United States
Environmental Proection
Agency
Share your opinions
EPA invites you to participate in
the cleanup process at the Copley
Square Plaza site. Your input helps
EPA determine the best course
of action. Please attend a public
meeting at 7 p.m., Wednesday,
July 22, at the Copley Community
Center, 1278 Sunset Drive.
A comment period has been set
up to provide you an opportunity
to share your comments on the
site cleanup. Comments should be
submitted from June 29 to July 30,
2009:
• Orally or in writing at the
public meeting.
• Via the Internet at www.epa.
gov/region5/publiccomment/
copleysquare-pubcomment.htm.
• Fax to Susan Pastor at
312-385-5344.
Contact EPA
Sam Chummar
EPA Remedial Project Manager
312-886-1434
chummar. sam@epa.gov
Susan Pastor
EPA Community Involvement
Coordinator
312-353-1325
pastor.susan@epa.gov
Call EPA Region 5 toll-free
800-621-8431
9:30 a.m. to 5:30 p.m., weekdays
Mike Bolas
Site Coordinator/Geologist
Ohio EPA
330-963-1109
mike.bolas@epa.state.oh.us
EPA Proposes Cleanup Plan
for Polluted Ground Water, Soil
Copley Square Plaza Superfund Site
Copley, Ohio
June 2009
Site map with general outline of plume.
A cleanup plan proposed1 by U.S. Environmental Protection Agency
calls for polluted shallow ground water (between 0 and 20 feet below
the surface) to be treated and several homes in the Copley Square
Plaza area connected to public water supplies. In addition, access to
ground water would be restricted and systems put in place under some
homes to prevent harmful gases from rising up through the ground into
homes in a process known as "vapor intrusion."
'Section 117 (a) of the Comprehensive Environmental Response, Compensation, and Liability
Act (CERLCA) requires publication of a notice and a proposed plan for the site remediation.
The proposed plan must also be made available to the public for comment. This proposed plan
is a summary of information contained in the remedial investigation, feasibility study, and
other documents in the administrative record for the Copley Square Plaza site. Please consult
those documents for more detailed information.
-------
EPA and state partner Ohio EPA have been
investigating ground water pollution south and east of
the Copley Square Plaza. The proposed cleanup plan
is a result of that study.
Investigators believe old wastewater pits at a former
dry cleaner in the shopping plaza allowed a chemical
called tetrachloroethene, commonly known as PERC,
to soak into the ground where it contaminated the
ground water. PERC is in a class of chemicals called
volatile organic compounds or VOCs. VOCs can
dissolve in water and evaporate easily, giving off
dangerous fumes.
You have 30 days to file written comments on EPA's
proposed plan. See the box on Page 1 to find out how.
EPA could alter its proposed plan or even choose a
new one based on public comments.
Site background
Ohio EPA responded to complaints in April 1990 of
an odor in water from wells serving two businesses
in the Copley Square Shopping Center, a dry cleaner
and a grocery store. Ohio EPA found that the ground
water contained VOCs at levels higher than what EPA
considers safe.
After four years of extensive testing, Ohio EPA
discovered the wastewater pits at the former dry
cleaner and found several homes affected by the
contamination. Ohio EPA then asked for assistance
from EPA to protect local residents from the polluted
water. EPA oversaw the installation of water treatment
systems in nearby homes with contaminated wells, the
closing of eight wastewater tanks at the dry cleaner
and the installation of a system to collect the ground
A device such as this one could possibly be used indoors to
collect air samples from underneath homes.
This residential vapor abatement system, which is about the size
of a football, could be installed on the outside of a house.
water. Ohio EPA maintains these systems today. In
2000, Ohio EPA found the ground water was still
contaminated. There had been no improvement since
the mid-1990s. The site was placed on the federal
Superfund list in April 2005. That made the site
eligible for federal funding because no private parties
have been identified with the financial ability to pay
for the investigation and cleanup.
EPA's study of the site revealed that the PERC-
contaminated ground water had formed a plume, or
mass of contaminated water, affecting the homes
previously identified by Ohio EPA. Not only is the
plume not safe for drinking should a private well tap
into it, but the pollution may pose the threat of vapor
intrusion.
All units in the Meadows of Copley are on a public
water supply, so drinking contaminated water is
not a concern. Air samples were collected at four
buildings, which contain 26 units, for soil gas and
indoor air contamination. The four buildings were
selected for testing because they sit nearest the
underground plume. Sample holes were drilled next
to the buildings as well as in an undeveloped area
to the west. Low levels of PERC and other harmful
VOCs were detected in the indoor air but not at levels
considered dangerous in the short term.
EPA tested 23 private wells, including eight already
on filtration systems, along Copley Road, North
-------
Plainview Avenue and South Plainview Drive. EPA
was looking for PERC contamination in private
well water and the indoor air at some of the homes.
Sampling defined the boundaries of a ground water
plume extending from Copley Square Plaza southeast
along Copley Road to South Plainview Drive and
Appletree Road. Contamination wasn't found in any
additional homes.
