HRS DOCUMENTATION RECORD

-- REVIEW COVER SHEET

Name of Site: Dewey Loeffe l Landfill

Date Prepared: March 2010

Date Revised : March 2011

Contact Persons :

Site Investigation: James Desir U.S. Environmental Protection Agency New York, N Y

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) , t he Ground Water Migration , Soil Exposure,

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

. The site score based solely on the Surface W ater Migration P athway is sufficient to list the site.

Some hazardous substances, in parti cular 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 gro und water contamination

associated with the disposal facility as Operable U nit 2 ( OU2 ) [Ref. 6, pp. 7, 10]

. General Electric Company ( GE ) has conducted remedial investigations and remedial actions associated with OU2 since 199 2 , and has reported that Aroc lor

1260 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 RECOR D

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

Date Revised: March 2011

EPA ID No.: N Y D000512335

EPA Region: 2

Street Address of Site*: Mead R oa d

, Nassau , NY 1 2123

County and State: Rensselaer Count y , N ew York

General Location in the State: Capit a l District ( east ern portion of state)

Topographic Map: Nassau , NY

Latitude*: 4 2° 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, p p . 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

consi ders 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 p recisely 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 determinat ion 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 .0 0 Soil Exposure Pathway Not Scored Air Pathway Not Scored

HRS SITE SCORE 50.002 WORKSHEET FOR COMPUTING HRS SITE SCORE

DEWEY LOEFFEL LANDFILL

S S 2

1. Ground Water Migration Pathway Score (S gw ) 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 Sco red (from Table 4

- 25, line 28)

2c. Surface Water Migration Pathway Score (S

sw ) 100.00 10,000.00 Enter the larger of lines 2a and 2b as the pathway score.

3. Soil Exposure Pathway Score (S

s ) Not Scored (from Table 5

- 1, line 22)

4. Air Migration Pathway Score (S

a ) Not Scored (from Table 6

- 1, line 12)

5. Total of S gw 2 + S

sw 2 + S

s 2 + S

a 2 10,000.00

6. HRS Site Score Divide the value on line 5 by 4 and take the square root 50.003 SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCOR ESHEET

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 (F lood) 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

n ot 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 score d

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 wa ste characteristics category.

** Maximum value not applicable4 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 Quantit y

17. Waste Characteristics *

*

1,000 5.00E+0 8

1 0 0

32 0

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 .0 3 03

21. HUMAN FOOD CHAIN THREAT SCORE ([lines 14 x 17 x 20]/82,500) 100 96.06

* Maximum value appl ies to waste characteristics category.

** Maximum value not applicable5 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. Hazard ous Waste Quantity

25. Waste Characteristics *

*

1,000 5.00E+08

1 0 0

32 0

Targets

26. Sensitive Environments

26a. Level I Concentrations

26b. Level II Concentrations

26c. Potential Contamination

26d. Sensi tive 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. S URFACE W ATER OVERLAND/FLOOD

MIGRATION COMPONENT SCORE (S of ) 100 100.00

SURFACE WATER MIGRATION PATHWAY SCORE (S

sw ) 100 100.00

* Maximum value applies to waste characteristics category.

** Maximum value not applicabl e6 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. [13 8 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 f rom http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0201218 on September 16, 2009. [ 2 page s ]

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 f ile, Subject: Geographic Coordinates

– Dewey Loeffel Landfill site ; wit h Google Earth map att ached

. 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,

Rensse laer County, N ew 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)

. Loeff el 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 . [1 51 pages]

12. NY SDEC

. 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 A ugu st 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, 20 09 . [ 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, Contrac t 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. 11 9, 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 Nu mber: JA25103, Sampling Date: 0 8 /0 6 /09

. August 25 , 2009. [ 95 pages]

21. Accutest Laboratori es. 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 Repor t for: Weston Solutions, Inc., Dewey Loeffel Landfill, Mead Road, Nassau, NY, Project # 20113.111.00.0119.00, Accutest Job Number: JA2 5223 , Sampling Dates : 0 8 /0 7 /09

– 0 8 /0 8 /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 page s]

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/ wa ste /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 Ma pTM Report with GeoCheck®, Dewey Loeffel Landfill, Mead Road, Nassau, NY 12123 , Inquiry Number: 2593233 .1 s . September 16 , 200 9 . [ 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 pag es]

