United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R09-88/024
September 1988
Superfund
Record of Decision
Motorola (52nd Street Plant), AZ
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3027?-IQI
REPORT DOCUMENTATION
PAGE
r. REPORT NO.
EPA/ROD/R09-88/024
3. Recipient's Accession No.
4. Title end Subtitle
SUPERFUND RECORD OF DECISION
Motorola 52nd Street Facility, AZ
Remedial Action
5. Report Oete
09/30/88
horts)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contraet(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The Motorola 52nd Street site is located in the eastern part of the city of Phoenix,
Maricopa County, Arizona. The site is bounded by the Phoenix Military Reservation and
mixed residential and commercial neighborhoods. The site is currently owned by
Motorola, Inc., which operates a manufacturing facility at the site using solvents for
various manufacturing processes. In January 1983, Motorola tested some underground
storage tanks used to store virgin solvents for leaks and determined that a 5,000-gallon
ik containing TCA was leaking. Subsequently, Motorola conducted a preliminary
(estigation, which indicated soil and ground water contamination on the plant site and
'bund water contamination offsite to the west. Motorola initiated an onsite ground
water treatment program in 1986, which included treatability testing, design and
installation of a Pilot Treatment plant (FTP), treatment of ground water, and beneficial
use of the effluent in the plant's air fume scrubbers. The PTP is still in operation.
The selected remedy for this ROD requires partial cleanup of onsite and offsite organic
solvents contamination in the soil and alluvium groundwater. A subsequent remedial
action will address cleanup of all onsite and offsite contamination in the soil,
alluvium ground water, and the bedrock underlying the alluvium. The primary contaminant
of concern affecting the soil and ground water is TCA.
(See Attached Sheet)
17. Document Analysis . a. .Descriptors
Record of Decision
Motorola 52nd Street Facility, AZ
First Remedial Action
Contaminated Media: gw, soil
Key Contaminants: VOCs (1,1,1-TCA), metals
b. Idantiflers/Open-Ended Terms
c. COSATI Field/Group
liability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
44
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R09-88/024
Motorola 52nd Street Facility, AZ
First Remedial Action
16. ABSTRACT (continued)
The selected remedial action for this site includes: onsite soil-gas extraction and
treatment using granular activated carbon systems; pump and treatment of on- and offsite
ground water with treatment onsite and use of the treated ground water in site
manufacturing processes; and ground water monitoring. The estimated present worth cost
for this remedial action is $7,600,000 with annual O&M costs of $700,000.
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RECORD OF DECISION
Motorola 52nd Street Site
Phoenix, Arizona
September, 1988
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TABLE OF CONTENTS
A. DECLARATION Tab A
B. ADEQ LETTER OF DETERMINATION Tab B
Location
Reason for the Remedial Action Plan
Voluntary On-site Treatment
Community Relations
Purpose of the Remedial Action Plan
Alternative Selected
Evaluation Criteria
C. ATTACHMENTS Tab C
1. Vicinity Map
2. Site Plan
3. Responsiveness Summary
4. Environmental Contamination
D. ADMINISTRATIVE RECORD INDEX Tab D
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Tab A
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RECORD OF DECISION
DECLARATION
SITE NAME AND LOCATION;
Motorola 52nd Street Facility
Phoenix, Arizona
STATEMENT OF BASIS AND PURPOSE;
This document serves as EPA concurrence with the remedial
action for the Motorola 52nd Street site, as approved by the
Arizona Department of Environmental Quality (ADEQ). ADEQ
approved this remedial action in conformance with: the Arizona
Administrative Code (A.A.C. R18-7-108, Remedial Action Plan);
Arizona Revised Statute (A.R.S. §49-282, Water Quality Assurance
Revolving Fund); CERCLA, as amended by SARA; the National
Contingency Plan, to the extent practicable; and relevant state
and federal requirements.
This EPA concurrence with the State's selection of remedy is
based upon ADEQ's Letter of Determination, the Remedial Action
Plan, the Responsiveness Summary, and the Administrative
Record for this site. The attached index lists the items
comprising the administrative record.
DESCRIPTION OF THE REMEDIAL ACTION;
This is an operable unit for the Motorola 52nd Street site.
The selected remedy provides partial clean-up of on-site and
off-site contamination by organic solvents in the soil and
alluvium ground water. The overall and final remedy will
address clean-up of all on-site and off-site contamination in
the soil, alluvium ground water, and the bedrock underlying
the alluvium.
The selected remedy consists of soil-gas and ground water
recovery and treatment at an on-site facility. On-site,
soil-gas from the main source areas will be extracted and
alluvium ground water will be pumped. One-half mile off-site,
near the Old Cross Cut Canal, alluvium ground water will be
pumped. Both the soil-gas and the contaminated ground water
will be treated at an on-site facility. The treated ground
water will be used in the manufacturing processes, replacing
potable water supplied by the City of Phoenix. ADEQ's Letter
of Determination and the Remedial Action Plan describes the
approved remedy in greater detail.
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DECLARATION.
EPA concurs with the remedy selected by the ADEQ for this
operable unit at the Motorola 52nd Street site. The remedy
will be protective of human health and the environment, is
cost-effective, and attains the Federal and State require-
ments that are applicable or relevant and appropriate (ARARs),
except as noted here: specific to this site, this remedy is
unlikely to meet drinking water standards in the aquifer
during the period of the operable unit. A waiver can be
justified for this ARAR, on the basis that it will be
addressed in the final Record of Decision. This remedy
satisfies the statutory preference for remedies which employ
treatment to reduce toxicity, mobility or volume as a principal
element, and uses permanent solutions and alternative treatment
technologies to the maximum extent practicable.
As this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years after commencement of remedial action to
ensure the remedy continues to provide adequate protection of
human health and the environment.
Date Daniel W. McGovern
Regional Administrator
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Tab B
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ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY
Rose Mofford, Governor
Ronald L. Miller, Ph.D., Acting Director
Letter of Determination
for
Motorola 52nd Street Facility, Phoenix
September 27, 1988
CERTIFIED MAIL
Return Receipt Requested
Mr. Robert Lee, Manager
Environmental Affairs
Discrete and Special Technologies Group
5005 East McDowell Road
Phoenix, Arizona 85008
Dear Mr. Lee:
RE: Approval of Draft Remedial Action Plan (RAP)
for Motorola 52nd Street Facility (June 24, 1988).
The Draft Remedial Action Plan has been reviewed for
conformance with the Arizona Administrative Code A.A.C.
R18-7-108 (Remedial Action Plan), Arizona Revised Statute
A.R.S. S 49-282 Water Quality Assurance Revolving Fund
(WQARF), the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), the
Superfund Amendments and Reauthorization Act of 1986 (SARA),
and other pertinent state and federal requirements.
The draft Remedial Action Plan is approved. This decision
took into consideration the comparison of Alternative C, (the
approved alternative), with alternatives A and D and the no
action alternative. Each alternative was evaluated using the
same criteria. See exhibit A. In addition, the decision is
consistent with recommendations made in the Health Assessment
conducted by the Agency for Toxic Substances and Disease
Registry (ATSDR), of the U.S. Public Health Service.
The following provides a brief historical summary of the
contamination problem, including initial efforts to
The Department of Environmental Quality is An Equal Opportunity Affirmative Action Employer
Central Palm Plaza Building 2005 North Central Avenue Phoenix, Arizona 85004
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Mr. Robert Lee
September 27, 1988
Page 2
remediate, along with a discussion of the Alternative C and
how this operable unit meets the evaluation criteria and
provide a containment and treatment remedy that can be
implemented on an accelerated schedule.
