RECORD OF DECISION
Former Facility and Groundwater Portion of the
General Motors - Inland Fisher Guide Subsite
of the Onondaga Lake Superfund Site
Town of Salina, Onondaga County, New York
New York State Department of Environmental Conservation
and
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United States Environmental Protection Agency
Region II
September 2023
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Former Facility and Groundwater Portion of the General Motors - Inland Fisher Guide
Subsite of the Onondaga Lake Superfund Site
Town of Salina, Onondaga County, New York
New York State Superfund Identification Number: HW734057
New York State Operable Unit: 1
Federal Superfund Site Identification Number: NYD986913580
Federal Operable Unit: 26
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the New York State Department of
Environmental Conservation (NYSDEC) and U.S. Environmental Protection Agency's
(EPA's) selection of a remedy for the former facility and associated groundwater portion
of the General Motors Inland Fisher Guide subsite (Subsite) of the Onondaga Lake
Superfund site, chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, as amended
(CERCLA), 42 U.S.C. § 9601-9675, and the National Oil and Hazardous Substances
Pollution Contingency Plan, 40 CFR Part 300 (NCP). This decision document explains
the factual and legal basis for the selection of a remedy to address the contaminated
soil/fill materials and shallow and intermediate groundwater associated with this Subsite.
The attached index (see Appendix III) identifies the items that comprise the Administrative
Record upon which the selected remedy is based.
The New York State Department of Health (NYSDOH) was consulted on the proposed
remedy in accordance with CERCLA Section 121(f), 42 U.S.C. § 9621(f), and it concurs
with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances at this Subsite, if not addressed
by implementing the response action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy includes the following components:
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• Three areas where high concentrations of residual volatile organic compound
(VOC) contamination exist in saturated soil will be addressed using in-situ
treatment. These three areas contain contaminants at concentrations greater than
10,000 parts per million (ppm) and represent continuing sources of groundwater
contamination. Specifically, these areas include the Former Thinner Tanks Area,
where non-chlorinated VOC residual contamination remains, and areas beneath
and northeast of the former manufacturing building where residual chlorinated
VOC contamination remains. As part of the remedial design (RD), pre-design
investigations will be performed in each of these areas to determine the volumes
requiring treatment and the most effective type of in-situ treatment(s).
• Installation of deep groundwater extraction wells along the northern perimeter of
the facility property. Contaminated groundwater that has migrated from the source
areas identified above will be extracted from these wells to prevent off-property
migration. Following extraction, the contaminated groundwater will be treated at
the existing State Pollution Discharge Elimination System (SPDES)1 water
treatment system (using filtration and granulated activated carbon) prior to being
discharged to Ley Creek. The groundwater extraction system will be designed
with a capture zone sufficient to address the areal and vertical extent of the
groundwater contamination. During the RD, a study will be performed to determine
the extraction well location placement, the groundwater pumping rates, and the
drawdown levels necessary to achieve optimal capture. To evaluate the
effectiveness of the extraction system, a groundwater monitoring program will be
implemented as part of this remedy.
• An estimated 38 cubic yards of unsaturated surface soil will be excavated and
disposed of off-site at a licensed disposal facility. The soils requiring excavation
are those that contain contaminants at concentrations greater than the Industrial
Use soil cleanup objectives (SCOs) for polycyclic aromatic hydrocarbons and
polychlorinated biphenyls and are located in areas not currently addressed by an
approved Interim Remedial Measure (IRM)2 or covered and isolated by facility
paved surfaces (roadways or parking lots) or the former manufacturing building.
Following confirmatory soil sampling to demonstrate that the SCOs have been
achieved, the excavated areas will be restored to grade with clean fill meeting the
requirements of 6 NYCRR Part 375-6.7(d).
• The existing sub-slab depressurization system (SSDS) beneath the former
manufacturing building includes two sub-slab vapor extraction systems that
withdraw air at a rate of approximately 195 cubic feet per minute for System 1 and
94 cubic feet per minute for System 2. An evaluation of the SSDS will be
performed during the RD to determine whether enhancements to the system could
further improve the removal of elevated VOCs in the unsaturated soil beneath the
1 SPDES is a permit program that regulates the discharge of water from point sources into the
waters of the State of New York.
2 An IRM is a New York State law term for an environmental response that is synonymous with
the CERCLA environmental response term "removal action." The use of the term "IRM" in this
document is used solely for consistency with underlying documents, but references actions that
are in fact removal actions under CERCLA.
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former manufacturing building. Data will be collected to determine if the existing
SSDS can be upgraded to not only continue to prevent sub-slab vapors from
entering the former manufacturing building, but also to enhance the removal of
chlorinated VOC contamination present in the vadose zone soil beneath the
building.
• As part of long-term groundwater quality monitoring, data will be collected in the
shallow and deep groundwater throughout this portion of the Subsite to assess the
contaminants of concern (COC) concentrations and natural attenuation. Following
the operation of the perimeter groundwater extraction and treatment system for a
period up to five years, an evaluation will be performed to determine whether the
system is effectively reducing COC concentrations in the off-property groundwater.
If it is determined that continued groundwater extraction at the facility property
perimeter alone will not achieve the remediation goals for the off-property
groundwater within a reasonable timeframe, then off-property in-situ treatment
techniques and extraction and treatment will be considered and incorporated into
the remedy as determined to be appropriate.
• The evaluations of the SSDS and perimeter extraction system and the
implementation of any of the associated alternative remedies will be documented
via an Explanation of Significant Differences (ESD).
• As part of a long-term monitoring program, shallow and deep groundwater samples
will be collected from monitoring wells throughout this portion of the Subsite to
evaluate the performance of the groundwater extraction and treatment system, as
well as the effectiveness of the in-situ treatment in the three residual source areas
where high concentrations of site contaminants remain. The details of the
monitoring program will be developed as part of the RD/remedial action (RA) and
outlined in a Monitoring Plan.
• The remedy will also include an Institutional Control (IC) in the form of the existing
environmental easement for the controlled property which will achieve the
following:
1. require the submission of a periodic certification of institutional and
engineering controls in accordance with Part 375-1.8 (h)(3);
2. restrict the use and development of the former facility property to industrial
use as defined by Part 375-1.8(g), subject to local zoning laws;
3. restrict the use of groundwater as a source of potable or process water
without appropriate treatment as determined by the NYSDOH or the
Onondaga County Health Department; and
4. require compliance with the approved Site Management Plan (SMP).
• An SMP will be required that includes the following components:
1. An Institutional and Engineering Control Plan that identifies all use
restrictions and engineering controls for the portion of the Subsite and
details the steps and media-specific requirements necessary to ensure the
following institutional and/or engineering controls remain in place and
effective:
¦ an excavation plan that details the provisions for management of
future excavations in areas of remaining contamination;
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¦ a provision for further investigation and remediation should large-
scale redevelopment occur, if any of the existing structures are
demolished, or if the subsurface is otherwise made accessible. The
nature and extent of contamination in areas where access was
previously limited (beneath the 800,000 square foot former
manufacturing building) or unavailable will be immediately and
thoroughly investigated pursuant to an approved plan. Based on the
investigation results and a determination of the need for possible
additional RAs, a remedy modification will be developed for the
portion of the Subsite, including removal and/or treatment of any
source areas to the extent feasible. Citizen Participation activities will
continue through this process. Any necessary future remediation will
be completed prior to, or in association with, redevelopment. This
includes the former manufacturing building;
¦ descriptions of the provisions of the environmental easement
including any land use or groundwater use restriction;
¦ provisions for the management and inspection of the identified
engineering controls;
¦ maintain site access controls and notification; and
¦ steps necessary for the periodic reviews and certification of the
institutional and/or engineering controls.
2. A Monitoring Plan to assess the performance and effectiveness of the
remedy. The plan will include, but may not be limited to the following:
¦ monitoring of groundwater to assess the performance and
effectiveness of the remedy;
¦ a schedule of monitoring and frequency of submittals; and
¦ monitoring for vapor intrusion for any buildings on the facility
property, as may be required by the Institutional and Engineering
Control Plan described above.
3. An Operation & Maintenance (O&M) Plan to ensure continued operation,
maintenance, optimization, monitoring, inspection, and reporting regarding
any mechanical or physical components of the remedy. The plan includes,
but is not limited to, the following:
¦ procedures for operating and maintaining the remedy;
¦ compliance monitoring of treatment systems to ensure proper O&M,
as well as providing the data for any necessary permit or permit
equivalent reporting;
¦ maintaining site access controls and required notification; and
¦ provide access to the site and O&M records.
• Long-term O&M will be performed for the above-noted RAs, as well as for the
previously implemented IRMs, including the Former Landfill IRM, Surface
Impoundment Cover #1 IRM, Former Thinner Tanks Groundwater Recovery
System IRM, SPDES Treatment System IRM, and the Vapor Intrusion Mitigation
IRM (i.e., SSDS).
• Maintenance activities and performance monitoring will be conducted to ensure
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that the remedial elements and IRMs are operating effectively and efficiently and
to identify the need to implement corrective action(s). Corrective actions for the
IRM covers, as well as the existing paved surfaces {i.e., roadways or parking lots)
and the former manufacturing building that currently serve as a cover for impacted
shallow soils, may consist of repair in areas of disturbance or re-application of
vegetation in areas of non-survival.
• Green remediation techniques, as detailed in NYSDEC's Green Remediation
Program Policy-DER-31,3 and EPA Region 2's Clean and Green Policy4 will be
considered during the implementation of the selected remedy to reduce short-term
environmental impacts. Green remediation best practices such as the following
may be considered:
1. Use of renewable energy and/or purchase of renewable energy credits to
power energy needs during construction and/or O&M of the remedy;
2. Reduction in vehicle idling, including both on- and off-road vehicles and
construction equipment during construction and/or O&M of the remedy;
3. Design of cover systems, to the extent possible, to be usable for alternate
uses, require minimal maintenance {e.g., less mowing), and/or be
integrated with the planned use of the property;
4. Beneficial reuse of material that will otherwise be considered a waste, and
5. Use of ultra-low sulfur diesel.
DECLARATION OF STATUTORY DETERMINATIONS
Part 1- Statutory Requirements
The selected remedy meets the requirements for RAs set forth in CERCLA in Section
121, 42 U.S.C. § 9621, because, as implemented, it will: 1) protect human health and the
environment; 2) meet a level of standard of control of the hazardous substances,
pollutants, and contaminants which at least attains the legally applicable or relevant and
appropriate requirements under the federal and State laws; 3) be cost-effective, and 4)
utilize permanent solutions and alternative treatment technologies to the maximum extent
practicable.
Part 2- Statutory Preference for Treatment
CERCLA includes a preference for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of hazardous substances as a
principal element (or provide a justification for not satisfying the preference). Under the
selected remedy, VOCs in the groundwater will be subjected to both extraction and
treatment at the SPDES treatment plant and in-situ treatment by injecting an
amendment(s), thereby reducing their volume, toxicity, and mobility. In addition, the
3 See http://www.dec.nv.qov/docs/remediation hudson pdfZder31.pdf
4 See http://epa.gov/reqion2/superfund/qreen remediation
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SSDS may be upgraded to enhance the removal of chlorinated VOC contamination
present in the vadose zone soil beneath the former manufacturing building, thereby
reducing their volume, toxicity, and mobility. Therefore, the selected remedy satisfies the
statutory preference for treatment as a principal element of the remedy.
Part 3- Five-Year Review Requirements
Because this remedy will result in hazardous substances, pollutants, or contaminants
remaining on-site above levels that allow for unlimited use and unrestricted exposure, a
statutory review will be conducted within five years after initiation of the RA and at five-
year intervals thereafter until levels that allow for unlimited use and unrestricted exposure
are attained to ensure that the remedy is, or will be, protective of human health and the
environment.
ROD DATA CERTIFICATION CHECKLIST
The ROD contains the remedy selection information noted below. More details may be
found in the Administrative Record file for this Subsite.
• COCs and their respective concentrations (see ROD, pages 8-13 and Tables 1
and 2 in Appendix II);
• Baseline risk represented by the COCs (see ROD, pages 14-20);
• Cleanup levels established for COCs and the basis for these levels (see ROD,
page 30 and Tables 1 and 2 in Appendix II);
• Manner of addressing source materials constituting principal threats (see ROD,
page 37);
• Potential land and groundwater use that will be available at this Subsite as a result
of the selected remedy (see ROD, page 14);
• Estimated capital, annual operation and maintenance, and present-worth costs;
discount rate; and the number of years over which the remedy cost estimates are
projected (see ROD, page 42 and Table 5 in Appendix II); and
• Key factors used in selecting the remedy {i.e., how the selected remedy provides
the best balance of tradeoffs with respect to the balancing and modifying criteria,
highlighting criteria key to the decision) (see ROD, pages 36-38).
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AUTHORIZING SIGNATURES
<^U(^&k£h€6>
Andrew 0. Guglielmi, Director
Division of Environmental Remediation
NYSDEC
Digitally signed by Pat
Evangelista
Date: 2023 09 28 15:51:42
Pat Evangelista
-04'00'
Pat Evangelista, Director
Superfund and Emergency Management Division
EPA, Region 2
9/28/2023
Date
September 28, 2023
Date
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DECISION SUMMARY
Former Facility and Groundwater Portion of the
General Motors - Inland Fisher Guide Subsite
of the Onondaga Lake Superfund Site
Town of Salina, Onondaga County, New York
New York State Department of Environmental Conservation
and
United States Environmental Protection Agency
Region II
September 2023
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Table of Contents
Page
SUBSITE NAME, LOCATION, AND DESCRIPTION 1
SUBSITE HISTORY 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 4
SCOPE AND ROLE OF OPERABLE UNIT 5
SUMMARY OF SUBSITE CHARACTERISTICS 7
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 14
SUMMARY OF SUBSITE RISKS 14
REMEDIAL ACTION OBJECTIVES 21
SUMMARY OF REMEDIAL ALTERNATIVES 21
COMPARATIVE ANALYSIS OF ALTERNATIVES 28
PRINCIPAL THREAT WASTE 35
SELECTED REMEDY 36
STATUTORY DETERMINATIONS 42
DOCUMENTATION OF SIGNIFICANT CHANGES 45
ATTACHMENTS
APPENDIX I FIGURES
APPENDIX II TABLES
APPENDIX III ADMINISTRATIVE RECORD INDEX
APPENDIX IV NYSDOH LETTER OF CONCURRENCE
APPENDIX V RESPONSIVENESS SUMMARY
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SUBSITE NAME, LOCATION, AND DESCRIPTION
The General Motors - Inland Fisher Guide (GM-IFG) subsite (Subsite) of the Onondaga
Lake Superfund site is located in the Town of Salina, Onondaga County, New York. The
Subsite consists of two operable units (OUs) - one being the former plant property and
groundwater, which is referred to by the US Environmental Protection Agency (EPA) as
OU26 and by the New York State Department of Environmental Conservation (NYSDEC)
as OU11 of the Subsite, and the other being approximately 9,200 linear feet of Ley Creek
between Townline Road and the Route 11 bridge, including the adjacent floodplains,
which is referred to by EPA as OU9 and by NYSDEC as OU2 of the Subsite. The focus
of this Record of Decision (ROD) is OU1.
