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Home My WebLink About20240682 25 New St Subdivision NYSDEC Environmental Remediation #546052 12102025Department of Environmental Conservation Division of Environmental Remediation Record of Decision Sharon Cleaners Site Saratoga Springs, Saratoga County, New York Site Number 5-46-052 March 2009 New York State Department of Environmental Conservation DAVID PATERSON, Governor ALEXANDER GRANNIS, Commissioner DECLARATION STATEMENT -RECORD OF DECISION Sharon Cleaners Inactive Hazardous Waste Disposal Site Saratoga Springs, Saratoga County, New York Site No. 5-46-052 Statement of Purpose and Basis The Record of Decision (ROD) presents the selected remedy for the Sharon Cleaners site, a Class 2 inactive hazardous waste disposal site. The selected remedial program was chosen in accordance with the New York State Environmental Conservation Law and is not inconsistent with the National Oil and Hazardous Substances Pollution Contingency Plan of March 8, 1990 (40CFR300), as amended. This decision is based on the Administrative Record of the New York State Department of Environmental Conservation (the Department) for the Sharon Cleaners inactive hazardous waste disposal site, and the public's input to the Proposed Remedial Action Plan (PRAP) presented by the Department. A listing of the documents included as a part ofthe Administrative Record is included in Appendix B ofthe ROD. Assessment of the Site Actual or threatened releases of hazardous waste constituents from this site, if not addressed by implementing the response action selected in this ROD, presents a current or potential significant threat to public health and/or the environment. Description of Selected Remedy Based on the results ofthe Remedial Investigation (Rr) and the Soil Vapor Mitigation Evaluation memo, which compared remedial action alternatives for the Sharon Cleaners site and the criteria identified for evaluation of alternatives, the Department has selected installation of vapor mitigation systems at structures determined to be impacted by soil vapors. The components of the remedy are as follows: 1. A remedial program will be ~mplemented to perform the necessary construction, operation, maintenance, and monitoring activities required for the installation of three Vapor Mitigation Systems (one on-site and two-off site). Basement conditions will be upgraded at two off-site structures to address cracks. 2. Imposition of an institutional control in the form of an environmental easement that will require (a) restricting the use of groundwater as a source of potable or process water, without necessary water quality treatment as determined by NYSDOH; and (b) the site property owner to complete and submit to the Department a periodic certification of institutional and engineering controls. i 3. Development of a site management plan which will include the following institutional and engineering controls: (a) monitoring of sub-slab soil vapor and indoor concentrations at two additional structures, identified as AS-I and AS-10, which had levels that did not warrant mitigation will be monitored for a minimum of three years; and (b) provisions for the continued proper operation and maintenance ofthe components of the remedy. 4. The site property owner will provide a periodic certification of institutional and engineering controls prepared and submitted by a professional engineer or such other expert acceptable to the Department, until the Department notifies the property owner in writing that this certification is no longer needed. This submittal will: (a) contain certification that the institutional controls and engineering controls put in place are still in place and are either unchanged from the previous certification or are compliant with Department-approved modifications; (b) allow the Department access to the site; and (c) state that nothing has occurred that would impair the ability of the control. New York State Department of Health Acceptance The New York State Department ofHealth (NYSDOH) concurs that the remedy selected for this site is protective of human health. , Declaration The selected remedy is protective of human health and the envirorunent, complies with State and Federal requirements that are legally applicable or relevant and appropriate to the remedial action to the extent practicable, and is cost effective. This remedy utilizes permanent solutions and alternative treatment or resource recovery technologies, to the maximum extent practicable, and satisfies the preference for remedies that reduce toxicity, mobility, or volume as a principal element. MAR 3 2009 Da e A. Desnoyers, Direc Date Division of Environmental Remediation ii T ABLE OF CONTENTS SECTION PAGE 1: SUMMARY OF THE RECORD OF DECISION 1 2: SITE LOCATION AND DESCRIPTION 1 3: SITE HISTORy 2 3.1: OperationallDisposal History 2 3.2: Remedial History : 2 4: ENFORCEMENT STATUS 2 5: SITE CONTAMINATION 3 5.1: Summary of the Remedial Investigation 3 5.2: Interim Remedial Measures 5 5.3: Summary of Human Exposure Pathways: :6 5.4: Summary of Environmental Assessment.. 6 6: SUMMARY OF THE REMEDIATION GOALS 6 7: SUMMARY OF THE EVALUATION OF ALTERNATIVES 7 7.1: Description of Remedial Alternatives 7 7.2: Evaluation of Remedial Alternatives 9 8: SUMMARY OF THE SELECTED REMEDy 10 9: HIGHLIGHTS OF COMMUNITY PARTICIPATION 12 Tables Table 1: Nature and Extent of Contamination 13 Table 2: Remedial Alternative Costs 14 Figures Figure 1: Location Map 15 Figure 2: Groundwater Flow Map 16 Figure 3: Soil Investigation Exceedances of Unrestricted Use Soil Cleanup Objectives for VOCs and Metals -May 2008 .... 17 Figure 4: Groundwater Investigation Exceedances for VOCs and Metals -May 2008 18 Figure 5: Schematics of a Vapor Mitigation System 19 Appendices Appendix A: Responsiveness Summary A-I Appendix B: Administrative Record B-1 iii RECORD OF DECISION Sharon Cleaners Site Saratoga Springs, Saratoga County, New York Site No.5-46-052 March 2009 SECTION 1: SUMMARY OFTHE RECORD OF DECISION The New York State Department ofEnvironmental Conservation (the Department), in consultation with the New York State Department of Health (NYSDOH), has selected this for the Sharon Cleaners. The presence ofhazardous waste has created significant threats to human health and/or the environment that are addressed by this remedy. As more fully described in Sections 3 and 5 of this document, site dry cleaning operations prior to 2001 have resulted in the disposal of hazardous wastes, including volatile organic compounds (VOCs), such as tetrachloroethene (PCE). These wastes have contaminated the soil, soil vapor, and groundwater at the site, and have resulted in: • a significant threat to human health associated with potential exposure to soil vapors. • a significant environmental threat associated with the current impacts of contaminants to groundwater by tetrachloroethene. To eliminate or mitigate these threats,the Department has selected installation ofvapor mitigation systems at structures determined to be impacted by soil vapors. The selected remedy, discussed in detail in Section 8, is intended to attain the remediation goals identified for this site in Section 6. The remedy must conform with officially promulgated standards and criteria that are