Location
The Motorola 52nd Street plant is located in the eastern part
of the City of Phoenix (attachment 1). A legal description
of the plant boundary is included in the RAF. Major
geographic features are the Papago Buttes to the east of the
plant, the Salt River flowing westerly about one mile to the
south, the Old Crosscut Canal located along 46th Street, and
the Grand Canal which flows northwesterly through the area
west of 40th Street and Van Buren Street. Phoenix Sky Harbor
Airport is located approximately 1 1/2 miles to the
southwest. The Phoenix Military Reservation, a 3/4 square
mile area used by the Arizona National Guard, is located
northeast and east of the plant.
Reason for the Remedial Action Plan
In November 1982, Motorola discovered a discrepancy in the
inventory records for 1,1,1-trichloroethane (TCA) at the 52nd
Street plant. TCA, a solvent used in various manufacturing
processes at the plant,1 was stored for use in a 5,000 gallon
underground tank. In January 1983, the TCA tank and other
underground tanks used for storing virgin solvents were
tested. The results indicated that the TCA tank was leaking.
Within a few days after testing, Motorola discontinued use of
all the virgin solvent tanks and began purchasing solvents in
55 gallon drums.
When the results of the tank test showed TCA leakage,
Motorola notified the Arizona Department of Health Services
(ADHS) and initiated a Preliminary Investigation for soil and
groundwater contamination. The report of the Preliminary
Investigation* which was published on December 9, 1983,
indicated soil and groundwater contamination on the plant
site and groundwater contamination off-site to the west. As
the result of these findings, Motorola entered into a verbal
agreement with the DSEPA, ADHS and ADWR to characterize the
environment near the plant site,, identify the nature and
extent of contamination and recommend remedial actions. One
of the terms of the agreement was that the work would be
performed in accordance with requirements established by the
Comprehensive Emergency Response, Compensation, and Liability
Act of 1980 (CERCLA, or the Superfund Act), Public Law
96-510. During the course of the investigation, CERCLA was
amended by the Superfund Amendments and Reauthorization Act
of 1986 (SARA), Public Law 99-499.
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Mr. Robert Lee
September 27, 1988
Page 3
Draft Remedial Investigation and Feasibility Study reports of
June 1987 were prepared in accordance with the requirements
of CERCLA and SARA. These reference documents contain
citations for the task specifications under which the work
was performed, and list draft reports issued as part of these
studies (see attached Index to Administrative Record). This
Remedial Action Plan has been prepared to summarise the
findings of these investigations.
Voluntary On-Site Treatment
Motorola Inc., . as a responsible party has volunteered to
conduct the RI/FS. The Company has initiated an on-site
groundwater treatment program in 1986. This included
treatability testing, plus design and installation of a Pilot
Treatment Plant (PTP) in the Courtyard at the Motorola plant
site. (See attachment 2} The PTP is still operational and
treats groundwater supplied from two extraction wells which
were installed •in the Courtyard area. Contaminated
groundwater is treated in the PTP, and the effluent is
utilized in air fume scrubbers located at the plant site.
Motorola is currently (1988) expanding the PTP from a nominal
capacity of 35 gpm to 60 gpm to treat contaminated ground
water on site and use the water in manufacturing processes to
replace potable water supplied to the plant from the City of
Phoenix. Motorola intends to maintain operation of the PTP
to continue cleanup of groundwater as part of ongoing
remediations.
Community Relations
A public meeting was conducted on July 11, 1988, to receive
public comment on the proposed partial remedy. Response to
all comments received have been prepared and appear in the
Responsiveness Summary (See attachment 3). The
Responsiveness Summary also outlines other community
relations efforts accomplished in past years.
Purpose of Remedial Action Plan
The purpose of the RAP is to describe the operable unit as a
part of the final remediation of soil and groundwater
contamination. An operable unit is a remedial action that is
•eparated from the overall site cleanup actions when it can
be done expeditiousy, is cost effective, prevents contaminant
migration, and is consistent with the final site remedy.
This RAP has been prepared to describe the interim cleanup of
soil and groundwater contamination associated with historical
disposal of waste solvents and other contaminants at the
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Mr. Robert Lee
September 27, 1988
*age 4
Motorola Inc. 52nd Street Facility in Phoenix, Arizona. (See
attachment 4). The Arizona Department of Environmental
Quality (ADEQ) on March 25, 1988, requested the preparation
of the RAP. Several alternative plans are addressed in the
RAP, each considered as a partial solution or operable unit
for cleanup of contamination. A complete list of all
alternatives considered can be found in the Remedial
Investigation/feasibilty Study (RI/FS). The recommended
alternative, or plan, will be an integral and basic element
for a more comprehensive cleanup of soil and groundwater
contamination.
Alternative Selected
The Remedial Action Plan serves to document the selection of
Alternative C, as the operable unit for remediation of
contamination. Alternative C was modified in the RAP to
discourage discharge of extracted and treated groundwater in
favor of beneficial use options. Alternative C consists of
the following basic components:
o Onsite extraction and treatment of groundwater from the
courtyard and 50th Street area;
o Onsite extraction and treatment of vapor phase organic
contaminants from soils from the courtyard and 50th
Street area, the acid treatment plant, and the southwest
parking lot;
o Offsite extraction of groundwater designed to contain
contaminant migration (east of) at the Old Crosscut
Canal;
o Onsite treatment of groundwater extracted from offsite
wells ;
o Use of all treated groundwater at the Motorola 52nd
Street facility.
Total groundwater extraction and treatment under alternative
C will equal to approximately 810 gpm. Treated effluent
would be used at the Motorola plant to replace water
currently purchased from the City of Phoenix. The only
current uses of the groundwater are one private well for lawn
irrigation and swimming pool filling, and a second well which
is pumped by the Salt River Project to supplement irrigation
water flow in the Grand Canal. There is no current use of
the groundwater for drinking water purposes.
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Mr. Robert Lee
September 27, 1988
Pa
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Mr. Robert Lee
September 27, 1988
Page 5
toxicity, mobility/ or volume as a principal element. All
substantive permit requirements will be met during
implementation of this remedial action. It is determined
that the remedy for this operable unit uses permanent
solutions and alternative treatment technologies to the
maximum extent practicable.
Outstanding issues pertaining to this operable unit will be
more clearly defined and addressed during the Consent Order
negotiations. One item on the list of issues is recovery of
costs. The State and EPA intend to seek recovery of past and
future oversite costs.
Your cooperation and voluntary actions to date are reflective
of a commitment to provide a permanent remedy in the near
future. This operable unit is a step in the right direction.
As explained earlier, the Consent Order will constitute an
enforceable agreement and will provide the vehicle to
implement and accomplish containment and partial remediation.
Further efforts will be required for remediation of the
aquifer. This will be addressed in the Consent Order and
ongoing WQARF investigations.
Thank you for your cooperation. If you should have any
questions regarding this decision letter, please contact
Mr. Dan Marsin at (602) 256-2338.
Sincerely,
Norm Weiss
Assistant Director
NW/gls
cc: Gerald Clifford, EPA
Doug Toy, ADWR
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Tab C
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Attachment 1
VICINITY MAP
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Attachment 2
•.DC t SkOtt *
•kOfi E
-* v
COURTYARD
•LOS 0
^-.IBLOO-
•LOG
•LOG U
ACID TREATMENT j £
PLANT (ATP) AREA
•LOO
SOUTHWEST
PARKING I
LOT (SWPL) }
DRAFT
JUNE 24,1988
FEET
•iiOC »-0i
J]
ir1
VCIT n
" ' SITE PLAN
MOTOROLA 52nd STREET PLANT
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ATTACHMENT 3
RESPONSIVENESS SUMMARY
MOTOROLA 52ND STREET SITE
A. OVERVIEW
During the public comment period for the Motorola 52nd Street
Operable Unit Remedial Action Plan (OU-RAP) from June 24 through
July 25, 1988, the Arizona Department of Environmental Quality
received comments and questions oh the recommended partial
remediation for the Motorola 52nd Street site.
