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EPA

Region 2

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Notice of

U.S. Environmental Protection Agency's
Determination to Not Take
Superfund Action at
LCP Bridge Street Operable Unit 2
and Wastebeds 9 to15

October 2010

INTRODUCTION

The Onondaga Lake Superfund Site consists of Onondaga
Lake and its tributaries and upland areas that contribute or
have contributed contamination to Onondaga Lake.
Currently, twelve areas of concern have been determined
to be part of the Onondaga Lake Superfund Site. This
Notice is intended to solicit public comment on the
Environmental Protection Agency's (EPA's) determination
to not take federal Superfund action at two areas, which
have been evaluated, but are not included in the twelve
areas of concern noted above. These areas of concern are
LCP Bridge Street Operable Unit 2 (OU2)1 and Wastebeds
9 to 15 (see the attached figure for the location of the
areas of concern).

Because there is no identified pathway for Site-related
contamination to migrate from either the LCP Bridge Street
OU2 or Wastebeds 9 to 15 areas of concern to Onondaga
Lake, no action is required under the Comprehensive
Environmental Response, Compensation and Liability Act
of 1980 as amended (CERCLA), 42 U.S.C.§9601, et seq.
The fact that no federal Superfund response action is
anticipated regarding these areas of concern does not in
any way affect what is considered to be the Onondaga
Lake Superfund Site. In addition, this determination does
not preclude New York State from taking actions at these
areas under its authorities, as appropriate.

DETERMINATION TO NOT TAKE SUPERFUND ACTION

the Town of Geddes, Onondaga County, New York. The
approximately 20-acre property is located in an industrial
area on Gere Lock Road, west of Bridge Street (Route
297), and south of the New York State Fairgrounds and an
active railroad right-of-way. A scrap yard is located north
of the property, a cogeneration facility is located to the
west, and the former NAKOH Chemical facility is located
to the northeast.

The LCP Bridge Street Site consists of two OUs. OU1
consists of approximately 18 acres of the facility. Since it
was determined that OU1 has impacted the Onondaga
Lake Site, actions under CERCLA were performed to
address those impacts. A Record of Decision was issued
in September 2000 which selected a remedy for OU1.
The major components of the selected remedy included
the following:

removal of tanks, containers and transformers;
building demolition;

sediment excavation and restoration of the West
Flume and wetlands;

soil washing, which reclaimed approximately 8
tons of elemental mercury;

soil excavation of the Brine Mud Area and North
Ditch;

excavation of pipes and sewers, which provided
preferential pathways for contamination to enter
into the West Flume; and

installation of a slurry wall, groundwater collection
and cap system.

LCP Bridge Street Operable Unit 2

The LCP Bridge Street area of concern is situated
approximately 2 miles northwest of the City of Syracuse, in

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An operable unit (OU) is, defined, as a discrete action.that
comprises an incremental step toward comprehensively

addressing site problems. This discrete portion of a

remedial response manages migration, or eliminates or

mitigates a release, threat of a release, or pathway of

exposure. The cleanup of a site can be divided into a

number of OUs, depending on the complexity of the

problems associated with the site. OUs may address

geographical portions of a site, specific-site problems, or

initial phase of an action, or may consist of any set of

actions performed over time or any actions that are

concurrent but located in different parts of a site.

All of the remedial work at OU1 has been completed with
the exception of the final cap (a temporary cap is currently
in place) and some limited soil excavation work.

OU2 consists of a 1.7-acre area where a former hydrogen
peroxide plant was located at the facility. This area is north
of the West Flume (a man-made stream), south of the
New York State Fairgrounds, a scrap metal recycling
facility and an active railroad right-of-way, east of an area
of OU1 called the brine mud area, and west of the former
NAKOH Chemical facility.

In September 2002, under a consent order with the New
York State Department of Environmental Conservation
(NYSDEC), Honeywell commenced a remedial


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investigation and feasibility study (RI/FS) for LCP Bridge
Street OU2. During the Rl, sediment, soil, groundwater
and surface water samples were collected and analyzed.
The results of the Rl indicate that the historical use of
xylene at the facility has contaminated the groundwater,
which migrates to the West Flume. Localized
contamination of sediment in the West Flume has resulted.
The concentration of xylene, however, rapidly decreases
downstream of the facility and does not extend to the
mouth of the West Flume, which in turn flows into Geddes
Brook, then into Ninemile Creek, and ultimately into
Onondaga Lake. The contaminated sediments in the
West Flume have been addressed as part of the OU1
remedy.

In March 2010, following the completion of the RI/FS,
NYSDEC selected a remedy for LCP Bridge Street OU2
under state authorities. The major components of that
remedy include:

•	Injection of chemical oxidants into the ground to
treat the contaminated soil and groundwater;

•	Construction of a cover to prevent contact with
contaminated soils and migration via storm water
runoff;

•	Development of a site management plan;

•	Imposition of an environmental easement to (a)
limit the use and development of the property to
commercial/industrial use; (b) insure compliance
with the site management plan; and (c) restrict the
use of groundwater for drinking; and

•	Long-term monitoring.