directly applicable, or that are relevant and appropriate. The selection of a remedy must also take into consideration guidance, as appropriate. Standards, criteria and guidance are hereafter called SCGs. SECTION 2: SITE LOCATION AND DESCRIPTION The Sharon Cleaners site is located in an urban portion of Saratoga County, New York. See Figure 1, Site Location Plan. The site is located at the southeast corner ofthe intersection ofLincoln Avenue and Whitney Place. A one-story structure that covers approximately 2,200 square feet is located at the site and presently occupied by AJ's Wash and Dry Cleaners. The surrounding area is mixed commercial and residential. The nearest residential structure is located approximately 25 feet to the east. Soil borings were conducted during the site characterization and remedial investigation to a maximum depth of 27 feet below ground surface. Site geology consists of approximately 27 feet of brown fine to medium sand. Groundwater was encountered at approximately 16 feet below ground surface and determined to flow in a northeast direction, which is illus·trated on Figure 2. Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 1 SECTION 3: SITE mSTORY 3.1: OperationalJDisposal History The site has been used as a dry cleaning business for over 50 years. During this time Sharon Cleaners was in operation for approximately 22 years. In conducting a site audit for use in selling the property, the site owner discovered chlorinated volatile organic compounds, primarily tetrachloroethene (PCE), in the soil and groundwater in February 2000. Dry cleaning and spot removal processes are believed to have utilized PCE, which is a typical chemical used in the dry cleaning industry. Improper housekeeping is likely the cause of the environmental impacts. The current owner has been operating as AJ's Wash and Dry Cleaning at the property since 200 1. Current dry cleaning equipment utilizes a petroleum based dry cleaning agent, which is different from the chlorinated volatile organic compounds detected in the environment. 3.2: Remedial History In 2007, the Department listed the site as a Class 2 site in the Registry of Inactive Hazardous Waste Disposal Sites in New York. A Class 2 site is a site where hazardous waste presents a significant threat to the public health or the environment and action is required. • In February and March 2000, site investigations as part of a property assessment were conducted. • In 2000, the Sharon Cleaners owner entered into the Voluntary Cleanup Program to investigate and remediate the site. • In March 2001, the Volunteer, unilaterally installed and operated a soil vapor extraction system to address contamination detected at the site. • In November 2001, The Volunteer signed an administrative order on consent after the Department reviewed the respondent's financial data. The Department will undertake further remedial activities at the site. • In December 200 I,Department personnel located and sampled two ofthe five monitoring wells and indicated that the soil vapor extraction system was shutdown. • In September 2006, a State-funded site characterization was conducted. SECTION 4: ENFORCEMENT STATUS Potentially Responsible Parties (PRPs) are those who may be legally liable for contamination at a site. This may include past or present owners and operators, waste generators, and haulers. The PRPs for the site, documented to date, include: Mr. James Smalley (Sharon Cleaners) Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 2 In November 2001, after review of the PRPs financial data the Department determined that they were not financially viable to implement remedial activities at the site. The remedial activities were conducted with State Superfund money. SECTION 5: SITE CONTAMINATION A remedial investigation and alternatives analysis has been conducted to evaluate the alternatives for addressing the significant threats to human health and/or the environment. 5.1: Summary of the Remedial Investigation The purpose of the RI was to define the nature and extent of any contamination resulting from previous activities at the site. The RI was conducted between April 2008 and May 2008. The field activities and findings of the investigation are described in the RI report. Remedial investigation activities included the collection of environmental samples and soil vapor intrusion evaluations. Soil samples collected are illustrated on Figure 3. Groundwater samples collected are illustrated on Figure 4. Soil vapor intrusion evaluations were conducted at the site and at structures located in the vicinity of the site. 5.1.1: Standards, Criteria, and Guidance (SCGs) To determine whether the soil, groundwater, and soil vapor contains contamination at levels ofconcern, data from the investigation were compared to the following SCGs: • Groundwater, drinking water, and surface water SCGs are based on the Department's "Ambient Water Quality Standards and Guidance Values" and Part 5 of the New York State Sanitary Code. • Soil SCGs are based on the Department's Cleanup Objectives "6 NYCRR Part 375 Soil Cleanup Objectives Tables 6.8," dated December 2006. • Concentrations of VOCs in air were evaluated using the air guidelines provided in the NYSDOH guidance document titled "Guidance for Evaluating Soil Vapor Intrusion in the State ofNew York," dated October 2006 for tetrachloroethene using Soil Vapor/Indoor Air Matrix 2. • Background soil samples were taken from five locations. These locations were within the vicinity of the site, and were unaffected by historic or current site operations. The samples were analyzed for metals. The results of the background sample analysis were compared to relevant RI data to determine appropriate site remediation goals. Based on the RI results, in comparison to the SCGs and potential public health and environmental exposure routes, certain media and areas of the site require remediation. These are summarized in Section 5.1.2. More complete information can be found in the RI report. Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 3 5.1.2: Nature and Extent of Contamination This section describes the findings of the investigation for all environmental media that were investigated. As described in the R1 report, many soil, groundwater and soil vapor samples were collected to characterize the nature and extent of contamination. As seen in Figures 3 and 4 or summarized in Table I, the main category of site related contaminants that exceed their SCGs are volatile organic compounds (YOCs). For comparison purposes, where applicable, SCGs are provided for each medium. Chemical concentrations are reported in parts per billion (Ppb) for water and parts per million (ppm) for soil. Air samples are reported in micrograms per cubic meter (llg/m3). Figures 3 and 4 and Table 1 sUll?illarize the degree ofcontamination for the contaminants of concern in soil, groundwater and air. and compares the data with the SCGsfor the site. The following are the media which were investigated and a summary of the findings of the investigation. Surface Soil Seven surface soil samples were collected at the site from 0 to 12 inches below ground surface and analyzed for YOCs. These samples were located in the grassy areas at the north and south portions ofthe site. Figure 