The former GM-IFG property comprises approximately 78.46 acres that includes the
800,000 square foot former manufacturing building located at 1 General Motors Drive
(collectively, the facility). See Figure 1, Site Location, in Appendix I.
SUBSITE HISTORY
The GM-IFG facility began operations in 1952 as GM's Brown-Lipe-Chapin Division.
Facility operations included metal die casting; nickel, chromium, and copper cyanide
electroplating; stamping; polishing; buffing; painting; and machining. In 1961, Brown-
Lipe-Chapin merged with another GM division, Ternstedt, and in 1968 became part of
GM's Fisher Body Division. During the early 1960s, injection molding operations were
added to the metal operations. Metal finishing and diecasting were subsequently
reduced and replaced by plastic injection molding by the early 1970's. The facility
operated as the Fisher Body Division until 1984, when it became the Fisher Guide
Division. The facility then operated as GM's IFG Division from 1989 until it ceased
manufacturing operations in 1993. After the cessation of manufacturing operations, the
facility was reassigned to GM's North American Operations Property Management
Group, later re-designated the Worldwide Facilities Group.
On June 23, 1989, the Onondaga Lake site was added to the New York State Registry
of Inactive Hazardous Waste Disposal Sites. On December 16, 1994, Onondaga Lake,
its tributaries, and the upland source area sites which have contributed or are
contributing contamination to the lake (subsites) were added to the EPA's National
Priorities List (NPL). This NPL listing means that the Lake system is among the nation's
highest priorities for remedial evaluation and response under the federal Superfund law
for sites where there has been a release of hazardous substances, pollutants, or
contaminants as defined under the Comprehensive Environmental Response,
1 Henceforth, the former facility and groundwater portion of the Subsite will be referred to as
OU1.
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Compensation, and Liability Act, as amended, 42 U.S.C. §9601 et seq. (CERCLA or
Superfund).
In 1997, GM and NYSDEC entered into an Administrative Order on Consent in which
GM agreed to conduct a remedial investigation and feasibility study (RI/FS) for both OUs
of the Subsite. At that time, GM also implemented a facility cleanup program to
decontaminate surfaces and decommission unneeded systems. GM redeveloped the
facility, starting in 2000, as commercial/light industrial multi-tenant spaces; use of these
spaces continues today.
Following GM's filing for bankruptcy in 2009, an RI/FS Order on Consent was executed
between the Revitalizing Auto Communities Environmental Response (RACER Trust)
Trust2 and NYSDEC in 2015. That Order requires the RACER Trust to conduct an RI/FS
and risk assessments for OU1. The Subsite was classified by NYSDEC as a Class 2 Site
in the New York State Registry of Inactive Hazardous Waste Disposal Sites (a Class 2
site represents a signification threat to public health or the environment; action is
required).
A remedy was selected for OU2 in March 2015; however, based on a significant increase
in the estimated overall volume of soil requiring remediation in the OU2 area and the
associated cost of addressing it, after considering alternatives to the selected remedy,
two separate Explanations of Significant Differences (ESDs) were issued by EPA and
NYSDEC in September 2022 and April 2023, memorializing and reaffirming the remedial
approach notwithstanding the increased volume and cost. The design of the OU2 remedy
is currently underway and it is anticipated that it will be completed in late 2023.
Interim Remedial Measures
Various Interim Remedial Measure (IRMs)3 have been implemented at OU1,
commencing in the early 1980s. The purpose of the IRMs, which are described below,
was, primarily to prevent migration and immediate human health and environmental
exposure. The IRMs included the following:
• Oil/Water Collection Sump System - In the 1980s, oil containing polychlorinated
biphenyls (PCBs) was discovered in the facility's discharge to Ley Creek and within
the underground storm sewer system beneath the former manufacturing building. The
storm sewers beneath the former manufacturing building were decommissioned and
2 The RACER Trust was created by a U.S. Bankruptcy Court to clean up and position for
redevelopment former GM properties.
3 An IRM is a New York State law term for an environmental response that is synonymous with
the CERCLA environmental response term "removal action." The use of the term "IRM" in this
document is used solely for consistency with underlying documents, but it references actions
that are in fact removal actions under CERCLA.
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collection pumps were installed at locations where the sewers formerly exited the
building. These sumps collected residual oil/water present within the sewer lines.
• Storm Sewer Rehabilitation - GM rehabilitated select storm sewers located outside
the facility buildings. The effort included cleaning the sewer lines and abandonment
and repair/replacement of some storm sewer sections on the west side of the facility.
This work was completed in 2001.
• Former Thinner Tanks Area Groundwater Recovery System - Following a spill in the
conveyance piping of three underground storage tanks in 1987, GM installed a
groundwater collection system to collect shallow overburden groundwater with
elevated concentrations of toluene, ethylbenzene, and xylenes in the Former Thinner
Tanks Area. The recovery system consists of two groundwater collection trenches.
The collected groundwater is piped to the facility stormwater treatment system and
treated using filtration and granulated activated carbon prior to discharge to Ley
Creek under a State Pollution Discharge Elimination System (SPDES)4 permit. To
assess the effectiveness of this IRM, the RACER Trust implements an annual
monitoring program including the collection and laboratory analysis of groundwater
samples from eight monitoring wells for toluene, ethylbenzene, and xylene.
• Former Landfill IRM - An industrial landfill located at the facility contains chromium
and PCB-contaminated material. Areas within the landfill with high concentrations of
contaminants were excavated and transported off-site for disposal at a licensed facility
and the landfill was capped in 2004. The RACER Trust maintains the landfill integrity
by performing operation and maintenance (O&M) activities, including inspections and
repairs, as needed, and mowing the vegetative cover.
• Former Drainage Swale IRM - GM used a drainage swale in the 1950s-60s as a
conduit for the discharge of liquid process waste to Ley Creek. The swale was
subsequently filled in, but highly contaminated soil remained. This IRM involved the
removal of the contaminated soil from the former drainage swale in 2004. As part of
this IRM, GM removed over 26,000 tons of soil containing PCBs from this area of the
facility. Soils with PCB concentrations less than 50 parts per million (ppm) were placed
in the landfill (described above) before it was capped. Soils with PCB concentrations
greater than 50 ppm were transported off-site for disposal at a licensed facility.
• Surface Impoundment #1 closure - In 1989, GM closed and covered Surface
Impoundment #1 with a clay and soil cover consistent with Resource Conservation
and Recovery Act requirements, and this area was subsequently paved. The cover in
this area limits infiltration and prevents direct contact with subsurface soil in this area.
To evaluate the effectiveness of this IRM, the RACER Trust conducts annual
monitoring of two downgradient wells for the presence of volatile organic compounds
(VOCs) and PCBs.
4 SPDES is a permit program that regulates discharges into the waters of the State of New York.
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• SPDES Treatment System IRM - The purpose of this IRM was to stop the intermittent
discharge of PCBs and other contaminants originating from OU1 to Ley Creek during
storm events. This IRM involved GM's construction of a retention basin and associated
water treatment system that was completed in 2003. This retention basin collects
surface water runoff that accumulates on the GM-IFG property in the storm sewers or
abandoned process sewers. The basin water is treated by the RACER Trust at the
treatment plant prior to discharge to Ley Creek. As part of this IRM, vegetated soil
covers were placed over the Soil Staging Area and the Soil Consolidation Area.
• Vapor Intrusion Mitigation IRM - In 2011, the RACER Trust completed the installation
of two sub-slab depressurization systems beneath the facility's concrete slab to
prevent the migration of soil vapors containing VOCs into the building. Since
operation began, the RACER Trust has performed routine O&M of the system and
periodic air monitoring.
• Redevelopment IRMs - Multiple IRMs have been performed over the years to
facilitate the redevelopment of the facility. These IRMs include the removal of soil
and surface paving at the former temporary hazardous waste storage area located
west of the Mold Storage building, removal of surface soil containing high
concentrations of site contaminants south of the former Industrial Wastewater
Treatment Plant (IWTP), demolition of the IWTP clarifiers, construction of two truck
loading docks, and regrading at the former CDM Outdoor Storage Area.
• Decommissioning Activities IRM - Following a facility assessment, decommissioning
activities were performed in the early 2000s that consisted of cleaning the floors (and
applying epoxy floor coating in some areas) and above-ground surfaces, cleaning
and dismantling various process systems, and removing residue from facility sumps
and drains. The demolition of the IWTP on the facility's south side was completed in
2006.
As described above, many of these IRMs have addressed and/or continue to address
potential risks identified in media at OU1 through removal, control, and/or treatment. It
should also be noted that as part of a property transfer in 2020, an environmental
easement under Article 71, Title 36 of New York State Environmental Conservation Law
was conveyed and recorded for the facility property. This environmental easement
provides controls to restrict future activities at the property, such as limiting land use to
industrial uses and prohibiting the use of groundwater.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Rl and FS reports and a Proposed Plan proposing EPA and NYSDEC's preferred
remedial alternative were released to the public for comment on July 28, 2023. These
documents were made available to the public via NYSDEC's website and at information
repositories maintained at the Solvay Library, the Onondaga County Public Library,
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Atlantic States Legal Foundation, and the NYSDEC Region 7 office, all located in
Syracuse, New York, and the NYSDEC Division of Environmental Remediation office,
located in Albany, New York. A NYSDEC listserv announcement notifying the public of
the availability for the above-referenced documents, the comment period
commencement and completion dates, and the date of an open house and public
meeting was issued on July 28, 2023. A notice providing the same information was
published in the Syracuse Post-Standard on July 30, 2023. The public comment period
went from July 28, 2023 to August 27, 2023.
On August 16, 2023, NYSDEC and EPA held an open house and a public meeting at the
Salina Town Hall in Salina, New York to inform local officials and interested citizens
about the Superfund process, to present the Proposed Plan for this Subsite, including
the preferred remedy, respond to questions, and accept comments. There was one
member of the public in attendance. Responses to the questions and comments
received at the public meeting and to comments submitted in writing during the public
comment period are included in the Responsiveness Summary (see Appendix V).
The Onondaga Nation reviewed the draft Rl and FS reports and draft Proposed Plan,
and NYSDEC and EPA communicated with representatives of the Onondaga Nation
regarding these documents. NYSDEC and EPA will continue consultation with the
Onondaga Nation and provide documents for its review throughout the design,
construction, and long-term management phases of the remedy.
SCOPE AND ROLE OF OPERABLE UNIT
As was noted above, Superfund sites are often divided into OUs for managing site-wide
response actions. NYSDEC and EPA have, to date, organized the work for the
Onondaga Lake NPL site into 11 subsites. These subsites, which are managed as OUs
of the Onondaga Lake NPL site, include:
1. General Motors - Inland Fisher Guide (NYSDEC site code 734057);
2. LCP Bridge Street (NYSDEC site code 734049);
3. Ley Creek PCB Dredgings (NYSDEC site code 734044);
4. Lower Ley Creek (NYSDEC site code 734123);
5. Niagara-Mohawk Hiawatha Blvd (NYSDEC site code 734059);
6. Onondaga Lake Bottom (which includes Geddes Brook/Ninemile Creek as
an OU) (NYSDEC site code 734030);
7. Salina Landfill (NYSDEC site code 734036);
8. Semet Residue Ponds (NYSDEC site code 734008);
9. Wastebeds 1 -8 (NYSDEC site code 734081);
10. Wastebed B/Harbor Brook (NYSDEC site code 734075); and
11. Willis Avenue (NYSDEC site code 734072).
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Remedial actions (RAs) have been fully implemented at the Semet Residue Ponds,
Wastebeds 1-8 OU1, Wastebed B/Harbor Brook OU1, Geddes Brook/Ninemile Creek,
Niagara-Mohawk Hiawatha Boulevard, LCP Bridge Street, Ley Creek PCB Dredgings,
Onondaga Lake Bottom, and Salina Landfill subsites. These subsites are undergoing
long-term site management. Remedial activities for portions of the Wastebeds 1 -8, GM-
IFG, and Wastebed B/Harbor Brook subsites have been completed or are in progress.
The Lower Ley Creek and Willis Avenue subsites are in the RD phase.
The 2015 ROD for OU2 called for, among other things, excavation of approximately
9,600 cubic yards (CY) of contaminated upper Ley Creek channel sediments and
approximately 2,900 CY of adjacent contaminated floodplain soil/dredged materials in
the reach from Townline Road to the Route 11 bridge. The remedy also included
excavating contaminated soils/sediments in an adjacent wetland called the National
Grid Wetland and roadway shoulders near the facility and on the northern side of Factory
Avenue in the vicinity of LeMoyne Avenue. In 2016, the RACER Trust excavated and
disposed of at a licensed facility contaminated floodplain soil from residential properties
(located adjacent to the creek) and in 2017, performed the remediation of the Factory
Avenue and National Grid Wetland soils. Based on the results of pre-RD investigation
sampling, it was determined that the ROD-estimated volume of contaminated
soil/dredged materials requiring excavation and off-site disposal increased from
approximately 15,000 CY to approximately 142,500 CY. This new information prompted
NYSDEC and EPA to reevaluate the remedy selected in the ROD and explore other
possible remedial alternatives. In September 2022, EPA affirmed the 2015 remedy, as
memorialized in an ESD, to reflect that notwithstanding the increased soil volumes at
LCDM and the associated remedial costs, based on the current and reasonably
anticipated future land use, the clean-up approach remains unchanged. In the ESD,
NYSDEC and EPA chose not to address a specific portion of OU2 that contains mature
tree growth (hereinafter referred to as the "forested area") that is located mostly to the
north of Ley Creek toward the Townline Road end of the reach of Ley Creek, between
Townline Road and Route 11. The forested area was not addressed in the ESD
because, at that time, an alternative in-situ remedial approach was being evaluated for
this area. Following the completion of the evaluation, EPA and NYSDEC concluded that
it is unlikely that the in-situ treatment would be an effective remedy in the forested area.
Therefore, the soil remedy selected in the ROD remains the most suitable approach for
addressing the forested area, notwithstanding the increased soil volumes and
associated remedial costs. This decision was documented in an April 2023 ESD. The
design of the sediment and soil remedy is currently underway; it is anticipated that it will
be completed in late 2023.
The scope of the action for OU1, the subject of this ROD, is to incorporate actions
undertaken as IRMs as final actions, address the contaminated soil/fill material and
shallow and deep groundwater not addressed under the IRMs discussed above, and
implement additional actions where needed. NYSDEC and EPA expect this remedy to
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be a final, comprehensive remedy for OU1
SUMMARY OF SUBSITE CHARACTERISTICS
The Rl activities that were conducted at OU1 included geological and hydrogeological
investigations, an ecological assessment, and the collection of samples from the shallow
soil (top two feet of soil), subsurface soil (below two feet), groundwater, and soil vapor.
Based upon the results of the Rl, the primary contaminants of concern (COCs) include
volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), metals,
and polychlorinated biphenyls (PCBs).
To evaluate the nature and extent of contamination at OU1, the Rl included the collection
and laboratory analysis of soil and groundwater samples from several areas at the
facility. Also, as documented in the Rl, various investigations spanning many years
included analysis of soil, soil vapor, groundwater, and indoor air. As shown on Figure 2
in Appendix I, for purposes of NYSDEC and EPA management, the facility is divided into
six areas plus the former manufacturing building. These areas are the Northern,
Northeast, Southeast, former IWTP, Southwest, and Former Thinner Tanks Areas.