Wastebeds 9 to 15

Wastebeds 9 to15 are a series of massive waste mounds,
670 acres in size, that are former liquid waste lagoons
which received process wastes from Allied Chemical's
(predecessor to Honeywell International Inc. or Honeywell)
manufacturing operations from 1944 to 1986. The
Wastebeds are located adjacent to Ninemile Creek, a
major tributary to Onondaga Lake. The waste in the
former lagoons is primarily nonhazardous calcium
carbonate/chlorides from the manufacturing of soda ash
using the Solvay Process. In addition, wastes from the
Bridge Street Chlor-alkali plant, consisting of spilled
materials, mercury, asbestos, lead, and wash water, and
wastes from the chlorinated benzene manufacturing at the
Willis Avenue plant, consisting of asbestos, wash water,
spilled material, lead, mercury, and heavy organic
residues, were disposed of here. Other substances
disposed of at the Wastebeds include fly and bottom ash
from the plants, sewage sludge from the County's
wastewater treatment plant, Anheuser-Busch brewery
sludge, and brine purification muds. Wastebed 15 also
received demolition debris and soil from decommissioning

the Allied Chemical main plant. A portion of the old Erie
Canal, which lies beneath Wastebed 15, was used as a
landfill by the Town of Camillus. In addition, the Town of
Camillus operates a construction and demolition waste
landfill in portions of Wastebed 15.

Most of the surface of the Wastebeds is covered with a
variety of vegetation, including grasses, brush, and trees.

The groundwater under the Wastebeds is highly saline
due to the leaching of salts from the Solvay waste. A
hydrogeological assessment was performed between
1987 and 1989 to evaluate groundwater and nearby
surface water quality near the Wastebeds. A Supplemental
Site Investigation was conducted in 1998. Contaminants
that were identified include relatively low concentrations of
volatile organic compounds, phenols, and metals,
including mercury. While contaminants were detected in
the sediments and surface water in seeps and swales
located adjacent to the Wastebeds and in Ninemile Creek,
it is likely that these contaminants were released when the
lagoons were in operation and/or released from the former
LCP Bridge Street facility. While hazardous substances
are present at the Wastebeds, the available data indicates
that the levels of contaminants from the Wastebeds that
are present in Ninemile Creek are minimal and that the
Wastebeds do not impact Onondaga Lake. Specifically,
water samples collected from Geddes Brook and Ninemile
Creek indicated that mercury contamination in the water
column is mainly confined to the reaches below the source
at the LCP Bridge Street plant. Data from sediment
samples collected around Wastebeds 9 to 15 indicated
that groundwater and runoff of sediment from the
Wastebeds is not contributing to the high concentrations of
mercury seen in the sediments downstream of the Geddes
Brook discharge. Data collected for the Geddes
Brook/Ninemile Creek Rl indicate that the upper reaches
of the streams (i.e., Geddes Brook upstream of the West
Flume; and Ninemile Creek upstream of the Geddes Brook
discharge), are not significant sources of mercury and
other CERCLA contaminants to the lower reaches of the
streams. Surface water sampling during the Geddes
Brook/Ninemile Creek Rl also indicated that the West
Flume and the sediments downstream of the West Flume
were significant sources of mercury to surface water.
Overall, the data collected during the Geddes
Brook/Ninemile Creek RI/FS and Geddes Brook/Ninemile
Creek OU1 Supplemental FS indicate that contamination
from Honeywell operations was primarily confined to the
lower reaches of Geddes Brook and Ninemile Creek), and
that surface water and sediment concentrations of mercury
in the upper reaches of Geddes Brook and Ninemile Creek
were generally consistent with non-point sources (e.g.,
urban runoff), thus, not warranting remediation. It should
be noted, however, that results from an investigation of a
drainage ditch which adjoins Geddes Brook upstream of

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the culverts beneath the Conrail railroad tracks indicate
that elevated levels of mercury are present in sediment
and flood p la in soils. The presence of contamination in the
drainage ditch appears to be the result of backflow from
Geddes Brook and/or historic overflows from the
Wastebeds when they were in use as settling basins.
Contaminated sediments and flood p la in soil in and near
the drainage ditch will be addressed under the Geddes
Brook Interim Remedial Measure prior to remediating
contaminated channel sediment and flood plain
soil/sediment in and adjacent to the lower reach of Geddes
Brook.

NYSDEC is currently negotiating a consent order with
Honeywell for the closure of Wastebeds 9 to 15.

It should be noted that sediments removed from
Onondaga Lake as part of the Lake Bottom remedy will be
dewatered and permanently stored in an engineered
Sediment Consolidation Area (SCA) located on Wastebed
13.