3 presents the analytical results and locations of. the soil samples. Based on the analytical results tetrachloroethene was detected up to 0.055 ppm, which is below the unrestricted use cleanup objective of 1.3 ppm. Elevated concentrations of metals were detected in the surface soils above unrestricted use at the site, as shown on Figure 3. Due to the sporadic detections ofthese metals, the contamination is considered to be representative of background conditions from fill material placed at the site and not a result of the dry cleaning activities conducted at the site since metals are not utilized as part of the dry cleaning process. No site-related surface soil contamination of concern was identified during the Rl. Therefore, no remedial alternatives need to be evaluated for surface soil. Subsurface Soil Nineteen subsurface soil samples were collected at the site and analyzed for YOCs. Thirteen soil borings, identified as B-1 through B-13, were completed to assess site soil conditions south and north of the facility. One soil sample was collected from each boring at depths ranging from 10 to 16 feet below ground surface based on visual observations or depth to groundwater. One shallow soil sample, 1 to 2 feet below ground surface, was collected beneath the pavement, identified as SS-I. Five sub-slab soil samples, identified as SS-6 through SS-1 0, were collected from 0 to 12 inches beneath the concrete slab in the vicinity ofthe dry cleaning equipment and former trench. Figure 3 presents the analytical results and locations of the soil samples. Based on the analytical results tetrachloroethene was detected up to 0.170 ppm beneath the structure and up to 0.029 ppm beyond the buildings footprint, which are below the unrestricted use cleanup objective of 1.3 ppm. The greatest concentration oftetrachloroethen~ was detected at 1.6 ppm beneath the concrete slab during the site characterization in 2006. Tetrachloroethene detections are minimal in concentration and extent, which indicates that a source of tetrachloroethene was not identified during the investigation due to discontinued use oftetrachloroethene at the dry cleaning facility, operation of the soil vapor extraction system under the Y oluntary Cleanup Program and natural attenuation ofsite contaminants over time. Sharon Cleaners -Site No. 5-46·052 March 2009 RECORD OF DEcrsroN PAGE 4 Elevated concentrations ofmetals were detected in the shallow subsurface soils above unrestricted use at the site, as shown on Figure 3. Due to the sporadic detections of these metals, the contamination is considered to be representative of background conditions from fill material placed at the site and not a result of the dry cleaning activities conducted at the site since metals are not utilized as part of the dry cleaning process. No site-related subsurface soil contamination of concern was identified during the RI. Therefore, no remedial alternatives need to be evaluated for subsurface soil. Groundwater Twelve groundwater samples were collected and analyzed for YOCs. These samples were collected from ten monitoring wells and two temporary wells located within 30 feet of ground surface. Six samples were collected at the site and six samples were collected from off-site locations that are considered either up gradient, down-gradient or side gradient. Figure 4 presents the analytical results and locations of the groundwater samples. Based on the analytical results tetrachloroethene was detected up to 24 ppb at MW 11, which is above the groundwater standard of 5 ppb. The low level contamination appears to be originating from the site and naturally attenuates within 400 feet of the site. Groundwater contamination was detected during the RI at concentrations marginally above groundwater standards. Therefore, a groundwater usage restriction is necessary, but an evaluation of groundwater remedial alternatives is not warranted given the low contamination levels and lackof a source area to remediate. Soil Vapor/Sub-Slab Vapor/Air Ten structures in the vicinity of the site were evaluated to assess the soil vapor intrusion pathway. An indoor air sample and a sub-slab vapor samples were collected from each structure and analyzed for YOCs. Analytical results were compared to ambient air levels, building questionnaires, and reported background values for residential structures. Table I surnrnarizes the detections from each indoor air, suo-slab soil vapor, and ambient air sample. Based on the analytical results tetrachloroethene was detected within the indoor air samples at concentrations up to 7.3 ug/m3 . New York State Department of Health tetrachloroethene factsheet, dated May 2003, indicates that typical background concentrations of tetrachloroethene in residential homes are less than 10 ug/m3 . Elevated tetrachloroethene concen'trations were detected in sub-slab soil vapor on-site, identified as structure 9, up to 23,000 ug/m3, and at four off-site structures, identified as structures 1, 7, 8, and 10, up to 5,000 ug/m3 . Soil vapors impacting sub-slab vapor concentrations appear to be a result of site contamination that emanated from the site or off-gased from groundwater. Soil vapor contamination identified during the RI will be addressed in the remedy selection process. 5.2: Interim Remedial Measures There were no IRMs performed at this site during the RI. However, as was noted in Section 3.2, the owner did briefly operate a soil vapor extraction system-unilaterally during 2001. Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGES 5.3: Summary of Human Exposure Pathways: This section describes the types of human exposures that may present added health risks to persons at or around the site. A more detailed discussion ofthe human exposure pathways can be found in Section 2.9 of the RI report. An exposure pathway describes the means by which an individual may be exposed to contaminants originating from a site. An exposure pathway has five elements: [1] a contaminant source, [2] contaminant release and transport mechanisms, [3] a point of exposure, [4] a route of exposure, and [5] a receptor population. The source of contamination is the location where contaminants were released to the environment (any waste disposal area or point of discharge). Contaminant release and transport mechanisms carry contaminants from the source to a point where people may be exposed. The exposure point is a location where actual or potential human contact with a contaminated medium may occur.. The route of exposure is the manner in which a contaminant actually enters or contacts the body (e.g., ingestion, inhalation, or direct contact). The receptor population is the people who are, or may be, exposed to contaminants at a point of exposure. An exposure pathway is complete when all five elements of an exposure pathway exist. An exposure pathway is considered a potential pathway when one or more ofthe elements currently does not exist, but could in the future. Elevated levels of tetrachloroethene vapors detected beneath the on-site and adjacent buildings indicate a potential exposure pathway. However, indoor air quality has not been compromised at this time. The remedy for the site will further protect the public by addressing the potential for contaminated sub-slab vapors to enter the structures. The area is served by public water, so people are unlikely to come into contact with the low levels oftetrachloroethene detected in groundwater. Surface soils did not contain contaminants at levels that would present an exposure concern. 