Based on Title 6 New York Code of Rules and Regulations (6 NYCRR) Part 375 soil
cleanup objectives (SCOs) for Industrial Use, Protection of Groundwater, New York
State Class GA groundwater standards, and New York State's Guidance for Evaluating
Soil Vapor Intrusion, conditions at OU1 were evaluated. Tables 1 and 2 in Appendix II,
summarize the exceedances of SCOs in surface and subsurface soil/fill material for OU1.
The results of the Rl are summarized below.
Site Geology and Hydrogeology
The local geology for OU1 consists of fill, glaciolacustrine deposits, and lodgment till
underlain by red shale bedrock. Beneath the facility, the thickness of the glaciolacustrine
unit increases toward the facility's northern boundary. The glaciolacustrine deposit has
three units: the upper unit (silt and fine-grained sand); the middle unit (silt and clay); and
the lower unit (silt and fine-grained sand).
OU1 has two distinct groundwater zones, a shallow groundwater zone (at a depth of
approximately 1 foot to 15 feet [ft] below ground surface [bgs]) within the fill layer and
the upper glaciolacustrine unit and a deep groundwater zone (at a depth of approximately
20 to 45 ft bgs) within the lower glaciolacustrine unit and the sand and gravel layer.
Between the two groundwater zones is the middle glaciolacustrine layer, which acts as
a low permeability zone that separates the shallow and deep groundwater zones. This
low permeability glaciolacustrine layer extends from near the northern edge of the former
manufacturing building to the northern portion of the facility. The deep and shallow
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groundwater zones are connected in the vicinity of the building where the glaciolacustrine
layer is absent. Shallow and deep groundwater generally flow in a northeast direction
across the facility toward Ley Creek.
Soil
The sampling activities and associated results from various investigations conducted
facility-wide indicate that surface and subsurface soils in certain locations on OU1
contained PCBs, VOCs, semi-volatile organic compounds (SVOCs), and site-related
metals {i.e., arsenic, chromium, copper, nickel, and zinc) exceeding New York State
Standards, Criteria, and Guidance (SCGs). Figure 3 in Appendix I, shows the sample
locations where there are exceedances of SCOs in the surface and subsurface soil.
Table 1 and Table 2 in Appendix II, summarize the detected concentrations and
frequency of SCO exceedances for surface and subsurface soil, respectively.
Surface Soil
PCBs were detected above their Part 375 Industrial Use SCO (25 ppm) in the Northern
Property Area at a maximum concentration of 37 ppm.
SVOCs were detected above the Part 375 Industrial Use SCOs in the Former Thinner
Tanks Area and Northern Property Area. Specifically, in the Former Thinner Tanks Area,
benzo(a)pyrene (SCO of 1.1 ppm), chrysene (SCO of 110 ppm), and fluoranthene (SCO
of 1,000 ppm) were detected at maximum concentrations of 300 ppm, 380 ppm, and
1,200 ppm, respectively. In the Northern Property Area, benzo(a)anthracene (SCO of
11 ppm), and benzo(a)pyrene were detected at maximum concentrations of 1.8 ppm,
and 1.7 ppm respectively.
In the Southeast Property Area, arsenic was detected above the Part 375 Industrial Use
SCO (16 ppm) at a maximum concentration of 92.8 ppm (at depths greater than 2-feet
bgs).
Subsurface Soil
PCBs were detected in subsurface soil in different areas of the facility at concentrations
above Part 375 Protection of Groundwater SCO (3.2 ppm). Specifically, PCBs were
detected in the northeast area at a maximum concentration of 24 ppm, in the IWTP area
at a maximum concentration of 190 ppm, beneath the former manufacturing building at
a maximum concentration of 4,300 ppm, in the Northern Property Area at maximum
concentration of 79 ppm beneath the landfill. Field screening using ultraviolet irradiation
suggested that Non-Aqueous Phase Liquid (NAPL) may be present in three soil sample
locations along an abandoned sewer under the former manufacturing building. The area
beneath the building may represent a potential source area for PCBs.
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VOCs detected above Part 375 Protection of Groundwater SCOs were limited to toluene
(SCO of 0.7 ppm), xylene (SCO of 1.6 ppm), ethylbenzene (SCO of 1 ppm), methylene
chloride (SCO of 0.05 ppm), trichloroethene (TCE; SCO of 0.47 ppm), cis-1,2-
dichloroethene (cis-1,2-DCE; SCO of 0.25 ppm), and vinyl chloride (SCO of 0.02 ppm),
across the facility. Specifically, toluene, xylene, and ethylbenzene were detected
respectively at maximum concentrations of 720 ppm, 317 ppm, and 61 ppm in
subsurface soil samples collected from the Former Thinner Tanks Area. Methylene
chloride, ethyl benzene, toluene, xylene, cis-1,2-DCE, and vinyl chloride were detected
respectively at maximum concentrations of 0.14 ppm, 11 ppm, 110 ppm, 110 ppm, 0.45
ppm, and 0.12 ppm in the northern property area. TCE was detected at a maximum
concentration of 1.5 ppm in the northeast property area. Methylene chloride, TCE, cis-
1,2-DCE, and vinyl chloride were detected at a maximum concentration of 7.8 ppm,
9,800 ppm, 5.1 ppm, and 7.8 ppm, respectively, beneath the former manufacturing
building at depths ranging from 0.5 ft to 15 ft below the concrete slab, generally in the
center of the building in the vicinity of the former paint room.
SVOCs were detected above the Part 375 Protection of Groundwater SCOs in
subsurface soil beneath the transformer/switch area located in the Former Thinner Tanks
Area, former landfill in the Northern Property Area, and in the Northeast Property Area.
Benzo(a)anthracene (SCO of 1 ppm), benzo(a)pyrene (SCO of 22 ppm), and
benzo(b)fluoranthene (SCO of 1.7), were detected respectively at maximum
concentrations of 150 ppm, 110 ppm, and 140 ppm, in the Former Thinner Tanks Area.
P-Cresol (SCO of 0.33 ppm) was found at a maximum concentration of 3.9 ppm in the
Northern Property Area. Benzo(a)anthracene, benzo(b)fluoranthene, and chrysene
(SCO of 1 ppm) were detected at maximum concentrations of 9.3 ppm, 16 ppm, and 11
ppm, respectively, in the Northeast Property Area.
Site-related metals {i.e., arsenic, chromium, copper, lead, nickel, zinc, and cyanide) were
detected above the Part 375 Protection of Groundwater SCOs in limited areas in
subsurface soil near the Northern, Northeast, Southeast, Southwest, IWTP Property
Areas, and beneath the former manufacturing building. Specifically, arsenic (SCO of 16
ppm), chromium (SCO of 19 ppm), copper (SCO of 1,720 ppm), lead (SCO of 450 ppm),
nickel (SCO of 130 ppm), and zinc (SCO of 2,480 ppm) were detected respectively at a
maximum concentration of 65 ppm, 17,200 ppm, 3,920 ppm, 7,940 ppm, 243 ppm, and
53,300 ppm in the Northern Property Area beneath the landfill IRM cover. Arsenic was
detected at a maximum concentration of 16.3 ppm in the Northeast Property Area.
Arsenic was detected at a maximum concentration of 16.4 ppm in the Southeast Property
Area. Chromium was at maximum concentrations of 1,220 ppm the Southwest Property
Area. Chromium was detected at a maximum concentration of 44 ppm in the IWTP
Property Area. Chromium, cyanide (SCO of 40 ppm), and nickel were detected
respectively at a maximum concentration of 120 ppm, 247 ppm, and 4,000 ppm beneath
the former manufacturing building.
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The majority of subsurface soil locations identified as having COCs at concentrations
exceeding SCOs are located beneath the covers/caps within the Former Landfill, Soil
Staging Area, or Soil Consolidation Area and were previously addressed by the IRMs.
Groundwater
The groundwater analytical results indicate that the shallow overburden groundwater
contains VOCs and PCBs at concentrations exceeding SCGs and the deep overburden
groundwater contains VOCs, SVOCs, and metals at concentrations exceeding SCGs.
Shallow Groundwater Zone
PCBs were detected above New York State Class GA groundwater standard (0.09 parts
per billion [ppb]) in groundwater samples collected from monitoring wells (OBG-6S and
OBG-7S on Figure 4 in Appendix I) located in the Northeast Property Area at a maximum
concentration of 0.72 ppb. An elevated concentration of PCBs was detected in
groundwater immediately north of the former manufacturing building at a maximum
concentration of 55 ppb in the vicinity of a closed surface impoundment (MW-2S on
Figure 4 in Appendix I). Otherwise, PCBs are present at concentrations marginally above
New York State Class GA groundwater standard in a few localized areas in the shallow
overburden groundwater zone.
Chlorinated VOCs, consisting mainly of TCE (SCG of 5 ppb), cis-1,2-DCE (SCG of 5
ppb), and vinyl chloride (SCG of 2 ppb) were detected in facility groundwater at maximum
concentrations of 25,000 ppb, 4,700 ppb, 23 ppb, respectively, in samples collected from
beneath the former manufacturing building (see Figure 4 in Appendix I). Field screening
techniques suggest that VOC NAPL may exist beneath the former manufacturing
building and may be a continuing source for groundwater contamination. The TCE
detected may be associated with the former TCE storage area/IWTP previously located
south of the former manufacturing building and possible solvent storage and usage
within the former manufacturing building. Figure 4 in Appendix I, provides site-wide
shallow groundwater sample results for VOCs. As shown on Figure 4 in Appendix I, the
possible VOC NAPL beneath the building has not resulted in a shallow overburden
groundwater plume north of the former manufacturing building.
Non-chlorinated VOCs, including toluene, ethylbenzene, and xylene, are present in the
shallow groundwater zone in the Former Thinner Tanks Area at concentrations above
the SCG of 5 ppb for these compounds. Specifically, the 2021 annual groundwater
sampling detected these constituents at maximum concentrations of 3,400 ppb, 39,000
ppb, and 190,000 ppb, respectively. While NAPL is suspected to be present in the
Former Thinner Tanks Area based on these groundwater concentrations, this
groundwater is contained by the two recovery trenches and is not migrating off-property.
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Arsenic was detected above the groundwater SCG in the Northern Property Area and
Chromium was detected above the groundwater SCG beneath the former manufacturing
building. In addition, other non-site-related metals, including iron, magnesium,
manganese, and sodium, were also detected at concentrations above groundwater
SCGs.
Deep Groundwater Zone
PCBs {i.e., Aroclor 1242) were detected above New York State Class GA groundwater
standard (0.09 ppb) in the Northern Property Area at a maximum concentration of 0.18
ppb (monitoring well OBG-W6DR on Figure 5 in Appendix I).
TCE, cis-1,2-DCE, and vinyl chloride were detected in the deep overburden groundwater
at concentrations exceeding SCGs immediately north of the former manufacturing
building, in the Northern Property Area, and off-property beneath the Ley Creek
floodplain area (see Figure 5 in Appendix I). North of the former manufacturing building
and in the Northern Property Area, TCE, cis-1,2-DCE, and vinyl chloride were detected
in the deep overburden groundwater at maximum concentrations of 170,000 ppb, 11,000
ppb and 120 ppb, respectively, compared to their respective groundwater standards of
5 ppb for TCE and cis-1,2-DCE and 2 ppb for vinyl chloride.
Off-property, TCE, cis-1,2-DCE, and vinyl chloride were detected at maximum
concentrations of 3,500 ppb, 570 ppb and 140 ppb, respectively in monitoring wells
located approximately 200 ft. north of the property. NAPL source material may be
present at areas between the northern extent of the former manufacturing building and
the northern facility perimeter based upon the suspected movement of the TCE plume
along the top of the till and the concentrations of TCE detected in deep groundwater.
Figure 5 in Appendix I, provides site-wide deep groundwater zone sample results for
VOCs.
SVOCs and site-related metals were not detected above SCGs in the deep groundwater.
Soil Vapor
As part of the June 16, 2010 Vapor Intrusion Mitigation IRM, sub-slab vapor and indoor
air samples were collected. The investigation identified elevated levels of chlorinated
VOCs above air guidelines and other criteria referenced in the State's Guidance for
Evaluating Soil Vapor Intrusion (New York State Department of Health [NYSDOH], 2006
w/ updates). Evaluation of the data resulted in the installation of an SSDS to address
the soil vapor intrusion. The sub-slab and indoor air sampling results are summarized
below.
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Sub-Slab
1,1,1-Trichloroethane (1,1,1-TCA), Tetrachloroethene (PCE), TCE, and cis-1,2-DCE
were detected in the sub-slab vapor samples at concentrations exceeding NYSDOH
guidance values beneath the former manufacturing building at maximum concentrations
of 1,400 micrograms per cubic meter (|jg/m3), 2,800 jjg/m3, 1,900,000 jjg/m3, and 270
|jg/m3, respectively.
Indoor Air
PCE, TCE and cis-1,2-DCE were detected in the indoor air at concentrations exceeding
NYSDOH guidance values at maximum concentrations of 540 jjg/m3, 130 jjg/m3, and
0.23 jjg/m3, respectively.
Suspected Nonaqueous Phase Liquids
Chlorinated VOC NAPLs may be present in some areas of the facility property based on
the elevated concentrations (TCE at 25,000 ppb) that were detected in the shallow
groundwater beneath the former manufacturing building and in the deep groundwater
near the property boundary (TCE at 160,000 ppb). Chlorinated VOC NAPLs, if present
beneath the former manufacturing building, would be expected to flow along the till down
into the deep groundwater unit. In fact, and as described above, analytical results from
the shallow overburden groundwater north of the former manufacturing building show
that the VOC NAPL under the building has not resulted in a shallow overburden
groundwater plume.
Suspected PCB NAPL may be present underneath the former manufacturing building as
a result of past releases of PCB-containing hydraulic fluid to sumps and to leaking
process sewers during the manufacturing processes.
A past leak from the underground paint thinner storage tanks/piping in the Former
Thinner Tanks Area is a potential source of non-chlorinated VOC NAPL that may be
present in this area. As part of the Thinner Tanks System Area Groundwater Recovery
IRM, GM installed two groundwater collection trenches and associated piping to collect
and treat the contaminated groundwater. While the IRM has contained the plume, there
may be a source (e.g., NAPL) that remains based on contaminant levels in groundwater
in this area (including concentrations of total xylenes greater than 100,000 ppb since
1999).
Conclusions
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Based on the results of the various iterations of the Rl from 2010 through 2022 and prior
investigations, the contamination at OU1 is summarized as follows:
• Approximately 2,580 CY of soil has been identified as exceeding the Industrial Use
SCOs and/or the Protection of Groundwater SCOs for PCBs and VOCs. All but
approximately 340 CY of this material is currently covered as part of completed IRMs
or located below the building. Of the material not covered by IRMs, approximately
241 CY is covered by paving (roadways or parking lots). Of the remaining uncovered
soil exhibiting concentrations greater than the Protection of Groundwater SCO,
approximately 15 CY are located in the top 1 ft and 84 CY are at depths greater than
1 ft. Approximately 38 CY of material is to be removed in the surface soil and 1500
CY of material is to be removed in the surface and subsurface soil with the
assumption of over excavation of 10 ft for locations shallower than 5ft and extended
20 ft for locations between 5 and 15 ft bgs.
