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RECORD OF DECISION
Site: GE Moreau Site, Moreau, Saratoga County,-New York
Documents Reviewed:
I'am basing ray decision on the following documents describingthe analysis of cost-effectiveness of remedial alternatives forthe GE Moreau Site:
a
- Remedial Investigation, GE/floreau S3.te> Oct'ob.e-r 191*4;- Addendum, Remedial Investiaation. GE/'MoreaCi Sits, March
1985;- Feasibility Study of Remedial Alternatives, Moreau Site,
August 1985;- Regional Water Supply Evaluation for the General ElectricCo., April 30, 1984
- The attached Site History, Alternatives Evaluation, andSelection;
- Public Comments and Responsiveness Summary; and- Staff summaries and recommendations. ...- Quantity and Quality of Water From Public-Supply-'Wells
and Springs in the Village of South Glens Falls; HewYork, 1987 (USGS Administrative Report)
Description of Selected Remedies;
This Record of Decision (ROD) for the GE Moreau site callsfor the following actions:
0 Utilize the soil-bentonite cutoff wall constructed in 1984around the former disposal area to contain the source.ofof f site groundwater contamination. The wall was, confifructedin compliance with an Order on Consent between the .GieiieralElectric Company (GE) and the Hew York State Department ofEnvironmental Conservation dated September 23, 1980. It is1600 feet in circumference, 30 inches thick, 10,0 feet deep andkeyed a minimum of 6 feet into the underlying natural clayconfining layer.
0 Continue to monitor 18 downgradient wells to assure t'hat ;the ;•'slurry wall is containing the-source of. groundwater contamina--tion and monitor 29 wells to determine if changes are occurringin the size and direction of "the plume.
0 Continue treatment of the plume where it exits at Reardon,..Brook. This water is currently treated by the air 's'trip'piVigsystem for the Village of Fort Edward public water .supply.The degree of lateral dispersion of the plume is .dictatedby existing hydrogeologic features. Therefore, .it is jicjtanticipated that further significant lateral..dispersibrt7 ofthe plume will occur. Consequently, active pumping of theplume prior to its discharge at Reardon Brook, does not;appear to be necessary to control further widshing 6f; theplume. Although active pumping may accelerate aquifer,restoration it may also adversely affect grpundwater ;£lowfeeding the resevoirs which comprise the Village of FortEdward resevoirs. In addition, evaluations indicate thatactive pumping is not cost-effective at this tirae.
0 Uti l ize the air stripping system installed in fall 1985 toremove volatile organics fron Reardon Brook feeding NewReservoir which is one of 4 reservoirs making up the publicwater supply system of the Village of Fort Edward. Thiswork was performed as a remedial measure under the Comprehen-sive Environmental Response, Compensation, and Liability Actwith the agreement of EPA,- NYSDEC, and the Village of FortEdward. This air stripping system is sized for -flows" up to400 gallons per minute and volatile organic contaminantconcentrations up to 100 parts per billion. It has beenoperating since late fal l 1985 and effect ively removescontaminants to non-detectable (less than 1 part per bi l l ion) .This also provides for the treatment of both the downgradientplume and the aquifer as well as the surface water streamswhich form Reardon Brook.
0 Remove 8 ,600 cubic yards of PCB-contaminated soil adjacentto the disposal area and place these soils within the dis-posal site, which is contained by the slurry wall describedabove. This work was completed in late summer 1985 incompliance wi th an Administrat ive Order between GE and EPAdated July 12, 1985 which found that the removal of these
• materials would prevent and/or mitigate immediate andsignificant risk of harm to human health. Construct animpermeable cap over the disposal area in conformance withthe NYSDEC/GE Administrat ive Order. This has also beencompleted.
0 Provide a public water supply for residences affected by theplume of contaminated groundwater identified in the RemedialInvestigation and modified by EPA's comments, by extendingpublic water supply mains from the Village of South GlensFalls. The institutional requirements of this alternativeinclude the formation of a water district which is ordinarilycreated by local government; alternatively GE may be thepurveyor of water to the affected area, if necessary.Approximately 100 homes will be provided with public water.They are along Bluebird Road, Cheryl Drive, Terry Drive, andMyron Road. These mains will be sized to be consistent withthe Town of Moreau Water Service Comprehensive Plan. EPA isalso recommending that the Town of Moreau establish institu-tional controls for restricting the withdrawal of ground-water within the groundwater plume.
0 Review the remedial action no less than each 5 years af terthe initiation of such action to assure that human healthand the environment are being protected by the remedialaction. Require additional action as EPA deems appropriatebased upon this review.
Declarations;
Consistent with the Comprehensive Environmental Respons.fi,Compensation, and Liability Act of 1980 as amended by theSuperfund Amendments and Reauthorization Act (C^RCLA), 42U.S.C. §9601, et seq., and the National Oil and-HazardousSubstances Contingency Plan (NCP), 40 CFR Part 300, I havedetermined that the following remedies implemented at the GEMoreau Site, constitute cost-effective remedies and wouldprovide adequate protection of public health, welfare, andthe environment.
0 the already-installed soil bentonite cutoff wall inconjunction with continued groundwater monitoring;
0 the currently-operating air stripper system on ReardonBrook;
0 the previously-removed PCB contaminated soils; and
0 the extension of the South Glens Falls water supply tothe residences deemed by EPA to be affected or potentiallyaffected by the plume of contaminated groundwater.
The State of New York has been consulted and agrees with theapproved remedies. GE has performed the Remedial Investigation/Feasibility Study activities in conformance with an AdministrativeOrder between EPA and GE dated November 21, 1983. The resultsof these studies have provided a basis for the selection of theremedies contained in this Record of Decision. Pursuant to theabove-referenced Administrative Order, GE has agreed to providefor those operation, maintenance, and monitoring activitiesnecessary to assure the future effectiveness of the selectedremedies.
Date/ ' ChristopherRegional Administrator
SITE HISTORYALTERNATIVES EVALUATION
ANDSELECTION
SITE; GE Moreau Site
SITE LOCATION AND DESCRIPTION
The GE Moreau Site is located on Fort Edward Road in the Townof Moreau in Saratoga County, New York, approximately 20 milesnorth of Albany and 18 miles south of the Hudson River. SeeFigure 1.1, attached. The site is located in a semi-ruralsetting with single-family houses nearby. These houses rely onindividual drinking water wells as their water supply. Thesewells tap the Moreau sand aquifer which is some 60 feet thickat the site. Groundwater in the area flows in a southerlydirection and the aquifer decreases in thickness in the southerlydirection. Eventually, the aquifer discharges into surfacestreams which feed the Village of Fort Edward public watersupply reservoirs.
SITE HISTORY
The GE Moreau site was used as an industrial waste disposalsite from 1958 to 1968. An evaporative pit at the site receivedapproximately 452 tons of waste material generated by theGeneral Electric Company. The waste materials included trichloro-ethylene (TCE), polychlorinated biphenyls (PCBs), spent solvents,oils, sludge, and other miscellaneous waste. In 1978, the Townof Moreau and the New York State Department of Health testedgroundwater, surface water, soil, and air at and around thesite. In September 1980, the site was included in an Order onConsent with the NYSDEC whereby GE would conduct investigationsat seven waste disposal sites in the area and contain the wastematerials at these sites. In late 1982, it was determined thatthere were elevated levels of TCE in the groundwater at thissite. The site was proposed for inclusion on the NationalPriorities List (NPL) in December 1982. The Town of Moreauinstalled activated carbon filter systems on the drinking watersystems of 70 homes believed to be downgradient of the site andtherefore affected or potentially affected by contaminantsemanating from the site. In the Summer of 1983, after meetingswith the Town of Moreau and New York State representatives, EPAinitiated negotiations with GE to address the off-site contamin-ation problems. These negotiations resulted in an AdministrativeOrder between EPA and GE whereby GE would (1) install andmaintain activated carbon filter systems on homes whose wellsexceeded contaminant levels established by EPA and specified inthe Order; (2) sample and analyze drinking water well water inhomes downgradient of the site on a monthly basis until fullremediation is completed; (3) conduct a Remedial Investigationand Feasibility Study; (4) design and construct the EPA-selectedremedy; and (5) conduct post-remediation monitoring and operationand maintenance.
Immediate Corrective Action
As a result of GE's testing program/ GE has installed activatedcarbon filter systems on six homes whose drinking water_hasexceeded the volatile organic contamination established in theAdministrative Order. GE is also monitoring the influent andeffluent of these carbon filter systems to assure that theunits continue to reduce contaminants from the well water toacceptable levels until the final remedy is implemented.
Remedial Investigation
The Remedial Investigation focused on groundwater contamination.It consisted of a complete characterization of the aquiferincluding groundwater flow and contaminant transport phenomena.This entailed the installation of groundwater monitoring wellclusters at 25 locations along with the installation of singlemonitoring wells at 5 other locations to fully identify anddefine the groundwater flow pathways as well as the horizontaland vertical extent of contamination emanating from the GE.Moreau site. In all, 72 monitoring wells were installed from flaythrough November, 1984. See Plate 1, March 1985 Remedial Investi-gation, Study Area, Well Locations & Location of Geologic CrossSection for the well locations; not attached because of largesize. This plate is part of the Remedial Investigation reportand is available for viewing at the EPA Region 2 offices.
Water level measurements were obtained monthly for severalmonths from the monitoring wells and groundwater samples wereanalyzed for volatile and semivolatile organics as well asPCBs for several months. This included over 200 groundwatersamples obtained between June 1984 and February 1985. Inaddition, water samples were obtained from 160 private resi-dential drinking water wells and analyzed for these contamin-ants on a monthly basis. These data were used to supplementthe monitoring well sampling and to provide a basis for theprovision of activated carbon filter systems under the auspicesof the Administrative Order.
A plume of volatile organic contaminants has been identifiedemanating from the GE Moreau site. The plume consists oftrichloroethylene, trans-1,2-dichloroethylene, vinyl chloride,1,1,1-trichloroethane, 1,1-dichloroethylene, tetrachloroethy-lene, methylene chloride, chloroform, chlorobenzene, anddichlorobromomethane. The plume is approximately 4800 feetlong and about 2000 feet at its widest point. The plumeoriginates at the GE Moreau site and follows the regionalgroundwater flow? extending southeastward to the point wherethe Moreau aquifer decreases in thickness, resulting insurface water streams feeding the New Reservoir. Trichloro-ethylene is the most prevalent organic contaminant detectedin the Remedial Investigation and its highest level can befound within the center of the plume. The highest levels arefrom 70 to 81 milligrams per liter or parts per million (ppm)
for trichloroethylene and 46 to 52 ppm for trans-1,2-dichloro-ethylene in monitoring well TM 4. These levels decrease to16 ppm for trichloroethylene and 11 ppm for trans-1,2-dichloro-ethylene in monitoring well DGC 3 after travelling a distanceof 3200 feet downgradient due to dilution and dispersion. SeeTable 6,1, Summary of Analytical Results, Groundwafcer Monitoring,-March 1985 Remedial Investigation, attached. The level ofcontamination is lower on the outskirts of the plume and some10's of micrograms per liter or parts per billion (ppb) oftrichloroethylene have been detected in monitoring wells (DGC15, near Terry Drive) on the western edge of the plume. SeePlate 1, not attached. EPA sampling, conducted on January 30and 31, 1985, detected trans-1,2-dichloroethene at 140 ppb andtrichloroethylene at 200 ppb in monitoring well DGC 24. Four GEsampling events and one other EPA sampling event of monitoringwell DGC 24 have detected no contamination. Some of thesesampling events occurred prior to the EPA January 30 and 31,1985 event and some occurred after that event. One samplingevent was on the same date. Monitoring well DGC 24 is 800 feetwest southwest of monitoring well DGC 15. This level of contam-ination has not been detected in monitoring well DGC 15.Subsequently, EPA ordered GE to install seven piezometers toconfirm the western boundary of the plume. The results ofwater level measurements from these piezometers indicate that agroundwater mound exists in the area which precludes the movementof contaminants further west than DGC 15.
The Remedial Investigation identified contamination in ReardonBrook which feeds the Village of Fort Edward public watersupply reservoirs which are along Reservoir Road. ReardonBrook had been diverted by the Village of Fort Edward inearly 1984. Surface water samples were collected and analyzedsome 40 times from nine stream locations as well as New Reservoirand the Village's three other reservoirs. Trichloroethyleneand trans-1,2-dichloroethylene have been identified in ReardonBrook. The highest level of trichloroethylene detected inReardon Brook was 900 ppb, at its origin. Contamination has notbeen detected in New Reservoir which is fed by Reardon Brooknor in the other reservoirs of the Village of Fort Edwardpublic water supply. See Table 7.1 and Figure 7.2, Streamand Reservoir Analytical Results, Fort Edward, New York,March 1985 Remedial Investigation, both attached.