5.4: Summary of Environmental Assessment This section summarizes the assessment of existing and potential future environmental impacts presented by the site. Environmental impacts include existing and potential future exposure pathways to fish and wildlife receptors, as well as damage to natural resources such as aquifers and wetlands. Samples from the surface soils, subsurface soils and groundwater did not contain elevated levels of contaminants; therefore a viable exposure pathway to fish and wildlife receptors is not present. Site contamination has impacted the groundwater resource in the shallow aquifer. SECTION 6: SUMMARY OF THE REMEDIATION GOALS Goals for the remedial program have been established through the remedy selection process stated in 6 NYCRR Part 375. At a minimum, the remedy selected must eliminate or mitigate all significant threats to public health and/or the environment presented by the hazardous waste disposed at the site through the proper application of scientific and engineering principles. Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 6 The remediation goals for this site are to eliminate or reduce to the extent practicable: • exposures of persons at or around the site to tetrachloroethene in soil vapor and sub-slab vapor. Further, the remediation goals for the site include attaining to the extent practicable: • ambient groundwater quality standards. SECTION 7: SUMMARY OF THE EVALUATION OF ALTERNATIVES The selected remedy must be protective of human health and the environment, be cost-effective, comply with other statutory requirements, and utilize permanent solutions, alternative technologies or resource recovery technologies to the maximum extent practicable. Potential remedial alternatives for the Sharon Cleaners site were identified, screened and evaluated in the Soil Vapor Mitigation Evaluation memo, which compared remedial action alternatives. Soil vapors and groundwater present the only concern to the environment andlor public health. As a result a focused evaluation of remedial technologies utilizing the PresumptivelProven Remedial Technologies (DER-15) document, dated February 2007, was performed. Based on DER-15 Section 3.3, two remedial alternatives identified as Soil Vapor Extraction and Vapor Mitigation System, were identified as appropriate actions that would address the soil vapors detected during the investigations. A summary of the remedial alternatives that were considered for this site is discussed below. The present worth represents the amount of money invested in the current year that would be sufficient to cover all present and future costs associated with the alternative. This enables the costs ofremedial alternatives to be compared on a common basis. As a convention, a time frame of30 years is used to evaluate present worth costs for alternatives with an indefmite duration. This does not imply that operation, maintenance, or monitoring would cease after 30 years if remediation goals are not achieved. 7.1: Description of Remedial Alternatives The following potential remedies were considered to address the contaminated soil vapor at the site. Alternative 1: No Action The No Action Alternative is evaluated as a procedural requirement and as a basis for comparison. It requires continued· air monitoring at five structures for three years and an institutional control to limit groundwater use at the site, allowing the site to remain in an unremediated state. This alternative would leave the site in its present condition and would not provide any additional protection to human health or the environment. Present Worth: $48, 000 Capital Cost: , $20, 000 Annual Costs: (Years 1-5): $28,000 (Years. 5-30): , $0 Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE? Alternative 2: Vapor Mitigation System The Vapor Mitigation System Alternative would be applied to three structures. Two of these structures require significant upgrades to the basements due to the poor condition of the concrete floors prior to installation of the vapor mitigation system. This alternative would repair or replace the concrete floors and seal any cracks and utility penetrations. Vapor mitigation systems are commonly known as sub-slab depressurization systems and is similar to radon systems, which reduce the air pressure beneath the slab and provides a preferential path that draws soil vapors from below the building and vents the vapors through a series of pipes to the atmosphere above the building where it is quickly diluted. The effectiveness of different vapor mitigation systems depends on the building types and equipment utilized. If the property owner approves, a pilot test would be performed to select the appropriate equipment to be utilized (i.e. electric fan or wind driven fan). Otherwise an electric fan would be installed .. In buildings with basements or slab-on-grade foundations, sub-slab depressurization is the most common and usually the most reliable mitigation method. In buildings with crawlspaces, sub membrane depressurization is the most effective mitigation method. Figure 5 presents a general illustration and additional description of a vapor mitigation system. The guidelines for soil vapor intrusion mitigation can be found in NYSDOH's "Guidance for Evaluating Soil Vapor Intrusion in the State of New York." This remedy would be implemented within a short period of time and is assumed to operate for approximately 30 years. This Alternative also requires continued air monitoring at two off-site structures for three years and an institutional control to limit groundwater use at the site. Present Worth: Capital Cost: Annual Costs: (Years 1-5): (Years 5-30): · $160,000 $140,000 $13,000 $7, 000 Alternative 3: Soil Vapor Extraction (SVE) This technique addresses VOC contamination at sites by removing contamination from soil and reducing soil vapor migration. SVE is an in-situ process which physically removes contaminants from vadose zone soils, soils located above the groundwater, by inducing air flow through the soil matrix. The flowing air strips volatile compounds from the soil and carries them to extraction wells. The recovered vapors may require further treatment prior to being released to the atmosphere. The radius of influence of a SVE system is dependant on site conditions and equipment. The impacted off-site structures would be assessed to determine if the SVE system is addressing the soil vapor contamination beneath the structures. More details on the operation ofa SVE system can be found in Appendix I ofDER-15. This remedy would require time to conduct a pilot test and design the system prior to operation. An operating duration of 5 years has been estimated for this site. The limitations of a SVE system is that the influence of the vacuum decreases with the distance from the site. If the SVE system is unable to influence the soil vapor contamination beneath the off-site structures installation of Vapor Mitigation Systems (Alternative 2) would be required at these structures and is identified as "Contingency Cost" presented below. Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 8 This Alternative would also require continued air monitoring at two off-site structures for three years and an institutional control to limit groundwater use at the site. Present Worth: $370,000 Capital Cost: $160,000 Contingency Cost: $100,000 Annual Costs: (Years 1-5): $1 10,000 (Years 5-30): $0 7.2 Evaluation of Remedial Alternatives The criteria to which potential remedial alternatives are compared are defmed in 6 NYCRR Part 375, which governs the remediation of inactive hazardous waste disposal sites in New York A detailed discussion ofthe evaluation criteria and comparative analysis is included in the Soil Vapor Mitigation Evaluation memo. The first two evaluation criteria are termed "threshold criteria" and must be satisfied in order for an alternative to be considered for selection. 1. Protection of Human Health and the Environment. This criterion is an overall evaluation of each alternative's ability to protect public health and the environment. 2. Compliance with New York State Standards, Criteria, and Guidance CSCGs). Compliance with SCGs addresses whether a remedy will meet environmental laws, regulations, and other standards and criteria. In addition, this criterion includes the consideration of guidance which the Department has determined to be applicable on a case-specific basis. The next five "primary balancing criteria" are used to compare the positive and negative aspects of each of the remedial strategies. 3. Short-term Effectiveness. The potential short-term adverse impacts of the remedial action upon the community, the workers, and the environment during the construction and/or implementation are evaluated. The length of time needed to achieve the remedial objectives is also estimated and compared against the other alternatives. 4. Long-term Effectiveness and Permanence. This criterion evaluates the long-term effectiveness of the remedial alternatives after implementation. If wastes or treated residuals remain on-site after the selected remedy has been implemented, the following items are evaluated: 1) the magnitude of the remaining risks, 2) the adequacy of the engineering and/or institutional controls intended to limit the risk, and 3) the reliability of these controls. 5. Reduction of Toxicity, Mobility or Volume. Preference is given to alternatives that permanently and significantly reduce the toxicity, mobility or volume ofthe wastes at the site. 6. Implementability, The technical and administrative feasibility of implementing each alternative are evaluated. Technical feasibility includes the difficulties associated with the construction ofthe remedy and the ability to monitor its effectiveness. For administrative feasibility, the availability of the necessary Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 9 personnel and materials is evaluated along with potential difficulties in obtaining specific operating approvals, access for construction, institutional controls, and so forth. 7. Cost-Effectivness. Capital costs and annual operation, maintenance, and monitoring costs are estimated for each alternative and compared on a present worth basis. Although cost-effectiveness is the last balancing criterion evaluated, where two or more alternatives have met the requirements ofthe other criteria, it can be used as the basis for the final decision. The costs for each alternative are presented in Table 2. This final criterion is considered a "modifying criterion" and is taken into account after evaluating those above. It is evaluated after public comments on the Proposed Remedial Action Plan have been received. 8. Community Acceptance -Concerns of the community regarding the RI, Soil Vapor Mitigation Evaluation memo and the PRAP have been evaluated. The responsiveness summary (Appendix A) presents the public comments received and the manner in which the Department addressed the concerns raised. No significant comments were received. SECTION 8: SUMMARY OF THE SELECTED REMEDY Based on the Administrative Record (Appendix B) and the discussion presented below, the Department has selected Alternative 2, Vapor Mitigation System as the remedy for this site. The elements of this remedy are described at the end of this section. The selected remedy is based on the results of the RI and the evaluation of alternatives presented in the Soil Vapor Mitigation Evaluation memo. Alternative 2 is being proposed because, as described below, it satisfies the threshold criteria and provides the best balance of the primary balancing criteria described in Section 7.2. It will achieve the remediation goals for the site by reducing the potential exposures to the public health where elevated soil vapors have been detected. Alternative 3 would also comply with the threshold selection criteria but to a lower certainty and additional cost. Alternative 1 would not satisfy the threshold criteria. Alternative2 and Alternative 3 would each satisfy the threshold criteria, thus the five balancing criteria are particularly important in selecting a final remedy to address soil vapor at the site and in the vicinity of the site. Achieving short term effectiveness is best accomplished by Alternative 2, which will require a short duration for implementation of the action. The relative short term impact to structures is high and would require proper coordination with the occupants. Alternative 3 would require sufficient time to properly design and install a remedial system at the site, but would only impact operations at the site. The final construction of Alternative 2 will have minimal impacts on daily activities; where as Alternative 3 would require a portion of the site to be occupied by remedial equipment. Achieving long-term effectiveness and performance is best accomplished by Alternative 2 since a source of contamination was not identified during the investigation, the alternative is more than capable of addressing detected soil vapor contamination that poses a potential threat to the structures at the site as well as off-site, and requires minimal site controls to confirm operation of the system. Alternative 3 would address any contamination not encountered during the investigation at the site, but may not be capable of addressing Sbaron Cleaners -Site No. 5-46-052 Marcb 2009 RECORD OF DECISION PAGE 10 contamination at off-site structures and requires additional maintenance activities to confirm site controls are operational. The off-site portion ofAlternative 2 would be required as a contingency for Alternative 3, in case the operation of Alternative 3 is unable to obtain the desire effect at the off-site structures. The duration of operation for Alternative 2 is anticipated to be significantly longer than Alternative 3. An environmental easement would be required for both alternatives that limit the use of on-site groundwater. Alternative 2 is favorable in that it is readily implementable. Alternative3 would require a pilot test to be performed so the radius of influence of the system can be determined prior to implementation. The cost of the alternatives varies significantly. Alternative 2 is less expensive than Alternative 3. Alternative 3 is a permanent remedy that would likely eliminate most ofthe continuing source of soil vapor contamination, but off-site influence of the Alterative is uncertain. The estimated present worth cost to implement the remedy is $160,000. The cost to construct the remedy is estimated to be $140,000 and the estimated average annual costs for 30 years is $500. The elements of the selected remedy are as follows: 1. A remedial program will be implemented to perform the necessary construction, operation, maintenance, and monitoring activities required for the installation ofthree Vapor Mitigation Systems (one on-site and two-off site). Basement conditions will be upgraded at two off-site structures to address cracks. 