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 Prod ucts 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 Haza rdous 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 . Ju ne 24 , 1992. [32 4 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. Lab oratory 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,

Environment al 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, Remedia l 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 Departmen t of Health (NYSDOH). Chemicals in Sportfish and Game, 2010

- 2011 Health

Advisories . May 21, 2008. [30 pages]

51. Kane, Mich ae l W, Biologist, NYSDEC

, Division of Fish, Wildlife & Marine Resources

- Bureau of

Habitat

. Presentation Slides: Valatie Kill and N assau Lake PCBs 2009 Data and Trends in Fish . M arch 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 Operab le 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 La ndfill (DLL) site (CERCLIS ID No. NY D 000 512335 ) is composed of a n 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 re ferred 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, sludge s
, and solids [Ref. 6, p p . 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

, result ing in contamination of ground water, surface water, sediments, and several species of fish [Ref. 6, p p . 5

- 7, 12

- 17 ; 8, pp. 18

- 21 ; 9, pp. 6, 15

- 17 ]. The geographic coordinates of the DLL facility are 4 2 ° 33 **′** 39

. 4 4 ” north latitude ( 42.5609 57 °) and 73 ° 33 **′** 37

. 7 8 **′′** west longitude (

- 73.560 496 °) [Ref. 4, p. 1; 5 , p p . 1

- 2 ]. Figure 1 presents the s ite l ocation, 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 ( “ L oeffel” ) operated the DLL proper ty 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)

report ed that a pproximately 37,530 tons of waste materials from GE manufacturing facilities were deposit ed 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 Corporat ion 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 in to a lagoon area, oil pit, and drum burial area [Ref. 7, p. 8; 8, p p . 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 order ed Loeffel to stop discharges from the disposal facility and perform remedial activities [Ref. 6, p. 8; 7, p. 7]. By 1974, Loeffel had cover ed and grad ed the disposal area s with soil and construct ed 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 investigat ion and remediat ion at the facility [Ref. 6, p. 9 ; 7, pp. 9

- 10 ; 29, pp. 1, 13

- 27 ]. From 198 2 to 1984

,

a pproximately 500 surface drums and the 30,000

- gallon ASTs were removed from the property , and a NYSDEC

- approved slurry wall, clay cap, and lea chate collection system were installed [Ref. 6, p p

. 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. 515 91 ]. The facility is not classified

as a treat ment, 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 act ivities 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 i n January 2002, NYSDEC issue d a ROD for OU3 . No ROD

for OU1 was issued [Ref. 6, p. 1; 9, p. 1]

. GE has conducted remedial investigations and rem edial 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 ]

. T he January 2001 NYSDEC ROD concerning

O U 2 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, f rom 2001 to 2004, GE remo ved 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, T ributary 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 Na ssau 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

c arbon (TOC)

, and grain s ize [Ref. 1 6 through 22 ] . The analytical results indicated the continuing presence of PC Bs in sediment1 1 samples from the former M ead Road Pond, Tributary T11A, Valatie Kill, and Nassau Lake [Ref. 1 6 , pp. 30

- 32 ; 1 7 , 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 th at 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 , p p. 21, 26; 23 , pp. 13, 17, 21 ; 45 , p p. 4, 6 ; 50, pp. 19, 20, 29 ].FIGURE #: DATE: CLIENT NAME: PROJECT: LEGEND: TITLE: ! ( Facility Entrance

2,000 0 2,000 1,000

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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NORTHWEST
DRAINAGE AREA

PPE2
SOUTHEAST DRAINAGE AREA

NASSAU LAKE Closed Fishery ('Eat No Fish' advisory) SMITH POND V A L L E Y S T R E A M 

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# DLL-SED47A See Inset

MEAD ROAD POND Valatie Kill Closed Fishery ('Eat No Fish' advisory)

LYONS LAKE V A

L A T

I E

K

I L L 

# 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

FIGURE #: DRAWING NUMBER: 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 08829 2 January 2011 

# . ! ( ! ( ! (

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. 