The Remedial Investigation also identified PCB-contaminatedsoils within the dirt roads leading to the GE Moreau sitefrom Fort Edward Road. About 8600 cubic yards of contaminatedsoils were identified with varying concentrations of PCBs*512 locations on these dirt roads were sampled and 76 locationsshowed detectable concentrations of PCBs. The highest leveldetected was 3000 ppm at the ground surface. Lower levels, upto 42 ppm, were detected down to a depth of 6 inches belowthe surface. See Plate 10, not attached, and Figure 8.1,attached, March 1985 Remedial Investigation.
ALTERNATIVES EVALUATIONAND
SELECTION
Objectives
The most important objective of the proposed remedial actionsis to provide a safe drinking water supply for residentswhose drinking water wells have been adversely impacted bygroundwater contamination emanating from the GE Moreau site.This objective includes the continued monitoring of thegroundwater quality in the area to assure that the existinggroundwater plume does not adversely affect other areas.Part of this objective is to insure that the soil-bentoniteslurry cut off wall is effective in containing the hazardoussubstances within the site. A second objective is to remediatethe water quality of Reardon Brook feeding the New Reservoirwhich is one of the public water supply reservoirs of theVillage of Fort Edward. A third objective is to reduce thepotential for exposure to PCB contaminated soils adjacent tothe GE Moreau site.
The level of response for NPL sites is determined by therequirements of CERCLA Section 104, which mandates that EPAprotect public health and welfare and the environment. Atthis site, the response is dictated by the desire to minim-ize the public health risk presented by exposure to drinkingcontaminated water and exposure through direct contact withcontaminated soils.
Initial Screening Process
Remedial alternatives for the GE Moreau site can be dividedinto the following categories: Surface Water Supply, ResidentialWater Supply, Aquifer Restoration, and Soil Remediation. Allremedial alternatives were screened according to three criteria.These were cost, effects of the alternative, and engineeringacceptability. The cost of installing or implementing theremedial alternative is considered including operation andmaintenance costs. An alternative that far exceeds the costof other alternatives and does not provide greater health orenvironmental benefit is excluded from further considerationin accordance with the National Oil and Hazardous SubstancesContingency Plan (NCP). The effects of each alternative areevaluated in two ways. These are whether the alternative orits implementation has any adverse environmental effects andwhether the alternative is likely to effectively mitigate andminimize the threat of harm to public health, welfare, or theenvironment. The engineering acceptability means that thealternative must be feasible for the location and conditionsat the site and present a reliable means of addressing theproblem. The level of technological development is alsoconsidered.
Alternatives passing the initial screening process were thenevaluated in greater detail. All considered alternatives arelisted in Table 2, Potential Remedial Action Alternatives atthe Moreau Site, August 1985, attached, and alternatives-which passed the initial screening process and'then, subjectedto a detailed evaluation of alternatives are listed on page53 of the Feasibility Study, also attached. A discussionfollows for describing the process whereby alternativesidentified in Table 2 were either eliminated from or includedin the detailed evaluation of alternatives. This discussionis organized according to the site problems they are intendedto mitigate.
Surface Water Supply
Surface water at the Site is used for drinking water, therefore,the proposed Maximum Contaminant Levels (MCLs) establishedunder the Safe Drinking Water Act will be considered relevantand appropriate standards. The New York State Ambient Water•Quality Standards and Guidance Values will be considered relevantand appropriate where proposed MCLs do not exist. Trichloro-ethylene and trans-1,2-dichloroethylene have been detected atReardon Brook. The proposed MCL for trichloroethylene is5 ppb. An MCL has not been proposed for trans-1,2-dichloro-ethylene; the State Guidance Value for this contaminant is50 ppb.
-No ActionWater in Reardon Brook contains trichloroethlyene and trans-1,2-dichloroethylene in excess of the appropriate and relevantrequirements described above. The Village of Fort Edwardpublic water supply depends on Reardon Brook to meet its watersupply needs, therefore, remedial alternatives are required.Accordingly, the no action alternative was eliminated.
-DiversionEarly in 1984, Reardon Brook was diverted to bypass New Reser-voir and continue on and discharge into the Hudson River.Under this alternative, that diversion would be maintained.Reardon Brook, however, supplies approximately 40 percent ofthe Village's total water supply demand. Therefore, duringextended periods of low precipitation, without the ReardonBrook supply, the Village's water supply demand would exceedthe amount of water available. Thus, stream diversion as along term remedy is eliminated because it would lead to a watersupply shortage for the Village.
-Treatment by Carbon AdsorptionActivated carbon treatment has the advantage of high adsorptionpotential, tolerance of fluctuation in concentrations andflows,- and has high flexibility in operation and design* Thesuspended solids in Reardon Brook water and its microbialcontent would cause premature fouling of the activated carbon.Activated carbon will also remove the naturally occurring
organic chemicals found in this water, which by causingcompetition for adsorption sites on the carbon, can result inreduced removal efficiency of organic contaminants. This wouldnecessitate pretreatment of the influent water prior to thecarbon adsorption process. The appropriate and^relevant"requirements discussed above, could be met by this alternative.
-Treatment by Air StrippingAir stripping provides an effective means of removing thetrichloroethylene and trans-1,2-dichloroethylene from ReardonBrook water. The appropriate and relevant requirements discussedabove, could be met by this alternative.
-Treatment by Resin AdsorptionResin adsorption is another effective means for removingorganic contaminants. The method is not that widely employedfor potable water treatment because of the difficulty ofselecting the appropriate resin and adsorbant/regenerationcombinations. Disadvantages of resin adsorption includehigh initial cost due to its lower adsorption capacityrelative to activated carbon. Resin adsorption was thereforeeliminated from further analysis.
-Treatment by Ion ExchangeIon exchange will remove a limited number of organic contam-inants from aqueous solutions. The nonpolar organic compoundsfound in the water of Reardon Brook are inappropriate forthis treatment technology and therefore ion exchange waseliminated from further analysis.
-Reverse OsmosisThe technology of reverse osmosis is not well suited fortreatment of Reardon Brook water. It would require pretreatmentto remove colloidal and suspended solids, rigid pH control,and may lead to routine fouling of the expensive reverseosmosis membranes due to the precipitation of insolublesalts. Reverse osmosis is better suited to a water "polishing"operation following conventional treatment. Therefore, reverseosmosis was eliminated from futher consideration.
Residential Water Supply
Although the water supplies affected by the site are privateand not public supplies, the proposed MCLs will be consideredrelevant and appropriate standards. Trichloroethylene has beendetected in private wells. As stated above, the proposed MCL fortrichloroethylene is 5 ppb.
-No ActionConcentrations of trichioroethyiene in some residentialdrinking water wells along Bluebird Road have exceeded theproposed MCL thus necessitating further action. In addition,the no action alternative would not assure that residentialdrinking water wells in areas adjacent to the currently-definedgroundwater plume would not become contaminated in the future.
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These wells are along Cheryl Drive, Terry Drive, and Myron Road.The no action alternative for the Bluebird Road area is elimina-ted from further consideration and the no action alternativefor the Cheryl Drive, Terry Drive, and Myron Road-area is givenfurther consideration and addressed in the Detailed Analysissection of this document.
-MonitoringThe monitoring of residential drinking water wells would notprovide any control on groundwater movement; it would onlyprovide the capability to detect contamination. This alternativewould allow the proposed MCL for trichloroethylene to be exceeded.This alternative was therefore eliminated from further consider-ation. Monitoring of groundwater monitoring wells is consideredin greater detail in connection with long term operation andmaintenance of the slurry wall containment along with continuedmonitoring in the Detailed Analysis section.
-Groundwater Pumping and RechargeThe pumping of groundwater would not remedy the currentlycontaminated residential drinking water wells along BluebirdRoad (i.e., the MCL for trichloroethylene would still be exceeded).It would only prevent wells along Cheryl Drive, Terry Drive,and Myron Road from eventually becoming contaminated. Groundwaterpumping and recharge is a viable option for rehabilitation ofthe aquifer. For these reasons, a more detailed analysis ofthe groundwater pumping and recharge option is given furtherconsideration in the Detailed Analysis section.
-Individual Whole House TreatmentThe use of activated carbon filter systems to treat the watercoming from residential wells is a viable way of reducing theconcentration of trichloroethylene in drinking water to meetthe proposed MCL. This option is given further considerationin the Detailed Analysis section.
-Alternate Water Supply (Pipeline)An alternate water supply to residents whose wells do notmeet water quality standards may be accomplished by extendinga pipeline from a nearby public water supply system. Thisoption would meet the proposed MCL for trichloroethylene andis given further consideration in the Detailed Analysis section.
-New Domestic WellsThis option is eliminated from further consideration because,at certain locations, the contaminants are distributed through-out the entire thickness of the Moreau sand aquifer and changingthe well depth will not provide safe potable water (i.e., belowthe proposed MCL for trichloroethylene). Wells completed inthe bedrock aquifer and disturbing the integrity of the confininglayer could provide a pathway for movement of contaminants intothe bedrock aquifer. Even if wells could be safely installedto preclude this possibility, the option would have to includelong term monitoring to assure water quality. The new domesticwells alternative was therefore eliminated from further consideration.
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-CisternsWith the use of cisterns, precipitation water is collected fromthe roof and piped to a holding tank in the basement or elsewhereunderground. Filters are used to eliminate dust "and debrisfrom the collected water. Although the proposed MCL for tri-chloroethylene would not be exceeded by this alternative withrespect to private wells, it was eliminated from furtherconsideration because water quantity may not be sufficientand cisterns could also present hydraulic and sanitary problems.
-Bottled WaterThe use of bottled water would require 210 five-gallon con-tainers on a weekly basis for each house and would also re-quire a system for pumping the water through the house distri-bution system. Although this alternative would not exceedthe proposed MCL for trichloroethylene with respect to privatewells, it would not eliminate direct contact with contaminatedwater during bathing. This option was eliminated from furtherconsideration.
Aquifer Restoration
The aquifer at the GE Moreau site may be used as a potablewater supply, therefore, the proposed MCLs are consideredrelevant and appropriate requirements. Absent a proposed MCL,the New York State Ambient Water Quality Standards and GuidanceValues will be considered relevant and appropriate.
-No ActionWater within the groundwater plume emanating from the sitecontains significant concentrations of volatile organiccontaminants which exceed proposed MCLs and State standardsand guidelines. The no action alternative would rely uponthe ability of the Moreau sand aquifer to dilute and attenuatethese contaminants under natural conditions. The GE Moreausite was contained with the installation of the soil-bentoniteslurry wall. In the absence of source control, contaminantswould continue to flow from the site and dilution and attenuationwould not be effective. For these reasons, the no actionalternative was eliminated from further consideration.
-Containment BarriersExcept for source containment purposes at the GE Moreau siteitself, additional downgradient containment barriers areeliminated from further consideration. This is because thecontaminant plume has already migrated to its full areal extent,as evidenced by groundwater sampling, water level measurementsand surface water sampling conducted at Reardon Brook.Therefore, these barriers would be ineffective at this pointin time.
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-Source Containment, Groundwater Monitoring and Air StrippingGroundwater DischargeThis alternative would include the combination,of groundwatercontainment barriers to restrict groundwater movement, samplingand analysis of selected monitoring wells to assess the degreeof natural aquifer restoration over time, and air stripping thevolatile contaminants from groundwater discharges leading toReardon Brook. This alternative would not meet the appropriateand relevant requirements described above. As the GE Moreausite already has a containment barrier and air stripping thegroundwater discharge can provide a cost effective means oftreating the contaminants, this combination of remedial alterna-tives passes the initial process and is considered in theDetailed Analysis section.
-Source Containment, Groundwater Pumping and RechargeThis alternative includes the containment system describedabove along with the installation and operation of groundwaterrecovery wells to capture the downgradient contaminant plume,treatment to remove the groundwater contaminants, and eitherdischarging the effluent from the treatment system to thestreams feeding Reardon Brook or discharging the effluentback to the aquifer through recharge basins or injectionwells. Although this alternative could meet the relevant andappropriate requirements described above, is not consideredfurther because it could adversely affect the distributionpattern of water flowing to the reservoirs which comprise theVillage of Fort Edward reservoirs. Injection wells are prefer-red over recharge basins in the second case because many basinswould be required which would require the utilization of landin a residential neighborhood. The alternative of sourcecontainment, recovery wells, and treatment and reinjectionwells is considered in the Detailed Analysis section.
-Permeable Treatment BedsPermeable treatment beds require the installation of a trenchfilled with permeable treatment materials that would passivelyintercept and treat contaminated groundwater flows emanatingfrom a site. The trench would have to be long enough and deepenough to intercept the entire contaminant plume. Such a trenchfor the GE Moreau site would have to be some 100 feet deep andfilled with activated carbon for organics removal. This depthwould prohibit installation and the volume of carbon would alsobe large. Therefore this alternative is eliminated from furtherconsideration.
Soil Remediation-No ActionThis alternative would not eliminate the threat of publicexposure to the highly-contaminated soils at the GE Moreausite. The no action alternative is therefore eliminated fromfurther consideration.
