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Home My WebLink AboutJ - 11 CHA Periodic Review Report Comment Response Letter - South Hill DumpJuly 10, 2023 Ms. Brianna Scharf New York State Department of Environmental Conservation Division of Environmental Remediation, Remedial Bureau E, Remedial Section C 625 Broadway Albany, New York 12233 RE: Periodic Review Report- South Hill Dunep, Town of Cortlandville NYSDEC Site No. 712009 CHA Project No.: 034236 Dear Ms. Scharf The Town of Cortlandville and CHA Consulting, Inc. (CHA) received a response letter regarding the 2022 Periodic Review Report (CHA, November 2022) from the New York State Department of Environmental Conservation (NYSDEC) dated June 27, 2023. On behalf of the Town of Cortlandville, CHA has prepared the following comment response letter to address the to the comments/modifications. Comment 1: Update the 2015 SMP with the new frequencies and other changes approved following the 2020 PRR and NYSDEC approval letter. Response 1: CHA updated the SMP with the new sampling and reporting frequencies and other changes in June 2021. A copy of the updated report was submitted to the NYSDEC on June 11, 2021. A response was received from the NYSDEC on June 11, 2021, stating that the report had been received. A copy of the email submission is included at the end of this report. No additional updates are warranted at this time. Comment 2: Prepare a scope of work and provide a cost estimate for the repair of the damaged monitoring well MW- 2D. Response 2: As noted in Section 3.1 of the 2022 PRR, the damage to MW-2D was reported to the Town of Cortlandville in 2021 and MW-2D was subsequently repaired. A PVC coupling with riser extension and new steel casing were installed. The monitoring well appeared to be in good condition during the 2022 inspection and samples were collected during the following event. Comment 3: Verify the acreage of the Site; 2015 SMP states 2.5 acres, and the 2022 PRR states 10.4. Revise the 2015 SMP if necessary. Response 3: The 2015 and 2021 SMPs and the Record of Decision (ROD) state the South Hill Dump consists of approximately 2.5 acres and refers specifically to the waste material. According to the remedial investigation, dumping activities were confined to about 2.5 acres of the site. The ROD states the entire site is 6 acres in size, but the environmental easement states the tax mapparcel is approximately 10.865 acres. CHA will use 10.9 acres to describe the size of the entire site, consistent with the Institutional and Engineering Controls Certification Forms. CHA contends the 2021 SMP does not require revision since the 2.5 acres specifically discusses the portion of the site remediated. Future PRRs will utilize the correct total size acreage of 10.9 acres. One Park Place, 300 South State Street, Suite 600, Syracuse, NY 13202.2024 T 315.471.3920 9 F 315.471.3569 • w ..chacompaniesxom Ms. Brianna Scharf July 10, 2023 Periodic Review Report- South Hill Dump, Town of Cortlandville NYSDEC Site No. 712009 Comment 4: During the next certification period (January 1, 2023 to December 31, 2024), in addition to the standard groundwater analysis outline in the 2015 SMP, collect groundwater to be analyzed for emerging contaminants (EC, PFAS and 1,4-Dioxane). Response 4: CHA and the Town of Cortlandville understand the NYSDEC is conducting a state-wide evaluation of PFAS and 1,4-dioxane and are utilizing existing monitoring programs to gather additional data. Due to the potential threat of PFAS and 1, 4-dioxane to the Cortland-Hanter-Preble Aquifer System, the Town of Cortlandville agrees to conduct limited PFAS and 1,4-Dioxane sampling during one sampling event in the January 2023 through December 2024 certification period. In response to this request, CHA proposes sampling three monitoring wells for PFAS and 1, 4-Dioxane. By sampling one upgradient and two downgradient monitoring wells, CHA will obtain sufficient information to determine if the groundwater is impacted by emerging contaminants. The Town of Cortlandville agrees to sample the following three monitoring wells: • MW-1B, upgradient well • MW-4S, downgradientoverburden well • MW-4B, downgradient bedrock well CHA will evaluate the expanded parameter list of PFAS using the DRAFT EPA Method 1633 and include 1, 4-dioxane analysis in the standard EPA Method 8270list. Should you have any questions, please feel free to contact Karyn Ehmann at kehmannachacomnanies.com. Sincerely, Samantha Miller, P.E. Senior Engineer KE/ llclm-Ilp.cornlprojlprojectslanylk41342361reportsl2a22 prrlfinallclialodec-oonuaenl response leuerfinal.docs M Gmail Site No. 712009 South Hill Dump 2022 PRR Comments 8 messages Amanda Rainbow <arainbow@cortlandville.org> 'Scharf, Brianna L (DEC)' via Supervisor <supervisorl @cortlandville.org> Tue, Jun 27, 2023 at 3:00 PM Reply -To: "Scharf, Brianna L (DEC)" <Brianna.Schart@dec.ny.gov> To: "Ehmann, Karyn" <KEhmann@chacompanies.com>, "supervisorl@cortlandville.org" <supervisorl@cortlandville.org> Cc: "Miller, Samantha" <SMlller@chacompanies.com>, "Bone, Jonathan" <JBone@trccompanies.wm>, "Sergolt, Mark S (HEALTH)" <mark.sergott@health.ny.gov>, "Saucier, Sarah K (DEC)" <Sarah.Saucier@dec.ny.gov> Good Afternoon Karyn, Please find attached the comment letter on the 2022 PRR. I apologize this is so delayed. If you have any questions or concerns please feel free to contact me. Thank you, Brianna Brianna Scharf Assistant Engineer (Environmental) (shelhed Division of Environmental Remediation, Remedial Bureau E, Remedial Section C New York State Department of Environmental Conservation 625 Broadway, Albany, NY 12233-7017 P: (518) 402-5987 1 brianna.scharf@dec.ny.gov -J/�YOL Departmentof _ � STpir Environmental `/ ST Conservation in letter.HW.712009.2023-06-27.SouthHillDump2023PRR.pdf 246K Cassalta, Laura <LCassalia@chacompanles.com> To: "tawilliams@cortlandvllle.org" <tawilliams@cortlandville.org>, John Delvecchio <arainbow@cortlandville.org>, "townclerk@cortlandville.org" <townclerk@cortland Cc: "Ehmann, Karyn" <KEhmann@chacompanies.com> Thu, Jul 6, 2023 at 8:52 AM Amanda Rainbow All, I am not sure if you received a copy of this letter from the NYSDEC regarding the South Hill Dump, so I am forwarding it and providing the following responses to their comments for your information. The only item of real concern is the last one (#4) regarding emerging contaminants. 1. The SMP was updated in 2021. In the PEM, we have documentation of CHA sending the updated SMP to Brianna (NYSDEC) on 6111/2021, so this comment is not applicable. 2. MW-2D has already been repaired and this is stated in the report. No scope of work and cost estimate are necessary. 3. We will verify the size of the site and make the necessary corrections, as there are a few different values being referenced for the total acreage. 4. Request for PFAS and 1,4-dioxane sampling. DEC has requested emerging contaminants be included in the next groundwater monitoring event at the South Hill Dump. Over the last several years, CHA has seen this request at many landfills and groundwater monitoring programs and understands the DEC to be in a "data gathering" phase of this work. Essentially, the DEC Is doing a state-wide evaluation of per- and poly8uoroalkyl substances (PFAS) and 1,4- dioxane and utilizing existing monitoring programs to do so. The request implies the DEC is asking for all monitoring wells on -site to be sampled (11 wells total). At other sites, CHA has been successful at requesting a reduction in the number of samples. In response to the DEC's request, CHA proposes sampling three monitoring wells for emerging contaminants. By sampling one upgradient and two downgradient (one overburden and one bedrock well), CHA will obtain sufficient information to determine if the groundwater is impacted by emerging contaminants and believe that the DEC's request to sample all 11 monitoring wells is burdensome. Here is an estimated breakdown of fees if all 11 monitoring wells and if only 3 wells are sampled for PFAS and 1,4-Dioxane, so that you can see the cost impact: DEC request for all 11 wells to be monitored for PFAS and 1,4-Dioxane Unit Cost PFAS via DRAFT Method 1633 I $468 1,4-Dioxane via EPA Method 8270E-SIM $158 1 Additional Day On -Site for sampling effort I $1,800 PVC Bailers and twine I $10 Total Number of Samples 11 11 11 The additional fee if CHA requests and DEC approves sampling only 3 monitoring wells: CHA proposes sampling only 3 wells for PFAS and 1,4-Dioxane PFAS via DRAFT Method 1633 1,4-Dioxane via EPA Method 8270E-SIM Additional time on -site (no additional day required) PVC Bailers and twine Total 1 Unit Cost $468 $158 $400 $10 Number of Samples Cost $5,143 $1,742 $1,800 $110 II $8,795 1 I Total Cost $1,403 J $475 $400 $30 $2,308 We will put together a comment response letter to the NYSDEC but wanted to provide the above information to the Town regarding the additional cost of the emerging contaminant sampling. As noted above, on other projects we have proposed sampling just a few wells for emerging contaminant sampling to appease the DEC and reduce costs by not sampling all wells. We can try that approach if the Town would like use to proceed in that direction. Please let me know your thoughts or concerns, and then we can respond to the NYSDEC. If needed, we can schedule a call with my environmental team to discuss further. Laura Cassalia Sr. Project Manager I CHA Office: (315)228-0717 Icassa lia@chacompanies.com www.chacompa nies.com C+Vk Responsibly Improving the World We Live In y { in lJ to [Quoted text hidden) letter.H W.712009.2023.06.27.SouthHiliDump2023PRR.pdf 246K Amanda Rainbow <arainbow@cortlandville.org> Thu, Jul 6, 2023 at 12:15 PM To: "Cassalia, Laura" <LCassalia@chacompanies.com> Cc: "tawilliams@cortlandville.org" <tawilliams@cortlandville.org>, John Delvecchio <jdelvecchlo@cortlandville.org>, "townclerk@cortlandville.org" <townclerk@cortlandville.org>, "Ehmann, Karyn" <KEhmann@chacompanies.com> Good afternoon Laura, Yes, we did receive and file at the TB meeting last night. I was planning on following up with you. I will bring this to the Town's attention and report back to you with what they decide to do regarding the request for PFAS and 1,4-dioxane sampling. Best, Amanda [Quoted text hidden)