2. Imposition of an institutional control in the form of an environmental easement that will require (a) restricting the use of groundwater as a source of potable or process water, without necessary water quality treatment as determined by NYSDOH; and (b) the site property owner to complete and submit to the Department a periodic certification of institutional and engineering controls. 3. Development of a site management plan which will include the following institutional and engineering controls: (a) monitoring of sub-slab soil vapor and indoor concentrations at two additional structures, identified as AS-I and AS-10, which had levels that did not warrant mitigation will be monitored for a minimum of three years; and (b) provisions for the continued proper operation and maintenance of the components of the remedy. 4. The site property owner will provide a periodic certification of institutional and engineering controls, prepared and submitted by a professional engineer or such other expert acceptable to the Department, until the Department notifies the property owner in writing that this certification is no longer needed. This submittal will: (a) contain certification that the institutional controls and engineering controls put in place are still in place and are either unchanged from the previous certification or are compliant with Department-approved modifications; (b) allow the Department access to the site; and (c) state that nothing has occurred that would impair the ability of the control to protect public health or the environment unless otherwise approved by the Department. Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 11 SECTION 9: HIGHLIGHTS OF COMMUNITY PARTICIPATION As part of the remedial investigation process, a number of Citizen Participation activities were undertaken to inform and educate the public about conditions at the site and the potential remedial alternatives. The following public participation activities were conducted for the site: • Repositories for documents pertaining to the site were established. • A public contact list, which included nearby property owners, elected officials, and other interested parties, was established. • A fact sheet was issued on March 14,2008, which provided the current status and proposed remedial activities. • The Saratogian released an article about the site on April 18, 2008. • A Citizen Participation Plan was prepared and provided in the document repository. • A fact sheet was issued on February 25, 2009, which provided the current status and the date of the public meeting to discuss the proposed action. • A post card was issued on March 4, 2009 as a reminder for the public meeting. • A public meeting was held on March 11,2009 to present and receive comment on the PRAP. • A responsiveness summary (Appendix A) was prepared to address the comments received during the public comment period for the PRAP. Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 12 Table 1 TETRACHLOROETHENE SUB-SLAB SOIL VAPOR AND INDOOR AIR CONCENTRATIONS DETECTED AND APPROPRIATE ACTION March to May 2008 Structure Identification PCE Sub-Slab Soil Vapor Concentration Detected (Jlglm3)& PCE Indoor Air Concentration Detected (Jlg/m 3 )& SCGb,c 1 98 4.6 Monitor 3 9.4 1.3 No Further Action 4 1.2 1.3 No Further Action 5 2.5 ND No Further Action 6 6.9 2.0 No Further Action 7 3,000 2.2 Mitigate 8 5,000 7.3 Mitigate 9 23,000 4.6 Mitigate 10 740 1.5 Monitor 11 52 ND No Further Action a ug/m3 = micrograms per cubic meter b SCG = standards, criteria, and guidance values; C SCG = New York State Department of Health Guidance for Evaluating Soil Vapor Intrusion in the State of New York, dated October 2006, Matrix 1 and Matrix 2 tequires both sub-slab soil vapor and indoor air concentrations of volatile organic compounds to determine the appropriate action. Tetrachloroethene concentrations are applied to Matrix 2. ND = Not Detected Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 13 Table 2 REMEDIAL ALTERNATIVE COSTS Remedial Alternative Capital Cost ($) I Annual Costs ($) Total Present Worth ($) No Action $20,000 $28,000 $48,000 Vapor Mitigation System $140,000 $20,000 $160,000 Soil Vapor Extraction $260,000 $110,000 $370,000 Sharon Cleaners -Site No. 5-46-052 March 2009 RECORD OF DECISION PAGE 14 ---- • • I") N N ""'" 1 :::l! Cl u N., ~ c: -0 o c: ::J i ~ .. o :i: UI ~ CD N .n CD a ....... ..... ' N "","I I") x N N ./a. ~ 0' ~ ~ N ~ ..... Ol ~ ./ .:..i ~. ';\ II II 1\"I~ ~f=4\ \\ lLl 7lBld1'# /,qmn~K~1 AV.l\ ~~JH~e~3~io~\ ~ II 1\ ! ~··.t=ifJJ~r ·~l-drJY@J~ ~}A ~~. Ldf=--~~ Elem Sc I r--Par~_r nn n 29.~ ~ rl ~. ~~ • -~: SHARON CLEANERS SITE NO. 5-46-052 r. ~ LOCATION MAP SHARON CLEANERS -~ LOCATION MAP FIGUREPLAN NO. NOT TO SCALE CI:I\II Camp Dresser & McKee Inc. 1 NYSDEC SHARON CLEANERS SITE NO. 5-46-052 NOTES: 1. FIGURE NOT TO SCALE. WELL LOCATIONS ARE APPROXIMATE. SEE GROUNDWATER FLOW MAP FIGURE 3 FOR SURVEYED INFORMATION. 2. ELEVATIONS (FT AMSL) ARE TIED INTO THE UTM ZONE 18N COORDINATE FigureSYSTEM. 3. STATIC WATER LEVELS ARE FROM 5/5·7/08 EVENT. CONI 2 -------- CLEANUP OBUECTNES (THESE SAMPLES WERE NOT TESTED FOR 4 HG "''' , J I \. . "I do I ®SV-7 l.'rc -----------.-;,...------------------ ~ ..f: r '''· "fjt-~ l.IW-9 I Il.- ~ ~,f/ -F i \ 1.lN~. "fF O~ / .= . bcl=;"i\ /..:~ JI _T/ -------------1I . ':;7'-- Tt'lU' lND SPI. M'nT!L rr.c -- I ~ F /t.4W-1q,SOIL IoIB-5, AtID <!., ~",,;:o ~,,~ / VAP.6R ,POINT SV-S BE'I'OOj) ., /" ,,' AT UB~ (APPROXIMI\l'£LY SOD Ft IN A NORTHEAS'TPlLY DIRECTlON!"ROM ,THE(SOUTHWEST CORNER OF , 'SHARON CL£b.i'lERS·BUILDING) .t'.!'- ~I/ I / .... i'~ --.' /' l lIJlll!l!u. •. l.wowt (1~1/10l!) -'. / ,s.: 'C ~"'r '. E \,- ~.::--:------ --~----'- .,"!' ~ - .. II$;'~W-~ i , t:J MB-~ i • ,I q -a ~ a,l Nt"'" U~ ... ~"1vllp"'L..r,,-~ W'" ~ "J~---==:-SS-9 \~ ~I'rj "; "i [i i: il i't ~ ~ y J "01''''''' I .... I IJ • II I,' ~.......... ,..... I m I !~ _ ~. .~ .-----r-;" 1...,1. ---.... o >U D SOIL VAPOR POINT SV-9, MONITORING WELL MW-1 1, AND SOIL BACKGROUND SAMPLE MB-1 BEYOND (SEE KEY PLAN) .~ 1...\Jrul:i rvr (1)1 11l)l/t11111 - ,.. C -' ~. -.---....,.. ~ _' __ --a.,~,. --o MB-4 120 t,80 Legend • Sol Vopot PoInt • __l'oI:>b LocaIlOt'IS / I I jI I I 1IN:heQUelS 100 lee: Souree o.u. N:IuI ' ~ CoiOf !Qgn Rn SAMPLE LOCATION PLAN SHARON CLEANERS SITE NO. 5-46.0.62 SARATOGA SPRINGS, SARATOGA COUNTY, NEW YORK DILUllON EsnMATED VALUE NON DETECT SURFACE SOIL OR SUB SLAB BELOW CLEANUP OBJECTiVEs sample 10 Part 375 I 55-1-1-2 55-2-0-12 55-3-0-12 55-4-0-12 55-5-0-12 SS--6-0-12 55-7-0-12 55-10-0-12 B-1A-Q-1 8-18-15-16 B-2A-Q-1 6-28-15-16 B-3A-Q-1 6-36-15-16 compound Name CAS # SlaOOwd 05062008 05062008 05062008 05062008 05062008 05052008 05062008 05062008 05062008 0S062008 0S062008 05062008 0S062008 05062008 VOC"s mglkg mgIkg mglkg mgIkg rnglkg mglkg mg/kg mglkg rnglkg mglkg mglkg mglkg mgtkg rn9'kg mgfkg Methylene Ollonde 175-09-2 0.05 0.066 NO NO NO NO NO 0.051 0.05 NO NO 0.06 NO BC BC Metals mglkg mgikg mgikg mgikg rnglkg mglkg rnWkg mglkg mglkg mglkg mglkg rnglkg mglkg rnglkg mglkg Arsenic 7440-38-2 13 BC BC BC BC BC BC BC NT 20.6 BC BC BC 22.8 BC Ctlrormum 744047-3 30 BC BC BC 193 BC BC BC NT BC BC BC BC BC BC Copper 744lJ.