Many of the comments and questions received concerned issues
that are not pertinent to ADEQ's selection of a partial remedy at
the site. However, all comments and questions received are
addressed in this document. In some cases involving complex
questions or those requiring an involved technical response,
reference is made to sections of the draft Remedial Investigation
(RI), the draft Feasibility Study (FS), or the draft RAP.
A number of comments and questions concerned risk and health
assessments associated with the site and indicated a need to
explain the various health related studies. A public health
assessment is an evaluation of potential public health impacts at
a site. A health risk assessment involves characterizing the
risk to human health • posed by chemical releases into the
environment by combining exposures and known dose-responses. An
epidemiologic survey is an evaluation of incidents of diseases in
an area that can be attributed to a specific environmental
factor. A Risk Assessment and Public Health Assessment are
included as part of Motorola's draft Feasibility Study. The
Agency for Toxic Substances Disease Registry (ATSDR) completed a
Health Assessment for the Motorola 52nd Street Facility on May 8,
1988. The ATSDR report concluded that water from offsite wells at
the currently detected concentrations of volatile organic
compounds (VOCs) and inorganic contaminants pose no significant
human health risks as it is now being used, and that no follow-up
health study is indicated at this time. ADEQ however, has
contracted with the Arizona Department of Health Services (ADHS)
to perform a health risk assessment, and an epidemiologic survey
of the area around the Motorola 52nd Street facility.
Final selection of a remedial action alternative and the
design and operation of that alternative will consider issues
brought up during the public comment period.
B. BACKGROUND ON COMMUNITY INVOLVEMENT
As soon as the initial 1,1,1 Trichloroethane (TCA) leak was
confirmed in January 1983, Motorola conducted a number of
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Page 2
activities to inform and update the general public and their
employees at the 52nd Street facility. Most of these activities
involved written correspondence, as summarized below:
Date
Correspondence 2/83 3/83 5/83 9/83 12/83 3/84
News releases to x x
media
Press conference x
Hand-delivered x x x
letters to
residents near
the facility
Interoffice memo x x x x x
to 52nd Street
employees
Summary of premininary x
findings distributed
the media, neighbors,
employees
The October 1984 factsheet and the January 1985 Update #1
newsletter were delivered to approximately 5,000 residents around
the 52nd street facility. Residents were requested to return a
self-addressed stamped business reply card if they wanted to be
placed on the mailing list. One hundred sixty-five (165) cards
were received, 3 percent of those contacted. Agency
representatives, interest groups, and elected officials were added
to the mailing list. In June 1988, the mailing list numbered 450.
The CRP has been followed since December 1984 and became an
appendix to the RI/FS Work Plan. Specific community relations
activities that were conducted from that time through the public
comment period that ended in July 1988 are discussed in
Section F.
C. SUMMARY OF PUBLIC COMMENTS AND AGENCY RESPONSES
LETTER FROM ROBERT C. ANDERSON. P.E.
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Page 3
JL». Question/Comment t It (Newsletter |6) does not address: (1) the
migration rate of the contaminants, (2) the location of other
wells used for potable, irrigation, or swimming pool water (3) an
estimate of when the contaminants will reach those wells (4) how
the proposed remedial action plan pumping rate and duration of
pumping is designed to keep the contaminants from reaching those
wells (5) the effects on dillution of contaminants from migration
and dillution from future ground water charging during the course
of a R.A.P. that may last as long as 20 years (6) why the pumping
rates are not required to be higher.
Response; Update 52nd Street RI/FS, Newsletter |6, is intended
only to summarize the extent of the contamination, the cleanup
alternatives described in the draft Remedial Action Plan (RAP) ,
and the recommended alternative. It also identifies the involved
agencies and tells where the public can find out more about the
site and actually participate in the cleanup decision.
2 . Question/Comment ; Why would the Federal Government consider
funding a clean-up effort such as this that is clearly
attributable to a particular industry that could be held
responsible?
Response ; The Federal Government (or the State of Arizona) is not
considering funding this cleanup action. Motorola, Inc. will
bear the entire cost including appropriate costs incurred by the
Federal Government and those of the State of Arizona as a result
of oversight activities.
Question/Comment t The leaking underground storage tank
referenced was a "virgin" solvent tank and had nothing to do with
the "waste" solvent collection system that was installed. Both
virgin and waste solvents contributed to the contamination
problems over many years.
Response ! Motorola has installed a new virgin solvent system as
well as a new waste solvent collection system.
Question/Comment! Why did it take from 1982 to 1986 for a
pilot treatment program to be initiated?
Response : Immediate remedial actions were initiated during the
first year of the study (1983). Please refer to the RAP for
additional efforts undertaken before and after the implementation
of the PTP.
fbl What is the schedule for construction and operation of the
•roposed R.A.P.?
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Page 4
Response; The schedule for all activities to be performed in the
implementation of the proposed RAP will be addressed in a Consent
Order. The scheduled activities will begin only upon approval of
the RAP and issuance of the Consent Order.
4. fcl How far have the contaminants traveled during the four
years it took to initiate a pilot study?
Response: Contamination in groundwater is predicted to migrate at
varying rates up to 300 feet/year, depending on the configuration
of the contaminant plume. In 4 years, contamination could have
migrated a distance of 1,200 feet or less.
4. fd) How far will they travel before the proposed R.A.P. is
functional?
Response; Contamination migration rates are variable depending on
many factors including local hydrogeologic conditions. Volatile
organic compounds are predicted to migrate at rates approaching
300 feet per year. A primary objective of the recommended
remedial action, Alternative C, is to contain further migration at
the Old Crosscut Canal. As stated above, the implementation
schedule for Alternative C will be established in the Consent
Order.
5. Question/Comment; You list other contaminants found in the
soil and groundwater sampling but you do not identify a R.A.P.
except for volatile organic compounds. What are or were the
sources of the other contaminants? Are the sources now under
control? How are the sources monitored to prevent reoccurance?
When did the contamination occur? What are the measured levels
of contamination? What levels of contamination are safe? Will the
contaminants continue to leach out of the soil into the
groundwater? Is the soil contaminated at the surface level where
it could be potentially harmful by contact with the soil or storm
water runoff over the soil? Are these other contaminants
migrating like the V.O.C.'s? Were measurable quantities of
nickel, cyanide, or other contaminants not listed in page 3
found?
Response; Volatile organic compounds make up the major part of
environmental contamination at the Motorola 52nd Street site.
Inorganics will also be extracted during treatment of
groundwater. Twenty-five (25) potential sources of contamination
have been identified at the Motorola 52nd Street plant (see Table
2.1 of the RAP). All sources were thoroughly investigated and
efforts were made to prevent any further releases. A history of
chemical releases as well as measured concentrations of
contaminants is contained in the Remedial Investigation Report.
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Page 5
All hazardous wastes are managed in compliance with the
Resource Conservation and Recovery Act (RCRA) regulations to
prevent unpermitted releases to the environment. The risk to
public health of contamination is a function of exposure pathways
as well as concentrations. A health Assessment report, dated May
2, 1988, was prepared for the project by the federal ATSDR. Also,
a draft health risk assessment was prepared by Dames & Moore
Chapter 7 of the draft FS reports.
Inorganic contaminants are identified in the draft RI
report, and remediation of contamination is discussed in the
draft Feasibility Study. The migration of inorganic contaminants
is not the same as voc contamination migration in groundwater.
The inorganics bond to soil particles thus the difference in
migration rate. As discussed in the draft RI, inorganic
contaminants detected were found not to have migrated at the same
rate as groundwater in the aquifer. Inorganic levels that were
encountered in the source studies and in groundwater monitoring
are reported in the draft RI report.
