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Au......"., Nz..... Volt'l. 122.33-1010 

OCT f 3 2009 

~1: . Walter Mugda.'1 


Director 


Emergency & RemediO!I Response Division 


United S[ate~ EnviroIL.i.¢r:.tal Protection Agdlcy 


Region 2 


290 Broadway-19th floor, E38 


New York, New York 10007-1866 

Dear Mr. Mugdan: 

Under authority ddegat~d by Ll,c: Governor of New York in 1995 to the Com. ...nissioner ofthc 

D~putmt::m of En....ironmental Conservation (DEC), I U"l requesting that thc Dewey Loeffel 

In2ctive Hazardous Was,e Disposal Site Joca[ed io the TO\l,n of~assau, Rensselaer County, 'f'.:(!\.\.' 

York be nominatl!d i.0 the ~ational Priorities List. 

The Pre-Remedial Section, Special Projccts Branch of the Emergency and Remedial Response 

Division ofthe EPA in Region 2 has initiated an investigation and hazard ranking system scoring 

effort at the Dewey Loeffel Site. The landfill was operated from about 1953 to 1970 by Dewey 

Loeffel, a private waste hauler. WasteS bauled to the site bcluded indusnial solvents, oils 

contair.bg PCBs, paints and other chemicals. The site received an estimated 46,300 tons of 

waste materials ori;ii&!ing from General Electric Company. Schenectady Chemicals, fnc. (now 

Schenectady Imem2tion21) and Bendix Corporation (now a pan of Allied Sign:!!, Inc.). The 

d i5posz.l and oil tr;:::::.::ifer fac ili:ies c.onsisted of lagoons, s!Orage ta!'j;s and a drum burial are2. 

Thl! site consists ofthrc:~ operable units (aUs): aUI was the implementation ofa soil cap and 

slurry wall, OU2 is the disposal site and associated contaminated groundw3tl.."T, and aU3 is the 

PCB impacted surface water, sediment .and biota in the Nassau Lake dra:nage basin. The 13l1d!ill 

was closed and capped in the early 1980s and a slurry wall was keyed into bedrock around the 

entire la."!dfill per:meter. DEC issued 3 Record of Decision (ROD). dated January 2001. 

addressing :;roundw31er coma!nination and enhanced source controls for OL:2 and l5Sued a ROD, 

daled lancary 2002, addressing surface water PCB contamirotion tll2.t bas impacted water, 

sec.!i! r.ent and biota in the Nassau Lake dra inage basin for OU3 . Are<>--s of eJevated PCB 

contamination tn the drair..a,;e basis has been mitigated and the Nass!!u L<!.ke darn b.Ui been 

rep laced because ofsrructural concems. 

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2. 

Thl! OU2 ROD requires an enh3nced leachate collection system and an on-site !rear:ment plact. 

During the dcsign ofth~ enhanced leachate collection system and an oc-site treaunem plant, the 

site-specific ge¢logicai conditions and required effluent limitations that need to be met have 

presented some difficult and unforeseen [Cchnical challenges. nus has increased the estimated 

com.-rrllction and operational costs dramatically. Consequently, review and consideration of 

l:ldditional alternatives is warranted prior to proceeding. Further, a r~iew of the remedy for OU3 

r.eeds to be completcd at the end of a five year T¢view period. While it is premature to assess if 

a.."\y remedial measures will be needt!>d based upon the five year review, the Nassau Lake 

drainage basin is a t) important resource which further justifies nomination to The !,-rpL. 

rfyou or yOU! staff would !ike to discuss this sire further, please cont2ct Dah~ Desnoyers at (518) 

02 9706 . . 

c: D. Desnoyers 

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