive Environments

There are approximately 2.83 miles of wetland frontage located along the contaminated portion of Valatie Kill[Figure 2; 

45, pp. 4, 6]. 

Distance from PPE Sensitive

to Sensitive Environment

Sensitive Environment Environment Reference Value(s) 

N/A 0.00 mile 1, pp. 51624-51625 0 

Sum of Sensitive Environments Value: 0

Wetlands

Wetland Wetland Frontage Reference(s)

Valatie Kill 2.83 miles Figure 2; 45, pp. 4, 6

Total Wetland Frontage: 2.83

Wetland Value: 75

Sum of Sensitive Environments Value + Wetland Value: 75

====================================================================================

Level II Concentrations Factor Value: 75

4.1.4.3.1.3 Potential Contamination

Since a maximum score of 100.00 was achieved for the surface water migration pathway, the Potential Contamination 

Factor Value within Environmental Threat-Targets was not scored (NS) [Ref. 1, p. 51608, Table 4-1, Section 

4.1.4.3.1.3].

======================================================================================

Potential Contamination Factor Value: NS