6. Question/Comment: How did the contaminants arrive at the
Southwest parking lot area? Surface run-off? Groundwater
migration? chemical spills? Leaks? In addition to Motorola
property, isn't part of this 'general area both public and private
property where natural storm water drainage flows from Northeast
to Southwest washing across and under Motorola property and the
public and private property? What effort is being made to
prevent reoccurence (sic) of the contamination? Will the proposed
R.A.P. address this area and the area on West and Southwest of
the parking lot? The Newsletter indicates the wells will only
extend from McDowell 200 feet South along the canal which does
not appear to address potential migration from the Southwest
parking lot area.
Response; The proposed offsite groundwater extraction system at
the Old Crosscut Canal (Alternative C) will actually extend 2,000
feet or more south of McDowell Road, not 200 feet. The figure 200
feet was a typographical error. Model predictions indicate that
the zone of capture created by this recovery system will encompass
contaminated groundwater emanating from the area of the Southwest
Parking Lot. Information regarding the groundwater extraction
system can be found in the draft RI/FS study.
7. Question/Comment; What is scope and time frame for a
forseeable "complete solution" vs. the partial cleanup or
"operable unit" proposed? Why the Delay?
Response; The proposed operable unit is predicted to
substantially reduce the groundwater contamination in the area of
the plant site, and between the plant site and the Old Crosscut
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Page 6
Canal. It will also contain the high levels of contamination
found to exist within that area from migrating to the west of the
canal. Monitoring of the performance of the operable unit
remediation and/or further studies offsite will be needed before
any further remedial actions can be approved by ADEQ. A risk
assessment and health effects study will also be necessary before
the complete remedy, or final solution, is agreed upon and
implemented. The section pertaining to modeling in the RI provides
timeframe for remediation.
8. Question/Cop™«>nt * What is the planned pumping rate from the
groundvater beneath Motorola property? You state 700 GP? will be
pumped from off-site to the Motorola plant for treatment and use.
What is the total G.P.M. that the water table will be reduced?
700 G.P.M. is approximately 1 million gallons per day x 7
days/week x 52 weeks/year x ? years plus the on-site pumping/
Where is the concern for Arizonas (sic) groundwater supply
problems that are widely publicized and that the Rio Salado
project was going to help resolve? As you state, Motorola
currently gets their water from the city.of Phoenix whose primary
supply is surface water, not ground water.
I believe the Motorola plant uses between 3 and 4 million gallons
per day for all purposes - product processing, sanitary, cooling,
etc. The reclaimed water will have very little value to
Motorola, particularly since the contaminants addressed in item 5
will untimately be discharged into the city of Phoenix sewer
system and then will be discharged in the effluent from the city
treatment plants where they will again have the opportunity to
contaminate soil and ground water or be removed in the sludge
from the. treatment plants which is placed in land fills which
have a similar potential for contamination. Contaminants of this
nature have been a long standing problem for city treatment
sytems.
Assuming a total pumping rate of 2 million gallon per day of
contaminated water that can only be used in a special isolated
system where it could not cross contaminate Motorolas (sic)
potable or process water supplies, the use would- be limited to
scrubbers and cooling towers which are not likely to use that
much water. The end result will likely be direct pumping of the
excess to the city sewer system; which I believe is in violation
of city codes, places an unnecessary load on city sewers and
treatment plants, and depletes the groundwater supply.
Why doesn't the R.A.P. address proper cleaning of all
contaminants and recharging back to the groundwater instead of
proposing an apparently fragrant waste of one of Arizonas (sic)
vital resources?
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Page 7
Two million (sic) gallon/day would supply a population of between
13 and 20,000 people.
Response; Alternative A proposes 4 to 6 wells located in the
Courtyard and the 50th Street area pumping a total of 60 GPM of
groundwater from the alluvium. Each well would include a sump
pump in the bedrock for removal of free phase organic liquid.
Alternative C would place an additional 10 wells among the Old
Crosscut Canal pumping 75 GPM each. The total pumping rate for
the recommended remedial action is therefore 810 GPM
(approximately 1.2 million GPD or 426 million gallons annually).
The treated groundwater will be beneficially used by Motorola at
the plant site. Treatment levels may vary depending on uses of
the water. Prior to discharge to City of Phoenix (COP) sewer all
effluent will meet state Permit requirements and COP discharge
requirements. Recharge of treated groundwater is not judged to be
a technically viable alternative because of the thin alluvium in
the plant area. Use of the treated groundwater for industrial
purposes reduces the demand on the City's potable water supply.
Under the State Superfund rules beneficial use of groundwater
includes industrial uses.
Question/Comment; How will monitoring be done and who will
Vbnitor the discharges of the -removed V.O.C.'s into the
atmosphere from the "cleaning" system? Carbon beds have a
limited capacity and must be replaced or reactivated or
atmospheric discharges will occur. What is the disposal means
for the spent V.O.C. contaminated carbon?
Response; Maricopa County Pollution Control discharge standards
will be met with the utilization of groundwater treatment
system(s). Granulated activated carbon (GAC) Systems will used for
treating soil gases and stripping tower off system gases, and
final polishing of groundwater will vary, current plans call for
some solvent to be recovered (for recycling or incineration) by
steam regeneration of the activated carbon system Other
alternatives are off site disposal as a hazardous waste or off
site regeneration of activated carbon. ADEQ will be attentive to
all monitoring conducted by Motorola and retain the authority to
observe and/or actually conduct the monitoring to assure
compliance with all applicable discharge requirements.
10. Question/CpTOTO?ntT How will monitoring be done and who will
monitor the liquid effluent from the "treatment system" to assure
it is operating effectively so the V.O.C.'s (sic) are not
bypassed on the cooling tower where they will be discharged into
atmosphere?
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Page 8
Response; Motorola Inc. will have monitoring responsibilities.
However, ADEQ will closely supervise and insure the
extraction/treatment systems are working efficiently and that this
system protects public health and environment.
11. Ouesti.on/ppjnflgnti You state T.C.A. replaced T.C.E. at
Motorola in 1973. I believe you will find some T.C.E. was still
being used at Motorola 52nd Street in the early 1980 's.
Response: A small quantity of TCE has been used at the plant since
1980.
LETTER FROM ROBERT C. ANDERSON. P.E.
12. Question/Comment; What specific sources of contamination,
both past and current, from V.O.C.'s as well as the various
inorganics have been identified? What action has been taken to
control the contamination sources and assure they do not reoccur
in the future?
Response: Similar questions/comments were answered as part of
ADEQ's response to number 5. ADEQ will closely supervise the
selected alternative that when implemented will contain migration
and provide treatment._
13. Question/Comment; It is stated the final RI/FS report was due
2/86. Newsletter No. 4 dated 6/86 indicates the feasibility study
had just begun. Why the delay?
Responset The Newsletters are prepared to inform the public of
the status of the investigation and/or remediation at the time
the letters are issued. The schedule for ongoing and future
activities will be stipulated in the Consent Order.
J.4. Question/Comment; It is stated that economic criteria is one
of the factors used in determining the technology to be used for
containment and treatment. I assume this means the cost of the
remedial action. How is the cost evaluated in relation to the
public benefit achieved? In relation to the degree of the
cleanup required? In relation to the number of contaminants that
must be cleaned up? In relation to the number of years it will
take for cleanup? Who has input into the cost evaluation? Who
makes the final decision? How much influence does Motorola have
in this determination? How much influence does Motorolas
Environmental Consultant (sic) have?
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Page 9
Response! Coat effectiveness is only one of many criteria
determining the selection of a remediation plan at the Motorola
52nd Street site. (See A.A.C. R18-F-109). Protection of public
health and water quality are the primary concerns. The Motorola
52nd Street site is a State Lead site with ADEQ as the lead agency
involved in the decision making process.
15. Question/Comment; It is stated that cleanup of inorganic
contaminants was under consideration. Newsletter No. 6 does not
indicate any cleanup effort except for volatile organic carbons
(V.o.C.'s). Why?
Response: Inorganic remediation will be fully addressed as part of
the complete remedy. The RI/FS provides data and information
pertaining to inorganics.