• Three residual source areas may exist at the facility: potential non-chlorinated VOC
NAPL in shallow overburden soil within the Former Thinner Tanks Area; potential
chlorinated VOC NAPL and PCB NAPL in shallow/deep overburden soil beneath the
former manufacturing building; and potential chlorinated VOC NAPL in deep
overburden soil within the Northeast Property Area. From calculations based on the
groundwater data, the Former Thinner Tanks Area VOC residual source area is
approximately 35,800 sf by 10 ft thick, the former manufacturing building VOC
residual source area is approximately 115,100 sf by 10 ft thick, and the VOC residual
source in the Northeast Property Area is approximately 56,200 sf by 1 -ft thick.
• Shallow and deep groundwater is contaminated with chlorinated VOCs and PCBs,
and there are high concentrations of toluene, ethylbenzene, and xylene in the Former
Thinner Tanks Area. Specifically:
¦ VOC NAPL is potentially located under the former manufacturing building but has
not resulted in a shallow overburden groundwater plume.
¦ In general, PCBs are present at concentrations above New York State Class GA
groundwater standards in a few localized areas in the shallow overburden
groundwater zone (PCBs up to 55 ppb as compared to the groundwater standard
of 0.09 ppb) and in one location in the deep overburden groundwater zone. Given
that most of the PCB detections were associated with PCBs observed in
subsurface soils, the groundwater detections are likely indicative of localized
conditions.
¦ Chlorinated VOCs were detected at elevated concentrations (TCE up to 25,000
ppb as compared to the groundwater standard of 5 ppb) in the shallow overburden
groundwater beneath the former manufacturing building.
¦ Chlorinated VOCs were detected at elevated concentrations (TCE up to 170,000
ppb as compared to the groundwater standard of 5 ppb) in the deep overburden
groundwater north of the former manufacturing building and off-property beneath
the Ley Creek floodplain area.
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¦ Toluene, ethylbenzene, and xylene contamination in the shallow overburden
groundwater are contained by operation of the Former Thinner Tanks Area
Groundwater Recovery System.
Contamination Fate and Transport
The COCs that were detected in the soil and groundwater at OU1 are consistent with the
operation of a large automotive manufacturing facility for more than 40 years. The
location of the COCs and their mass distribution correlate reasonably well to the location
of the process and disposal areas of the former plant, releases to sumps and leaking
process sewers during the manufacturing processes, and leaks from the underground
paint thinner storage tanks/piping in the Former Thinner Tanks Area.
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
Land Use
OU1 is zoned for industrial use and is bounded by commercial and industrial properties.
The current and reasonably-anticipated future land uses for this Subsite is industrial.
Currently, the former manufacturing building is occupied by a variety of tenants
performing light industrial activities.
SUMMARY OF SUBSITE RISKS
As part of the Rl, baseline quantitative risk assessments were conducted for this Subsite
to estimate the risks to human health and the environment (under current and anticipated
future land uses). Baseline risk assessments, consisting of a baseline human health risk
assessment (BHHRA), which evaluates potential risks to people, and a fish and wildlife
impact analysis (FWIA), which evaluates potential risks to the environment, analyze the
potential for adverse effects caused by hazardous substance releases from a site
assuming no further action to control or mitigate exposure to these hazardous
substances are taken.
Human Health Risk Assessment
A BHHRA was conducted to estimate current and future effects of contaminants on
human health. A BHHRA is an analysis of the potential adverse human health effects
caused by hazardous substance exposure in the absence of any actions to control or
mitigate these exposures under current and future site uses. If it is determined that an
unacceptable risk exists, the BHHRA provides the basis for taking an action and
identifies the contaminants and exposure pathways that need to be addressed through
implementation of a remedial action. This section of the ROD summarizes the results of
the BHHRA for OU1.
A four-step process is utilized for assessing site-related human health risks for
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reasonable maximum exposure scenarios, as follows:
Hazard Identification - uses the analytical data collected to identify the
contaminants of potential concern (COPCs) for each medium, with consideration of a
number of factors explained below.
Exposure Assessment - estimates the magnitude of actual and/or potential
human exposures, the frequency and duration of these exposures, and the pathways
(e.g., ingesting contaminated soil) by which humans are potentially exposed.
Toxicity Assessment - determines the types of adverse health effects
associated with chemical exposures, and the relationship between magnitude of
exposure (dose) and severity of effect (response).
Risk Characterization - summarizes and combines outputs of the exposure and
toxicity assessments to provide a quantitative assessment of site-related risks. The risk
characterization also identifies contamination with concentrations that exceed
acceptable levels, defined in the NCP as an excess lifetime cancer risk greater than 1 x
10_6to 1 x 10"4 or a Hazard Index greater than 1.0 (discussed in more detail, below);
contaminants at these concentrations are considered COCs and are typically those that
will require remediation at a site. Also included in this section is a discussion of the
uncertainties associated with these risks.
Hazard Identification
In this step, analytical data collected during the Rl is used to identify COPCs in the
contaminated media (e.g., surface and subsurface soil, groundwater, indoor and outdoor
air) at a site based on factors such as toxicity, frequency of occurrence, fate and transport
of the contaminants in the environment, and concentrations of the contaminants, as well
as their mobility and persistence.
Exposure Assessment
OU1 is zoned industrial and exposure scenarios were developed based on this current
and likely future land use. The BHHRA considered exposure to soil, outdoor air (via
dusts) and groundwater through several current and future exposure scenarios.
Receptors and pathways that were evaluated included the following: exposure to surface
soil and outdoor air by older children and adult trespassers as well as industrial workers
and construction workers; and exposure to shallow groundwater by construction
workers; and exposures to groundwater used as drinking water by future child and adult
residents.
Exposure scenarios were developed for these populations and considered exposure
through incidental ingestion and inhalation of and dermal contact with surface and,
subsurface soil, and ingestion of groundwater as a hypothetical drinking water source in
the future. Human health risks associated with the ingestion of groundwater are based
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on groundwater data from the Rl. Risks from exposure to volatile contaminants within
indoor air via vapor intrusion were also evaluated in the BHHRA.
As referenced above, however, the vapor mitigation system as installed, operated, and
maintained by the RACER Trust continues to prevent vapor intrusion from the soil and
groundwater beneath the former manufacturing building into the building's indoor air.
The BHHRA included a recommendation that, based on the vapor intrusion screening
presented in the BHHRA, a vapor intrusion evaluation should be conducted if any
buildings (new or existing) will be occupied on the facility property. The vapor intrusion
screening identified chemicals with a potential to migrate to indoor air, based on factors
such as the chemical- specific vapor pressure. Because these factors apply to chemicals
present in media such as soil, fill material, and groundwater, all media with these
chemicals have the potential for future vapor intrusion concerns. A full discussion of the
BHHRA evaluation and conclusions is presented in the BHHRA Report (Appendix I of
the Rl report).
Toxicity Assessment
In this step, the types of adverse health effects associated with contaminant exposures
and the relationship between the magnitude of exposure and the severity of adverse
health effects were determined. Potential health effects are contaminant-specific and
may include the risk of developing cancer over a lifetime or other noncancer health
effects, such as changes in the normal functions of organs within the body {e.g., changes
in the effectiveness of the immune system). Some contaminants are capable of causing
both cancer and noncancer health effects.
Under current EPA guidelines, the likelihood of carcinogenic risks and noncancer
hazards because of exposure to site chemicals are considered separately. Consistent
with current EPA policy, it was assumed that the toxic effects of any site-related
chemicals would be additive. Thus, cancer and noncancer risks associated with
exposures to individual COPCs were summed to indicate the potential risks and hazards
associated with mixtures of potential carcinogens and noncarcinogens, respectively.
Toxicity data for the human health risk assessment were taken from the Integrated Risk
Information System database, the Provisional Peer Reviewed Toxicity Database, or
another source that is identified as an appropriate reference for toxicity values consistent
with EPA's directive on toxicity values.
Risk Characterization
This step summarizes and combines outputs of the exposure and toxicity assessments
to provide a quantitative assessment of Subsite risks. Exposures were evaluated based
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on the potential risk of developing cancer and the potential for noncancer health hazards.
For carcinogens, risks are generally expressed as the incremental probability of an
individual developing cancer over a lifetime as a result of exposure to a carcinogen, using
the cancer slope factor (SF) for oral and dermal exposures and the inhalation unit risk
(IUR) for inhalation exposures. Excess lifetime cancer risk for oral and dermal exposures
is calculated from the following equation, while the equation for inhalation exposures
uses the IUR, rather than the SF:
Risk = LADD x SF
where: Risk = a unitless probability (1 x 10"6) of an individual developing cancer
LADD = lifetime average daily dose averaged over 70 years (milligrams
per kilogram [mg/kg]-day)
SF = cancer slope factor, expressed as 1/(mg/kg-day)
The likelihood of an individual developing cancer is expressed as a probability that is
usually expressed in scientific notation (such as 1 x 10"4). For example, a 1 x 10"4 cancer
risk equates to a "one-in-ten-thousand excess cancer risk;" or one additional cancer may
be seen in a population of 10,000 people as a result of exposure to site contaminants
under the conditions described in the exposure assessment. Current Superfund
guidelines for acceptable exposures are an individual lifetime excess cancer risk in the
range of 10"4 to 10~6 (corresponding to a one-in-ten-thousand to a one-in-a-million excess
cancer risk).
For noncancer health effects, a hazard index (HI) is calculated. The HI is determined
based on a comparison of expected contaminant intakes and benchmark comparison
levels of intake (reference doses, reference concentrations). Reference doses (RfDs)
and reference concentrations (RfCs) are estimates of daily exposure levels for humans
(including sensitive individuals) that are thought to be safe over a lifetime of exposure.
The estimated intake of chemicals identified in environmental media (e.g., the amount of
a chemical ingested from contaminated drinking water) is compared to the RfD or the
RfC to derive the hazard quotient (HQ) for the contaminant in the particular medium. The
HI is determined by adding the hazard quotients for all compounds within a particular
medium that impacts a particular receptor population.
The HQ for oral and dermal exposures is calculated as shown below.
HQ = Intake/RfD
where: HQ = hazard quotient
Intake = estimated intake for a chemical (mg/kg-day)
RfD = reference dose (mg/kg-day)
The intake and the RfD will represent the same exposure period {i.e., chronic,
subchronic, or acute).
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The HQ for inhalation exposures is calculated using a similar model that incorporates
the RfC, rather than the RfD.
The principle concept for a noncancer HI is that a "threshold level" (measured as an HI
of less than 1.0) exists below which noncancer health effects are not expected to occur.
The HI is calculated by summing the HQs for all chemicals for likely exposure scenarios
for a specific population. An HI greater than 1 indicates that the potential exists for non-
carcinogenic health effects to occur as a result of site-related exposures, with the
potential for health effects increasing as the HI increases. When the HI calculated for all
chemicals for a specific population exceeds 1, separate HI values are then calculated for
those chemicals which are known to act on the same target organ. These discrete HI
values are then compared to the acceptable limit of 1 to evaluate the potential for
noncancer health effects on a specific target organ. The HI provides a useful reference
point for gauging the potential significance of multiple contaminant exposures within a
single medium or across media.
At this Subsite, the cancer risks and noncancer hazards were estimated for each of the
exposure areas/media and the risk was evaluated for the specific populations identified
in each unit under current and reasonably-anticipated future use. A summary of the
cancer risks and noncancer hazards above threshold levels for each population in each
of the areas of OU1, along with the chemicals that contribute the most to the risk or
hazard, or COCs, can be found in Tables 11 and 12 in Appendix II.
Total cancer risk for the adult trespasser, industrial worker and construction worker
exceeded EPA's 10~4 - 10~6 risk range, primarily driven by exposure to polycyclic
aromatic hydrocarbons (PAHs) (particularly benzo(a)pyrene) in surface soil. Noncancer
hazard for the industrial worker and construction worker also exceeded the threshold of
1 due primarily to PCBs in surface soil. For the construction worker, exposure to
ethylbenzene in groundwater also contributed to elevated hazard. Furthermore,
hypothetical future residential exposure to groundwater as potable water resulted in
elevated cancer risk and noncancer hazards. These estimates were driven by exposure
to ethylbenzene, TCE, cis-1,2-DCE, xylenes, vinyl chloride, arsenic, chromium, and
PCBs in groundwater. A summary of the cancer risks and noncancer hazards above
threshold levels for each population in each of the OU26 areas, along with the COCs
that contribute the most to the risk or hazard can be found in the Facility Risk and Hazard
Summary table of the BHHRA.
The BHHRA included a recommendation that based on the vapor intrusion screening
presented in the BHHRA, a vapor intrusion evaluation should be conducted if buildings
that will be occupied are constructed at this Subsite. The vapor intrusion screening
identified chemicals with a potential to migrate to indoor air, based on factors such as
the chemical-specific vapor pressure. Because these factors apply to chemicals present
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in media such as soil, fill material, and groundwater, all media with these chemicals have
the potential for future vapor intrusion concerns. Based on the vapor intrusion evaluation,
measures may be included in the design and construction of buildings at this Subsite to
mitigate the potential for exposure to constituents that may be present in soil vapor. Such
measures may include an active sub-slab depressurization system, use of a vapor barrier
or the installation of a venting system.
Uncertainty in the Risk Assessment
The process of evaluating human health cancer risks and noncancer health hazards
involves multiple steps. Inherent in each step of the process are uncertainties that
ultimately affect the final risks and hazards. Important site-specific sources of uncertainty
are identified for each of the steps in the four-step risk process below.
Uncertainties in Hazard Identification
Uncertainty is always involved in the estimation of chemical concentrations. Errors in
the analytical data may stem from errors inherent in sampling and/or laboratory
procedures. While the datasets for this Subsite are robust, because environmental
samples are variable, the potential exists that these datasets might not accurately
represent reasonable maximum concentrations. There is a low potential that the risks
may be overestimated or underestimated.
Uncertainties in Exposure Assessment
There are two major areas of uncertainty associated with exposure parameter
estimation. The first relates to the estimation of exposure point concentrations (EPCs).
The second relates to parameter values used to estimate chemical intake {e.g., ingestion
rate, exposure frequency). The estimates of the EPCs are influenced on how likely the
dataset fully characterizes the contamination at OU1. These datasets are robust, so the
potential for overestimating or underestimating risk is low. Many of the exposure
parameters used in the BHHRA are based on best professional judgement. There is a
low potential that the risks may be overestimated or underestimated.
Uncertainties in Toxicity Assessment
A potentially large source of uncertainty is inherent in the derivation of the EPA toxicity
criteria {i.e., RfDs, RfCs, SFs, lURs). Although these toxicity criteria have been
extensively reviewed and peer-reviewed, there is a medium potential that uncertainty
factors applied during their derivation may result in overestimation or underestimation of
risk. Additionally, there are many contaminants for which no toxicity values are available
and therefore they are not quantitatively evaluated in the BHHRA. There is high potential
for underestimation because of this lack of toxicity information.