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-SealingSurface sealing or capping the contaminated soils wouldeliminate the possibility of public exposure-as well asminimize water infiltration and erosion runoff*
-Excavation and RemovalExcavation of the PCB-contaminated soils and removal to asecure chemical landfill is an appropriate alternative. Theultimate disposal site could be the GE Moreau site itself,within the slurry wall or other secure chemical landfills inwestern New York State. These alternatives are consideredfurther in the Detailed Analysis section.
-TreatmentIncineration, either on site or off site for some 8600 cubicyards of materials would be prohibitively expensive comparedto the the other two alternatives described above. Inciner-ation was therefore eliminated from further consideration.
Detailed Analysis and Alternatives Selection
Each alternative and combination of alternatives passing theinitial screening process was evaluated in detail. The de-tailed analysis consisted of evaluating the following aspects:technical feasibility, public health protection, institutionalrequirements, environmental effects, and cost. This analysisis in accordance with Section 300.68 of the NCP and Section121 of CERCLA.
The technical feasibility of a remedial action was evaluatedfor performance, reliability, implementability, safety andlevel of technological development. Two aspects of performancedetermine desirability on the basis of performance, namelyeffectiveness and useful life. Effectiveness refers to thedegree to which the action will prevent or minimize substantialdanger to public health, welfare, or the environment. Theuseful life is the length of time this level of effectivenesscan be maintained. The cost of installing and operatingremedial alternatives, and the importance of protectingpublic health and the environment factor into reliability.The frequency and complexity of operation and maintenance arealso considered in evaluating the reliability of alternatives.Implementability is the relative ease of installation and thetime required to achieve a given level of response. The timerequirements are generally classified according to the timerequired to implement a technology and the elapsed timebefore results are actually realized. The safety evaluationconsidered threats to nearby communities and environments aswell as those to workers during implementation. The majorrisk considered was exposure to hazardous substances. A provenand widely used technology was rated high for technologicaldevelopment, and those technologies considered experimentalwere rated lower.
In addition to being technologically feasible and reliable, aremedial action must adequately protect public health. Remedialactions were evaluated with respect to the dearee to which
14
they mitigate health and environmental impacts^ and for eachremedial alternative evaluated, any negative environmentaleffects resulting from the implementation of that alternative.Alternatives requiring federal, state or local permits areidentified where relevent.
As specified in Section 300=68 (i)(2)(B) of the NGP remedialalternative cost estimates, including distribution of costsover time were developed. In developing detailed cost estimates,the following steps were performed;
1. Estimated capital and operation and maintenance costsfor remedial action alternatives.
2. Present worth analysis was calculated assuming 10percent interest and 5 percent inflation. Thisanalysis allows evaluation of expenditures that occurover a length of time by discounting all futurecosts to the present. This allows the cost of remedialaction alternatives to be compared on the basis of asingle figure representing the amount of money, that,if invested in the base year and disbursed as needed,would be sufficient to cover all costs associatedwith the remedial action over a thirty year life.
Surface Water Supply
From the initial screening of alternatives, activated carbonadsorption and air stripping the water in Reardon Brook arethe two alternatives considered. Both alternatives can meetthe appropriate and relevant requirements for surface watersupply.
-Carbon AdsorptionCarbon Adsorption is technically feasible for removing thevolatile organic contaminants from the waters of Reardon Brook.The carbon adsorption capacity for trichloroethylene and trans-1,2-dichloroethylene is 28 mg/gm and 3.1 mg/gm respectively.For the streamflow of Reardon Brook and its contaminant loading,the rate of carbon usage would be 22 pounds per day. A standardcarbon unit, holding 20,000 pounds of carbon, would have a lifespan of 2-1/2 years.
Public health would be protected by this alternative becausethe effluent water quality would meet or exceed the MCL fortrichloroethylene and State guidelines for trans-1,2-dichloro-ethylene.
New York State Department of Environmental Conservationpermits would be required for construction and operation of acarbon adsorption water treatment facility.
There should be no adverse environmental effects from theoperation of a carbon adsorption water treatment facility.
The capital costs of a 20,000 pound carbon adsorption unit is$600,000. The annual operation and maintenance costs are$150,000 which converted to a 30-year basis would be $2,306,000.Therefore, the total costs are $2,906,000 for such a unit.There are some disadvantages to a carbon adsorption unit whichshould be considered. It has some inherent inflexibility asfar as contaminant loading which can reduce the useful lifeof the carbon. In addition, the carbon, when saturated withorganic contaminants, has to be replaced. This operation islabor intensive.
-Air StrippingRemoving volatile organic contaminants from water by airstripping is a well proven and available technology. Becausetrichloroethylene and trans-1,2-dichloroethylene have highvapor pressures compared to water, these organic compoundscan be removed from the water phase by exposure to air ina packed stripping column. Air stripping can remove thecontaminants in Reardon Brook to levels less than 1 part perbillion which meets and exceeds the MCL for trichloroethylene'and the State guideline for trans-1,2-dichloroethylene.
A permit to construct an air stripping tower on Reardon Brookhas been granted by Region 5 of the New York State Departmentof Environmental Conservation. This initial remedial measurecomplies with Section 300.68(e) of the NCP whereby remedialactivities may be instituted prior to the selection of thefinal remedy.
There is no detrimental environmental impact associated withan air stripping water treatment facility.
The air stripping tower costs $90,000 and the entire treatmentfacility including pumps, supplementary air heating for extremecold weather operations, and supplementary back up equipment is$500,000. The annual operation and maintenance costs for thefacility is $16,000 and, when converted to a 30-year presentcost, is $246,000. The total cost for the air strippingfacility is therefore $746,000.
Comparison of Alternatives for Surface Water Treatment-Carbon adsorption and air stripping are both technically feasibleand available alternatives for treating Reardon Brook waters.
Carbon adsorption, costing $2,906,000, is some $2.2 million moreexpensive than air stripping which costs $746,000. The Environ-mental Protection Agency hereby selects air stripping as thecost effective alternative for treating Reardon Brook waters.As the air stripping facility has been operational since fall1985, the EPA decision is therefore to continue to utilizethe air stripping facility initial remedial measure as theselected remedial measure.
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Residential Water Supply
The options for residential water supply in the Cheryl Drive,Terry Drive, and Myron Road areas are the no action alter-native, groundwater monitoring alone,- and groundwater pumpingand recharge. For the Bluebird Road area, the alternatives areindividual whole house treatment and alternate water supplyfrom an existing public water supply which both can meet theappropriate and relevant requirements for residential watersupplies.
-Individual Whole House Treatment (Bluebird Road)The in-line, whole house treatment unit consists of two activatedcarbon filter canisters in series with the incoming water fromthe individual domestic well followed by an ultraviolet disin-fecting unit. Monthly sampling and analysis to assure theproper operation of these units is indued within this altern-ative. It is also assumed that the carbon units would bechanged annually.
The whole house treatment alternative is technically feasibleand achieves a high level of decontamination almost immediately.The whole house treatment alternative effectively reduces therisk of consuming contaminated drinking water. A small riskstill exists for contaminant breakthrough to occur between thesampling events and therefore the potential for consumption ofcontaminated water exists during that time period.
There are no institutional requirements for the whole housetreatment alternative.
No adverse environmental effects are related to the whole housetreatment alternative. The only negative aspect with respectto environmental concerns is the disposal or regeneration ofspent carbon.
The costs for whole house treatment units are strictly linearwith respect to the number of treatment units ultimately needed.For eight units the capital costs would be $24,000. The annualoperation and maintenance costs are $32,000 and converted to a30 year basis are $492,000. Therefore, the total cost for thisalternative is $516,000. Again, if more domestic wells needtreatment, this cost would escalate linearly.
-Alternate Water Supply (Bluebird Road)This alternative involves the extension of the public watersupply mains to the Bluebird Road area. Public water suppliesin the area include Village of South Glens Falls supply to thenorth and the Town of Moreau Water District No. 2 to the west.Water could also be obtained from the Town of Queensbury WaterDistrict No. 1 and the Village of Hudson Falls, water couldalso be obtained from a new, not yet constructed, public watersupply. Water mains would be sized to be compatible with theTown of Moreau Water Service Comprehensive Plan. The alternate
1?
water supply pipeline is both technically feasible and achievesa high level of performance and reliability in a short time.The pipeline alternative would effectively isolate residentsfrom exposure to contaminated drinking water and would thereforeeliminate risks to public health.
Permits to install the pipeline may be required trbm the Townof Moreau and New York State Department of Health approval toextend water supply mains may be required. If the Queensburysupply is the source of alternative water, permission from theNew York State Department of Transportation, the Federal HighwayAdministration, and the U.S. Coast Guard would have to be grantedfor a water main to be installed on the I 87 bridge across theHudson River.
No adverse environmental effects can be attributed to thisalternative.
The capital cost for extending water supply mains to the BluebirdRoad area range from a low of $463,000 to a high of $692,000'depending on pipeline sizing and compatibility with the Townof Moreau Water Service Comprehensive Plan. Operation andmaintenance costs would be covered by water usage fees: i.e.,the operation and maintenance expenses for this alternativeare contained within the water bills collected from all watersupply users within the water district.
-No Action (Cheryl Drive, Terry Drive, Myron Road)The no action alternative for the Cheryl Drive, Terry Drive,and Myron Road area would not mitigate any potential impactfrom the existing groundwater contaminant plume and further,selection of this alternative alone would not provide verif-ication that the plume has remained unchanged from its presentcondition.
This involves no analysis of technical feasibility, institu-tional requirements, or cost.
-Groundwater Monitoring (Cheryl Drive, Terry Drive, Myron Road)This alternative involves the regular sampling and analysisof groundwater monitoring wells between the GE Moreau siteand the Cheryl Drive, Terry Drive, and Myron Road area. Fourmonitoring wells, sampled on a semi-annual basis, would providefor the implementation of additional remedial measures inthis area.
This alternative is technically feasible and well established.The monitoring wells were installed under the Remedial Inves-tigation and already exist.
This alternative would only provide a warning system for thisarea. It would not, on its own, provide public health protection.Access to the four monitoring wells would have to be assuredas an institutional requirement.
18
This alternative would have no adverse environmental effect.The capital cost of the four monitoring wells is zero becausethey already exist. The annual operation and maintenance ofsemi-annual monitoring and analysis is $22,000. That cgst, whenconverted to a 30-year term, is $338/000 which-means the totalcost of this alternative is also $338,000.
-Groundwater Pumping and Recharge (Cheryl Drive, Terry Drive,Myron Road)
This alternative would involve the installation of four ground-water production wells placed between the GE Moreau site andthe Cheryl Drive, Terry Drive, and Myron Road area. Pumping,treating, and returning this water to the aquifer would providea barrier between the contaminants at and downgradient of theGE Moreau site and the Cheryl Drive, Terry Drive, and MyronRoads area. The system would include eight recharge wells,southeast of the withdrawal production wells, to return treatedwater to the aquifer. The treatment system would be an airstripping water treatment facility.
'This alternative is technically feasible and commonly used tocontrol groundwater contaminant plumes.
This alternative would provide a barrier between the GE Moreausite and the Cheryl Drive, Terry Drive, and Myron Road areato prevent groundwater contaminants from migrating to thewells in this area.
The institutional requirements for this alternative includethe purchase of land for the production wells, treatment plant,and the reinjection wells. Permits would have to be obtainedunder the Clean Air Act for the air stripping treatment plant,and under the Underground Injection Control program of the SafeDrinking Water Act for the injection wells.
The detrimental environmental effects are drawdown of resi-dential drinking water wells, creation of groundwater sinksand mounds, and drawing groundwater contaminants closer tothe Cheryl Drive, Terry Drive, Myron Road area by pumpinggroundwater.
The capital cost of this alternative is $1,100,000. The annualoperation and maintenance costs are $74,000 which convertedto a thirty year base is $1,144,000. The overall cost of thegroundwater pumping and recharge alternative for this area is$2,244,000. This is not a cost effective alternative.
-Individual Whole House Treatment (Cheryl Drive, Terry Drive,Myron Road)This alternative involves installing activated carbon watertreatment units and ultraviolet disinfection units on residentialdrinking water wells in the Cheryl Drive, Terry Drive, and
19
Myron Road area. This alternative is technically feasibleand easily installed. It also effectively mitigates publichealth risks.
There are no institutional requirements for this- alternative.This alternative has no adverse environmental effect except forthe regeneration of spent activated carbon.
The capital costs for the installation of whole house treatmentunits is, for 22 houses, $63,000. Operation and maintenanceis $72,000 annually and for 30 years is $1,107,000. If more than22 houses are involved, the costs will increase on a linear basis.
-Alternate Water Supply (Cheryl Drive, Terry Drive, Myron Road)This alternative is the same as that described for the alternatewater supply alternative for Bluebird Road previously; namelythe extension of water mains from an existing public watersupply or a new, not yet constructed, public water supply.The analysis of technical feasibility, public health effects,institutional requirements, and environmental effects areidentical. The capital cost of this alternative is between$527,000 and $755,000 once again depending on pipeline sizing.The operation and maintenance costs are again within the userfees.