16. Question/Comment; It is stated there are few precedents for
solving groundwater contamination problems. The concepts of
pumping for chemical and physical treatment have been practiced
in various parts of the United States for more than 10 years.
The technology is little different than that used for wastewater
treatment, potable -water treatment, and many industrial
applications.
Response t We agree that in the State of Arizona there are only a
few full scale operations addressing groundwater contamination.
Also please refer to response number 5 for more detail.
17. Question/Comment! It is stated .the V.o.C.'s are not
considered a health hazard when irrigation water is used for
edible crops but the affect of heavy metals and other inorganic
contaminants is not addressed. Why? What is the potential health
hazard?
Response t The Arizona Department of Health Services (ADHS) is
currently conducting a risk assessment and epidemiological survey
relative to the Motorola 52nd Street site. Inorganics will be
addressed along with associated risks in the final RI/FS.
18. Question/Comment; The Newsletter avoids answering the
question on health hazards from contact with contaminated
irrigation water by simply referencing the physical dangers in
canals and irrigation ditches. What are the potential hazards?
Again, V.o.C.'s are addressed but not other contaminants. If I
understand correctly, well water is used for irrigation when the
canals are "dried up" for cleaning and maintenance.
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Page 1C
Response: similar questions/comments were addressed as part of
ADEQ's response to number 17.
19. Question/Commenti The Newsletter states the public hearing on
the Remedial Action Plan (R.A.P.) was to be held in mid 1986. It
is two years late. Why?
Response t Alternative C as presented in the current RAP is the
first acceptable plan for extraction and treatment of contaminated
groundwater. Limited remediation in the pilot treatment plant
has been ongoing since 1986. Please also refer to the Community
Relations section of this Responsiveness Summary.
20. Question/Comment; It is stated the Pilot Plant was designed
to treat 35 G.P.M. According to Letter No. 6, 700 G.P.M. will be
treated from off-site pumping and an unstated G.P.M. will be
treated from on-site pumping. What is the total G.P.M. to be
treated? What is the estimated cost of the treatment and pumping
facility? What is the schedule for full capacity operation.
What portion of the costs for the R.I./F.S. will Motorola pay?
What portion of the costs for the Pilot Study and R.A.P. will
Motorola pay? Who pays the remainder of each?
What is the G.P.M. demand for Motorolas (sic) process
exhaust scrubbers and cooling water towers? What happens to the
remaining G.P.M. of water pumped or will pumping be limited to
the capacity needed for the scrubbers and cooling towers?
Response; See response to comment #8. It is estimated that
Alternative C implementation (design and construction) and the
first year of operation will cost about $3 million to $3.5
million. Motorola, Inc. will bear all costs. Thereafter, operation
and maintenance will cost up to about $1 million annually. The
schedule for full capacity operation will be negotiated as part of
the Consent Order. The demand for treated water for the process
exhaust scrubbers is approximately 170 gpm, cooling towers will
vary between 120-240 gpm, and the deionization plant will use the
balance of the extracted and treated water.
21. Question/Comment! It is stated the Pilot Plant was to be
designed for both organic and inorganic contaminant removal. Was
it? Is inorganic removal part of the R.A.P.?
Response t Yes. the FTP was designed for treatment of organic and
inorganic contaminants. Please refer to the RI/FS.
22. Question/Cppnen^; The water table contour map on Page 4 shows
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Page 11
ground water flow to be in a southwesterly direction, much the
sane as surface water flow. Letter No. 6 states interceptor
wells are to be placed along the canal to approximately 200 ft.
south of McDowell Road. The map on Page 5 shows a pocket of
contaminants extending out to the McDowell Road/Canal area that
the proposed wells would intercept. This pocket appears
inconsistant with the indicated direction of ground water flow
except for the stated differences in permeability. The city
sewer flowing west among McDowell Road could have contributed to
this pocket by leaking Motorola wastes. The McDowell sewer was
the main Motorola discharge until about 1960 when a west bound
sewer along Culver Street was installed. McDowell still received
some Motorola discharge. The proposed interceptor wells among
the canal will certainly not intercept the indicated main
direction of sub-surface slope. This is supported by the
statement at the bottom of Page 3 of Newsletter* No. 4 which says
that in the alluvium the plume appears to extend farther to the
southwest but in the bedrock it is more westerly.
Response; See Figure 5.4, Predicted Zones of Influence Pumping
at Old Crosscut Canal, in the Draft Remedial Action Plan. The
predictions of groundwater movement and contaminant migration are
presented in the draft RI and FS reports, and will be updated
data from continued groundwater monitoring. Please refer to
response to Question number 6 for additional information.
23. Question/Comment; Page 6 shows isolated contaminated pockets
south of the plant. The 15" primary sewer line serving the plant
(installed in the mid 1960's when the Culver Street sewer was
abandoned) runs south along what was formerly 50th Street with
some discharge to the city sewer on McDowell Road but the primary
flow goes south. The 50th Street sewer is Motorola owned to
Roosevelt Street where it enters the city system, the city sewer
flows south to south of the high school and then goes west to
48th Street, and then again south to the Salt River interceptor.
These contamination pockets are consistant with the direction of
flow of Motorola chemical wastes. Again, leaks in the city sewer
could account for this contamination.
It is stated the contaminants in these pockets "differ" from
those found elsewhere. How are they different? Chemical
constituents? Concentrations? What are the contaminants? Does
Motorola use or have they ever used these chemicals? Who
researched Motorolas past and present chemical use? Could the
contaminants be a by-product of Motorolas chemical processes?
Improper treatment of waste discharges from the Motorola
Facility (such as pH control) could have damaged the 50th Street
and McDowell Road sewers causing leaks.
e; This will be addressed in the final RI. See the draft
These potential sources were investigated with soil-gas
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Page 12
monitoring and other techniques employed in the RI investigation.
The results are reported in the draft RI report.
24. Question/CQTmflifrn.'ti it is stated that former and present plant
employees were interviewed. Those most knowledgable of the
plants environmental history are: -Leo Rogers, Former
Environmentalist; Robert Hays, Former Environmentalist and
Chemical Operations Manager; Harry Kattelman, Former Facilities
Engineers & , Operations Supervisor; Nicholas Hild, Former
Envoronmental Manager; H. Theodore Werner, Former Environmental
Legal counsel; Robert C. Anderson, P.E. Z was not interviewed?
Were any of the others? Which ones? Who did the interviewing?
There are documented records and witnesses to the fact that
spills and leaks from buried pipes and buried tanks contaminated
the site. This included acid waste, heavy metals, etc. Dry
wells were used routinely. In earlier years, wastes were dumped
in a depression on site fondly known as "Lake Motorola".
The statements in this Newsletter indicate either the
content is controlled by Motorola, and inadequate investigation
was done, or the people interviewed were not knowledgeable.
Hopefully, the knowledge of current actual and potential
contamination sources is more accurate.
There is no excuse to be apparently ignorant of actual facts
four years into the investigation.
Response; Information was gathered from many sources as
identified in Chapter 2 of the draft RI report. Please also see
the Community Relations section of this Responsiveness Summary.
25. Question/Comment t Page 4 states surface water is checked for
V.O.C.'s. is it checked for inorganics? What are the results?
The stormwater drainage channels along 50th Street and southwest
through public and private property have a long history of
chemical contamination from leaks, spills, and washdown
operations .
Response ! This has all been addressed in the draft Remedial
Investigation report, Section 2, Source Characterization. The
practices years ago are not the same as today. The current
objective is cleanup to protect public health and the environment.
26. Question/Comment: Page 2 states the Pilot Plants (sic)
success at removing V.O.C.'s but does not address the
effectiveness of removing inorganics although it is stated that
the Pilot Plant is designed for inorganic removal.
Response; See the draft FS. The newsletters are not intended to
present every detail of the data collected or work performed.