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Uncertainties in Risk Characterization
When all of the uncertainties from each of the previous three steps are added,
uncertainties are compounded. Because it is unknown whether many of the
uncertainties result in an overestimation or underestimation of risk, the overall impact of
these uncertainties is unquantifiable. However, some of the uncertainties, such as the
lack of toxicity information, will likely result in an overall underestimation of risk.
Ecological Risk Assessment
The industrialized nature of OU1 (i.e., presence of buildings, paved surfaces, and
stormwater management facilities) minimizes its value as fauna habitat. The
undeveloped portions of OU1 consist primarily of turf grass that is periodically mowed,
minimizing its availability and suitability for wildlife use, such as nesting and foraging.
The grassed habitats of OU1 range in value to wildlife in relation to their sizes and
locations. Grassed areas surrounding facility-related structures are not likely frequently
used by wildlife. Larger open lawns provide invertebrate and vegetative food sources for
a limited number of small mammals and birds, such as mice, voles, American robin, and
killdeer that may forage there. Waterfowl, reptiles, and small mammals may forage
and/or rest in the grass areas adjacent to the retention basin, and bats may forage on
insects flying above the basin. However, given the limited habitat and utilization by area
wildlife, the conclusion contained in the FWIA is that site-related impacts to ecological
receptors are minimal within OU1. A full discussion of the FWIA evaluation and
conclusions is presented in the FWIA Report (Appendix J of the Rl report)
Summary of Human Health and Ecological Risks
The results of the human health risk assessment indicate that the contaminated soil,
indoor air, and groundwater present current and/or potential future exposure risks. Based
on the industrial nature of OU1 and its limited habitat available for area wildlife, the
ecological risk assessment indicates that site-related impacts to ecological receptors is
minimal. Many of the risks to human health associated with contaminated soil have been
mitigated, in part, by the implemented IRMs. While potential ecological and human health
risks have been mitigated by OU1 IRMs, long-term O&M will be necessary to maintain
protectiveness. Also, as noted above, ICs in the form of an environmental easement
have been recorded for the property controlling and limiting site use and prohibiting
groundwater use in its current state.
Basis for Action
The response action selected in this ROD is necessary to protect public health and the
environment from actual or threatened releases of hazardous substances.
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REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are specific goals to protect human health and the
environment. These objectives are based on available information and standards, such
as Applicable or Relevant and Appropriate Requirements (ARARs), To-Be-Considered
guidance, and site-specific risk-based levels established using the risk assessments.
The following RAOs have been established for OU1:
• Prevent ingestion/direct contact with contaminated soil/fill material.
• Prevent inhalation of or exposure to contaminants volatilizing from contaminants in
soil/fill material.
• Prevent ingestion of groundwater with contaminant levels exceeding drinking water
standards.
• Restore groundwater to levels that meet state and federal standards.
• Prevent contact with, or inhalation of, volatiles from contaminated groundwater.
• Prevent the discharge of contaminants to surface water and sediment in Ley Creek.
• Prevent contaminants in soil/fill material from impacting groundwater above drinking
water standards.
NYSDEC's SCOs have been identified as remediation goals for soil to attain these
RAOs. SCOs are risk-based criteria that have been developed by New York State
following methods consistent with EPA's methods/protocols/guidance, and they are set
at levels consistent with EPA's acceptable levels of risk that are protective of human
health, ecological exposure, or the groundwater depending upon the existing and
anticipated future use of OU1. The land use of OU1 has historically been industrial, and
current and anticipated future uses can be reasonably expected to remain industrial.
Groundwater remedial goals are the lower of the federal Maximum Contaminant Levels
(MCLs) and the New York State Ambient Water Quality Standards. The lower, more
stringent of the New York State Guidance Values and EPA's Vapor Intrusion Screening
Levels will be used to evaluate future potential for vapor intrusion.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA Section 121(b)(1), 42 U.S.C. § 9621(b)(1), mandates that remedial actions
must be protective of human health and the environment, cost-effective, and utilize
permanent solutions and alternative treatment technologies and resource recovery
alternatives to the maximum extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions that employ, as a principal element, treatment to
permanently and significantly reduce the volume, toxicity, or mobility of the hazardous
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substances, pollutants, and contaminants at a site. CERCLA Section 121(d), 42 U.S.C.
§ 9621(d), further specifies that a remedial action must attain a level or standard of
control of the hazardous substances, pollutants, and contaminants that at least attains
ARARs under federal and state laws unless a waiver can be justified pursuant to
CERCLA Section 121(d)(4), 42 U.S.C. § 9621(d)(4).
Based on anticipated future use of OU1, expectations of the reasonably anticipated land
use, as described above, were considered in the FS to facilitate the development and
evaluation of remedial alternatives. Given current zoning and the present and historical
use of the property, the reasonably anticipated land use is to remain an industrially zoned
property.
All the alternatives, other than Alternative 1, No Further Action, include the long-term site
management of the IRMs. The long-term site management would include maintenance
activities and performance monitoring to ensure that the IRMs are operating effectively
and efficiently and to identify any needed corrective measure(s) specific to the IRMs.
Corrective measures for the IRM cover systems, such as the existing paved surfaces
{i.e., roadways or parking lots) and the former manufacturing building that currently serve
as a cover for impacted shallow soils, may consist of repair in areas of disturbance or re-
application of vegetation in areas of non-survival.
As discussed in more detail in Alternative 2 below, each active remedial alternative
(Alternatives 2 through 5) includes the following common components:
Environmental Easement: An existing environmental easement shall be maintained
and enforced, if necessary. It requires land use and groundwater use restrictions for
the facility. Land use restrictions restrict activities that could result in unacceptable
exposure to contaminated soil. Groundwater use restrictions preclude the use of
groundwater without prior notification and approval from NYSDEC. The existing
environmental easement also includes requirements that necessary engineering
controls be operated, maintained, and monitored to provide protectiveness to human
health and the environment.
Site Management Plan: A Site Management Plan (SMP) would guide future activities
at the facility by addressing use restrictions and by developing the following
requirements: periodic reviews; operation and maintenance of engineering controls;
and groundwater monitoring. The periodic site management reviews would focus on
evaluating the on-site conditions regarding the continuing protection of human health
and the environment as evidenced by information such as groundwater monitoring
and documentation of field inspections.
Soil Management Plan: A soil management plan would be implemented to outline the
implementation of engineering and institutional controls for the handling and
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management of soil during remedial, maintenance, or site redevelopment activities.
The soil management plan would detail the implementation of on-site consolidation
(temporary or permanent), off-site disposal, soil characterization procedures, and hot
spot excavation.
Shallow and Deep Groundwater Monitoring: A monitoring program for shallow and
deep groundwater and/or adjacent surface water would be performed to determine
effectiveness of the implemented remedy.
Excavation and Off-Site Disposal of Soil: Excavation would be conducted to remove
contaminated surface and/or subsurface soil as required under the respective
alternative. Excavated soils would be disposed of at an offsite permitted facility.
The remedial alternatives are as follows:
Alternative 1 - No Further Action
The Superfund program requires that the "no further action" alternative be considered
as a baseline for comparison with the other alternatives. The no further action remedial
alternative would not include any additional remedial measures to address the soil and
groundwater contamination at OU1.
As this alternative does not involve further actions, there are no estimated capital,
annual, and present-worth costs. The costs of this alternative are as follows:
Alternative 2 - Perimeter and Targeted Shallow Groundwater Collection and
Treatment, Perimeter and Targeted Deep Groundwater Extraction and Treatment,
and Soil Excavation with Off-Site Disposal
Alternative 2 would include the construction of a perimeter shallow groundwater
collection trench (approximately 1,800 ft in length and 15 ft deep) and the installation of
deep groundwater extraction wells (approximately 35 ft deep) along the northern
perimeter of the facility property. These two systems would be used to collect
contaminated groundwater and prevent further off-property migration. This alternative
would also include targeted deep groundwater extraction to address the contamination
beneath and immediately northeast of the former manufacturing building, and an
enhancement and expansion of the Former Thinner Tanks Area Groundwater Recovery
Capital Cost:
Annual O&M Cost:
Present-Worth Cost:
$0
$0
$0
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System to target the shallow groundwater contamination in that area. All collected
groundwater would be treated at the current SPDES treatment system to meet discharge
criteria prior to being discharged to Ley Creek. Groundwater monitoring would be
performed to evaluate the effectiveness of the groundwater extraction systems.
This alternative would also include the excavation and off-site disposal of unsaturated
surface soil exhibiting contaminant concentrations of PAHs and PCBs greater than the
Industrial Use SCOs for those substances in areas not currently addressed by an
approved IRM or covered by facility paved surfaces (roadways or parking lots) or the
former manufacturing building. The approximate volume of material associated with this
excavation is estimated to be 38 CY. The excavated areas would be restored to grade
with certified clean fill following confirmatory sampling.
The enhancement to the Former Thinner Tanks Area Groundwater Recovery System
would include the installation of a flow meter with a totalizer on each of the two existing
collection trenches to monitor effluent withdrawn from each trench and conveyed to the
SPDES treatment system. The Former Thinner Tanks Area Groundwater Recovery
System would be expanded with the installation of an additional collection trench or
groundwater extraction wells to help increase the removal of VOC mass {i.e., xylene,
ethylbenzene, and toluene) and to restore groundwater quality in this area. While the FS
cost estimate assumes that two wells would be installed, the appropriate method for
extracting the groundwater would be determined during the RD.
During the RD, studies would be performed to determine the well placement, pumping
rates, and drawdown levels that would allow for optimal capture for the three
groundwater extraction systems (located in the perimeter shallow, perimeter deep, and
the targeted deep area northeast of the former manufacturing building).
This alternative would also include an evaluation of the existing SSDS during the RD to
determine whether enhancements to the system could effectively improve the removal
of elevated VOCs in the unsaturated soil beneath the former manufacturing building.
As part of the long-term groundwater quality monitoring, COC concentration and natural
attenuation data would be collected from the shallow and deep groundwater throughout
OU1. Following the operation of the new perimeter groundwater extraction system for a
period up to five years, an evaluation would be performed to determine whether the
system is effectively reducing or attenuating COC concentrations in off-property
groundwater. If it is determined that continued groundwater extraction at the property
perimeter alone would not achieve the remediation goals for the off-property
groundwater within a reasonable timeframe, then off-property in-situ treatment and/or
extraction and treatment would be considered and may be incorporated into the remedy
as determined to be appropriate.
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The evaluations of the SSDS, targeted groundwater extraction system, and perimeter
extraction system would be documented, and the implementation of any of these
additional remedial components (e.g., SSDS enhancement and off-property groundwater
treatment) would be documented in an ESD.
Monitoring the enforcement, as necessary, of the existing environmental easement for
the property which achieves the following:
• require the submission of a periodic certification of institutional and engineering
controls in accordance with Part 375-1.8 (h)(3);
• restrict the use and development of the property to industrial use as defined by Part
375-1.8(g), subject to local zoning laws;
• restrict the use of groundwater as a source of potable or process water without
appropriate treatment as determined by the NYSDOH or the Onondaga County
Health Department; and
• require compliance with the approved SMP.
Under this alternative, a SMP would be required that will include the following
components:
1) An Institutional and Engineering Control Plan that identifies all use restrictions and
engineering controls for the site and details the steps and media-specific
requirements necessary to ensure the following institutional and/or engineering
controls remain in place and effective:
¦ an excavation plan that details the provisions for management of future
excavations in areas of remaining contamination;
¦ a provision for further investigation and remediation should large-scale
redevelopment occur, if any of the existing structures are demolished, or if the
subsurface is otherwise made accessible. The nature and extent of contamination
in areas where access was previously limited or unavailable would be investigated
pursuant to an approved plan. Based upon the investigation results and a
determination of the need for possible additional response activities, a remedy
modification would be developed for OU1, including removal and/or treatment of
any source areas, to the extent feasible. Citizen Participation Plan activities would
continue through this process. It is anticipated that any necessary remediation
would be completed prior to, or in association with, redevelopment. This includes
the former manufacturing building;
¦ descriptions of the provisions of the environmental easement including any land
and groundwater use restrictions;
¦ provisions for the management and inspection of the identified engineering
controls;
¦ plans to maintain site access controls and notification requirements; and
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¦ Identification of steps necessary for the periodic reviews and certifications of the
institutional and/or engineering controls.
2) A Monitoring Plan to assess the performance and effectiveness of the remedy. The
plan includes, but may not be limited to, the following:
¦ monitoring of groundwater to assess the performance and effectiveness of the
remedy;
¦ a schedule of monitoring and frequency of submittals;
¦ monitoring for vapor intrusion for any buildings on the facility property, as may be
required by the Institutional and Engineering Control Plan described above.
3) An O&M Plan to ensure continued operation, maintenance, optimization, monitoring,
inspection, and reporting of any mechanical or physical components of the remedy.
The plan would include, but not be limited to, the following:
¦ procedures for operating and maintaining the remedy;
¦ compliance monitoring of treatment systems to ensure proper O&M, as well as
providing the data for any necessary permit or permit equivalent reporting;
¦ maintaining site access controls and required notifications; and
¦ provide access to the site and O&M records.
Because this alternative would result in contaminants remaining above levels that would
otherwise allow for unrestricted use and unlimited exposure, CERCLA requires that OU1
be reviewed at least once every five years. A conceptual depiction of Alternative 2 is
presented in Figure 6 in Appendix I.
The estimated construction time for this alternative is one year.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Capital Cost: $5,560,000
Annual O&M Cost: $264,000
Present-Worth Cost: $8,990,000
Alternative 3 - Targeted Shallow Groundwater Collection and Treatment,
Perimeter and Targeted Deep Groundwater Extraction and Treatment, and Soil
Excavation with Off-Site Disposal
Alternative 3 is similar to Alternative 2, except there would be no shallow groundwater
trench installed at the property perimeter. Enhancement and expansion of the Former
Thinner Tanks Area Groundwater Recovery System to target the shallow groundwater
contamination in that area would, however, be retained in this Alternative. Alternative 3
would rely on a deep groundwater extraction and treatment system at the property
perimeter combined with a targeted deep groundwater extraction system to address the
contamination in the areas beneath and immediately northeast of the manufacturing
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building. A conceptual depiction of Alternative 3 is presented in Figure 7 in Appendix I.
The estimated construction time of this alternative is one year.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Alternative 4 - In-Situ Treatment of Residual Source Areas, Perimeter Deep
Groundwater Extraction and Treatment, and Soil Excavation with Off-Site Disposal
Alternative 4 is similar to Alternative 2, except there would be no shallow groundwater
collection trench installed at the property perimeter and no expansion of the Former
Thinner Tanks Groundwater Recovery System. Instead, in-situ treatment would be
employed rather than groundwater extraction and treatment to significantly reduce
contaminant concentrations in the residual source areas (the Former Thinner Tanks
Area, northeast of the manufacturing building, and beneath the former manufacturing
building). In-situ treatment would involve injecting amendment(s) using horizontal drilling
techniques to promote contaminant degradation in the area beneath the building.
Injection points would be positioned at the perimeter of the manufacturing building and
extended horizontally to target the contamination beneath the building. A conceptual
depiction of Alternative 4 is presented in Figure 8 in Appendix I.