The alternate water supply alternative for the Cheryl Drive,Terry Drive, Myron Road area can be combined in an effectivemanner with the alternate water supply alternative for BluebirdRoad. This combination would result in a significant costsaving. The combined alternative cost is between $695,000and $974,000. This range is again dependent of pipe sizing.Connection to the Town of Queensbury Water District No. 1would cost an additional $1,403,800 beyond the cost of connectionto the Village of South Glens Falls or the Town of MoreauWater District No. 2 sources. The connection to Queensburyinvolves the installation of an additional 29,700 feet, orroughly six miles, of water main as well as a crossing of theHudson River. These cost figures were derived from theFeasibility Study and the Regional Water Supply Evaluationreports.
-Comparison of Alternatives for Residential Water Supply:(Bluebird Road and Cheryl Drive, Terry Drive, Myron Road)-
Comparison of Alternatives for Bluebird Road results in theselection of the alternate water supply as the cost effectivesolution. The technical feasibility and public health protec-tion aspects are higher for a water supply pipeline than forwhole house treatment units and the costs are the same. Forthe Cheryl Drive, Terry Drive, Myron Road area,- the alternatewater supply is also the cost effective alternative. The noaction alternative alone would not assure public healthprotection and groundwater monitoring would only indicate theneed for other remedial action. Groundwater pumping andrecharge has several disadvantages along with high cost and
20
individual whole house treatment is even more expensive thanthat. The alternate water supply pipeline provides a highdegree of public health protection and is also a technicallyfeasible solution. The Environmental Protection Agency-herebyselects an alternate water supply as the cost Effectivealternative for contaminated or potentially contaminatedresidential drinking water wells on Bluebird Road and in theCheryl Drive, Terry Drive, and Myron Road area. There areseveral existing public water supplies that can provide thenecessary water. The Village of South Glens Falls has statedthat its supply has an excess capacity of approximately100,000 gallons per day. The ability of this water supply toprovide water to the 100 additional homes contemplated bythis alternative is further supported by the USGS Adminis-trative Report. The Town of rioreau Water District No. 2 wasreported to have an excess capacity of 100,000 gallons perday in the FS. However, subsequent comments from the Town ofMoreau in addition to discussions with the New York StateDepartment of Health, have revealed that sufficient capacity.does not exist. The Town of Queensbury Water District No. 1has a potential excess capacity of 1.8 million gallons perday. Discussion with the New York State Department of Healthindicate that modifications to the existing system would benecessary to increase the supply. The Village of HudsonFalls has an excess capacity of 250,000 gallons per day.
100,000 gallons per day can supply water for approximately263 homes. This is based on the following accepted engineeringassumptions. The average per capita water use is 100 gallonsper capita per day and the average household is comprised of3.8 residents.
The Town of Queensbury Water District No. 1 alternative wouldcost an additional $1.4 million beyond the selection of theVillage of South Glens Falls supply or the Town of MoreauWater District No. 2 supply. (This estimate does not includethe added expense of the river crossing and extending the mainfrom the Queensbury Regional Plant to the river).
The cost effective alternative that would supply water tohouses on Bluebird Road and Cherly Drive, Terry Drive, andMyron Road is the Village of South Glens Falls supply. TheEnvironmental Protection Agency hereby selects the Village ofSouth Glens Falls as the water supply source.
The water supply main sizes will be compatible with the Townof Moreau Water Service Comprehensive Plan. The attachedFigure 3 (modified) of the Regional Water Supply Evaluationreport describes the location and sizing of the water mainsfor Bluebird Road and Cheryl Drive, Terry Drive, and MyronRoad.
The institutional requirements for this alternative includethe formation of a water district which is ordinarily created
21
by local government; alternatively. GE may be the purveyor ofwater to the affected area, if necessary.
Aquifer Restoration
The two remedial alternatives to be evaluated in detail aresource containment, groundwater monitoring and air strippinggroundwater discharge; and source containment, groundwaterpumping and recharge. The aquifer restoration alternative isconsidered for the groundwater contaminant plume defined by theRemedial Investigation, namely the plume emanating from GEtloreau site and migrating south-southeasterly ultimately dis-charging as surface water flow at the Moreau sand aquiferescarpment. Both alternatives can meet the appropriate and £-£•£relevant requirements with respect to aquifer rehabilitation.
-Source Containment, Groundwater Monitoring, and Air StrippingGroundwater Discharge
Within this alternative, the soil-bentonite cutoff wall con-structed in 1984 around the disposal site is utilized to containthe source of off site groundwater contamination. The wall wasdesigned and constructed to prevent the further release of
\ contaminants from the site. The aquifer should be restored to' acceptable conditions within a time period of decades.
This should occur because the source is eliminated from further ^~)contributing contaminants to the aquifer, regional groundwater (flow will dilute by advection, dispersion, sorption, and degrad- u
ation of the contaminants within the plume on either side ofthe plume below grade, and precipitation will also dilute thesecontaminants from above. Groundwater monitoring under thisalternative will determine the rate at which aquifer restorationwill proceed. In addition, groundwater monitoring will assurethat the direction of plume migration does not change. Eighteengroundwater monitoring wells are included in this alternativefor groundwater monitoring on a semi-annual basis. They areDGC 25, I, D; DGC 15S, I, D; DGC 16 S, D; DGC 18 S, I, D; DGC25 la, Ib; Til 2; TM 5; TM C; TM G; and FE 1. In addition,water level will be measured in monitoring wells DGC 19, DGC20, DGC 21, DGC 28 and DGC 31-37. These groundwater monitoringwells define the existing boundaries of the plume and monitoringof these wells will identify changes in groundwater quality andflow direction.
The third element of this alternative is to utilize the airstripping water treatment facility at Reardon Brook to treatthe aquifer discharge flow. This facility has been operatingsince fall 1985 and is effectively removing volatile contaminantsfrom the brook.
The three technologies within this alternative are wellestablished and commonly used. These are in fact in place atthe present time.
22
The public health effects associated with this alternativeare those for removing contaminants from Reardon Brook whichis one source for the Village of Fort Edward public watersupply.
*
The institutional requirements for the soil-bentoni±e cutoffwall and the air stripping treatment facility have already beensatisfied. Easements for the wall were obtained from theproperty owners and the wall was installed with the approvalof the New York State Department of Environmental Conservation.Permits for the water treatment facility were obtained fromthe same agency as well and the facility was considered aninitial remedial measure under the NCP.
Since treatment at Reardon Brook will continue, no adverseenvironmental effects are forseen for this alternative.The capital cost for all elements of this alternative are$2,600,000. The annual operation and maintenance costs are$40,000 and converted to a 30 year basis are $615,000. Thetotal cost of the source containment, groundwater monitoring,and air stripping alternative is $3,215,000.
-Source Containment, Groundwater Pumping and RechargeThe source containment element of this alternative is the sameas discussed within the previous alternative. The groundwaterpumping and recharge element would utilize production wellswith the plume to remove contaminated groundwater. This waterwould then be passed through an air stripping water treatmentfacility to remove volatile organic contaminants and thenreturned to the aquifer through recharge wells. There arevarious pumping schemes that could be used to remove thecontaminant plume from the aquifer. For this alternative,placement of nine pumping wells along the logitudinal axis ofthe plume was evaluated. The combined pumping rate would be390 gallons per minute. The treated water would be returnedto the aquifer through 21 recharge wells located along theouter boundaries of the plume. Groundwater monitoring wellswould be sampled on a periodic basis to determine the effective-ness of groundwater pumping, treatment, and recharge in theway this alternative would affect the size and quality of theplume.
This alternative is technically feasible because the cutoffwall already exists, groundwater monitoring wells exist, anda great deal is known about the Moreau sand aquifer. Thesource containment, groundwater pumping and recharge alter-native would restore the quality of the Moreau sand aquifer*
The public health effects for this alternative are thoserelated to the operation of air stripping facilities.The institutional requirements for this alternative are theneed to purchase land or obtain agreements for access. Thetreatment plant would need a Clean Air Act permit and therecharge wells would need Underground Injection Control permits.
23
The environmental effects of the source containment, ground-water pumping and recharge alternative are that it wouldfacilitate the restoration of the Horeau sand aquifer. Theamount of time that would be saved by this alternative comparedto the time for unf acilitated restoration within. the sourcecontainment, groundwater monitoring, and air stiipp'ing ground-water discharge alternative is unknown. Possible 'detrimentaleffects associated with this alternative are an alteration ofthe groundwater flow regime with possible reduction of waterflow to Reardon Brook. This would effect the Village of FortEdward public water supply.
The capital cost of the source containment, groundwater pumpingand recharge alternative is $4,251,000. The operation andmaintenance costs are $240,000 annually and $3,689,000 on a 30year basis. Therefore the total cost is $7,940,000.
Comparison of Alternatives for Aquifer Restoration-Both the source containment, groundwater monitoring, and airstripping groundwater discharge alternative and the sourcecontainment, groundwater pumping and recharge alternative aretechnically feasible. The source containment, groundwaterpumping and recharge alternative has the disadvantages ofpossibly altering the groundwater flow system in the floreausand aquifer* and affecting the flow to Reardon Brook. Inaddition, the cost of source containment, groundwater pumpingand recharge alternative is some $4.7 million more expensivethan source containment, groundwater monitoring, and air strip-ping groundwater discharge. The possibly shorter time periodfor restoring the quality of groundwater in the Moreau sandaquifer does not justify this since absent this additionalpumping,, the groundwater quality will ultimately be restored toappropriate and relevant standards with respect to aquiferrestoration. The Environmental Protection Agency hereby selectssource containment, groundwater monitoring, and air strippinggroundwater discharge as the cost effective alternative foraquifer restoration at the GE Moreau site.
Soil Remediation
The initial screening process identified excavation/on sitedisposal and excavation/off site disposal for the PCB-contam-inated soils along with surface sealing the soils to minimizepublic exposure.
-Excavation/On Site DisposalThis alternative involves the excavation of 8,600 cubic yardsof PCB-contaminated soils and redeposition of these soils withinthe soil-bentionite slurry wall of the GE Moreau disposal site.
This is technically feasible and involves the well establishedtechniques of earth moving engineering. An impermeable claycap would be installed on top of the GE Moreau site after thesoils are deposited.
24
This achieves a high degree of public health protection as thecontaminated soils are removed from possible public exposureimmediately.
The New York State Department of Environmental Conservation andthe United States Environmental Protection Agency have alreadyapproved soil removal and on site disposal within the slurrvwall.
This has beneficial environmental effects becausethe land would become uncontaminated.
The cost of excavation/on site disposal is $500,000. There isno operation and maintenance cost for this alternative.
-Excavation/Off Site DisposalThis is the same alternative as described above except that thesoils would be transported off site to a secure chemical landfill.This alternative is also a well established technically feasible.
The only disadvantageous public health element associated withthis alternative is the possible public exposure to contaminatedmaterials during transport.
This also requires state and federal approvals as does theexcavation/on site disposal alternative.
It results in the same beneficial environmental effect of landrestoration.
The cost of this alternative is $2,500,000 with no operation andmaintenance costs.
-Surface SealingThis alternative has three choices. The in-place contaminatedsoils could be sealed with natural soils, asphalt, or syntheticmembrane. The contaminated soils are covered to prevent publicexposure and to minimize surface infiltration and erosion. Allof these choices include fencing of the sealed areas to restrictaccess.
All of these surface sealing choices are technically feasibleand can be implemented in a timely fashion.
These soil remediation alternatives all provide public healthprotection because the soils can no longer come in contact withpeople or the environment.
These choices require state and federal approvals.
25
Soil sealing costs $160,000 with $8,000 annual operation andmaintenance or $123,000 for 30 years resulting in a $283,000total cost. Asphalt sealing costs $286,000 with $14 ,000 "annualoperation and maintenance or $215,000 for 30 years, resulting ina $501,000 total cost. Synthetic sealing costs $23(5,000 with$12,000 operatiion and maintenance or $185,000 for 30 yearsresulting in a $415,000 total cost.
Evaluation of Alternatives for Soil Remediation -The excavation/removal alternatives have the advantage ofcompletely isolating the contaminated soils from public andenvironmental exposure. In addition, the decontaminatedland again becomes usable. The General Electric Companyhas already excavated and redeposited the PCB-contaminatedsoils within the slurry wall during mid-summer 1985 in com-pliance with an EPA Administrative Order signed July 12,1985. The United States Environmental Protection Agencyhereby selects the excavation/on site disposal alternativeas the cost effective alternative for the PCB-contaminatedsoils at the GE Moreau site.
ENFORCEMENT ANALYSIS
The General Electric Company has already installed and isoperating the Reardon Brook air stripping water treatmentfacility since fall 1985.
The General Electric Company has already removed the PCB-contaminated soils at the Moreau site and has already disposedof these soils within the slurry wall at the GE Moreau siteduring summer 1985.