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Page 13
Inorganics removal will be part of the criteria for authorizing a
remedial alternative. Please also refer to the draft RI for design
details.
27. Quest ion/CQnmie^fc' Aepainr there is no indication of inorganic
contaminant locations or concentrations. Why? What are they?
Response ; See draft RI. See response to comment number 26.
28. Quest ion/Cop^eirti what; are the "twenty" potential sources of
organic and inorganic contamination? Are these current sources?
Past sources? Both?
Response: Please refer to the section on Source Investigation of
the RI.
FROM PAMELA E. SWIFT. TOXIC WASTE INVESTIGATIVE GROUP. INC.
29. Question/Comment; If there is anyone here from the public, I
would like for them to tell me just how much of that number they
just understood. _
Response ; The information presented at the public meeting was to
inform the public. of the alternative remedial activities proposed
by Motorola, Inc. The speakers attempted to present the
information in non-technical language and answer any questions
that were brought up. Alternative C as an operable unit has been
recommended as the best plan to begin mitigation of the
contamination problem at the Motorola 52nd Street site. Public
response to the plan will be considered before a final decision
is reached on how to proceed.
30. Quest ion/C9Bff**Ttt * (MQ™ Peterson) doesn't follow that up by
telling the public there are not any health problems because we
along with the EPA and along either the CDC, Center for Disease
Control, are not looking for health problems.
Response: The ADHS is conducting studies to try and determine if
there is a connection between TCE contamination and public health
concerns. This work is being conducted under an agreement between
ADEQ and ADHS. See Administrative Record Index for reference to
Public Health Assessment studies.
31. Question/Comment: What they are not letting the public know
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Page 14
is one, in often cases, who polluted their water, how long their
water was polluted and with what. And the public is out there
being damaged every day.
Response; The known contaminant and extent of contamination from
the Motorola Plant was reported in Chapter 2 of the RI. The water
in that area is not used for drinking purposes. A Health
Assessment was completed May 2, 1988 by ATSDR. It can be reviewed
at the Saguaro Branch of the Phoenix Public Library or at the AOEQ
Library, 1st Floor, 2005 N. Central, Phoenix, AZ. An
epidemiological survey, scheduled for completion by May 1, 1989,
is being conducted by AOHS.
32. Question/Comment; DEO says the workers are not their
responsibility. Who is taking care of those workers?
Response: Motorola has a fully staffed safety department,
including an industrial hygienist, who monitors plant operations
for compliance with OSHA regulations. The State of Arizona is an
authorized state for enforcement of OSHA programs, which meets
federal standards. This is administered by the Arizona Industrial
Commission. The Arizona OSHA can be called at the request of
employees.
33. Question/Comment; This is supposed to be a public meeting.
It's held in July. Did you really want to get the public here?
Response-; An accelerated schedule was implemented in an effort to
begin remediation as soon as feasible. July 11, 1988 was chosen
as the date for a public meeting in an effort to fit the
schedules of the active participants in the Motorola 52nd Street
Project during the 30 day public comment period. The site of the
meeting was picked for the convenience of area residents and
proved to be quite comfortable.
Intent is to get interested public to the meeting. It was
held in a location near the plant. The meeting was held in the
evening to facilitate greater attendance. Proceeding the meeting
notice was published in local newspaters on July 7, July 8, and
July 25, 1988. Update |6 also announced the public meeting. It
was hand delivered to the 5,000 nearby residents, and mailed to
450 persons on the mailing list. The month the meeting was held
is basically irrelevant.
34. Question/Comment; T want these in my comments, and by the
way, I want the comments sent to me this time. I have heard that
since '83 you were not really making transcripts to properly
address my concerns.
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Page 15
Response; A written transcript of the entire public meeting was
nade and is available for review at ADEQ's office at 2005 North
Central Avenue in Phoenix.
35. Question/Comment: I have some problems with Dames & Moore
doing the studies and they also are on almost a full-time basis
with the city of Phoenix.
Response; See ADEQ response to similar comment number 66.
36. Question/Cop™?^? The great letters that were sent out by the
EPA, or DEQ or both, the last count I had, those letters that you
are mailing to the public, 15 people, (sic) Is that the count?
That's the count I have on record. That's why I didn't get
noticed.
Response; Ms. Swift and 450 other interested parties were
notified of the public meeting by regular mail. Notices were
delivered by hand to about 5000 residents throughout the area of
the Motorola 52nd Street site.
37. Question/Comment; I doubt very seriously that Motorola has
been out $10 million.
Response; Motorola's latest figures indicate the company has
spent approximately $10.5 to $10.6 million on this project. This
total includes expenditures for source elimination. The
preliminary investigation, the remedial investigation, the
feasibility study and Remedial Action Plan. This figure has been
verified by AOEQ. Please also see Mr. Steve Smith's response to a
similar question in the Public Meeting record.
38. Question/Comment! I'm asking you to please send me a list of
every dime the state has been out on this Motorola mess because I
have been finding out through other investigations that the
Department goes in and takes soil samples and puts monitoring
wells down and does all sorts of things and never recovers the
cost.
Response: ADEQ is currently compiling a list of all activities it
has participated in and the costs incurred relating to the
Motorola 52nd Street Project. The mechanism for cost recovery,
namely the Consent Order, is currently being drafted. Some
samples have undoubtedly be split and analyzed by the State Lab
to verify results reported by Motorola. The State of Arizona has
|Lncurred none of the capital expenditures relating to the
project. The state will also recover future oversight costs.
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Page 16
39. Question/Comment! These technical assistance grants that were
mentioned to the public, I'm going to comment about that because
we have jumped through that hoop.
Response; The Technical Assistance Grants (TAG) program is a
federal program designed to financially assist qualifying public
groups in hiring experts to represent their views and explain
technical aspects of projects such as the Motorola 52nd Street
Project. AOEQ will assist such groups in making applications
under the TAG program.
40. Question/Comment; I would also like the physical address of
all of the wells that were polluted.
Response; See Table 1.6 in the draft Feasibility Study (F/S).
FROM ROBERT C. ANDERSON. P.E.
41. Question/Comment: They are discharged to the sewer along
McDowell Road both ways. There is a natural drainage ditch runs
northeast to southwest to this site. Back in the early days that
was an open ditch. Motorola dumped their chemicals in it.
Response: Please refer to the Source Investigation section of the
RI and Table 2.1 of the RAP.
42. Question/Comment: That's cyanide waste treatment.
Response; Please see response to comment number 41.
43. Question/Comment! Heavy chemical use, discharges into the
atmosphere, heavy discharges chemicals to sewer, (sic)
Response t Please see response to comment number 41.
44. Question/Cppqgntt Qne time in the late •70s the drains in the
floors had been eaten through to the extent that they brought in
several Ready-Mix trucks, concrete Ready-Mix trucks, to fill the
hole in the ground under that building.
Response; Please see response to comment number 41.
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Page 17
45. Quest ion/C7m?ntr HQU *^out a leaking chrome tank in that
area?
Response: Please see response to comment number 41.
46. Quest ion/CoFperyt' There was some question about where
flourides came from. How about from the acid waste lines.
Response; Please see response to comment number 41.
47. Quest ion/7oitl?ien^i HQM about the heavy metals.
Response; Please see response to comment number 41._
48. Question/Comment; You talk about the plume from the plant.
You are probably seeing the tail of what was left.
Response; Please see response to comment number 41.
49. Question/Comment; Spills, contamination, washdown, leaks,
washed right through the plant into these people's property. The
high school is down here. Kids played in that ditch. How did
the contamination get in the south parking lot? that's one way
right there.
Response; Please see response to comment number 41.
50. Quest ion/ Comment; They had a sewer that they tapped into
going down Culver Street, surcharged to the point that it
overflowed into the people's yards.
Response ; Please see response to comment number 41.
51. Quest i on/ C9fl"q«»ntT i-*fcer they put in a 15 inch sewer going
south. That sewer is known to have leaks.