The estimated construction time of this alternative is one year.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Alternative 5 - In-Situ Treatment of Residual Source Areas, Perimeter Shallow
Groundwater Collection and Deep Groundwater Extraction and Treatment, and
Soil Excavation with Off-Site Disposal
Alternative 5 includes the same elements as Alternative 4, except that instead of using
horizontal in-situ injection techniques at the building perimeter to address contaminants
present beneath the building, vertical injection techniques would be used to address the
Capital Cost:
Annual O&M Costs:
Present-Worth Cost:
$3,890,000
$266,000
$7,340,000
Capital Cost:
Annual O&M Costs:
Present-Worth Cost:
$18,600,000
$264,000
$22,200,000
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contaminants present beneath the building. As such, Alternative 5 would require drilling
through the former manufacturing building floor. In addition, a shallow groundwater
collection trench at the property perimeter would be installed as described under
Alternative 2.
Alternative 5 would also include the excavation and off-site disposal of surface and
subsurface soil exhibiting concentrations greater than the Industrial Use SCOs, including
areas currently covered by an approved IRM, or paved surfaces (roadways or parking
lots). The approximate total volume of material associated with this excavation would be
1,500 CY. The excavated areas would be restored to grade with certified clean fill
following confirmatory sampling. A conceptual depiction of Alternative 5 is presented in
Figure 9 in Appendix I.
The estimated construction time of this alternative is one year.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
COMPARATIVE ANALYSIS OF ALTERNATIVES
The detailed analysis required under the NCP consists of an assessment of the individual
alternatives against each of the nine evaluation criteria (see below) and a comparative
analysis focusing upon the relative performance of each alternative against those
criteria.
The first two criteria are known as "threshold criteria" because they are the minimum
requirements that an alternative must meet to be eligible for selection as a remedy. The
next five criteria, criteria 3 through 7, are known as "primary balancing criteria." These
criteria are applied as factors between response measures so that the best option will
be chosen given site-specific data and conditions. The final two criteria, criteria 8 and 9,
are known as "modifying criteria." Community and support agency acceptance are
factors that are assessed by reviewing comments received during the public comment
period, including any new information that might be made available after publication of
the proposed plan that significantly changes basic features of the remedy with respect
to scope, performance, or cost.
The nine evaluation criteria are:
Capital Cost:
Annual O&M Costs:
Present-Worth Cost:
$22,600,000
$259,200
$26,000,000
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1. Overall protection of human health and the environment in which it is determined
whether an alternative eliminates, reduces, or controls threats to public health and
the environment through the implementation of remedial measures such as
institutional controls, engineering controls, or treatment.
2. Compliance with ARARs in which it is evaluated whether the alternative would
meet all of the applicable or relevant and appropriate requirements of federal and
state environmental statutes and other requirements that pertain to this Subsite
or provide grounds for invoking a waiver.
3. Long-term effectiveness and permanence is considered in the context of the
ability of an alternative to maintain protection of human health and the
environment over time.
4. Reduction of toxicity, mobility, or volume through treatment is the criterion by
which an alternative's anticipated performance related to treatment technologies
that an alternative may employ is gauged.
5. Short-term effectiveness is considered in the context of the duration needed to
implement an alternative and the risks that the alternative may pose to workers,
residents, and the environment during implementation.
6. Implementabilitv is the technical and administrative feasibility of implementing the
alternative, including the availability of materials and services.
7. Cost includes estimated capital and annual operation and maintenance costs, as
well as present-worth costs. Present worth cost is the total cost of an alternative
over time in terms of today's dollar value. Cost estimates are expected to be
accurate within a range of +50 to -30 percent.
8. State acceptance is whether, based on its review of the RI/FS reports and the
Proposed Plan, the State supports, opposes, and/or has identified any
reservations with the selected response measure.
9. Community acceptance refers to the public's general response to the alternatives
described in the Proposed Plan and the RI/FS reports.
A comparative analysis of these alternatives based upon the evaluation criteria noted
above follows.
Overall Protection of Human Health and the Environment
Alternative 1 would not be protective of human health and the environment because it
would not address contaminated soil or groundwater. Alternatives 2 through 5 would be
protective of human health and the environment because each of these alternatives
would rely upon remedial strategies and/or treatment technologies capable of eliminating
exposure to contaminated soil and groundwater. The existing ICs under Alternatives 2
through 5 would provide additional protection of public health.
Compliance with ARARS
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Alternative 1 would not provide for any direct remediation of groundwater and would,
therefore, not achieve chemical-specific ARARs for groundwater within a reasonable
timeframe. Alternatives 2 through 5 would be more effective in reducing groundwater
contaminant concentrations below MCLs because each option includes active
remediation of the contaminated groundwater.
There are no ARARs that were identified for Alternative 1 because it is a no action
alternative. With regard to location-specific ARARs for Alternatives 2 through 5, they
would be conducted in a manner consistent with federal and state freshwater wetlands
and floodplain requirements. Existing ICs would be monitored and enforced under
Alternatives 2 through 5 in general conformance with NYSDEC's DER-33 guidance.
Additionally, continued maintenance of cover systems included as part of Alternatives 2
through 5 (including existing cover systems) would prevent erosion and exposure to
contaminated soil. Cover systems would be implemented in general conformance with
NYSDEC's DER-10 guidance. Procedures would be implemented to adhere to the
location-specific ARARs and other requirements related to federal and state cultural,
archeological, and historical resources requirements. The need for a scope of cultural
resources survey, as required by the National Historic Preservation Act, would be
evaluated during the RD. With respect to action-specific ARARs, proposed cover
systems and excavation activities would be conducted consistent with applicable
standards; earth moving/excavation activities would be conducted consistent with air
quality standards; transportation and disposal activities would be conducted in
accordance with applicable state and federal requirements by licensed and permitted
haulers.
Compliance with action-specific ARARs related to hazardous waste management
requirements for treatment residuals and SPDES requirements for treated water
discharged to Ley Creek would be addressed in Alternatives 2 through 5 during the
continued operation of the Former Thinner Tanks Area shallow groundwater collection
and SPDES Treatment System IRM. Action-specific ARARs related to subsurface
injection of chemical oxidation amendments under Alternatives 4 and 5 would be met
during remedy implementation.
The chemical-specific ARARs in the water-column for PCBs (New York State Class GA
groundwater standard of 0.09 ppb), for VOCs (TCE SCG of 5 ppb, cis-1,2-DCE SCG of
5 ppb, and vinyl chloride SCG of 2 ppb), and non-chlorinated VOCs, including toluene,
ethylbenzene, and xylene SCGs of 5 ppb, would be met under Alternatives 2-5.
The provisions of ECL Section 27-1318, Institutional and Engineering Controls, is
applicable to the environmental easement under Alternatives 2 through 5.
Long-Term Effectiveness and Permanence
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Alternative 1 would involve no active remedial measures and, therefore, would not be
effective in eliminating the potential exposure to contaminants in the soil and
groundwater and would allow for the continued release of contaminants from the soil to
the groundwater and the continued migration of contaminated groundwater.
Alternatives 2 through 5 would be effective in the long term and would provide permanent
remediation by removing the contaminated soil and treating/disposing of the
contaminated soil at a licensed disposal facility. Alternatives 2 and 3 would be effective
in the long term because there would be continuous extraction and treatment of the
source material in the groundwater. Alternatives 4 and 5 would be more effective at
removing the source material in the groundwater than Alternatives 2 and 3 because
Alternatives 4 and 5 include the application of in-situ treatment techniques. Use of in-
situ techniques under Alternative 4 and 5 would also reduce the need to continuously
operate groundwater extraction and treatment systems. Alternatives 4 and 5 with the use
of in-situ treatment techniques would also be more effective than Alternatives 2 and 3 at
removing contamination beneath the former manufacturing building.
By actively addressing contamination, Alternatives 2 through 5 would maintain reliable
protection of human health and the environment over time. Under Alternatives 2 through
5, the groundwater treatment residues would have to be appropriately handled by the
on-site SPDES Treatment Facility. Alternative 1 would not generate such treatment
residual because it does not involve active remediation. Alternative 4 would generate the
least amount of greenhouse gases in the long term because there would only be the
perimeter deep groundwater extraction and treatment system operating as part of OU1
management compared to the other alternatives with multiple extraction and treatment
systems, thereby decreasing the use of energy and the production of greenhouse gas
emissions. The long-term performance of Alternatives 2 through 5 could be at risk during
severe storms/weather events and associated flooding. Potential flooding-related threats
to the in-situ treatment injection and groundwater extraction and treatment systems
would need to be evaluated during the RD to ensure adequate resiliency to the potential
effects of climate change.
Reduction in Toxicity. Mobility, or Volume Through Treatment
There would be no reduction in toxicity, mobility, or volume under Alternative 1.
Alternatives 2 through 5 would afford similar reductions in toxicity, mobility, and volume
through the collection and treatment of contaminated groundwater, thereby satisfying
CERCLA's preference for treatment. Alternatives 4 and 5, would rely upon in-situ
treatment techniques to address the contamination in certain portions of the
groundwater.
In-situ treatment, a remedial element included in Alternatives 4 and 5 would address
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contaminants in areas where high concentrations of site contaminants, and potentially
NAPL, which constitutes a principal threat waste, exist. In-situ treatment relies on a
chemical reaction or biological processes to permanently destroy VOC contamination.
Therefore, it would effectively reduce the toxicity, mobility, and volume of the site
contamination and directly treat principal threat waste if it is present.
Short-Term Effectiveness
Alternative 1 does not include any physical construction measures in any areas of
contamination, thus it would not present any potential adverse impacts to remediation
workers or the community as a result of its implementation.
There could be potential adverse impacts to remediation workers and nearby employees
and visitors at the former manufacturing building under Alternatives 2 through 5 through
dermal contact, incidental ingestion, and inhalation related to the removal, handling, and
processing of contaminated groundwater and soil. Noise from the soil excavation work
associated with these alternatives could present some limited adverse impacts to
remediation workers and nearby employees. In addition, soil and groundwater sampling
activities would pose some risk. The risks to remediation workers and nearby employees
under all of the action alternatives could, however, be mitigated by following appropriate
health and safety protocols, exercising standard construction and engineering practices,
and utilizing proper protective equipment.
Potential environmental impacts related to dust, volatile emission, and surface runoff
would be mitigated through appropriate control measures and adherence to a
Community Air Monitoring Plan.5
There is an environmental footprint inherent in implementation of each of Alternatives 2
through 5 as it relates to construction and long-term operation. The implementation
installation and long-term use of a shallow groundwater collection trench included in
Alternatives 2 and 5 would result in greater direct emissions and fuel consumption
needed for construction equipment, transporting necessary material, and long-term
extraction and treatment of groundwater from the shallow groundwater collection trench
as compared to the other action alternatives. Under Alternatives 4 and 5, in-situ
treatment would have higher initial, up-front greenhouse gas emissions than Alternatives
2 and 3 as a result of the use of heavy construction equipment needed for drilling and
introducing in-situ amendments. However, the emissions would decrease in the long-
term and ultimately produce the least greenhouse gas emissions. Alternatives 2, 3, 4,
and 5 would be able to utilize the existing SPDES treatment system. Specifically, instead
of constructing a new treatment plant, these Alternatives would be able to upgrade and
5 The purpose of a Community Air Monitoring Plan is to provide protection to potential receptors
(i.e., remediation workers, tenants, and visitors) from potential airborne contaminant releases as
a result of remedial work activities performed at the site.
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retrofit the existing treatment system to accommodate the additional volume of extracted
groundwater. Green remediation techniques would be considered to help minimize the
environmental footprint related to the implementation of the remedial alternatives.
For all the action alternatives, there is a potential for stormwater runoff and erosion during
construction and excavation activities that would have to be properly managed to prevent
or minimize any adverse impacts. For these alternatives, appropriate measures would
have to be taken during excavation activities to prevent transport of fugitive dust and
exposure of remediation workers and employees at the former manufacturing building
and surrounding community.
Alternatives 2 through 5 would address exposure-related RAOs upon implementation.
Alternatives 2 through 5 are expected to address the off-property migration RAO within
approximately one year of implementation of the remedies. Alternative 1 would not
address the RAO associated with adult trespassers or groundwater use.
The former manufacturing building is currently being utilized by tenants conducting
commercial and light industrial activities. Out of Alternatives 2 through 5, Alternative 5
would be the most disruptive to these businesses, as it would likely necessitate intrusive
actions within the building to treat the underlying contamination. It is estimated that
Alternatives 2 through 5 would require one year to implement.
Although it would likely take greater than 30 years to attain groundwater standards for
each of the alternatives, Alternatives 4 and 5, which include the use of in-situ and
traditional groundwater treatment to address areas with elevated VOC concentrations,
would likely achieve the groundwater standards in the shortest amount of time relative
to the other alternatives. Alternative 4 would achieve groundwater standards with less
disruption to the businesses than Alternative 5.
Implementabilitv
Alternative 1 would be the easiest alternative to implement, as there are no activities to
undertake. Soil excavation would be readily implementable under Alternatives 2 through
5.
Construction of the shallow perimeter trench under Alternatives 2 and 5 would require
excavation in the vicinity of utilities, including a National Grid high pressure gas line that
runs the length of the property border along Factory Ave; National Grid overhead power
lines along the property line along Factory Avenue; National Grid overhead high voltage
power lines that traverse Factory Avenue from the former landfill at the facility; an
Onondaga County sanitary sewer located on the southern shoulder of Factory Avenue;
and the former landfill (and associated low permeability membrane). Construction in the
vicinity of the above-noted obstacles and utilities would require offsets and are likely to
33
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require measures to protect workers and the utilities during construction activities. These
measures would not be necessary under Alternative 3 and 4, which do not include the
installation of the shallow groundwater collection system. Installation of the groundwater
extraction wells under Alternatives 2 through 5 would require measures to protect
workers and the utilities during construction activities.
In-situ treatment, a remedial element of Alternatives 4 and 5, would require a treatability
study. Subsurface soil conditions and the presence of underground utilities would need
to be evaluated as they might interfere with the injection of reagents.
The former manufacturing building is currently being utilized by tenants conducting
commercial and light industrial activities. Implementation of Alternative 5, which would
necessitate intrusive actions within the building to treat the underlying contamination,
would be more difficult to implement than Alternatives 2, 3, and 4.
Each alternative would require coordination among EPA, NYSDEC, Onondaga County,
the Town of Salina, and the current manufacturing building's tenants.
Off-site facilities for treatment, storage, and disposal of treatment residuals and
excavated soil would be readily available for each alternative. The necessary equipment,
specialists, and materials would be readily available.
Cost
The estimated present-worth costs were calculated using a discount rate of seven
percent and a thirty-year time interval for the post-construction monitoring and
maintenance period. (Although O&M would continue as needed beyond the 30-year
period, this is the typical period used when estimating costs for a comparative analysis.)
The estimated capital, annual O&M, and present-worth costs using a 7% discount factor
for each of the alternatives are presented in the table below.