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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 

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# See Map1 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

S ource 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 A ctions:

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 report ed that a pproximately 37,530 tons of waste

materials from GE manuf acturing 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 Chemic als, 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 includ ed chlorinated solvents, solvents, waste oils,

PCB s
, 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

trichloroet hylene (TCE), methyl chloride, toluene, xylene, silicone s
, phenols, lead , and other chemicals were known to be present [Ref. 32, p. 2].

Before remedial action was initiated, t he 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 , o r left at the facility in sealed drums [Ref. 8, p. 16 ; 33, p. 4 ]. Some waste s were reportedly burned during facility operations [Ref. 6, p. 8; 8, p. 16]. D rums were d iscarded on the lagoon perimeter or in a drum burial area , and were later covered with s oil 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 sto p discharges from the disposal facility and perform remedial activities [Ref. 6, p. 8; 7, p. 7]. R emedial activities began i n 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 cover ed and grad ed the d isposal facility with soil

and construct ed 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 ad ditional investigation and remediation at

the facility [Ref. 6, p. 9 ; 7, pp. 9

- 10; 29, pp. 1, 13

- 27 ]. From 198 0 to 1984

, a chain

- link fence around the facility was installed

, a pproximately 500 surface drums and four 30,000

- gallon ASTs were removed from th e 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 act ivities 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 contaminati on 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 PCB

contaminated soil and sediments from the drainage

- way between the facility and Nassau Lake , including the area immediately adjacent to the disposal faci lity, Mead Road Pond, T ributary 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, 2007 aerial photograph showing the boundary of the landfill (i.e., Source 1) is show n in Figure

2

.

Containment

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

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

surface waters [ s ee Section 4.1.2.1]. However, NYSDEC has indicated 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 leach ate collection system at the d isposal 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 w ells 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 m aintained 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

- Hazard ous Substances

Source No.: 1

2.4.1 Hazardous Substances

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

other scrap materials (resins, paints, solids and liquid chemicals)

, heavy met al 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 report ed

that a pproximately 37,530 tons of waste materials from GE manufacturing facilities were de posited 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

- 1 260) 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 accord ance with EPA’s “Test Methods for Evaluating Solid Waste , Physical/Chemical Methods ( SW

- 846 )”, Third Edition, Revision 1 dated December 1987 [Ref. 10, p p . 74 , 90

- 97 ; 36, p p

. 27 , 3 6

, 58 ]. The analytical results for

s ample PO4

- 1021 indicated the presence of VOC s , SVOC s
, and the PCB Aroclor

- 1260 [Ref. 10, pp. 2 3

- 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 μ g/ L

Chlorobenzene Leachate sample PO4

- 1021

, GE , Oct

- 1996: 10, p. 9 1

89 μ g/ L

1,2

- Dichlorobenzene Leachate sample PO4

- 1021

, GE , Oct

- 1996: 10, p p . 91 , 95 4.7 μ g/ L

1,3

- Dichl orobenzene Leachate sample PO4

- 1021

, GE , Oct

- 1996: 10, p p . 91 , 95 19 μ g/ L

1,4

- Dichlorobenzene Leachate sample PO4

- 1021

, GE , Oct

- 1996: 10, pp. 91, 95

8 0 μ g/ L

2,4

- Dimethylphenol Leachate sample PO4

- 1021

, GE , Oct

- 1996: 10, p. 95 14 μ g/ L1 7 SD

- Hazar dous 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 report ed that a pproximately 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 c ondition of the source changed significantly due to response actions [see Section 2.2.1]. The refore, the information available is not sufficient to evaluate Tier B source hazardous waste quantity

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

H azardous 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 (yd 3 ): NS Volume (V) Assigned Va lue: NS

2.4.2.1.4 Area

GE reported that t he 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 remove d 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 V alue

The source hazardous waste quantity value for Source 1 is > 0 for Tier D

- Area [Ref. 1, p. 51591].

Source Hazardous Waste Quantity Value: > 01 8 SD

- Summary

SITE SUMMARY OF SOURCE DESCRIPTIONS

Containment

Source

Source Hazardous Waste Grou nd Surface Air

Number Quantity Value Water Water Gas Particulate

1 > 0 NS 7 * NS NS

NS = Not Scored

* The o verland flow containment factor is 7 for the source [see Section 2.2.1]

.