CONCLUSION

Based on the foregoing, EPA, with NYSDEC's
concurrence, has concluded that no federal Superfund
response actions are required at LCP Bridge Street OU22
and at Wastebeds 9 to 15. Both potential areas of
concern are being or will be addressed under state
authorities.

It should be noted that pursuant to CERCLA requirements,
the Onondaga Lake Bottom Site remedy will be reviewed
not less than once every five years to ensure that it
remains protective of human health and the environment.
This review, which will be summarized in a "Five-Year
Review Report," will be based upon an evaluation of the
results from monitoring of the remedy. An assessment of
the protectiveness of the SCA on Wastebed 13 will be
included in that evaluation.

SUPPORTING DOCUMENTATION

Documentation in support of this determination includes
the following:

Environmental Assessment of Lower Reaches of
Ninemile Creek and Geddes Brook, Oswego
Watershed, New York. Prepared for AlliedSignal,
Solvay, NY by CDR Environmental Specialists,
Stow, MA. July 1991;

Summary Data Report, Allied Wastebeds 9 to 15
and Lower Nine Mile Creek Valley, Blaslound,
Bouck & Lee, July 1995;

Onondaga Lake RI/FS West Flume Mercury
Investigation and Supplemental Sampling and
Ninemile Creek Supplemental Sampling Data
Report. Prepared for AlliedSignal, Inc., Syracuse,
NY by PTI Environmental Services, Bellevue,
WA, 1996;

Supplemental Site Investigation Report,
Wastebeds 9 to 15, Blaslound, Bouck & Lee,
August 1999;

Wastebeds 9-15 Subsite Evaluation, NYSDEC,
June 2000;

Record of Decision, LCP Bridge Street Subsite,
NYSDEC, September 2000;

Remedial Investigation Report, Onondaga Lake,
TAMS, December 2002;

Remedial Investigation Report, Geddes
Brook/Ninemile Creek, TAMS/EarthTech, July
2003;

LCP Bridge Street OU2 Subsite Evaluation,
NYSDEC, February 2004;

Feasibility Study, Onondaga Lake, Parsons,
November 2004;

Record of Decision, Onondaga Lake Bottom
Subsite, NYSDEC and EPA, July 2005;

Feasibility Study, Geddes Brook/Ninemile Creek,
Parsons, May 2005;

Supplemental Feasibility Study, Geddes
Brook/Ninemile Creek OU1, Parsons, November
2008;

Record of Decision, Geddes Brook/Ninemile
Creek Site OU1, NYSDEC and EPA, April 2009;
Supplemental Feasibility Study, Geddes
Brook/Ninemile Creek OU2, Parsons, May 2009;
LCP Bridge Street Subsite, Five-Year Review,
EPA. October 2009;

Record of Decision, Geddes Brook/Ninemile
Creek Site OU2, NYSDEC and EPA, October
2009;

Remedial Action Report and Certification, LCP
Bridge Street Site (OU1), Parsons, November
2009;

Record of Decision, LCP Bridge Street OU2,
NYSDEC March 2010; and

Frequently Asked Questions (FAQs) Onondaga
Lake Dredging Project, Sediment Consolidation
Area (SCA) at Wastebed 13, NYSDEC, New York
State Department of Health, EPA, April 2010.
Geddes Brook/Ninemile Creek Addendum to the
Outfall 019 Drainage Ditch Pre-Design
Investigation Data Summary Report, Parsons,
May 2010.

LCP Bridge Street OU1, which is an identified source of
contamination to Onondaga Lake, has been addressed
through a nearly completed Superfund response action.

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These documents can be found in the following
repositories:

Onondaga County Public Library
Syracuse Branch at the Galleries
447 South Salina Street
Syracuse, NY 13202
Telephone: 315-435-1900

Atlantic States Legal Foundation
658 West Onondaga Street

Syracuse, NY 13204
Telephone: 315-475-1 170
Please call for an appointment.

New York State Department of Environmental
Conservation, Syracuse Office
615 Erie Boulevard West

Syracuse, NY 13204
Telephone: 315-426-7400
Please call for an appointment.

Solvay Public Library
615 Woods Road
Solvay, NY 13209
Telephone: 315-468-2441

New York State Department of Environmental
Conservation, Central Office
625 Broadway
Albany, NY 12233
Telephone: 518-402-9676

PUBLIC COMMENT

EPA is soliciting public comment on its determination to
not take Superfund action at the Wastebeds 9 to 15 and
LCP Bridge Street OU2 areas of concern. To this end, this
document has been made available to the public for a 30-
day comment period which concludes on November 30,
2010.

Comments should be sent to:

Robert Nunes
Remedial Project Manager
Central New York Remediation Section
U.S. Environmental Protection Agency, Region 2
290 Broadway, 20th Floor
New York, New York 10007-1866

telefax: 212-637-3966
e-mail: nunes.robert@epa.gov

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