Alternatives
Capital Cost
Annual O&M
Cost
Total Present
Worth Cost
1 - No Further Action
$0
$0
$0
2 - Perimeter and Targeted
Shallow Groundwater
Collection; Perimeter and
Targeted Deep Groundwater
Extraction and Treatment;
Soil Excavation and Disposal
$5.6 million
$264,000
$8.99 million
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3 - Targeted Shallow
Groundwater Collection;
Perimeter and Targeted
Deep Groundwater
Extraction and Treatment;
Soil Excavation and Disposal
$3.89 million
$266,000
$7.34 million
4 - In-Situ Treatment of
Residual Source Areas;
Perimeter Deep Groundwater
Extraction and Treatment;
Soil Excavation and Disposal
$18.6 million
$264,000
$22.2 million
5 - In-Situ Treatment of
Residual Source Areas;
Perimeter Shallow
Groundwater Collection and
Treatment; Perimeter Deep
Groundwater Extraction and
Treatment; Soil Excavation
and Disposal
$22.6 million
$259,000
$26 million
State Acceptance
NYSDEC is the lead agency for 0U1. EPA has determined that the selected remedy
meets the requirements for a RAas set forth in CERCLA Section 121, 42 U.S.C. §9621.
As such, for the purpose of satisfying this remedy selection criterion of the NCP,
NYSDEC, on behalf of New York State, supports the selected remedy. NYSDOH also
supports the selection of this remedy; its letter of concurrence is attached (see Appendix
IV).
Community Acceptance
Minimal feedback was received from the community during the public comment period.
The comments received from the single commenter were in support of efforts to minimize
disruptions to building tenants and to encourage coordination with the property owner.
The comments that were received during the public comment period are summarized
and addressed in the Responsiveness Summary, which is attached as Appendix V.
PRINCIPAL THREAT WASTE
The NCP establishes an expectation that EPA will use treatment to address the principal
threats posed by a site, wherever practicable (NCP Section 300.430 (a)(1)(iii)(A)). The
principal threat concept is applied to the characterization of source materials at a
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Superfund site. A source material is material that includes or contains hazardous
substances, pollutants, or contaminants that act as a reservoir for the migration of
contamination to groundwater, surface water, or air, or act as a source for direct
exposure. Principal threat wastes are those source materials considered to be highly
toxic or highly mobile that generally cannot be reliably contained or will present a
significant risk to human health or the environment should exposure occur. The decision
to treat these wastes is made on a site-specific basis through a detailed analysis of
alternatives, using those remedy-selection criteria that are described above. This
analysis provides a basis for making a statutory finding that the remedy employs
treatment as a principal element.
PCB NAPL may be present beneath the former manufacturing building due to past
releases of PCB-containing hydraulic fluid to sumps and to leaking process sewers
during the manufacturing processes. Chlorinated VOC NAPL may also be present
beneath and north of the manufacturing building, emanating from the center of the
building in the vicinity of a former paint room.
A past leak from the underground paint thinner storage tanks/piping in the Former
Thinner Tanks Area is a potential source of non-chlorinated VOC NAPL that may be
present in this area. As part of the Thinner Tanks System Area Groundwater Recovery
IRM, GM installed two groundwater collection trenches and associated piping to collect
and treat the contaminated groundwater. While the IRM has contained the plume, there
may be a source (e.g., NAPL) that remains based on contaminant levels in groundwater
in this area.
Because the noted NAPL is highly toxic, cannot be reliably contained, and will present a
significant risk to human health or the environment should exposure occur, it constitutes
a principal threat waste.
SELECTED REMEDY
Summary of the Rationale for the Selected Remedy
Based upon consideration of the requirements of CERCLA, the detailed analysis of the
alternatives, and public comments, NYSDEC and EPA have determined that Alternative
4 - In-Situ Treatment of Residual Source Areas; Perimeter Deep Groundwater Extraction
and Treatment; Soil Excavation and Disposal, best satisfies the requirements of
CERCLA Section 121, 42 U.S.C. § 9621, and provides the best balance of tradeoffs
among the remedial alternatives with respect to the NCP's nine evaluation criteria, set
forth at 40 CFR § 300.430(e)(9).
Alternative 1 does not satisfy the threshold criteria because it does not provide protection
36
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of human health or the environment or provide a means to attain ARARs. Alternative 3
is similar to Alternative 2, except there would be no shallow groundwater collection trench
installed along the northern perimeter of the facility property (only a deep groundwater
extraction and treatment system).
Alternative 4 is similar to Alternative 2, except there would be no shallow groundwater
collection trench installed at the property perimeter, no expansion of the Former Thinner
Tanks Groundwater Recovery System, and in-situ treatment techniques would be
employed instead of groundwater extraction and treatment to address residual
contamination in the Former Thinner Tanks Area, northeast of and beneath the former
manufacturing building. Because the shallow groundwater contamination on the property
is primarily located in the Former Thinner Tanks Area and would be addressed through
in-situ treatment, and as discussed above in the "Site Geology and Hydrogeology"
section, the shallow groundwater contamination that is present outside of the Former
Thinner Tanks Area is limited, shallow groundwater treatment at the property perimeter
is not essential for the remedy to be effective.
Alternative 5 is similar to Alternative 4, except Alternative 5 would use traditional vertical
well installation for the in-situ treatment remedy instead of horizontal wells and
Alternative 5 would also include the installation of a shallow groundwater collection
trench at the facility perimeter and soil removal beneath the cover systems and paved
areas (parking lots and roads).
While approximately $1.65 million more expensive than Alternative 3, Alternative 2 would
directly address contaminated shallow groundwater along the northern perimeter of the
facility property, whereas Alternative 3 would not. Alternatives 4 and 5 are more costly
($22,200,000 and $26,000,000, respectively) than Alternative 2 ($8,990,000), but both
Alternatives would be more effective than Alternative 2 in addressing the three residual
source areas.
Alternative 4 includes active treatment of three separate residual source areas with in-
situ treatment, therefore it does not include a shallow groundwater collection trench at
the property perimeter to address the low concentrations of shallow groundwater
contamination outside of the source areas. As stated above, the perimeter shallow
groundwater trench would not necessarily add to the effectiveness of the remedy, given
that the primary source of shallow groundwater contamination will be actively treated the
Former Thinner Tanks Area and there is a limited presence of contamination in the
shallow groundwater outside of the source areas. Alternatives 4 and 5 would be equally
effective in addressing the residual source areas where NAPL, which constituents a
principal threat waste, may be present under the former manufacturing building.
However, Alternative 5 would be more disruptive to the tenants because installing
traditional vertical wells for the in-situ treatment would require drilling through the building
concrete floor within tenant-occupied spaces inside of the former manufacturing building.
37
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Alternative 4 would rely on horizontal wells/directional drilling outside of the building
footprint for the in-situ treatment. In summary, both Alternatives 4 and 5 would be more
protective and significantly more costly than Alternatives 2 and 3. In comparing
Alternative 4 and 5, however Alternative 4 would be less disruptive to building occupants
and would cost approximately $3.8 million less than Alternative 5.
Based on information currently available, NYSDEC and EPA believe that Alternative 4 is
the most appropriate alternative to address contamination at OU1. The selected remedy
meets the threshold criteria and provides the best balance of tradeoffs among the other
alternatives with respect to the balancing and modifying criteria. NYSDEC and EPA
expect the selected remedy to satisfy the following statutory requirements of CERCLA
Section 121(b): 1) be protective of human health and the environment; 2) comply with
ARARs; 3) be cost-effective; 4) utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable; and
5) satisfy the preference for treatment as a principal element (or justify not meeting the
preference).
NYSDEC and EPA agree that the selected remedy is protective of human health and the
environment; can be readily constructed and operated, presents minimal potential short-
term impacts to workers and the community, and is cost-effective. The selected remedy
utilizes permanent solutions, alternative treatment technologies, and resource-recovery
technologies to the maximum extent practicable.
Description of the Selected Remedy
The selected remedy, Alternative 4, includes the following components:
• Three areas where high concentrations of residual VOC contamination exist in
saturated soil will be addressed using in-situ treatment. These three areas contain
contaminants at concentrations greater than 10,000 ppm and represent
continuing sources of groundwater contamination. Specifically, these areas
include the Former Thinner Tanks Area, where non-chlorinated VOC residual
contamination remains, and areas beneath and northeast of the former
manufacturing building where residual chlorinated VOC contamination remains.
As part of the RD, pre-design investigations will be performed in each of these
areas to determine the volumes requiring treatment and the most-effective type
of in-situ treatment(s).
• Installation of deep groundwater extraction wells along the northern perimeter of
the facility property. Contaminated groundwater that has migrated from the source
areas identified above will be extracted from these wells to prevent off-property
migration. Following extraction, the contaminated groundwater will be treated at
the existing SPDES water treatment system (using filtration and granulated
activated carbon) prior to being discharged to Ley Creek. The groundwater
38
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extraction system will be designed with a capture zone sufficient to address the
areal and vertical extent of the groundwater contamination. During the RD, a study
will be performed to determine the extraction well placement, the groundwater
pumping rates, and the drawdown levels necessary to achieve optimal capture.
To evaluate the effectiveness of the extraction system, a groundwater monitoring
program will be implemented as part of this remedy.
• An estimated 38 CY of unsaturated surface soil will be excavated and disposed
of off-site at a licensed disposal facility. The soils requiring excavation are those
that contain contaminants at concentrations greater than the Industrial Use SCOs
for PAHs and PCBs and are located in areas not currently addressed by an
approved Interim Remedial Measure (IRM) or covered and isolated by facility
paved surfaces (roadways or parking lots) or the former manufacturing building.
Following confirmatory soil sampling to demonstrate that the SCOs have been
achieved, the excavated areas will be restored to grade with clean fill meeting the
requirements of 6 NYCRR Part 375-6.7(d).
• The existing SSDS beneath the former manufacturing building includes two sub-
slab vapor extraction systems that withdraw air at a rate of approximately 195
cubic feet per minute for System 1 and 94 cubic feet per minute for System 2. An
evaluation of the SSDS will be performed during the RD to determine whether
enhancements to the system could further improve the removal of elevated VOCs
in the unsaturated soil beneath the former manufacturing building. Data will be
collected to determine if the existing SSDS can be upgraded to not only continue
to prevent sub-slab vapors from entering the former manufacturing building, but
to enhance the removal of chlorinated VOC contamination present in the vadose
zone soil beneath the building.
• As part of the long-term groundwater quality monitoring, data will be collected in
the shallow and deep groundwater throughout this portion of the Subsite related
to COC concentration and natural attenuation. Following the operation of the
perimeter groundwater extraction and treatment system for a period up to five
years, an evaluation will be performed to determine whether the system is
effectively reducing COC concentrations in the off-property groundwater. If it is
determined that continued groundwater extraction at the facility property
perimeter alone will not achieve the remediation goals for the off-property
groundwater within a reasonable timeframe, then off-property in-situ treatment
techniques and extraction and treatment will be considered and incorporated into
the remedy as determined to be appropriate.
• The evaluations of the SSDS and perimeter extraction system and the
implementation of any of the associated alternative remedies will be documented
via an ESD.
• As part of a long-term monitoring program, shallow and deep groundwater
samples will be collected from monitoring wells throughout this portion of the
Subsite to evaluate the performance of the groundwater extraction and treatment
system, as well as the effectiveness of the in-situ treatment in the three residual
39
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source areas where high concentrations of site contaminants remain. The details
of the monitoring program will be developed as part of the RD/remedial action and
outlined in a Monitoring Plan.
• The remedy will also include the imposition of an IC in the form of the existing
environmental easement for the controlled property which will achieve the
following:
1. require the submission of a periodic certification of institutional and
engineering controls in accordance with Part 375-1.8 (h)(3);
2. restrict the use and development of the former facility property to industrial
use as defined by Part 375-1.8(g), subject to local zoning laws;
3. restrict the use of groundwater as a source of potable or process water
without appropriate treatment as determined by the NYSDOH or the
Onondaga County Health Department; and
4. require compliance with the approved SMP.
• A SMP will be required that includes the following components:
1. An Institutional and Engineering Control Plan that identifies all use
restrictions and engineering controls for the portion of the Subsite and
details the steps and media-specific requirements necessary to ensure the
following institutional and/or engineering controls remain in place and
effective:
¦ an excavation plan that details the provisions for management of
future excavations in areas of remaining contamination;
¦ a provision for further investigation and remediation should large-
scale redevelopment occur, if any of the existing structures are
demolished, or if the subsurface is otherwise made accessible. The
nature and extent of contamination in areas where access was
previously limited (beneath the 800,000 sf former manufacturing
building) or unavailable will be immediately and thoroughly
investigated pursuant to an approved plan. Based on the
investigation results and a determination of the need for possible
additional remedial actions, a remedy modification will be developed
for the portion of the Subsite, including removal and/or treatment of
any source areas to the extent feasible. Citizen Participation
activities will continue through this process. Any necessary future
remediation will be completed prior to, or in association with,
redevelopment. This includes the former manufacturing building;
¦ descriptions of the provisions of the environmental easement
including any land use or groundwater use restriction;
¦ provisions for the management and inspection of the identified
engineering controls;
¦ maintain site access controls and notification; and
¦ steps necessary for the periodic reviews and certification of the
institutional and/or engineering controls.
40
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2. A Monitoring Plan to assess the performance and effectiveness of the
remedy. The plan will include, but may not be limited to the following:
¦ monitoring of groundwater to assess the performance and
effectiveness of the remedy;
¦ a schedule of monitoring and frequency of submittals; and
¦ monitoring for vapor intrusion for any buildings on the facility
property, as may be required by the Institutional and Engineering
Control Plan described above.
3. An O&M Plan to ensure continued operation, maintenance, optimization,
monitoring, inspection, and reporting regarding any mechanical or physical
components of the remedy. The plan includes, but is not limited to the
following:
¦ procedures for operating and maintaining the remedy;
¦ compliance monitoring of treatment systems to ensure proper O&M,
as well as providing the data for any necessary permit or permit
equivalent reporting;
¦ maintaining site access controls and required notification; and
¦ provide access to the site and O&M records.
• Long-term O&M will be performed for the above-noted remedial actions as well
as for the previously implemented IRMs, including the Former Landfill IRM;
Surface Impoundment Cover #1 IRM; Former Thinner Tanks Groundwater
Recovery System IRM; SPDES Treatment System IRM; and the Vapor Intrusion
Mitigation IRM {i.e., sub-slab depressurization system).
• Maintenance activities and performance monitoring will be conducted to ensure
that the remedial elements and IRMs are operating effectively and efficiently and
to identify the need to implement corrective action(s). Corrective actions for the
IRM covers, as well as the existing paved surfaces {i.e., roadways or parking lots)
and the former manufacturing building that currently serve as a cover for impacted
shallow soils, may consist of repair in areas of disturbance or re-application of
vegetation in areas of non-survival.
• Because this alternative will result in contaminants remaining above levels that
allow for unrestricted use and exposure, CERCLA requires that OU1 be reviewed
at least once every five years.
• Green remediation techniques, as detailed in NYSDEC's Green Remediation
Program Policy-DER-316 and EPA Region 2's Clean and Green Policy will be
considered during the implementation of the selected remedy to reduce short-
term environmental impacts. Green remediation best practices such as the
following may be considered:
1. Use of renewable energy and/or purchase of renewable energy credits to
power energy needs during construction and/or O&M of the remedy.