Response; Please see response to comment number 41.
52. Question/Comjn^n1?! Tn the influent boxes to the acid waste
treatment system, eaten through, has been leaking in the ground
for years.
Response ; Please see respose to comment number 41.
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Page 18
LETTER PROM PAMELA E. SWIFT. TOXIC WASTE INVESTIGATIVE GROUP. INC.
53. Quest ion /Comment! What is the groundwater migration and
surface water run-off? A map of this should be encluded in the
Draft Remedial Action Plan.
Response; These subjects are covered in the RI.
54. Question/Comment? wheyfe will Motorola get their water from
for this project? Since Motorola does not have any water rights
and this project will require thousands and thousands of gallons
of water it is important that Motorola state where this water
will come from. The City of Phoenix, whould not supply water to
Motorola for this project as they have stated in the past that
there is a great water shortage in the City. This fact has been
driven home by the City of Phoenix's increased water rates to the
public. What is the total amount of water used by Motorola?
Response t The beneficial use of treated groundwater will reduce
Motorola's demand on City of Phoenix supplied water. Alternative
C calls for the withdrawal of about 810 gpm of groundwater from
onsite and off site extraction wells. It is proposed that the
water be withdrawn under a Poor Quality Groundwater Withdrawal
Permit to be issued by the Arizona Department of Water Resources
(ADWR) , and monitored by ADWR, ADEQ, and Maricopa County.
55. Question/Comment; Who will monitor the discharges of
contaminates into the atmosphere from the air stripping process?
Air monitoring should not be done by Motorola as they cannot be
trusted to turn in proper readings. This should be done by the
department's air pollution department, (purchasing equipment for
this project if you have to) . Also, air monitoring should be
taken of the entire plant before and after the air stripping
project begins. I have long suspected that Motorola has
extensive air pollution around thier (sic) plant and has not been
truthful in the results of their air monitoring program. For
this reason they should not be allowed to do their own
monitoring.
Response t The Maricopa County Pollution Control has authority to
monitor air emissions. See also response to comment number 9.
56. Question/Cogent* whafc chemicals are being used at the
Motorola plant at this time. This is a very important factor as
I believe that Motorola is still using TCA amoung (sic) other
chemicals that are hazardous to the public. Motorola is one of
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Page 19
the states biggest polluters. They have little or no regard for
the public health and well being. Chemicals are being used by
Motorola that are harmful to the public. Motorola should be
required to list all of the chemicals that they are using. The
department should test for all the chemicals that Motorola has
used in the past and that Motorola is using now. Water, soil,
and air test should be taken at this site. While the department
is looking at this one problem, I suspect that Motorola is
creating several other chemical problems.
Response; Information on chemical use and discharge is to be made
available to the public under the Emergency Planning and
Community Right-to-Know Act program. Also, under the State's
Hazardous Waste Management Act, hazardous materials are regulated
as to storage, transfer, treatment and disposal.
57. Question/ Comment; More thought needs to be given to the
treatment system. This entire section is not complete. What
assurance does the public have that Motorola will operate this
system as they have stated? An outside firm should completely
take over the treatment system and apply BADCAT (sic) to this
project. Their (sic) are too many holes in the proposed treatment
operation as it is now.
Response: Best Available Demonstrated Contol Technology (BADCT)
will be applied. Through the Poor Quality Ground water
Withdrawal Permit process, administered by ADWR, and the Consent
Order to be administered by ADEQ, a monitoring system will be
established for the treatment process. Reports would be required
on a regular basis and oversight would be as specified in the
Consent Order.
58. Question/Cqmpgnti s^te and Federal money should not be used
in this project at all. Motorola made the mess and should use
their money to clean it up. So far the department has thousnads
(sic) , if not millions, invested in this project and have not made
an effort to recover public funds used to date. Since Motorola
has poison poisoned (sic) the environment for miles around their
plant and has no doubt caused endless damage to the public's
health and well being, it is foolish to use the public's money to
help Motorola clean up this mess. The department should send a
bill to Motorola for the cost incurred to date. The
Environmental Protection Agency should also send a bill for cost
to Motorola.
Response; Please see response to comments number 2 and number 38.
59. Quest jon/
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Page 20
that are classified as hazardous waste, for over ninty (sic) (90)
days before shipping them off site?
Response; Motorola does not store hazardous wastes on site over
90 (ninety) days. Storage of chemicals must follow RCRA
requirements.
60. Question/Comment; Un-used chemicals ploouted (sic) the
environment but have not been properly addressed in the Drfat
(sic) Remedial Action Plan. Not all of the chemicals that
polluted were hazardous waste. Are chemicals, other than
hazardous waste, being monitored by the Department? It not, why
not?
Response; Other pollutants are being monitored. Onsite chemical
handling is conducted in accordance with applicable lavs,
regulations and corporate guidelines.
61. Question/Comment; Since it has taken so long for this peoject
to get off the ground, how far have the contaminates traveled?
What is the projected travel distance for these environmental
hazards before this project is completed.
Response: Please refer to the draft RI and FS reports as well as
the responses to questions number 4(d) and number 22.
62. Question/Comment; I doubt that Motorola has invested over 10
million in this project. the department should not use
Motorola's figures in their printed matter since they have not
seen the proper and correct talley sheet for Motorola's cost to
date.
Responset See response to comments number 37 and number 38.
63. Question/Cpffrrent« Pameg and Moore does work for the City of
Phoenix. They are doing work for the City regarding the 19th
Avenue Landfill. In the past, Motorola used the 19th Avenue
Landfill, for this reason, and many others, Motorola should not
use Dames & Moore as their consultants. This is a clear conflict
of interest. The department should not relay soley (sic) on the
Dames and Moore (sic) report. They should do their own studies
and charge it back to Motorola.
Response t See response to comment number 35. Motorola is not using
Dames & Moore as its consultant on the 19th Avenue Superfund
project. As required under the Comprehensive Environmental
Response Compensation and Liability Act (CERCLA) Section 104,
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Page 21
Motorola, Inc. through its contractor, Danes & Moore, has
demonstrated the qualifications necessary to conduct the RI/FS
and implement remedial actions at the Motorola 52nd Street
facility. All activities by Motorola and its contractor(s) in
conducting the RI/FS and any remedial actions are subject to the
oversight of ADEQ and will in no way be subjected to a lesser
standard of performance or liability than if ADEQ was conducting
the RI/FS and remedial action.
64. Question/Comment; Contaminated wells in the property should
be closed down and Motorola should pay the cost of supplying
water to the property owners.
Response; Had a threat to public health existed this program
would have been implemented. No private wells have been
identified which are in use for drinking water purposes.
Furthermore, the ambient quality of the groundwater affected by
VOC contamination is too high in total dissolved solids (TDS) to
be utilized economically as a source of potable water. Therefore,
groundwater in the area is not used for potable purposes at this
time. Potable water is supplied to the area by the City of
Phoenix via surface water sources.
FROM MATTHEW R. BERENS. ESQ.. HERON. BUCHETTE. RUCKERT. &
ROTHWELL. FOR THE PHOENIX UNION HIGH SCHOOL DISTRICT 1210
65. Quest ion/Comment: Groundwater is currently contaminated
beneath the East High School property. The extent of contamination
beneath the East High School is unknown.
Response; This is generally correct. Model predictions are based
on a source of contamination (TCE) existing in the subsurface in
the area of the Courtyard. Predictions cannot represent all
observations accurately. In addition, other potential sources
such as in the Southwest Parking Lot could be contributing to the
observed contaminant levels in the area of East High School
property. Please also refer to figure 4.3 in FS.
66. Question/Cpmjn?Trti ****** ground water will be contaminated for a
long time in the future.