{;()-ll 50 71.2 BC BC BC BC BC BC NT BC BC BC BC BC BC Lead 7439-92-1 63 1100 189 168 963 119 BC 227 NT 228 BC 359 BC 375 BC Mercury 7439-97-ll 0.18 0.492 0.354 BC 0.188 BC BC 0.291 NT BC BC 0.770 BC 0.298 J BC <Inc 744O-ll8-6 109 370 199 183 624 4n BC 256 NT BC BC 163 BC 127 BC / I -----------I ! D J ND ss BC ~ ~ ® SV-5 MB-2 o ~,,< __tftl I J.El<EIiIl -$-MW-5 MONITORING WELL ®SV-7 PERMANENT SOIL VAPOR POINT j8lSVE'-2 SOIL VAPOR EXTRACTION WELL •B-1 SOIL BORING BP-5 I:OiiII SOIL BORING/PIEZOMETER MB-l SOIL METALS BACKGROUND0 SAMPLE 55-1 IJ SOIL SAMPLE I 1'3 ... N N I '" r!QID::::; o u 1. REFERENCE SURVEY MAP BY S.Y. KIM LAND SURVEYOR, P.C., 592 NEW LOUDON ROAD. LATHAM, N.Y. 12110. HORIZONTAL AND VERTICAL POSmONS TIED INTO NAD 1983 AND UTM ZONE <;i ~ 18N COORDINATE SYSTEM. NEW POINTS BASED ON MEASUREMENTS MADE IN THE FlELD. 2. SOME POINTS ARE ONLY REFERENCED, AND NOT SHOWN ON THE MAP DUE TO THE UMITS OF THE CURRENT SURVEY. SEE NYSDEC FlGURE INSERT FOR COMPLETE MAP. 3. SOIL CONCENTRATIONS ARE IN m9/k9.~ 4. SOIL SAMPLE 55-1 WAS COLLECTED BENEATH THE PAVEMENT. o 5. SEVERAL ADDmONAL SAMPLES WERE TAKEN, BUT WERE NOT ~ DETECTED ABOVE THE UNRESTRICTED USE SOIL CLEANUP ~ OBJECTIVES. THE FOLLOWING SUMMARIZES THE SAMPLES THAT WERE TAKEN, TESTED AND HAD RESULTS BELOW THE CLEANUP OBJECTIVES. THE SUB-SLAB SAMPLES 55-8, 55-9 AND 55-10 ci:i WERE TESTED FOR VOC'S AND THE RESULTS WERE UNDER THEo 0> METALS). THE SURFACE SOIL SAMPLE B-2A WAS TESTED FOR o VOC'S AND METALS AND THE RESULTS WERE BELOW THE"N CLEANUP OBJECTIVES. DEEP (15-15 FEET BELOW THE GROUND "SURFACE) SOIL SAMPLES WERE TAKEN AT B-1 B AND B-2B,N o WERE TESTED FOR VOC'S AND METALS, AND HAD RESULTS BELOW CLEANUP OBJECTIVES. DEEP SAMPLES B-4, B-5, B-5, B-7, B-8, B-9, B-l0, B-ll, B-12 AND B-13, RANGING NT-NO TEST FROM 10-15 FEET BELOW GROUND SURFACE, WERE TESTED~ I"= 20' FOR VOC'S AND FOUND TO BE BELOW CLEANUP OBJECTNES/"PLAN 10 0 20 (THESE SAMPLES WERE NOT TESTED FOR METALS).'" I"= 20'~ -:: 0> <0 PROJECT NO. 0897-52894L lNERlotOREI I I I I IOESIGNEO BY, NYSDEC FlL£ NAlAE, FlG 6.0WG~ COM SOIL INVESTIGATION EXCEEDANCES OFr----------------------------IDRAWN BY' .,. KOSKI c.np Dr8!Ul8l" & McKee 0> r-SHffi NO. Sanna Industrilll Powerp;w1t<0 /" t=EEEt=---------------------------~ SHEET CHK'Q BY; L lNERMQRE UNRESTRICTED USE SOIL CLEANUP OBJECTIVESOne General "'*n 0rMlo SHARON CLEANERS SITE NO. 5-46-052 CROSS CHK'O BY: M .,.ILLlAS/"SyraaJse, NY 13206 3o Tel: (315)434-3200 U < ~ IAPPROVED BY: _ FOR VOC'S AND METALS -MAY 2008 consulting· engineering • ~• openIIiona/" I ~~. I DATE I DflWN I CHKO I RElotARKS DArL FEBRLARY 2009 U ~ ~ MB-2 o I8i SV-6 ':&,'" 1. REFERENCE SURVEY MAP BY S.Y. KIM LAND SURVEYOR, P.C., 592 NEW LOUDON ROAD, LATHAM, N.Y. 12110. HORIZONTAL AND VERT1CAL PosmONS T1ED INTO NAD 1983 AND un.I ZONE l8N COORDINATE SYSTEM. NEW POINTS BASED ON MEASUREMENTS MADE IN THE FIELD. 2. SOME POINTS ARE ONLY REFERENCED, AND NOT SHOWN ON niE MAP DUE TO niE UMITS OF niE CURRENT SURVEY. SEE NYSDEC FIGURE INSERT FOR COM PLETE MAP. 3. GROUNDWATER CONCENTRAT10NS ARE IN ug/L "J" AFTER CONCENTRAT10NS MEANS AN EsnMATED VALUE. 4. CONCENTRAT10NS CAUED OUT ON nilS DRAWING ARE ABOVE THE STANDARD LEVELS PUT FORTH IN THE AWQS. 5. GROUNDWATER STANDARDS ARE AS FOLLOWS: IRON = 600 ug/L SODIUM = 20,00D ug/L THALUUM -0.5 ug/L PeE = 5 ug/L .LEG!tIIl -$-,\/W-5 MONITORING WELL I8i SV -7 PERMANENT SOIL VAPOR POINT l8lSYE'-2 SOIL VAPOR EXTRACTION WELL B-1• SOIL BORING I BP-5 I;;jI SOIL BORING/PIEZOMmR MB-l SOIL METALS BACKGROUND0 SAMPLE SS-1 IJ SOIL SAMPLE L .tlQIES.: MW-9-050n008 SODIUM ~ 44,900 THAWUM = 12.7J ,I"(!r.-- J ----- I@~-' I '1 .... ". ... -j\ ("', ~ ..... ~ ~ C=!l ~ PCE -7.1 'I SODIUM -28,700 ]!:W.UlJt,I--rn,j-- MW-5-050n008 j I ~~r7~: .~ ,,\9 . .. - l ~ I -"l". t.4M' NIP 0' 1<llU3S4 .. J.a8(lIID (lOotI/INt! '''':'Q. ,,,,,,,if,,, ~,~o:'" ~~ /MB-5, AND SGlL VAPOR POINT SV-5 BEYOND 1 I .. ': AT UB~ (APPROXIw,my 5"" ¢ IN'i>. NORTHEASTERLY DIRECTIOI"JFROM :rn~('~()UTHWEST C9JlNER OF . /StjAAON'CLEl>.~ERS BUILDING) ~ . -~-'-";;::--'- a.·,[IS .;.tIP 0, <nIlDl ... 1l&UJ U6~JU"j ~ ,,,,,' ''b ,'-..'t ~..... , ....... r.. ~($' .-" ........ '...... ~""'~ '~"";-" 'f'~~.~, ~ .J" " ..~~~_ ,/" - - 20u '" -20' ,/ _-..._ 10 .......," ---~'-;fl~!I~::J;:;J,'I n , / ~I. v~~-;;. ___ =1' SOIL VAPOR POINT SV-9, MONITORING WELL MW-'" AND SOIL BACKGROUND SAMPLE MB-I BEYOND (SEE KEY PLAN) t/1 1" = 20' PLAN II. ---_.-:-~~-:-~- .:::;.".;'~ ~aw~[. (1""'/77'1 { I I II'HI'~,~~ I ... I .. : f !r III , : ,TIUt'I t. "rRA\T1"5 ! ' ,(l"~/JO.I . ". '{ !'~----.. -.... ---- --'JI tt" It.~,:~ ~ --. .---(101/..01 -C"W MB .- I' PCE ~ 24 THAUJUM = 12.JJ SODIUM -47,100 THAUJUM = 7.45.1 SODIUM -51,300 MW-l0-05062008 MW-11-050n008 o MB-4 SAMPLE LOCATION PLAN SHARON CLEANER.S SITE NO. 5..46.052 SARATOGA SPRINGS, SARATOGA COUNTY, NEW YORK I , II I I I ----- '! I I / ! ! ~. -,----------..-I ~ -':'====JIOESIGNEO tlY, LCROCKER DRAWN EJ"Y: 1IA KOSKI ~ ISHEET CHKO Il'Y l CROCKF:R 1----------------------------CROSS CH" 0 BY M MIUJAS ~~. illiTE ORWN CHKO REMARKS :;:OVEO BY FEBRlJARV 2009 COM CIrnp Dr8aer & McKee...... _- am. GerMni Mc*JnI 0rM S)f8QIM, NY 13206 Tel: (3151 434-3200 oonaultlnv • engIneer1ng • CI::ll1Shdon • operatcns NYSDEC SHARON CLEANERS SITE NO. 5-46-052 GROUNDWATER INVESTIGATION EXCEEDANCES FOR VOC'S AND METALS· MAY 2008 PROoJECT NO. 0897-62B94 FILE NAIoOE: FIG ~.OWG SHEET NO. 4 C D F. G ;:t, N N I a " u N. ~ c "0 g ~ ~ ~ 5 ~ ~ o "' a; o ~ N "N o '" g ~•" ./...g; N <0 ./ 0> " OJ o ./ 3 ./ U 2 tQ 4 (oF ( ,/ ( SUB.;SLAB DEPRESSURIZATION· SUB-MEMBRANE DEPRESSURIZATION Source: Folkes, D.J. and Kurz, D.W.. Proceedings: Indoor Air 2002 Operation Principles A) Sub-slab depressurization -Suction pits are created below the concrete floor slabs by drilling a hole through the slab, ideally but not necessarily located near the middle of the slab. The hole is then hand excavated to form a void in the soil to increase the effectiveness of the depressurization system. A PVC pipe from the suction side of the fan is inserted in the hole. The annular space between the pipe and the slab, and any visible cracks and joints in the floor, is sealed with acrylic latex caulk or some compound that is impermeable to air. In most single family homes, one suction point should be sufficient to depressurize the floor area. According to NYSDOH guidelines, to avoid entry of subsurface vapors into the building, the vent pipe's exhaust must be above the roof (preferably, above the highest eave of the building at least 12 inches above the surface of the root), at least 10 feet above ground level, at least 10 feet away from any opening that is less than 2 feet below the exhaust point, and 10 feet from any adjoining or adjacent buildings, or HV AC intakes or supply registers. B) Sub-membrane depressurization -In homes with