Other Possible Sources (the se former sou rces were subject to response actions, including removal and encapsulation; all that remains of them is with in the encapsulat ed disposal area [Source No. 1] ):

Before remedial action was initiated, the Loeffel disposal facility consisted of a 6

- acre lagoo n , 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 organ ic 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 dr ums [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. 1 6]. 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

compoun ds, 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 app roximately 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]. S urface drain age 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, p p . 7 , 48 ; Ref. 25, p. 1] . The majority of sur face water drains

northwest into an unnamed stream (the “northwest drainage ditch” ; PPE1 ), t hrough 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

sou thwest 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 a n u nnamed 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 ch ange 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 Comple tion 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 , p p. 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 obs erved 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

- SD 34 A) , approxima tely 3 .4 miles downstream [see Figure 2].

Targets subject to actual contamination include the Valatie Kill and Nassau Lake fisher ies [see Section 4.1.3.3] and approximately 2.83 miles of wetland frontage [ see Section 4.1.4.3]

.

As mentioned above, PPE2 i s 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 J une 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 [Re f. 6, pp. 5

- 7, 13]

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

issue d its ROD for OU3 i n January 2002 [Ref. 6, p. 1; 8, pp. 7, 17

- 21; 11, pp. 1

- 2]. From 2001 to 2004, GE removed approximately 1 5,000 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, T ributary 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

A n observed release by direct observation is not being scored.

Chemic al 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

- S E D 12 in the former Mead Road Pond and sample

location DLL

- S E D 34A i n 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 s ize [Ref. 16 through 22] . The validated analytical results indicated the continuing pre sence of PCBs at concentrations significantly above background in sediment samples from the former Mead Road Pond, Tributary T11A, Valatie Kill, and Nassau Lake [ See Tables 1 and 2 ; Ref. 1 6 , pp. 17, 28, 30

- 32 , 38 ; 1 7 , 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 contaminat ion [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 sample s from the only usable upgradient background locations

, which came from stream samples [Tables 1 and 2] (i.e., there were no lakes or springs imm ediately 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 se diment 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 Progra m (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 Acc u test La borator ies 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 200721 [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 pe rcent 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 wa s collected from Nassau Lake in August 2009

. EPA collect ed b ackground 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 L yons Lake samples were found to be unusable because percent moisture content exceeded 90%.

The percent moisture values rang ed from 91% to 93%, whereas the percent moisture value for sample DLL

SED34A 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 collecte d 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 b ackground samples ranged from approximately 17 % to 62 %

, while percent moisture in the release samples ranged from approximat ely 15 % to 78 % [Ref. 1 6, 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 b ackground samples ranged from less than 1,300 milligrams per kilogram (mg/kg) to 33,000 mg/kg, while TOC levels in the release samples ranged from less than 1,200 mg/kg to 53,300 mg/kg [Ref. 1 8 , 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 p ortion 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 frame s , sampling and analytical methods, and sampling depths ; overlapping ranges [except for Nassau Lake sample DLL

- SED34A] of percent moisture , TOC, and gra in

- 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, comp aring 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 % d ifference that exceed ed 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, 16 9, 170 for the related original CCV laboratory data sheets, and Ref. 43, pp. 86, 94, 169, 170 for th ose data sheets corrected by the laboratory] . The Aroclor results for samples DLL

- SED08 and DLL

SED18 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 th e 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 tha n or equal to 90%,

which indicates a n 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, wo uld 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 s paces indicate that the results do not meet observed release criteria

. Explanation of the Comments R ow: “Background Sample” indicates a sample collected upstream from influence by the source . “ Dup. ” means duplicate of the sample specified.23 Table 1 Backg round 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

EP A 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 str eam

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, p p. 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 kilogra m SQL

- Sample quantitation limit

U

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

Notes:

* M aximum 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

Dew ey 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. o f DLL

SED06A

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. 1 7 Ref. 22, p. 17 Ref. 20, p. 1 5 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 su bstance 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 identi fied; 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 Conc entrations (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. 1 2 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. 1 7 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 t he 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 2Background and Observed Release ConcentrationsPhase II Sediment Sampling - August 2009Dewey Loeffel Landfill, Nassau, NYBackground ConcentrationsObserved Release Concentrations (concluded)Field Sample No.DLL-SED08ADLL-SED18ADLL-SED27ADLL-SED34ADLL-SED47AEPA Sample No.B5Q38B5Q48B5Q57B5Q64B5Q77Date8/7/20098/6/20098/8/20098/6/20098/7/2009Depth (inches)0-60-60-60-60-6CommentBackground Sample -streamBackground Sample -streamBackground Sample -streamlakespringReferencesRef. 13, pp. 21, 41; 15,pp. 5, 11, 21, 23Ref. 13, pp. 21, 33; 15,pp. 6, 11, 15, 17Ref. 13, pp. 21, 47; 15,pp. 7, 11, 25, 27Ref. 13, pp. 21, 27; 15, pp. 7, 11,16-17Ref. 13, pp. 21, 42; 15,pp. 8, 11, 22-23PCBs (μg/kg)ResultSQLResultSQLResultSQLResultBiasCRQLSQLResultSQLAroclor-123247 U4743 U4340 U40Aroclor-126047 U4743 U4340 U401,700JLow331501,00050% Moisture3024177835ReferenceRef. 17, pp. 23, 41-44; 37,p. 17Ref. 17, pp. 50, 69-72; 37,p. 22Ref. 17, pp. 7-11; 37, p.13Ref. 17, pp. 32, 41-44; 37, p.20Ref. 17, pp. 74, 81-84; 37,pp. 27-28Total Organic Carbon (mg/kg)11,6003,3502,00053,30017,300% Gravel0.169.214.4021.1% Sand8778.379.89.656.7% Silt, Clay, Colloids12.912.55.790.422.1ReferenceRef. 21, p. 14Ref. 20, p. 17Ref. 22,p. 17Ref. 20, p. 8Ref. 21, p. 9μg/kg - micrograms perkilogrammg/kg - milligrams per kilogramSQL - Sample quantitation limitCRQL - Contract required quantitation limitU - The substance was analyzed for, but no quantifiableconcentration 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; theassociated numerical valueis 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.2627 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, PCB s , scrap materials, sludge s , and solids [Ref. 6, pp. 5, 8; 7, p. 7 ; 29, pp. 1, 28

- 30 ]. GE report ed that a pproximately 37,530 tons of waste materials from GE

ma nufacturing 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 Che micals, 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 (Arocl or

- 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 [R ef. 10, pp. 2 3

- 24, 74, 90

- 97].

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 fa cility

, Mead Road Pond, T ributary 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 ]

.

PC Bs 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 brea k down and therefore remain in the environment for long periods of time [Ref. 27, p. 2]. There

are no other known PCB s ite s within 1 mile of the facility , including along the drainage pathways [Ref. 2 8 , pp. 2

- 45].

Hazardous Substances Released:

PCBs ( Aroclor

- 12 32 and Aroclor

- 12 60 )

[Tables 1 and 2 ]

=================================================================================== Observed Release Factor Value: 55028 SWOF/Food Chain

- Waste Characteristics

4.1.3.2 Human Food Chain Threat

- Waste Ch aracteristics

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

- 1 23 2 and

Aroclor

- 12 60 ] 10,000 1 50,000 5 x 10 8 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 l ake) within the target distance limit [Ref. 2, p. BI

- 10].

PCBs are associated with the highest toxicity/persistence/bioaccumulation factor value of 5 x 10 8

.

4.1.3.2.2 Hazardous Waste Quantity

Source Hazardous Is source hazardous Waste Quantity consti tuent 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 fa ct that targets are subject to Level I I 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]. Theref ore, a hazardous waste quantity factor value of 100 is assigned for the s urface water pathway [ Ref. 1, p. 51591

- 51592 ]

.

4.1.3.2.3 Calculation of Human Food Chain Threat

- W aste Characteristics Factor Category Value

One hazardous substance [PCBs] associ ated 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 1 0 ,000 and Bioaccumulation

Potential Factor Value of 50,000, as shown previously [ Ref. 1, pp. 5161 8 , 516 20 ; 2, p. BI

- 10 ]

.

