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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     Page 22


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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