The General Electric Company will be required to extend thewater supply mains from the Village of South Glens Fallsto provide public water supply to residences along BluebirdRoad and along Cheryl Drive, Terry Drive, and Myron Road.All of these remedial alternatives are in accordance with theAdministrative Orders between the General Electric Company andthe Environmental Protection Agency dated November 21, 1983and July 12, 1985. The General Electric Company is requiredto continue to provide for the operation and maintenance ofthe Reardon Brook air stripping facility. In addition, theGeneral Electric Company is required to maintain the GEMoreau Site. That is, the slurry wall surrounding the GEMoreau Site is to be maintained to prevent the release ofhazardous substances from the site» The cap above the GEMoreau site is to be maintained to prevent the infiltrationof precipitation waters which may lead to hazardous substancesrelease from the site.
26
COMMUNITY RELATIONS
The Environmental Protection Agency has conducted numerouscommunity relation activities since the GE Moreau facilitywas first listed as an NPL site. The agency has-met with theCitizens of Moreau Against Contamination (C,O.MiA.£.) andelected officials on numerous occasions. These meetings wereintended to describe the Superfund process and to informthese groups of the progress of the Remedial Investigationactivities. Meetings were held to inform the groups of theGE Moreau soils removal activities and the Reardon Brook airstripping water treatment plant activities. Meetings werealso held when the Feasibility Study was first presented tothe regulatory agencies. A public comment period starting onSeptember 9, 1985 and continuing to February 4, 1987/ wasutilized to solicit comments from these groups on the FeasibilityStudy as well as other aspects of the GE Moreau site. TheEnvironmental Protection Agency has attempted to respond toall the comments during these meetings. In particular, specificconcerns raised during the comment period are addressed inthe Responsiveness Summary which is attached.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The remedial activities described in this Record of Decisionare consistent with the technical requirements of both stateand federal environmental laws. The Reardon Brook air strippingwater treatment facility has already been issued an airpermit from the New York State Department of EnvironmentalConservation. The removal of the PCB-contaminated soils andthe disposal of these soils within the slurry wall at the GEMoreau site was performed with the approval of the New YorkState Department of Environmental Conservation and the Environ-mental Protection Agency. The extension of public watersupply mains to Bluebird Road and to Cheryl Drive, TerryDrive, and Myron Road may require permits from the Town ofMoreau and the New York State Department of Health as well asthe New York State Department of Transportation.
GE/KOREAU SITEREMEDIAL INVESTIGATION
CERCLA 30201
Moreau » Saratoga County, Nev YorkUSCS 7.5 sin. quad., Clens Falls
K Hudson Falls
f:Contour Interval 10 feet
Scale: 1" • 2000'
Figure 1.1
Table 2
Potential Remedial Action AlternativesAt the Moreau Site
SURFACE WATER
No ActionDiversionTreatment
Carbon adsorptionAir strippingResin adsorptionSon exchangeReverse osmosis
RESIDENTIAL WATER SUPPLY
Ko ActionMonitoringGroundwater Pumping and RechargeIndividual Whole-House treatmentAlternate Water Supply (pipeline from existing municipal system)Hew WellsCisternsBottled Water
AQUIFER RE5TOPATION
Ko ActionContainment BarriersSource Containment, Groundwater Monitoring and Air Stripping of
Groundvater DischargeSource Containment, Groundvater Pumping and RechargePermeable Treatment Beds
SOTI. REMEDIATION
Wo ActionSealingExcavation and RemovalTreatment
incinerationWet Air OxidationBiological DegradationChemical Treatment
4.4 Summary ef Inital Screening Ecsultft
\the screening process previously discussed Isi Beetle
the remedial alternatives that were initially devalopac.screened to aliainate infsasible' or son £ost-offialternatives.
\The following lift present* the alternative* which passedinitial screening phase. Theoo alternatives are eatigorInto groups according to %rhieh sit© : probleas the reaaddresses (i.e., aquifer reaedlttion, retidentie.1 vater supply!
Note: the following is a modification of p. 53ALTERNATIVE
Surface Water
-Treatment by Carbon Adsorption
-Treatment by Air Stripping
Residential Water Supply•
Cheryl Drive, Terry Drive, Myron Road--No Action
-Monitoring
-Groundwater Pumping and Recharge
-Alternate Water Supply
Bluebird Road--Individual Whole-House Treatment
-Alternate Water Supply
Cheryl Drive, Terry Drive, Myron Roadand Bluebird Road together--Alternate Water Supply
Aquifer Restoration
-Source Containment, Groundwater Monitoringand Air Stripping Groundwater Discharge
-Source Containment, Groundwater Pumpingand Recharge
Soil Remediation
-Excavation and Removal
COST
$ 2 , 9 0 6 , 0 0 0
746,000
0
338,000
2,224,000
527,000 to 75!
64 ,500 per ho
463,000 to 692,
695,000 to 974 ,0or
2,098,000 to 2 ,377,
3,215,000
C7,940,000 jj
500,000 to 2 , 5 0 0 , 0 0 0
note: all results in parts per billion
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Trtl* T.I
am Bnmou *n»tnic«. irsoinroar tou»«o. ntv TOM
note: all results in parts per billion
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PGC-2 9
IIIi11
Ii
(not toFIGURE 72
REMEDIAL INVESTIGATIONGE/MOREAU SITE
Cio«r«>>i i
SURFACE WATERApproximate Sampling Locations
tout
SECTION A
14 19 12 II 10 9 6 T 0 S 4 3 2 I t Sfta
§I «f-
30T-
f .
4*"-
49"-
FIGURE 8J
Extent of Soil ContaminationCross - Section
AI-Att
ffM
I*
Legend
H • Confarninofed
D - Non-Contaminated
Ve - Soils collected down to 8" belowground level may be anywherealong a lateral transect, soilscoHected below 8" ore always"C" points along ORJS of road.
3 — MODIFIED
LEGEND
COUNTY BOUNDARIESTOWN SERVICE AREASWATER DISTRICT
_2_ EXISTING TRANSMISSION LINESEXISTING DISTRIBUTION LINES
{2 PROPOSED TRANSMISSION 8 DISTRIBUTION LINES• WTF WATER TREATMENT FACILITIES£ WS WATER STORAGEA KNOWN OR POTENTIAL CONCERN AREAS
[ IMPACT AREA(S) SERVED
NOTES:1. THE EXISTING WATER SYSTEM PLAN WAS DEVELOPED AS SHOWN
THROUGH MEETINGS AND INTERVIEWS WITH THE VARIOUS WATER
SUPERINTENDANTS.
2. PIPE SIZES RANGE FROM 2 INCH TO 24 INCH, ONLY @ INCH AND
LARGER ARE NOTED.
BLUEBIRD ROAD IMPACT AREA
SHORT/LONG TERM ALTERNATIVE No. 2A
SCALE IN FEET
2000' 0' 2000' 4000*
B^UUVG ft BC4PGS BCMKIfiBL Pjft
•EO*
DEPARTMENT OF THE INTERIORU.S. GEOLOGICAL SURVEY
QUANTITY AND QUALITY OF WATER FROM PUBLIC-SUPPLY WELLS AND SPRISGS
IN THE VILLAGE OF SOUTH GLENS FALLS, NEW YORK !i
Administrative Report
Prepared for the
U.S. ENVIRONMENTAL PROTECTION AGENCY
DEPARTMENT OF THE INTERIORU.S. GEOLOGICAL SURVEY
QUANTITY AMI) QUALITY OF WATER FROM PUBLIC-SUPPLY WELLS AND SPRINGS
IN THE VILLAGE OF SOUTH GLENS FALLS, NKW YOEK
By Daniel C. Hahl and Edward F. Bugliosi
Administrative Report
Prepared for the
U.S. ENVIRONMENTAL PROTECTION AGENCY
Albany, Wew York
1987
gGt
DEPARTMENT OF THE INTERIOR
DONALD PAUL HODEL, Secretary
U,S, GEOLOGICAL SURVEY
Dallas L. Peck, Director
ADMINISTRATIVE REPORT
11
CONTENTS
Page
Abstract iIntroduction *>.«̂ ' 1Quantity of water ~ 3
Sources of water 3Potential yield of aquifers.... «., 0> .eoooo o o o o o o o o o c o 3Quantity used by village 6
Quality of water 6Conclusions 7References cited 8
TABLE
Table 1.— Concentrations of selected ground-water and surface-waterconstituents at South Glens Falls, N.Y ....................... 7
ILLUSTRATIONS
Figure 1. — Map showing bedrock geology and major geographic featuresof the Village of South Glens Falls and vicinity ............. 2
2. — Geologic section A-A* through Village of South Glens Fallswater-supply area..... .............. . ........................ 4
3. — Geologic section B-B' through Village of SouthGlens Falls water-supply area.. ...... . ....................... 5
e?
CONVERSION FACTORS AND ABBREVIATIONS
Factor* for converting the metric (International System) units used inthis report to inch-pound units are shown below.
Divide metric (SI) units
aeter (»)kilometer (km)
square kilometer (km2)hectare (ha)
liter per second (L/s)liter per second (L/s)liter per second (L/s)cubic centimeterper day (co3/d)
cubic aeter per second(a3/.)
aeter per day (n/d)
meter per kilometer (m/ka)
cubiccubic
iter (m3)ster (a3)
SL
Length
0.30481.609
Area
2.590.405
Flow
28.320.06309
43.813784
0.0283
Hydraulic Units
0.3048
0.1894
Volume
35.31264.2
To obtain inch-pound units
foot (ft)Bile (ml)
square mile (mi2)acre (a)
cubic feet per second (ft3/s)gallon per minute (gal/min)million gallons per day (Mgal/d)gallon per day (gal/d)
cubic feet per second (ft3/*)
hydraulic conductivity,foot per day (ft/d)
foot per mile (ft/ml)
cubic foot (ft3)gallon (gal)
National Geodetic Vertical Datum of 1929 (NGVD of 1929); A geodetic datumderived from a general adjustment of the first-order nets of both the UnitedStates and Canada, formerly called "Mean Set Level."
QUANTITY AND QUALITY OF WATER FROM PUBL'>SUPPLY WELLS ANU SPRINGS
IN THE VILLAGE OF SOUTH GLENS FALLS, NEW YORK
«.."/
Daniel C. Hahl and Edward F. Bugliosi
ABSTRACT
The Village of South Glens Fallo, N.Y. has not collectedsufficient data to describe, in detail, the quantity and qualityof water available from wells and springs that are used for itswater supply* The area contains a sand aquifer that is underlainby shale of the Snake Hill Formation. Data from several consultants'reports indicate that wells drilled in shale can yield 0.65 Billiongallons per day, and the spring gallery can yield up to 0.20 Billiongallons per day. The assumed range of horizontal hydraulic conduc-tivity of the bedrock shale and the Pleistocene sand aquifer thatfeeds the springs, together with the water-table gradient In thecand aquifer, suggest that the published yield values are correctto within an order of magnitude. Calculations based on the analysissuggest that regular use of the veils could provide the additional0.03 Mgal/d of water for the 100 homes in the Town of Moreau.
Water from the wells contains an elevated concentration ofhydrogen sulfide which supports the conclusion that the water isdirectly or indirectly supplied from the shale bedrock, which ischaracteristically high in hydrogen aulfide. The available datasuggest, however, that if the welli are pumped at a rate necessaryto satisfy the 100 additional homes in Moreau, the effect on thequality of the water supply will be small.
INTRODUCTION
In September 1986, the U.S. Environmental Protection Agency formallyrequested the U.S. Geological Survey to evaluate the quantity and chemicalquality of ground water in the Village of South Glens Falls (fig. 1) thathas been proposed for use as a supplemental source of public supply for about100 residences in the nearby Town of Moreau. The evaluation was based oninfcreation extrapolated from several engineering consultants' reports fornearby areas, data from the New York State Department of Health, geologic aapsby the New York State Geological Survey, well-operation records, and a geo-logic reconnaissance.
This report identifies the assumptions made, describes the oethode usedto estimate potential yield of the shale aquifer, and presents she dagoavailable on chemical quality of water from bedrock wells and springs.
SARATOGA
COUNTY
South Glens Fallswater-supply swellsand TrMBment plant
BEDROCK UNITS
Osh SNAKE HILL FORMATION
Ogf GLENS FALLS LIMESTONE
Oil ISLE LA MOTTE LIMESTONE
Ofo PORT ANN FORMATION
A- GEOLOGIC SECTION
GEOLOGIC CONTACT
<&«=** SPRING GALLERY
SOUTH GLENS FALLSSKATER-SUm.V FACILITYAREA
© WELL-Location with225
in fe«t above NGVDof 1929
SURFACE-WATER QUALITYSAMPLING
DUNN GEOSCIENCE WELL!DE.MT!F!CAT!ON N
B08C from U-&. GeologiCOl Survey.GI@ris FellsIIB&filand Mifllson Falls IIBfiSIJ ̂ ,000
Goologyartd otrotiorophic rtomsrvclotu^o frem FiDhor, 1S8S
o—Bedrock geology and sajor geogrophie fso£u?eoShe Village @f ioush Cleno
QUANTITY OF WATER
Sources of Water
The South Glen, Falls public water supply is derived ,-f r.os • Series ofsprings that flow from a Pleistocene sand aquifer east of the present pumpingand water-treatment plant (fig. 1). The supply is supplemented in summer bytwo wells that are about 600 feet southwest of the plant and about ICO feetsouth of the Hudson RiveTO Each veil is 210 feet deep and is reportedlyfinished in shale of the Ordovician Snake Hill Formation (fig. 2). Althoughthe veils are in an area that is napped as the Ordovician Ciena FallsLiaestone (Fisher, 1935), comparison of the drillers' logs for ihe supplywells, stratigraphlc data from selected wells east of the Bite, and measuredstratlgraphic sections in the limestone quarry to the northeast (fig. 3)suggest that the supply wells are completed, at least partially, in shale.