(Toxicity /Persistence Factor Value ) x ( Hazardous Waste Quantity Factor Value ) = 1 0 ,000 x 1 0 0 = 1 x 10 6

(Toxicity /Persistence Factor Value x Hazardous Waste Quantity Factor Value ) x ( Bioaccumulation Potential Factor Va lue ) = (1 x 10 6 ) x (50,000) = 5 x 10 1 0

The product of 5 x 10 1 0 corresponds to a n 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 10 8
Hazardous Waste Quantity Factor Value: 1 0 0 Waste Characteristics Factor Category Value: 32029 SWOF/Food Chain

- Targets

4.1.3.3 Human Food Chain Threat

- Targets

Nassau Lake an d 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 alt hough 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

D istance 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

- S ED11A 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 fee t 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 wh ich 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 Contami nation is

documented

, and the target closed fisher y 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 T he information used to prepare this presentation in Reference 51 came largely from the 2009 l etter from GE consultant ARCADIS to NYSDEC, Subject: Loe ffel Site Environs Operable Unit 3 2009 Biological Monit oring 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 Fig ure 2; Table 2; Ref. 1, p. 51620; 2, p. BI

- 1031 SWOF/Food Chain

- Targets /F ood Chain Individual

4.1.3.3.1 Food Chain Individual

Sample ID: NC

- SD 34 A

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 Bioaccumulat ion Potential Factor Value of 500 or greater and there is Level II Actual Contamination of the Valatie Kill and Nassau Lake closed fisher ies [ Figure 2

, Table s 1 and 2 ; Ref. 1, p p

. 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: 4532 SWOF/Food Chain

- Level I/Level II Concentrations/Potential Contamination

4.1.3.3.2 P opulation

4.1.3.3.2.1 Level I Concentrations

T here are no fisheries subject to Level I concentrations and t he 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 ]. T he 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. 0 3 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 do wnstream 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]. T he fish consumption rate for the do wnstream fisher y is not
well

- documented , so the fisher y 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. 0 3 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 (P i ) Weight (D i ) P i x D i

Valatie Kill 0

- 100 Small to mod

. stream 11 0.03 0.1 0. 0 0 3

Sum of P i x D i : 0. 0 03 (Sum of P i x D i )/10: 0.0 0 03

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

============================================== =============== = ============== === == === Potential Human Food Chain Contamination Factor Value: 0.0 0 0333 SWOF/Environment

- Waste Chara cteristics

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/Persi stence/

Bioaccumulation Factor Value (Table 4

- 21) Ref. 2 Page PCBs [Aroclor

- 12 3 2 and

Aroclor

- 12 60 ] 10,000 1 50,000 5 x 10 8 BI

- 10

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

- 10].

* * PCBs are assigned the same persiste nce 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 eco toxicity/persistence/ bioaccumulation factor value of 5

x 10 8

.

===================================================================================== Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 5 x 10 8

4.1.4.2.2 Hazardous Waste Quantity

Source Hazardous Is source hazardous Waste Quantity consti tuent 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 th at targets are subject to Level I I 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 s urface water pathway [ Ref. 1, p. 51591

- 51592]

.

4.1.4.2.3 Calculation of Environmental Threat

- W aste Characteristics Factor Category Value

A haza rdous 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 Ecot oxicity/Persistence Factor Value of 1 0 ,000 and

Bioaccumulation Potential Factor Value of 50,000, as shown previously [ Ref. 1 , pp. 5161 8 , 516 20 , 51624 ; 2, p. BI

- 10]

.

( Ecot oxicity/Persistence Factor Value) x (Hazardous Waste Quantity Factor Value) = 1 0 ,000 x 1 0 0 = 1 x 10 6

( Ecot oxicity/Persistence Factor Value x Hazardous Waste Quantity Factor Value) x (Bioaccumulation Potenti al Factor Value) = (1 x 10 8 ) x (50,000) = 5 x 10 1 0

The product of 5 x 10 1 0 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: 1 0 0

Waste Character istics Factor Category Value: 32034 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 Actual Contamination. There

are no media

- specific benchmarks for sediment, so the target sensitive environmen t is subject to Level II concentrations [Ref. 1, pp. 51592

- 51593 , 5162 4

- 5162 5 ].

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 environments su bject to Level I

concentrations and t he Level I Concentrations Factor Value is 0 [ Ref. 1, pp. 51592

- 51593, 5162 4

- 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

Sensitiv e Environment Environment Reference Value(s)

N/A 0.00 mile 1, p p . 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