Some homes were also tested for vapor intrusion.
Investigators drilled a 1-inch diameter hole 6-8 feet
deep outside each house and sampled for harmful
gas trapped between soil particles. Basements were
also sampled. VOCs were found in some of the
samples. Sample results were mailed to the affected
homeowners.
EPA considered three cleanup alternatives to clean
up the shallow ground water and deal with the
potential for vapor intrusion in homes. Each option
was evaluated each against nine criteria required
by law (see box on Page 7 for an explanation of the
criteria). They have not yet been evaluated for state
and community acceptance because these criteria are
typically judged after EPA proposes a cleanup plan
and holds a public comment period.
The recommended alternative provides the
best balance of the nine criteria and meets the
requirements of federal law. It protects public health
and the environment over the long term, complies
with state and local regulations, and is cost-effective.
Originally, several other alternatives were looked
at but were eliminated because they were deemed
ineffective.
Of
Four actions are common to Alternatives 2 and 3.
They are:
1. "Institutional controls" are measures that
prevent people from using or accessing a
particular area. In this case, a local ordinance
would prevent new wells from being installed
in contaminated areas and restrict use of the
ground water until EPA determines it meets
appropriate standards.
2. "Alternate water supply" means area homes
that use wells for their water supply would be
connected to the public water system. Some
work would be needed on the public water
supply infrastructure in the area.
3. "Sub-slab depressurization" is a system that
prevents vapor intrusion into basements. It
is not intended to treat soil beneath the slab.
The system extracts air from soil beneath a
building through holes in the slab, and then
vents any possible vapor to the outside where
it is harmless. EPA would do periodic indoor
air monitoring to ensure the system is keeping
potentially dangerous vapors out of the home.
4. "Ground water and indoor air samples"
will be taken on a regular basis to monitor
the contamination and effectiveness of the
treatment.
Alternative 1 - No Action: EPA would do nothing to
clean up the pollution, which means there would be
no effect on potential health risks. The Superfund law
requires the no-action alternative to provide a baseline
for comparison with other options. Cost: $0.
Evaluation Criteria
Overall Protection of Human Health and the Environment
Compliance with ARARs
Long- Term Effectiveness and Permanence
Reduction of Toxicity, Mobility, or Volume through Treatment
Short- Term Effectiveness
Implementability
Cost
State Acceptance
Community Acceptance
Alternative 1
c
o
c
c
•
«
$0
Alternative 2
*
*
»
•
•
®
$5 million
Alternative 3
«
•
*
*
®
®
$5 million
Will be evaluated after the public comment period.
Will be evaluated after the public comment period.
Meets Criteria ® Partially Meets Criteria o Does Not Meet Criteria
-------
Alternative 2 - Institutional controls, alternative
water supply, sub-slab depressurization and
in-place ground water treatment by reductive
dechloriiiation (EPA recommends this alternative):
In addition to the three common elements, this
alternative relies on a process called "in situ (in-
place) treatment," which simply means treating
the shallow ground water and soil while it is still
underground rather than digging/pumping it out to
remove contaminants. The process of "reductive
dechlorination" involves injecting a chemical
compound into the ground water at points directly
east and west of the former dry cleaners. This
compound would react with the PERC in the ground
water and soil and change it chemically into a non-
toxic substance that degrades easily. This process
could take as little as two years to remove the
contamination. Monitoring of the ground water and
vapor intrusion would continue until the water meets
EPA's standards. Cost: $5 million.
Alternative 3 - Institutional controls, alternative
water supply, sub-slab depressurizatlon, In-place
ground water treatment by chemical oxidation
reductive dechlorination polishing: This option
is almost identical to Alternative 2 except for the
method of treating the shallow ground water and soil.
This alternative would rely on injections of an oxidant
into the ground water over a period of a few months,
followed by an injection of the chemical compound
described in Alternative 2. This would more rapidly
decrease the amount of contamination in the ground
water. Cost: $5 million.
Of
EPA recommends Alternative 2 because it provides
the best, most cost-effective long-term cleanup
solution and best protection of people and the
environment.
In its detailed evaluation, EPA compared the
remaining alternatives to the nine criteria mentioned
on Page 7. EPA concluded the "no-action" alternative
would not protect people or the environment and it
was eliminated from further consideration.
All the alternatives except 1 comply with applicable
environmental laws and regulations.
Alternatives 2 and 3 provide long-term effectiveness.
They treat the soil and ground water and are adaptable
because it would be easy to conduct additional
treatment if ground water contamination returns or
persists.
Alternatives 2 and 3 would be effective in the short
term because they include connecting residents
to the public water supply, restricting access to
contaminated ground water and addressing the
potential problem of vapor intrusion.