Potential Yield of Aquifers
The springs reportedly yield an average of 0.2 Mgal/d (million gallonsper day) (Stearns and Wheler, 1966, p. VI-72). A discharge froa the springsin the sand aquifer was calculated from the equation:
Q = KiA
where: Q * total discharge, in Mgal/d;K • hydraulic conductivity of sand aquifer, in ft/d (feet per day);i - hydraulic gradient, In ft/ml (feet per mile); andA • cross-sectional area of the aquifer, in ft2 (feet squared).
The discharge of the springs would range from 0.014 to 0.14 Mgal/d, ascalculated from (1) horizontal hydraulic-conductivity values of 18.4 and 21ft/d (Dunn Ceoscience, 1985 and 1984, respectively), (2) hydraulic gradientsof 0.0123 and 0.0015 (Dunn Geoscience, 1984, 1985) for an area 1.5 milessoutheast of the village water supply, and (3) a lineal seepage face of 1,400feet and an assumed saturated thickness of 55 feet*
The veils reportedly are pumped at a rate of 0.65 Mgal/d or 450 gal/min(gallons per minute) (George Conyea, South Glens Falls water-treatment plantoperator, oral comnun., 1986) during the summer only. Pumpage was firstrecorded In May-August 1986, during which time an average of 0.65 Mgal/d vaspumped. The wells were pumped from 12 to 165 hours each month (George Conyea,oral comnun., 1986). Whether the pumping vas continuous or intermittent isuncertain. A veil-capacity test conducted in 1968 (Rist-Ftost Associates,1968) indicated that the bedrock aquifer has a specific capacity of 5(gal/mln)/ft (gallons per minute per foot) of drawdown and a calculatedtransmissivity of 3.2 s 10* to 4.3 x 106 ft3/(ft/d) (feet cubed per foot-day).Well logs indicate that 165 feet of shaie vas penetrated. On the assumptionthat the shale is the aquifer that is being tapped, the horizontal hydraulicconductivity of the shale can be estimated from the equation:
T - Kb
i
350
300
£u.O
§U 250
ofc
A'
(9_l
I 200
150
100
Report od staticwater levelin bedrock
Confining layer'•=35 fost thick
Bedrock. Sadroci.
<D 1000 2000 1000
COO 1000 METERS
VERTICAL EXAGGERATION HBO
Figure 2o~-Geologic oectioo A-A' through Village o? South Clcao Poliowater-supply area, (Location chovn in fig0 1.)
where: T = aquifer transmisiivity, in ft2/d;X = hydraulic conductivity, in ft/d; andb « saturated thickness of the aquifer, in feet.
then: T/b
Fros sn assumed saturated thickness of 165 ft (drillers' legs «5d fig. 2), andthe two reported transmissivities of 2,250 and 2,974 ft2/d (Rist-Froet,Associates. 1968), the horizontal hydraulic conductivity of the shale wouldrange fron 14 to 18 ft/d. Horizontal hydraulic conductivity of fracturedshale generally ranges frota 0.001 to 0.00001 ft/d (Heath, 1983); thus, theestimated transmlosivity range of 14 to 18 ft/d would appear at least 4 to 6orders of magnitude too large. One reason say be that bedrock is exposed inthe river about 1 aile downstream and, according to well logs of the supplywells, is at most 20 feet below the river bottom near the wells, which wouldallow direct infiltration from the river. Data are insufficient, however, todelineate the cone of depression generated by pumping of the wells or todescribe the extent to which pumping Induces river water to enter the aquifer,or to predict the effects of pumping on discharge of the springs.
550 r
tx _
'o
5|O 300
1O
250
I
&atO
200BOO
Bedrock unit notdifferimtictod in
^•v i
Projected 3% dip to thesouth (from Fiarwr 1985)
0 1000 3000 MOO METe—^_i—L
Glens Fellstime»ton«
1000 METERS
VERTICAL EXAGGERATION K80
Figure 3.—Geologic section B-B' through Village of South Cienawater-supply areso (Location shown ia figo Io)
The rough calculations of seepage free the springe end the transiaissivitynd hydraulic conductivity of the ghale aquifer near the supply wellsassuming infiltration from the river to the aquifer) indicate that the rangesgiven in consultants' reports for the discharge of the springs and for a"safe0 yield for the wells are reasonable.
Quantity Used by Village
Water demand by the Village of South Glens Falls during She fall, winter,and spring is met by the 0.2-Mgal/d discharge from the spring-collectiongallery (fig. 1) and is supplemented during the summer by intermittent pumpingfroa the supply wells at a rate of 0.6 Mgal/d. Rough calculations based onseveral assumptions suggest that regular use of the wells could provide theadditional 0.03 Mgal/d of water for the 100 homes in the Town of Moreau.
QUALITY OF WATER
Too few chemical analyses of ground water from the springs and water-supply wells of the Village of South Glens Falls are available to predict theeffect of increased puaplng on water quality. Table 1 shows the ranges inconcentration of constituents measured in finished water1 at South Glens Fallsduring 1974-81. Only one set of analyses was available for water comingdirectly from the spring gallery and from the wells. For reference, the rangesia corresponding constituents found in Hudson River water during 1975 areiven. Some generalization of the water quality may be made from the fewalyses available, however*
A comparison of water from the supply wells with water from the springgallery (table 1) indicates that the well water is harder and contains lesschloride than the spring water; it also contains a significant amount ofhydrogen sulfide. (The spring water shows none.) The presence of hydrogeneulflde ia the well water is typical of water from the shale unit of the SnakeHill Formation (Fisher, 1985) and is probably derived from the pyrit® depositsia the shale.
The lack of data on major cations »nd anion© in well and spring waterprecludes determination of the relation between ground water and surface wateria the South Glens Falls water-supply area. The available data suggest,however, that if the wells are pumped at a rate necessary to satisfy the 100additional homes in Moreau, the effect on water quality of the two systemswill b« small. Hardness may be expected to Increase end chloride con-centration to decrease, as the ratio of well water to spring water increases,but this assumption is baaed on only one data set and is inconclusive.
the tsrs "f inishsd" vst»r applies to the vatsr that hsi passed throughthe public-supply treatment process and is delivered to the South GlensFails distribution systea. The trsstasr.t consists ef aeration aadchlorination.
Table l>~-Ccnc»ntratt»n* of selected ground-tutor end aurface-watereoaeUjuente at Scuta Cl»n» ?all», B.7.
(Ceaceatrallon* in aUIi«r«daihei Indicate au da ta . )
par liter.
Coociltueot
Aaaooia, aa H
•It rate aloamltrlte. aa H
CUori*,
Total hardavaa.aa CaCOj
Iron
Codle*
Total 41»«ol»«daollda
Mydrogee aulftde(free)
Muaiaii iunr atrialihcd vater Cleni Falla_,
(ranfe la (range la ''concentration daw vater, Oct. II, 1974* concent rat toe.
I97t-tll») Sprint (all«ry Supply «Ut 1975 vater }.er&)
e.00i-0.0» 9.05 0.94 0.14-0.8$
2.2-l.t 1.1 .1 .D-.S1
2*-40 SO 6.0 2.2-e.O
2B-SI 174 200 9-1J
.02-.!) — — .14-.M
14-lt — — l.o-J.J
— ~ — 4»-77
— ~ .J4« ~
• Fro* Mev York State Dapartaeat ef Health. inpubllaM racerta.• Proa B.$. Ceolo»lcal tunrej. 197*.' Proai Caorge Ccnyei. Vlllaf* *t louth Ciena falla. traatawat-ylant operator,
vrlttea eovaua.. III*.
CONCLUSIONS
No reliable estimate of the quantity of vater available from thePleistocene sand and underlying bedrock aquifers can be given because (1) toofew data are present to calculate the amount of vater available; (2) hydraulicproperties ouch as saturated thickness and hydraulic gradient of the sandaquifer are only inferred; (3) aquifer-pumping tests have act been dooe; and(4) data indicative of the hydraulic properties of the bedrock aquifer are notavailable. A report by Stearns and Vheler (1968) indicates that a "safe"yield!/ of 0.6 Ngal/d for the supply veils and an average discharge from thespring gallery of 0.2 Mgal/d would be within an order of magnitude of grosscalculated values that vere based on simplified assumptions of aquifer proper-tics.
The effect of increased pumping on water quality of the springs and thesupply veils cannot be predicted because too few water-quality data areavailable. Increased pumping for the additional 100 homes probably would notcause a uignifleant change in vater quality, however, if the treataent forhydrogen sulfide vere adjusted to compensate for the increased volume of veilvater withdrawn.
The term "safe0 yield is imprecisely defined but commonly used byconsulting firms to indicate the amount of water available forwithdrawal from a well on a regular basis = The reference is usuallyrelated only to veil diameter, type of screening, and amount ofdevelopment and rarely includes aquifer characteristics or variationsIn recharge.
REFERENCES CITED
Dunn Geoscience Corporation,, 1984, Reaedisl investigation of CE/Moreau sitsli-CERCLA-30201: Albany, N.Y., Dunn Geoscience Corporation, 2 v.^
' /-"
1985, Addendum—remedial investigation GE/Moreau site lll-CtRCLA-30201:"Albany, N.Y., Dunn Geoscience Corporation, 2 v»
Fisher0 S. H», 1985, Bedrock geology of the Glens Falls-Whitehall region,Blew York: Albany, N.Y., New York State Museun Map and Chart Seriestoo 350 58 p.
Heath, R. C., 1983, Basic ground-water hydrology: U°S. Geological SurveyWater-Supply Paper 2220, 84 p.
Rist-Froet, Associates, 1968, Village of South Glens Falls, Saratoga County,• New York—technical report for proposed water facilities: Glens Falls,N.Ye,, Rist-Frost Associates-Consulting Engineers, 58 p.
Stearns and Vheler, 1968, Comprehensive Intel-municipal public water supplystudy, Saratoga County, New York, No<> 6: Casenovia, N.Yc, Stearns andtfheler, Civil and Sanitary Engineers, p<> ¥1-66-73<.
UoSo Geological Survey, 1976, Water Resources data for New fork—Water Year1975: U.S. Geological Survey Water-Cat® Report NY-75-1, p. 359
(2fi
RESOLUTION OF NOVEMBER 20, 1985BOARD OP TRUSTEES OF THE VILLAGE pr
SOUTH GLENS FALLS, NEW YORK
WHEREAS, inquiry has been made of the Village of South
Glens Falls by representatives of the General Electric Company
concerning the capacity of the Village of South Glens Falls water
supply and the interest of the Village, if any, in selling water
to the Town of Moreau; and«
WHEREAS, it has been determined that the Village of
South Glens Falls can supply up to a maximum of 100,000 gallons
per day to the Town of Moreau; NOW, THEREFORE,
BE IT RESOLVED, that the Village of South Glens Falls is
willing to enter into an agreement upon terms and conditions to be
mutually agreed upon by the parties thereto to sell water to the
Town of Moreau up to a maximum of 100,000 gallons per day, and
BE IT FURTHER RESOLVED, that the Mayor is hereby
authorized to enter into negotiations with the Town of Moreau and/
or its representatives, including representatives of the General
Electric Company for the aforesaid purpose.
This resolution shall take effect immediately.
RESPONSIVENESS SUMMARY FOR THEGE MOREAU SITETOWN OF MOREU
SARATOGA COUNTY, NEW YORK
JUNE, 1987
Introduction
This Responsiveness Summary for the GE Moreau Site outlines keycommunity concerns regarding the Remedial Investigation/Feasibi-lity Study (RI/FS) Report and the proposed alternatives forsite cleanup. These public comments will be taken into consider-ation when the Environmental Protection Agency (EPA) makes itsfinal selection of the preferred Remedial Actions. The Respons-iveness Summary is prepared by the EPA to addresss these commentsand is incorporated into the Record of Decision, which statesthe selected Remedial Actions.
This Responsiveness Summary is divided into the following sections:
Section A: Background on Community Involvement and Concerns;This section provides a brief history of communityrelations activities conducted by the EPA duringthe RI/FS.
Section B: Summary of Major Questions and Comments ReceivedDuring the Public Comment Period and EPA Responses;This section summarizes significant questionsand comments made to the EPA during the publiccomment period, including the public meeting ofSeptember 19, 1985. Comments with the EPAresponses are categorized under separate topics.
A. Background on Community Involvement and Concerns
The GE Moreau Site, also known as the Caputo Landfill, is locatedin the Town of Moreau in northeastern Saratoga County, New York.Waste materials were scattered over approximately 30 acres ofthe site/ a portion of which included a small evaporationlagoon and drum disposal area. The evaporation lagoon waspreviously an open sand pit that was used for the disposal ofpolychlorinated biphenyls (PCBs). The drum disposal areaconsisted or approximately 100 drums and associated contaminatedsoil.