Response; Please see the response to comment 168. Also,
Alternative C consists of plans to reduce VOC contamination
directly upgradient of the abandoned school property by
extracting and treating soil-gases from the unsaturated zone at
the Southwest Parking Lot. This remediation is expected to also
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reduce VOC contaminant levels in ground water downgradient of the
Southwest Parking Lot. Please refer to figure 4.3 in FS for
additional information.
£2.. Question/Comment: Motorola's proposed remedial program does
not address present contamination beneath the East High Property.
There is currently no plan to remediate the present ground-water
contamination beneath the East High property.
Response; Alternative c, consisting of 10 wells along the Old
Crosscut Canal pumping 75 gallons per minute each, does address
present contamination beneath the East High Property. The
northern half of the East High property is within the predicted
zone of influence of the proposed line of wells along the Old
Crosscut Canal. At the same time onsite remediation (Alternative
A) will reduce contaminate concentrations upgradient of the East
High property. In addition, see responses to comment number 70.
68. Question/Comment; Volatile organics in the gas phase (soil
gas) have been detected beneath the East High property.
Response; Soil boring results show soil gas contamination.
Remediation in the Southwest Parking Lot will result in reduction
of soil-gas concentration (see comment number 70) . It should be
noted that the observed concentrations of VOCs in the area of the
East High School property are approximately the same order of
magnitude as that detected in ambient air.
69. Question/Cogent* "Ph** use of water beneath the property is
limited.
Response: For several reasons, no beneficial use of groundwater
is effected at the present time. The alluvium is thin; bedrock
is shallow. Water is supplied economically by the City, and
inorganic background water quality would probably require
treatment before use in any case.
D. ATTACHMENT LISTING COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
THE SITE PRIOR TO AND DURING THE PUBLIC COMMENT PERIOD.
Mailing List
The mailing list was continually reviewed and updated
throughout the RI/FS. At three different times, newsletters were
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Page 23
hand delivered to approximately 5,000 residents asking them to
return a self-addressed stamped reply card if they wanted to be
added to the mailing list. At the time of the July 11, 1988
public hearing, the mailing list numbered 450.
Central Information Source
Three contact persons were designated to respond to
inquiries from the public. Their names, addresses, and telephone
numbers were identified in press releases, newsletters, and local
information repositories. These individuals were the community
relations specialists from EPA, AOEQ, and Mr. Ken Phillips of
Motorola.
Local Information Repositories
Two information repositories were established: the Saguaro
Branch of the Phoenix Public Library and the ADEQ Library. During
1985, the Balsz School was the repository until the branch library
opened. Technical reports, fact sheets, newsletters, articles,
and other written materials were placed in these repositories
throughout the RI/FS. The .locations and hours were advertised in
khe newsletter. The Administrative Record also contains a
complete index of project data and documents.
Task Force and Technical Subcommittee
A Task Force, comprised of representatives from federal,
state, and local agencies, was established to provide technical
oversight to Motorola, Inc. in performing RI/FS activities. A
Technical Subcommittee, chaired by ADWR, was formed to facilitate
review and approval of the technical aspects of the RI/FS.
The status of community relations was a regular agenda item
at the Technical Subcommittee meetings. Committee members were
kept informed of community relations activities, and helped to
identify public concerns and additional public information needs.
They were better able to understand the impact of committee
decisions or relationships with the community.
Factsheets and Newsletter
One factsheet and six newsletters, known as "Updates," were
prepared and distributed between October 1984 and June 1988.
itober 1984 Summary of site history, activities to date
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Page 24
Update II
January 1985
Update *2
May 1985
Update 13
October 1985
Update 14
June 1986
Update *5
December 1986
Update #6
June 1988
Drilling notices
and RI/FS Work Plan.
Specific RI/FS tasks; answers to citizens
questions.
Results of resident interviews; announcement
completion of Phase I; status of Phase II
studies; glossary.
Plans for pilot treatment plant; overview
of geology of area; summary of soil gas
results; glossary.
Status report on sources verification,
pumping tests, groundwater model, water
quality tests; announcement of start of
feasibility studies; glossary*
Description of pilot treatment
operation; status of feasibility
studies; glossary.
plant
Summary of draft Remedial Action Plan (RAP)
focusing on remedial alternatives; glossary;
announcement of public comment period and
public meeting.
During the RI, when wells were being drilled, notices were
delivered to nearby residents. These notices informed them of
the drilling schedule, how the site would be secured, what the
noise level night be, how the drillers would be dressed, and any
other inconveniences they might encounter. They were given names
and telephone numbers to call if they had questions. All drilling
has been done in accordance with state regulations under ADWR's
authority.
Public Comment Period
A 30-day public comment period on the draft RAP extended
from June 24 to July 25, 1988. Notice of the comment period and
the upcoming public meeting was published in local newspapers on
July 7, July 8, and July 12, 1988. Update #6 also announced the
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Page 25
comment period, the availability of the draft RAP, and the public
meeting. This was hand delivered to the 5,000 nearby residents,
and sent to those on the mailing list on June 24, 1988. The
draft RAP was placed in the information repositories.
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ATTACHMENT 4
• ENVIRONMENTAL CONTAMINATION
A. On-site end Off-Site Contamination
GROUNDWATER 1985 - 1986
Contaminant Maximum Values
On-Site Off-Site
Arsenic
Cadmium
Chromium
Lead
Nitrate
1,1,1 Trichloroethane
Trichloroethylene
Trans-1, 2-Dichloroethyler.t
1,1-Dichloroethane
1, l-Dichlorethylen,e
Tetrachloroethylene
2.6 ppm
•• 1.9 ppm
3.5 ppm
0.8 ppm
680 ppm
472 ppm
1280 ppm
19.6 ppm
15.8 ppm
93.6 ppm
127 ppm
0.4 ppm
140 ppm
1.6 ppm
0.1 ppm
12 ppm
7 ppm
37 ppm
28 ppm
0.3 ppm
5 ppm
0.4 ppm
Levels of inorganics determined from unfiltered samples.
Soil On-Site 1985-1986
1,1,1-Trichloroethane
Trichloroethylene
Tetrachloroethylene
Carbon Tetrachloride
Ethyl Benzene
189 ppm1
222 ppm1
130 ppm'
31 ppm
120 ppm'
Depth
25 Feet
28.5 Feet
20 Feet
25 ' Feet
20 Feet
'Values found
Courtyard area
in soil from a single soil boring taken in
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Soil-Gas 1985
On-Site Depth Off-Site Depth
10000 ppb 3.2 Feet 7000 ppb
5000 ppb 3.2 Feet 100 ppb
4000 ppb 3
40000 ppb 3
1.7
1.7
1,1,1 Trichloroethane
Trichloroethylene
Tetrachloroethylene
Trichlorotrifluoroethane
ppin-parts per million.
ppb-parte per billion
Maximum Off-Site values were found immediately adjacent
2 Feet 8000 ppb
2 Feet 2000 ppb
1
1
Feet
Feet
Feet
Feet
on-site sampling point where maximum on-site
were found.
to the
contaminant levels
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Exhibit A
COMPARISON OF REMEDIAL ACTION ALTERNATIVES
Issue
1. Postulated reduction
of threat to public
health
2. Amount of ground
water pumping for
treatment
3. Effective contain-
ment of off-site
contaminant migration No
No
Action
No
4. Need for off-site
treatment/disposal
5. Total costs (Capital
+ First Year O&M)
and Cost Per Gallon
TCE Removed
6. Institutional
Requirements
No
N/A
N/A
7. Beneficial Use
None
Plan A Plan C
Yes
60 gpm 810 gpm
No Yes
No No
$1.7 M $3.8 M
Minimal PQGWWP, Air
Emissions
Plan D
Substantial Substantial
100% in 100% in
plant plant
3500 gpm
Yes
Yes
$8.5 M
Plan C +
Aquifer
Protection
Permit and
Water Rights
Off-site
disposal;
exceeds
on-site
capacity
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