Alternative 2 protects workers better than Alternative
3 because the material injected into the ground is
less dangerous to cleanup crews. Workers could
come into contact with the soil and dust that
are potentially contaminated with VOCs. Both
alternatives would also present physical hazards to
workers and create noise and traffic problems in the
community. Alternatives 2 and 3 would have some
risk to construction workers, but these risks would be
minimal because substances used in Alternative 2 are
non toxic. The substances used in Alternative 3 just
require more care in handling by site workers.
Both alternatives protect human health and the
environment because they address the source of the
contamination by treating the ground water and soil.
Before it makes its decision final, EPA will review
comments received during the public comment period
and at the public meeting. Based on new information
presented in the comments, EPA may modify its
proposed plan or select another option.
EPA encourages you to review and comment on the
proposed cleanup plan. Much more detail on the
cleanup options is available in the official documents
on file at the information repositories or EPA's Web
site (listed on Page 7).
EPA will respond to the comments in a document
called a "responsiveness summary." This will be
part of another document called the "record of
decision" that describes the final cleanup plan. The
Agency will announce the selected cleanup plan in
a local newspaper, place a copy in the information
repositories and post it on EPA's Web site. Next year,
EPA plans to continue its investigation of deep ground
water to determine the best way to clean it up.
-------
Public Comment Sheet
EPA is interested in your comments on the proposed cleanup plan for the Copley Square site. You may use the space
below to write your comments, detach this page, then fold and mail the form. Or, you may submit comments on your own
paper. Comments must be postmarked by July 30, 2009. You may submit your comments to Susan Pastor at
pastor.susan@epa.gov or fax to 312-385-5344. You can also submit comments on the Web at
www.epa.gov/region5/publiccomment/copleysquare-pubcomment.htm or hand them in at the July 22 public meeting.
If you have any questions, please contact Susan Pastor at 800-621-8431, Ext. 31325, 9:30 a.m. - 5:30 p.m., weekdays.
Name:
Affiliation:
Address:
City:
State: Zip:
-------
COPLEY SQUARE SITE
PUBLIC COMMENT SHEET
Name
Address
City
State Zip
FIRST CLASS
Susan Pastor
EPA Community Involvement Coordinator
EPA Region 5 (mail code SI-7J)
77 W. Jackson Blvd.
Chicago, IL 60604-3590
-------
Evaluation criteria
EPA uses nine criteria to compare cleanup alternatives:
1. Overall protection of human health and the environment addresses whether an alternative
adequately protects both human health and the environment. The cleanup plan can meet this
criterion by reducing or eliminating contaminants or by reducing exposures to them.
2. Compliance with applicable or relevant and appropriate requirements assures that each project
complies with federal, state and local laws and regulations.
3. Long-term effectiveness and permanence evaluates how well an option will work in the long
term, including how safely remaining contaminants can be managed.
4. Reduction of toxicity, mobility or volume through treatment addresses how well the option
reduces the toxicity (the chemical makeup of a contaminant that makes it dangerous), movement and
amount of contaminants.
5. Short-term effectiveness is how quickly the project achieves protection, as well as its potential to
be harmful to human health and the environment while it's being constructed and operated.
6. Implementability evaluates the technical feasibility of the cleanup plan, and whether materials and
services are available to carry out the project.
7. Cost includes estimated capital or startup costs, such as the cost of buildings, treatment systems and
monitoring wells. The criterion also considers costs to implement the plan, and operate and maintain
it over time. Examples include laboratory analysis and personnel to operate equipment.
8. State acceptance is whether the state environmental agency, in this case Ohio EPA, agrees or
disagrees with EPAs recommended alternative.
9. Community acceptance evaluates if the community near the site accepts the option. EPA evaluates
community acceptance after it receives and evaluates public comments on its recommended
alternative.
For more information:
You may review site-related documents at:
Copley Township Trustees Office
1540 S. Cleveland-Massillon Road
Copley
Fairlawn-Bath Public Library
3101 Smith Road
Akron
On the Web:
www.epa.gov/region5/sites/copleysquare
An administrative record, which contains detailed information that will be used in the selection of the
cleanup plan, is also located at the Fairlawn-Bath Public Library.
7
-------
EPA Proposes
Cleanup Plan for
Polluted Ground
Water, Soil
Copley Square Plaza
Superfund Site
(details inside)
Upcoming Public Meeting about
Copley Square Plaza
Site Cleanup Plan
Wednesday, July 22
7 p.m.
Copley Community Center
1278 Sunset Drive
At the meeting, EPA will explain the proposed plan and
provide opportunities to ask questions and make oral
comments. You may also submit written comments.
If you need special accommodations for the meeting
contact Susan Pastor by Wednesday, July 15. Her contact
information is on Page 1.
Web Site
Site information is also posted on the Internet at:
www.epa.gov/region5/copleysquare
To comment electronically:
www.epa.gov/region5/publiccomment/copleysquare-
pubcomment.htm
069C-K)9091I 'o
•pA|g uos>per M ZZ
(rZ-IS) uojSjAia punjjsdns
g uojBsy
AousBy
|E)U9UJUOJ!AU3
------- |