In 1978, town and state officials began testing the air, surface•_• •* ̂ ,**. •* ^ w t M > * i v % s < 4 * . * * « ^ s * t ^ -* v* s4 f x s t ^ l f\r* 3 *-» /^ »"» o ^> »" V Vt o S ^ ^ & •£ S*i^ v x s * i 0 0 ^ f * k l AW Cl U O L f M J L ^ U l l U W C & C O J L f d l lU O W A. J. Wi • Cl 1 lu I I C U A . W I A W O A \.O ^ W A. ^/WdO*.*^.*.*—
PCB contamination. The evaporation pit was covered in May 1979.Also, several barrels of liquid PBC and some PCB-contaminatedsoils were removed from the site.
-5-
(1) Comments from the Town Board of the Town of Moreau;(2) Verbal comments expressed at the public meeting of
September 19, 1985; and(3) Written comments submitted to the EPA during the comment
period. " •'
1. Comments From the Town Board of the Town of Moreau
The Town Board had requested that the EPA require either a new,modified, or amended RI/FS Report to address relevant concernsand to comply with certain requirements of the Superfund act.The Town Board felt that the RI/FS Report was inadequate inthree areas: the provision of alternative water supply sources,the definition of the contaminated area, and the restoration ofthe aquifer.
The EPA, however, is completely satisfied with the results ofthe RI/FS Report and adopts it as conclusive. The report meetsthe requirements of the Administrative Order between GeneralElectric and the EPA. At this time, the EPA does not intend torequest that General Electric modify or amend its reports.However, as a result of a meeting held at the Town's request onJune 17, 1986, the EPA did direct General Electric to installpiezometers in the area between the GE Moreau site and theJamaica Avenue/Nolan Road areas of town.
GE, through its consultant, Dunn, installed seven additionalpiezometers, as directed. Water level measurements obtainedfrom the additional piezometers confirmed the existence of thegroundwater mound west of DGC 15, and thus enforced the conclusionthat DGC 15 locates the western-most edge of the contaminantplume.
Topic; Alternative Water Supply Provisions
Issue: The Feasibility Study Report does not adequatelyaddress alternative water supply provisions or thesource(s) of such water supply. Also, the reportdoes not address items of concern such as waterquality, water quantity, costs, and water pipesize. It therefore did not meet the requirementsof the Superfund Act.
Response: The Feasibility Study Report does mention alternativewater supply sources on pages 66 and 78. The sourcesof water are the public water supplies of the Townof Moreau and the Village of South Glen Falls.Public water supplies in New York State are regulatedby the New York State Department of Health; thesesources of water meet the quality standards^
The pipe sizes identified in the Regional WaterSupply Evaluation Report (Short/Long Term Alter-
-6-
native No. 2A) for the General Electric Company inApril 1984 are consistent with the pipe sizes out-lined in the Town of Moreau Water Service Comprehensive
' '
The Feasibility Study Report does meet the require-ments as stated in the National Contingency Plan(40 CFRf Section 300 . 68 ( a)-( j ) , because it doesevaluate (1) technical feasibility (2) publichealth (3) institutional requirements (4) environ-mental effects (5) cost evaluation and (6) comparisonof alternatives.
Issue: The Feasibility Study Report does not contain cost-estimates for the provision of an alternative watersupply. It also does not consider the capital,annual, and 30-year operation and maintenance cost.
Response: The costs are explained in the cost evaluation sect-ion in the report on pages 67 and 79. There are nofigures in the operation/maintenance of the waterpipeline because those costs are contained in usercharges.
Issue: It is not technically feasible to use either theTown of Moreau Water District No. 2 or the Villageof South Glen Falls as a source of water supply forresidences. Also, the water district in the Villageof Fort Edward does not have sufficient sourcecapacity to serve as a permanent alternative watersupply for the affected area.
Response: The EPA realizes that Water District No. 2 in theTown of Moreau has questionable available capacity.However, the Village of South Glen Falls has morethan enough water and is able to supply 100,000gallons per day. (Refer to attachment of resolutiondated November 20, 1985. Refer also to attachmentof Resolution dated February 27, 1986, reiteratingthat the capacity exists, but that the Village wasrescinding its offer to sell excess water forreasons other than quantity. Finally, refer to theQuantity and Quality of Water From Public-SupplyWells and Springs in the Village of South GlensT^ — . 1 1 — M —> . - \7 A »» 1. T Q O * 7 / M G f^ C S . ^ T T ' t r ^ ^ — £• ~ — •S-^'Tii "B A r%.—; ~ ?- *£ c* .*. JL ̂ jr 1*4 w« i "i«/i. r» ^ ^ ̂ ̂ : \vO*%jo ^~*^iii» ̂ • • * M J > V . A . M W A V N « > A V ^ V ^ / ^ ^ L W / ^
confirming that the supply can be utilized toprovide potable water to the 100 or so homes in thecontaminated area.) The EPA does not believe that270 homes are effected by the plume: it is likelythat the number of homes that may be potentiallyimpacted is closer to 120 homes. General Electric'sFS does not propose to tap the Village of FortEdward's water supply.
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Issues The 1100 acres of land affected by the plume willbe subject to sparse development or no developmentat all because of the limitations imposed by usingthe municipal water supply of the Village of" SouthGlens Falls.
Response: General Electric has offered (as indicated in theFeasibility Study Report) to provide public waterfor future development.
Issue: Supplying outside water to the homes in the plume-affected area will cause additional contaminantflows in the direction of the South Glen Fallswells.
Response: General Electric investigated whether the drinkingwater wells in the Cheryl, Terry, and Myron Roadarea could possibly affect the contaminant plume.The results of that investigation did not show suchan effect. General Electric has performed anadditional investigation to determine whether theaddition of imported water to the area of theaquifer could have an effect. The EPA believes thatany effect is negligible.
Issue: The Feasibility Study Report failed to include fireflow capacity in the alternative water supply costestimates.
Response: The EPA does not discuss fire flow capacity becausethis area of the town did not have provisions forsuch service before the GE Moreau site. If thetown desires fire protection capability in thearea, that issue may be included in discussionsbetween the Town and General Electric.
Issue: The Feasibility Study Report failed to evaluate indetail at least one alternative water supply thatdoes not involve connection with an existing municipalwater district.
Response: Such an alternative was not evaluated because itwould exceed the costs of connecting with an existingwater supply. However, the EPA may allow the construc-tion of a new public water supply if all existingsupplies could not supply water to the plume-impactedarea.
Issue: The Feasibility Study Report does not identify thenumber and location of the residences included inthe proposal for a water distribution system.
Response: Everyone in the Cheryl, Terry, and Myron Road areaand in the Bluebird Road area will be tied into the
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water system- Refer to the Feasibility StudyReport and the Short/Long Term Alternative No. 2Ain the Regional Water Supply Evaluation Report forGeneral Electric, dated April 30, T984.
Topic; Contaminated Area Definition
Issue: General Electric failed to adequately define thearea affected by the contamination from the GEMoreau site and to scientifically justify itsdefinition of the affected area.
Response: General Electric addressed this in both versions ofthe Remedial Investigation Reports--0ctober , 1984and March, 1985. Refer to plate 12 of the October1984 Remedial Investigation Report (along withplates 6, 7 and 8) and to plates 4, 5, 6, and 7(groundwater table countour maps) of the March1985 Remedial Investigation Report for discussionof groundwater flow and contaminant locations. Also,refer to the text of both reports. The area wasfurther defined in EPA's review of the RI Reports.Finally, refer to EPA's February 7, 1987, letter tothe Town of Moreau.
Issue: The RI/FS failed to identify the location and theextent of contamination in the plume because GeneralElectric's consultant used 30-foot-long screens onits monitoring wells.
Response: At each monitoring well location, General Electricinstalled three monitoring wells — one shallow, oneintermediate, and one deep — with 30-foot-long screensThe reason for this was to intercept every depth ofthe aquifer at that location to determine the loca-tion of the contaminants. Water analyses conductedto a detection limit of one part per billion servedas an indication of either the presence or absenceof contaminants at every location and elevationwithin the aquifer.
The depiction of contamination by isoconcentrationlines in plate 12, Dunn Report, 1984, shows thedetectable limit of TCE. Although 100 ppb was theoutside countour drawn, concentrations were non-detect at very short distances (less than 100 feet)fro!?, the 100 ppb line in most xcept in tCheryl, Terry, Myron area, where concentrationsrange from extremely small to non-detect, and whicharea will be provided, as a precautionary measure,with potable water. EPA believes that the plume isaccurately defined by the data generated by Dunn,and that concentrations for the major part of theplume are restricted very closely to the area
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depicted by the 100 ppb contour. It should benoted that plate 12 depicts wells outside, of the100 ppb contour, and lists the levels of contamin-ation detected at those wells.
Issue: The RI/FS failed to identify the exact locationand the extent of the contaminatant plume becauseof the exclusive use of TCE as an indicatorchemical. Also, if TCE was not detected insamples taken from a particular residence, thenthe well at that residence was not counted ascontaminated.
Response: Incorrect. General Electric conducted samplingand analysis of all monitoring wells and allpossibly affected drinking water wells for 50purgeable organics and PCBs. This analysisincludes approximately 50 priority pollutants.TCE was the predominant contaminant appearing inthese analyses.
Issue: The RI/FS failed to demonstrate that there is noevidence of radial flow of the plume toward thewater supply wells of the Village of South GlensFalls.
Response: The RI Report defined the plume as moving in asouth, southeasterly direction and not in anortherly direction toward the South Glens Fallssupply wells. The supply wells for the Villageof South Glens Falls are upgradient from thesite; in addition, there is a naturally occuringgroundwater mound north of the site that is alsoupgradient. In order for contamination to reachthe South Glen Falls supply wells, the groundwaterwould have to overcome the groundwater mound andthe regional groundwater flow pattern, which isin a southerly direction. Both situations arehighly unlikely to occur.
Issue: What is the possibility of contaminants travelingfrom the plume to the deep wells used by SouthGlens Falls through the extensively fracturedrock in which the wells are located?
Response: The GE Moreau Site is underlain at a depth ofapproximately 100 feet by a minimum of 13 feetof a naturally occurring clay layer. The slurrywall around the site is keyed into this claylayer and is, therefore, a separation betweenthe waste material and the fractured bedrock thatin which the Village of South Glens Falls wellsare located.
C
u
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Issue: There have been no monitoring wells or other teststo determine whether contamination exists "in. thegroundwater flowing into the Fort Edward watershedin and around the Reardon Brook area.
Response: Among others, monitoring well DGC 13 is located inthe Fort Edward watershed. This well has notshown any contamination.
Issue: General Electric failed to generate a working modelof the groundwater aquifer that has been contaminated.
Response: Failure to develop a working model is not relevantin this situation. The model would be used only tosimulate field conditions, and we feel that GeneralElectric has fully defined actual field conditions.
Topic: Aquifer Restoration
Issue: General Electric failed to adequately address therestoration of the aquifer that has been destroyedby the contamination.
Response: The EPA is requiring General Electric to provide analternative water supply to areas that currently donot show signs of contamination but may show signsin the future, i.e., the Cheryl, Terry, and MyronRoad areas. Although aquifer pumping is not requiredat this time (due in part to concern over alteration'sin groundwater flow patterns which may result in lossof water to the Fort Edward Water Supply), aquiferresoration should ultimately be accomplished by naturalforces. Furthermore, since the aquifer is beingtreated at its point of discharge analysis indicatethat additional aquifer treatment would not be cost-effective.
Issue: The Feasibility Study Report rejects the pump andrecharge alternative for aquifer restoration becauseof cost factors.
Response: Source containment is included in the pump andrecharge alternative. The separate cost for sourcecontainment is $2.3 million; the cost for pump andrecharge is $5. / million. PtuviCi i r iy an a l ternat ivesource of water via a pipeline is a more cost-effective solution than pumping and recharging theaquifer. In addition, the aquifer is being treatedat the Reardon Brook Water Treatment Facility. TheNational Contingency Plan requires the most cost-effective solution. Furthermore, as explained above,such pumping and recharge may result in loss of waterto the Fort Edward Water Supply.
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Issue: The construction of a water treatment plant utili-zing the Hudson River in the Town^of Moreau- shouldbe considered as an alternative ih "the. Feasibilityfii-..^.. rt>*n_uA_o u u u y rvcyui. v. o
Response; General Electric is not required to consider thisapproach, which would be considerably more expensivethan the solutions already proposed. It is, therefore,not cost-effective, as required by the NationalContingency Plan.
2. Verbal Comments Expressed at the Public Meeting of September19, 1985
The following comments were made by citizens at the public meet-ing. Robert Buttles, Sr., and Elizabeth Wimette served asrepresentatives of the Citizens of Moreau Against Contamination(COMAC).
Topic; Technological Concerns
Issue: With regard to the air stripping remedy, does thatmean that contamination would be released into theair?