a crawl space, a cross-laminated polyethylene membrane or liner is placed over the dirt floor and sealed to the concrete foundation walls using acrylic latex adhesive. The end of the pipe from the suction side of the fan is inserted through a hole cut in the liner. The liner is sealed to the pipe at the penetration hole using vinyl tape to prevent loss of vacuum. When concrete footings divide the crawl space, a separate suction point is generally installed in each separate area between the footings: The fan is installed outside the house and the pipe is routed up the outside wall to exhaust above the roof line. SHARON CLEANERS SITE NO. 5-46-052 SCHEMATICS OF A VAPOR Figure MITIGATION SYSTEM 5 APPENDIX A Responsiveness Summary RESPONSIVENESS SUMMARY Sharon Cleaners Saratoga Springs, Saratoga County, New York Site No. 5-46-052 The Proposed Remedial Action Plan (PRAP) for the Sharon Cleaners site, was prepared by the New York State Department of Environmental Conservation (the Department) in consultation with the New York State Department of Health (NYSDOH) and was issued to the document repositories on February 26,2009. The PRAP outlined the remedial measure proposed for the contaminated groundwater and soil vapor at the Sharon Cleaners site. The release of the PRAP was announced by sending a notice to the public contact list, informing the public of the opportunity to comment on the proposed remedy. A public meeting was held on March 11,2009, which included a presentation of the Remedial Investigation (RI) and the Feasibility Study (FS) as well as a discussion of the proposed remedy. The meeting provided an opportunity for citizens to discuss their concerns, ask questions and comment on the proposed remedy. These conunents have become part of the Administrative Record for this site. The public comment period for the PRAP ended on March 27, 2009. This responsiveness summary responds to all questions and comments raised during the public comment period. The following are the comments received, with the Department's 'responses: COMMENT 1: Does PCE affect brain cells? RESPONSE 1: At very high levels in air, PCE can affect the central nervous system. However, elevated levels of PCE were not detected within indoor air in structures surrounding the site, so health effects would not occur. COMMENT 2: Have any of the remedies been implemented? RESPONSE 2: No, implementation will take place after the Record of Decision is issued. COMMENT 3: When was the contamination discovered? RESPONSE 3: In February 2000 as part of a property assessment. COMMENT 4: They found metals? Arsenic and lead? RESPONSE 4: Site investigations detected metals as part of the site characterization. Further sampling under the remedial investigation determined that the metals were sporadically detected at the site and the contamination is considered to be representative of background conditions Sharon Cleaners RESPONSrvENESS SUMMARY PAGE A-I from fill material placed at the site and not a result of the dry cleaning activities conducted at the site since metals are not utilized as part of the dry cleaning process. COMMENT 5: Why are you choosing one alternative vs. the other? RESPONSE 5: Alternative 2 and Alternative 3 both would be protective remedies, however, Alternative 2 is the cost effective remedy. Section 8 compares the alternatives and Table 1 presents the associated costs for each alternative. COMMENT 6: Were the water samples taken deeper than the basements? RESPONSE 6: Yes, basements are approximately eight feet below ground surface and groundwater at the site is approximately 16 feet below ground surface. COMNIENT 7: Which two off-site buildings will be remediated? If we weren't contacted, does that mean our air should be OK? RESPONSE 7: The off-site buildings being mitigated are located near the site. The buildings sampled were sufficient in defining the extent of the contamination. If you were not contacted, you are located beyond the extent of the soil vapor contamination determined to be a potential concern for indoor air. COMMENT 8: Where does the money for the remedy come from? RESPONSE 8: Initial activities conducted in 2000 were performed to the Department's satisfaction under the Voluntary Cleanup Program. Subsequently the Department released the volunteer and future property owners from remedial liabilities regarding the site contamination in 2002. As a result current activities are being conducted under the State Superfund Program. COMMENT 9: So only levels slightly above the standard were found in groundwater? Is that city-wide? RESPONSE 9: Groundwater concentrations are very low in the vicinity of the site. The down gradient well located at the library approximately 400 feet from the site did not detect site contaminants, which indicates that the contamination is very localized and not city wide. COMMENT 10: What was the highest level ofPCE next to the site? RESPONSE 10: Section 5.1.2 details the levels of PCE in the soil, soil vapor, indoor air and groundwater. COMMENT 11: Who uses that water? RESPONSE 11: The groundwater is not utilized for drinking water. Public water is provided by the City. Sharon Cleaners RESPONSIVENESS SUMMARY PAGEA-2 COMMENT 12: Did the chemical enter the public water system? (i.e. through cracked pipes or the lake?) RESPONSE 12: No, the water supply pipes are located below the frost line at approximately five feet below ground surface and groundwater is 16 feet below ground surface. The groundwater contamination does not extend to Loughberry Lake, which is the primary source for City drinking water. COMMENT 13: So levels of PCE were higher in soil vapor at the site vs. off-site? RESPONSE 13: Yes. COMMENT 14: Are the sub-slab systems really necessary? RESPONSE 14: At this time, contaminated sub-slab vapors are present, but elevated levels of PCE were not detected in the indoor air within structures near the site. However, changes in the structures, such as altering the heating and cooling systems or the creation of new openings through the basement foundation could cause contaminated vapors to be drawn into the structures. The proposed systems will prevent the contaminated vapors from entering the buildings in the future. Sharon Cleaners RESPONSIVENESS SUMMARY PAGEA-3 APPENDIXB Administrative Record Administrative Record Sharon Cleaners Site No. 5-46-052 1. Proposed Remedial Action Plan for the Sharon Cleaners site, dated February 2009, prepared by the Department. 2. "Remediation Report for Sharon Cleaners", July 27, 2001, prepared by Environmental Hydrogeology Corporation. 3. "Investigation Report -Site Characterization at Sharon Cleaners", February 2007, prepared by Camp Dresser & McKee. 4. "Citizen Participation Plan", March 2008, prepared by New York State Department of Environmental Conservation. 5. "Soil Vapor Mitigation Evaluation and Interim Remedial Measure Scope of Work", November 7,2008, prepared by Camp Dresser & McKee. 6. "Remedial Investigation Report", February 2009, prepared by Camp Dresser & McKee. 7. "Proposed Remedial Action Plan for Sharon Cleaners Site", February 25,2009, prepared by N ew York State Department of Environmental Conservation. 8. Referral Memorandum dated October 19,2007 for Remedial Investigation. Sharon Cleaners ADMINISTRATIVE RECORD PAGE B-1