NYSDECResponse:
Issue:
Response:
The air stripper itself, when that was proposed tobe put in by EPA, the State Health Department, andthe DEC, was to require an air permit. The opera-tion of an air stripper does involve air emissions,if you will. General Electric applied to ouragency through our regional office and received apermit to discharge into the environment withincertain limits, given that kind of loading rate.General Electric was issued the permit; the airstripper has been tested and is in compliance withthe operating certificate from the Division ofAir. So yes, the air stripper is putting thingsin the air, but General Electric has a permitallowing for the operation of the air stripper.
What were the houses affected by when General Elec-tric determined the plume of contamination? Wereyou looking for one chemical?
No. We dictated to General Electric that those areall the homes that should be addressed as needinga remedy. We weren't looking for one chemical.There is a whole list of volatiles that we askedGE to test for, primarily in newly installedmonitoring wells in the area.
-12-
Issue: On page 15 of the Feasibility Study Report, couldyou comment about the concern that the Town Boardexpressed in regard to the small-sized pipes,which do not include an accurate flow capacity?The report tends to give the feeling that the pipesize is substandard in terms of its capacity.
Response: We were concerned about the size of the pipes, andwe want to check that out. One of the other itemsof interest that we tried to check out with GeneralElectric was hook-ups to individual homes, becausethat's not delineated in the report. GeneralElectric agreed to the hook-ups; they agreed toput in pipes that could handle a full-size waterdistrict. It's not a pipe that would only be ableto handle particular homes.
Topic; Administrative Concerns
CitizenComment: I would agree, as it has already been phrased, that
the Feasibility Study Report should be modified oramended. I don't feel that it needs a great dealof extensive research to amend it, but the peoplehave waited long enough. We need water and we needit quickly.
Issue: Was an environmental impact statement (EIS) done?
Response: A formal EIS was not done on this site; the primaryreason from the department's office of counsel wasthat this action is being conducted pursuant to anenforceable document. We have the State Order onConsent and the General Electric/U.S. EPA (FederalSuperfund) CERCLA Order. The substantive require-ments for what we consider in the environmentalimpact analysis were complied with by GE in itsapplication to our agency.
Issue: According to this, GE failed to define the affectedarea. When will that be done? And when will weknow what is considered to be the affected area?How will EPA deal with that?
Response: There was an opportunity under the Remedial Inves-tigation for GE to define the affected area. Thefirm limited itself to Bluebird Road at the time,with some westerly migration. We pushed thatwesterly migration even further to Cheryl, Terry,and Myron Roads. So, in effect, we defined thearea for General Electric, and that area willinclude all of the houses in the area.
Issue: Do you know actually which homes General Electricplans to hook up to those pipes?
-13-
Response: Ail of the homes in the area—Cheryl, Terry, and MyronRoads and down to the school. If this is-the mandatedalternative and if the Town Board approves it, or somefacsimile of it, there will be a design report thatwill specify individual homes in the area. TheFeasibility Study Report is not really a designdocument; it is a scoping document to look at altern-atives.
Issue: Approximately how many homes are we talking about?
Response: About 60-70 homes, counting Bluebird Road.
Issue: When you say counting Bluebird, what do you mean bythat?
Response: I mean counting homes on Cheryl, Terry, and MyronRoads. Maybe 80 homes altogether.
Issue: What kind of time frame are we looking at?been waiting for 3 years.
We' ve
Response: If this document goes through, with no further workon it, there's no reason why work should not begin amonth from the signing of the document on September29, 1985.
NYSDECResponse: Realistically, you are talking around the first of
the year.
Issue: Who gets to choose where we get the water from?
Response: That is included as part of the proposals in thereport. EPA will recommed where the water shouldcome from or whether General Electric should go backand look at other alternatives taking into consider-ation your comments here tonight.
Topic; Health Concerns
Issue: I'm very concerned about the sampling. Analysis ofthe sampling performed by NUS revealed so manychemicals, yet with the samples from Dunn GeoScience,my well has always been clean.
Response: We were concerned also with the differences in data*We had our own labs do the recent samples because wewere wondering about that inconsistency, which weexplained to you last time. That's why we had themturned around so quickly to see whether there was any
IC
particular problem, whether Dunn GeoScience was infact toeing the line as they should. Our mostrecent samples are from NUS. The samples _are sentout to contract labs. The EPA contracts a wholehost of labs, as they can't do all-'ttte analyses ontheir own. Even though those other labs arebacked up, we'll see what we can do regardingthose NUS samples.
3. Written Comments Submitted to the EPA During the Comment Period
The EPA received letters from the Citizens of Moreau AgainstContamination (COMAC); the New York State Department of Environ-mental Conservation (NYDEC); the law firm of Pattison, Sampson,Ginsberg, and Griffin, P.C.; Congressman Gerald B. Solomon;and Frank J. Kottman of South Glens Falls.
0 Robert Buttles, Sr., and Elizabeth Wimette, representativesof the COMAC citizens' organization, expressed concern overalternative water supplies, regarding their availability,quality, and cost, as well as fire protection capability.They suggested that the Town of Queensbury be considered asa source for an alternative water supply. It was alsorequested that Mr. Frank Hardick, engineer for the Town ofMoreau, act as the lead agency responsible for final construc-tion procedures, so that construction would be compatiblewith a final comprehensive water system implemented at alater date.
The EPA has previously addressed the issues related to thealternative water supply in this Responsiveness Summary.The Town of Queensbury was not considered as a source ofalternative water in the Feasibility Study Report but theQueensbury supply is considered in the Record of Decision.Also, General Electric is responsible as the lead agency forconstruction procedures. However, the Town of Moreau mayutilize Mr. Hardick as its advisor.
0 Mr. Gerald H. Katzman, representing the law firm of Pattison,Sampson, Ginsberg, and Griffin, P.C., submitted a letteroutlining the following concerns. The Feasibility StudyReport does not acknowledge that the plume has affected theCheryl, Terry, and Myron Roads area. Specifically, technicalevaluation of the plume is not believed to be precise in termsof its location and identification of contaminants. (Tosupport this claim, a deposition of Mr. Theodore Clark,division director and senior hydrologist with the DunnGeoScience Corporation, was attached to the letter,,)
The EPA believes that the Remedial Investigation Report didaddress these concerns. The EPA has previously addressed this —issue in this Responsiveness Summary. £
€i
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* The NYDEC requested that a permanent water hook-up to theMoreau Elementary School be included in the alternative watersupply alternative. The DEC also felt that general Electricdid not adequately address the aquifer restoration issue,specifically, with regard to the pumping and recharge altern-ative.
The EPA believes that General Electric did adequately addressthe issue of aquifer restoration because G.E. has agreed tosupply alternative water for homes in the affected area andalso for any future development in the plume affected areaand because aquifer restoration presents potential negativeimpacts and is not a cost-effective remedial action in thissituation. EPA's letter of September 25, 1986, explainsthat the plume does not extend as far west as the schoolbuilding. General Electric will not be ordered to hook upthe school to the alternative water source. It will beordered, however, to continue monitoring for at least thirtyyears, in orded to ensure that the size and shape of theplume does not change over time.
In addition, EPA will review the selected remedy no less theneach five years after implementation begins. EPA has theauthority to require additional corrective measures if itfinds that the remedial action is not protective of humanhealth or the environment.
0 Congressman Gerald B. Solomon, representing the 24th Districtof New York, requested that the EPA "act expeditiously andin a manner favorable to the residents of the town by selectingan alternative water supply that provides immediate yetpermanent relief to the entire affected area without undueadded cost to the property taxpayers of the town."
0 Mr. Frank J. Kottman of South Glens Falls requested an expla-nation as to why he is not eligible for a water hook-up; hishome is only 42 feet from the access to the entrance roadleading to the dump site.
The EPA stated that the plume is downgradient of his houseand, therefore, his water supply is not affected by the plume.The plume is moving in a south, south-easterly direction, andMr. Kottman's residence is located east of the site.
6o
CLERKS CERTIFICATION
I, Joyce M. Leombruao, Clerk ef the Board of Trustees of
the Village of South Glens Falls, Saratoga County, New York, do
hereby certify that the foregoing is a true copy of a Resolution
duly adopted by the Board of Trustees of said Village on the
20th day of November, 198S.
IN WITNESS WHEREOF/ I have hereunto subscribed my name
and affixed hereto the official seal of said Village of South
Glens Falls, this 20th day of November, 1985.
r,oCR(A
•VRESOLUTION OF AUGUST 6, 1986OF THE BOARD OF TRUSTEES OP THE
VILLAGE OF SOUTH GLENS FALLS, NEW YORKRESCINDING RESOLUTION OF NOVEMBER 20, 1985
WHEREAS, the Board of Trustees of the Village of South Glens\\Falls, New York, on November 20, 1985, adopted & Resolution wherein it
was stated that the Village of South Glens Falls has excess water
supply, which the said village would be willing to sell outside the/
Village to the Town of Moreau up to 100,000 gallons of water per day;
and\
WHEREAS, upon further consideration of the matter by the Board of
Trustees it has been determined that it is not in the public interest
to sell water to the Town of Moreau pursuant to the request of the
General Electric Company,
NOW, THEREFORE, BE IT RESOLVED that the Resolution of November 20,
1985, is hereby rescinded; and
BE IT FURTHER RESOLVED that water for sale to the Town of Moreau
pursuant to the request of General Electric is no longer available.
This Resolution shall take effect immediately.
.U*.'!.*»••«*•><
OO)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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:o br inM vou u:1* to dsto o^» the nr. ' -Af ' -v i ^ursct*1^.^ "ito. T^ /-r l f j c t r i c Co^nanv ( C L " ) his narfor^'*^ a r >e > ' ' ^ - ' J f l l Inv?^ t i •-,?. *. i
.o* t'">cj sit.? ;>urs'Jtnt to the j a t ion^ l oil arv.i !ia?:ar ''.fB.; s cu^.? t*»'i-r-'»c-rr>rt iriar.cy P l a n , to i '>n t l fv th? nature Pn'1. extent ^ ir ):ir>^', >f ->«-con t-v.i n a t i o n 9 -» fn r t i -T i f r t / n tii-i GT -lors«.ij sit« j. T'T^ w>^t - .» r l \ 'c»1'-;J» "-f the urounlw-Ttcr rent a^rn.^t inn ^lu-r-e hs«5 ^OM i ^ervi- ! f i •.-:' * r.—}r>it<->r in.-« woll HC-C IS nortn S3-
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to cont inue tf> monitor the Trovmf3'.»ati!>r nlu"y> ^or at loa^iinto the fut ' jr<* to assor*? t h n t tno size anrj Rr,.">-"^ of t . i -
nlu-.o <"-coa not chan^t? ovor t i^a.
"«o ar<=? no-)' «t the point of hiivinn GV install water r.i.ir>r>ly -inins
\ f i \ \ bf instal led on Mvron Pond, Torry Privr? , Chorvl ^r ivn, anri'Oue' ' irO ",o*r!« In fact, ^T A'C-t < j i th the *'%c'<"^ on 'To^to-ner 1?, 1 '•;to ')<nin plans for tho vator -lain i natal Jat ion.
»T your concorn ovor *\\to connect to th»s"> wat«»r ^«.irs, PP» .»? rrojert: o f f i ce r , "r. '->>-a^.h«r? ?lroa"'y f'iBcus^oc' th is vit '^ Cr ?f,l Ji?t -~»<* »spuro you th*t r.'.na connect, ion can be «»»^e ( > of course tv> school r-i strict v ? i l ] Jv:
'•-'' to O9V for inst.1;!tinT tN:> %;?itcr l i^o fro~! tho P
OFFICIAL FILE CO«*Y
• L . S . GPO 19H-«f-'*3
To cot-^ir . art-ii t ior.iJ J. ir. f ~ji" .-, ̂ ti ;r. •"»-. t '^e s c n-* 1 u 1 2 tor i r .srall ^t ict tlio wat-au ;rair.s, 'jit?^r>e contact 'L-. V. L'^o Col i ins , ^Mar.a ier ,t r .vivors^er. tal Q u a l i t y & •"5?souz.'cr> r i . ^ n n i r . i , C-^r^r^ 1 Elec_t-ricCo- ii jar./ at ( r > H ) 3J5-9 'J : ) .n oz: Mr. CaL-;!r.^r Cor.r,;Jo-» Supervisor,
r. of loi-o 3 u at ( " > ! _ ' ) 7 J j - l ) 3 ; j . :. ;: '
1 t rus t tna t tli^ s ->ovr? i r. f oi-nat ior. is ro.^r-or..s i ve to your cor.corr::
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C.'ir J 3 t r > p n « r J.Reg iona l - A d m i n i s t r a t o r
cc: Henry G. '..illians, CYork State Deo^i'tttpnt of
Envi ronmenta l Cor.servat jor.
.ir. T. Leo Coll ins, Mijr.viror.mer.tal Q u a l i t y & »<->source P l a n n i n g
'Jeneral Elect r ic Company
Mr. Gardner Conqciorj, SuoervisorTown of Moreau
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