6 See http://www.dec.nv.qov/docs/remediation hudson pdfZder31.pdf
41
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2. Reduction in vehicle idling, including both on and off-road vehicles and
construction equipment during construction and/or O&M of the remedy.
3. Design of cover systems, to the extent possible, to be usable for alternate
uses, require minimal maintenance {e.g., less mowing), and/or be
integrated with the planned use of the property.
4. Beneficial reuse of material that will otherwise be considered a waste.
5. Use of ultra-low sulfur diesel.
Summary of the Estimated Remedy Costs
The estimated capital cost of the selected remedy is $18.6 million, the annual O&M is
$264,000, and the total present-worth cost (using a 7% discount rate) is $22.2 million.
Table 5 in Appendix II provides the basis for the cost estimates for the selected remedy.
It should be noted that these cost estimates are expected to be within +50 to -30 percent
of the actual project cost. These cost estimates are based on the best available
information regarding the anticipated scope of the selected remedy. Changes to the cost
estimate can occur as a result of new information and data collected during the design
of the remedy.
Expected Outcomes of the Selected Remedy
Based on the industrial nature of OU1 and its limited habitat available for area wildlife,
the ecological risk assessment indicates that site-related impacts to ecological receptors
is minimal. The results of the HHRA indicate that the contaminated soil, indoor air, and
groundwater present current and/or potential future unacceptable exposure risk. While
some of the risks associated with contaminated soil have been mitigated in part by the
previously implemented IRMs, the calculated risks are still considered to be valid as the
IRM components relating to placement of clean cover materials did not address all
Subsite areas and are not necessarily final actions. The selected remedy will mitigate
these remaining risks. In addition, it is anticipated that the remedy will result in the
restoration of shallow and deep groundwater at this subsite by in-situ treatment.
Under the selected remedy, potential risks to human health and the environment will be
reduced to acceptable levels. Remediation goals for the COCs are presented in Tables
1 and 2 in Appendix II. Remediation goals for surface soil will be met following
construction and implementation of appropriate institutional controls {e.g., approximately
one year following the start of construction). Additionally, the groundwater portion of the
remedy is expected to restore groundwater to its designated use as a New York State
Class GA drinking water source.
STATUTORY DETERMINATIONS
42
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Under CERCLA Section 121 and the NCP, the lead agency must select remedies that
are protective of human health and the environment, comply with ARARs (unless a
statutory waiver is justified), are cost-effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum
extent practicable. Section 121(b)(1) also establishes a preference for remedial actions
that employ treatment to permanently and significantly reduce the volume, toxicity, or
mobility of the hazardous substances, pollutants, or contaminants at a site.
For the reasons discussed below, NYSDEC and EPA have determined that the selected
remedy meets these statutory requirements.
Protection of Human Health and the Environment
The results of the risk assessment indicate that, if no action is taken, OU1 poses an
unacceptable human health risk.
The selected remedy will reduce exposure levels to protective levels or to within EPA's
generally acceptable risk range of 10~4 to 10~6 for carcinogenic risk and below the HI of 1
for noncarcinogens. The implementation of the selected remedy will not pose
unacceptable short-term risks or cross-media impacts that cannot be mitigated. The
selected remedy will be protective of human health and the environment in that the
construction of cover systems over contaminated soil will preclude potential human and
ecological exposure to contamination in soil. Combined with institutional controls, the
selected remedy will provide protectiveness of human health and the environment over
both the short- and long-term. Additionally, the groundwater portion of the remedy is
expected to restore groundwater to its designated use as a New York State Class GA
drinking water source.
Compliance with ARARs and Other Environmental Criteria
The selected remedy will comply with the location-, chemical-and action-specific ARARs
identified. The ARARs, TBCs, and other guidelines for the selected remedy are provided
in Table 3 of Appendix II.
Cost-Effectiveness
A cost-effective remedy is one whose costs are proportional to its overall effectiveness
(NCP Section 300.430(f)(1)(ii)(D)). Overall effectiveness is based on the evaluations of
the following: long-term effectiveness and permanence; reduction in toxicity, mobility,
and volume through treatment; and short-term effectiveness. Based on the comparison
of overall effectiveness (discussed above) to cost, the selected remedy meets the
43
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statutory requirement that Superfund remedies be cost-effective.
Each of the alternatives underwent a detailed cost analysis. In that analysis, capital and
annual O&M costs were estimated and used to develop present-worth costs. In the
present-worth cost analysis, annual O&M costs were calculated for the estimated life of
the alternatives and related monitoring using a seven percent discount rate and a 30-
year interval. The estimated capital, annual O&M, and total present-worth costs for the
selected remedy are $18.6 million, $264,000; and $22.2 million, respectively. The
estimated cost for the selected remedy is higher when compared to Alternative 2 and 3
because in-situ treatment cost estimates are higher but would be more effective at
reducing toxicity, mobility and volume in the short term. While Alternative 5 would also
address the groundwater through in-situ treatment, it might be more disruptive to the
occupying tenants of the building and would be least cost-effective means of achieving
remedial action objectives identified for this subsite.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected remedy provides the best balance of tradeoffs among the alternatives with
respect to the balancing criteria set forth in NCP Section 300.430(f)(1)(i)(B), such that it
represents the maximum extent to which permanent solutions and treatment
technologies can be utilized in a practicable manner at this Subsite.
The soil component of the selected remedy will permanently address the contaminated
surface soil in areas not currently addressed by the IRMs or covered by facility paved
surfaces or the former manufacturing building by employing off-site treatment/disposal.
With regard to the contaminated groundwater, the selected remedy will provide a
permanent solution and employ a treatment technology to reduce the toxicity, mobility,
and volume of the contaminants in the groundwater. Specifically, contaminated
groundwater in the deep aquifer will be addressed via extraction wells installed along the
northern perimeter of the facility property and treatment at the on-site SPDES treatment
plant. VOC contaminated groundwater in the Former Thinner Tanks Area and beneath
and northeast of the former manufacturing building will be addressed by in-situ treatment.
The SSDS may be upgraded to enhance the removal of chlorinated VOC contamination
present in the vadose zone soil beneath the former manufacturing building.
The continued O&M of the prior IRMs as required under the selected remedy will provide
long-term effectiveness and permanence while addressing groundwater impacts.
Implementation of an engineered cover system and ICs under the selected remedy will
provide adequate and reliable means of controlling erosion of, exposure to, and direct
contact with contaminated soil/fill material.
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Preference for Treatment as a Principal Element
CERCLA includes a preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity, or mobility of hazardous substances as a
principal element (or justify not satisfying the preference). Under the selected remedy,
VOCs in the groundwater will be subjected to both extraction and treatment at the
SPDES treatment plant and in-situ treatment by injecting an amendment(s), thereby
reducing their volume, toxicity, and mobility. In addition, the SSDS may be upgraded to
enhance the removal of chlorinated VOC contamination present in the vadose zone soil
beneath the former manufacturing building, thereby reducing their volume, toxicity, and
mobility. Therefore, the selected remedy satisfies the statutory preference for treatment
as a principal element of the remedy.
Five-Year Review Requirements
The selected remedy, once fully implemented, will result in hazardous substances,
pollutants, or contaminants remaining on-site above levels that would otherwise allow for
unlimited use and unrestricted exposure. Consequently, a statutory review will be
conducted within five years after initiation of the RA, and at five-year intervals thereafter,
to ensure that the remedy is, or will be, protective of human health and the environment.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan, released for public comment on July 27, 2023, identified Alternative
4, In-Situ Treatment of Residual Source Areas, Perimeter Deep Groundwater Extraction
and Treatment, and Soil Excavation with Off-Site Disposal, as the preferred alternative
for OU1. Based upon its review of the written and verbal comments submitted during the
public comment period, EPA and NYSDEC have determined that no significant changes
to the proposed remedy, as originally identified in the Proposed Plan, were necessary or
appropriate.
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OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX I
FIGURES
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- I I jy —M
1940101904
JUNE 2022
RACER TRUST
GM - IFG OU1
SYRACUSE, NEW YORK
SITE LOCATION
0 1,000 2,000 4,000
I Feet
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
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Sefvice Layer Credtfe: feource: Esri, Maxar, Earthstar Geographies, and the dfts User Community
NORTHERN
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FIGURE 2
Q
LEGEND
PROPERTY AREA LIMITS
RACER TRUST
FORMER IFG FACILITY
SYRACUSE, NEW YORK
PROPERTY AREAS OF THE
FORMER GM-OU1 SITE
100 200
400
600
I Feet
1940101904
JANUARY 2023
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
Service Layer CrecMsr © 2022 Microsoft Corporation © 2022 Maxar ©CNES (2022) Distribution Airbus QS.
rA%BSfft'BlI*ANDFIl35
NORTHEASTERN
proper™
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[SOUTHWESTERN
jbJTm
¦bh5^
lBH^S
BH-48'
MANUFACTURING
BUIlJDING?fO|
SOUTHEASTERN
R^0PER^M|
FIGURE 3
LEGEND
APPROXIMATE LIMITS OF LANDFILL
APPROXIMATE LIMITS OF SOIL STAGING
AREA
PROPERTY AREA
SAMPLE LOCATION WITH
EXCEEDANCE
SUBSURFACE SAMPLE > IND/PROT GW
SCO
+ SURFACE SAMPLE > IND/PROT GW SCO
RACER TRUST
GM - IFG OU1
SYRACUSE, NEW YORK
LOCATIONS GREATER THAN
SCOs
100 200
400
600
5 Feet
1940101904
JUNE 2022
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
11/1/2006 | 8/25/2011 | 8/2/2016 | 4/9/2019
10/31/2006 I 8/24/2011 | 8/2/2016 | 4/11/2019
11/10/1999 | 8/2/2016
8/3/20161
11/10/1999
10/31/2006 | 8/24/2011
8/3/2016
RESULTS
No Detections
11/4/1999 I 10/27/2006 | 4/10/2019
10/31/2006 | 8/3/2016
10/31/2006 | 8/3/2016
11/10/1999 | 10/30/2006 | 8/24/2011 | 8/2/2016
RESULTS
| Ace tone
11/9/1999
10/30/2006 | 8/16/2011 | 8/2/2016
No Detections
10/24/2006 | 4/10/2019
RESULTS
OBG W6SR DP.
1996 to September 1996 | 3/17/1997 | 6/12/1997 | 1997 to 1999 | 11/8/1999 | 2000 to 2006
3/20/1996
10/24/2006
|lMo detection!
[OBGT9SR/DRj
|Trichloroether
10/25/2006 | 4/11/2019
10/27/2006
11/3/1999 | 10/26/2006 | 4/10/2019
11/10/1999 | 11/10/1999
No Detections
10/23/2006
11/8/1999 | 10/23/2006
RESULTS
No Detections
1995 to 1996 I 3/17/1997
6/2/2000 | 4/11/2001 | 4/11/2002 12003 to 2006 | 5/8/2007 |2008to2009 | 6/23/2010
8/18/1999
11/8/1999 [ 10/25/2006
11/11/1999
RESULTS
,,2-Dichloroethene
|Methylene Chl(
11/8/1999
|Trichloroether
RESULTS
11/8/1999
No Detections
11/8/1999
No Detections
11/3/1999
10/9/2003
RESULTS
8/18/1999
11/3/2006
11/4/1999
8/18/1999
| PARAMETER
RESULTS
-Dichloroether
|TrichU
-1,2-Dichloroether
MONITORING WELL
MONITORING WELL STATUS UNKNOWN OR
ABANDONED
Total CVOC*
Concentrations (ug/L)
O
r—i
o
>10 -100
>100 -1000
>1000
Total CVOCs -1,1 -DCA, 1,1 -DCE,
cis-1,2-DCE (total), TCE, and VC
* - Color coding within data boxes refers to
individual constituents
OBG-26S - Based on last sampling result
|— LOCATION ID
j RESULTS IN ug/L -
0BG-23D
10/24/2006
PARAMETER
RESULTS
1,1-Dichloroethene
12
Benzene
1
3700
tra ns-l,2-Dichloroethene
10
Trichloroethene
1600
Vinyl Chloride
1300
BOLD RESULTS _J
Chemical Name - VOCs
Class GA
1,1-Dichloroethane
5
1,1-Dichloroethene
5
1,2-Dichloroethane
0.6
2-Butanone
50(G)
Acetone
50(G)
Benzene
1
Bromodichlorome thane
50(G)
Chlorobenzene
5
Chloroform
7
cis-l,2-Dichloroethene
5
Ethylbenzene
5
Isopropylbenzene
5
Methylene Chloride
5
Toluene
5
trans-l,2-Dichloroethene
5
Trichloroethene
5
Vinyl Chloride
2
Xylenes (total)
5
Notes
"—" - Indicated compound not analyzed for.
" * * - Blind Duplicate
"B" - Compound found in associated blank
"D" - Diluted Sample
"U" - Not Detected.
"L" - Acceptable value, biased low
"J" - Indicates the compound was detected but below the
reporting limit. The reported concentration is estimated.
"N" - Tentatively Identified
"G" - Guidance Value
Bold - Exceeds GW Class GA
- New York State Department of Environmental
Conservation, Technical and Operational Guidance
Series (TOGS) 1.1.1. Class GA Standards and Guidance
Values, Revised June 1998.
- Routine annual monitoring results for Thinner Wells (T-
13. T-15, T-21, T-24, T-26, T-29, T-33B) are not included
oh this figure.
0 100 200
1 i I Feet
SITE-WIDE SHALLOW
AREA HISTORIC
GROUNDWATER
SAMPLE RESULTS
VOCS
RACER TRUST
NYSDEC Site #7-34-057
Operable Unit 1
SYRACUSE, NEW YORK
FIGURE 04
O'BRIEN & GERE ENGINEERS, INC.
A RAMBOLL COMPANY
-------
11/9/1999 | 8/24/2011
4/9/2019
10/25/2006 | 4/11/2019
RESULTS
No Detections
7/30/2001 I 11/1/2006 | 8/3/2016 | 4/11/2019
RESULTS
4/10/2019 I 4/29/2021
10/30/2006
8/24/2011 | 8/1/2016 | 4/28/2021
10/24/2006 I 4/9/2019
[OBG-W6DR
,,2-Dichloroethene
RESULTS
PARAMETER
Acetone
cis-l,2-Dichloroethene
Trichloroethene
6/19/2000 I 10/27/2006 | 4/29/2021
RESULTS
| PARAMETER
-1,2-Dichloroethene
10/24/2006
No detections
Trichloroethei
1,1-Dichloroethei
3/20/1995
9/21/1995 I 12/6/1995 | 3/20/1996 | 6/12/1996 | 9/10/1996
3/17/1997
3/20/1995 | 6/12/1997 | 10/27/1997 | 4/28/1998
10/29/1998 | 4/21/1999 | 11/8/1999
10/27/2006 | 4/29/2021
11/3/1999 | 6/19/2000 | 10/26/2006 | 4/10/2019
11/9/1999 | 6/20/2000
RESULTS
7/8/1999
11/8/1999 I 6/20/2000 | 10/23/2006
RESULTS
10/23/2006
RESULTS
6/20/2000
11/1/2006
11/8/1999
10/25/2006
7/8/1999
RESULTS
[Ethyl ber
iropylbenzei
IXylenes (total)
k^*WT:3Rl
7/8/1999
7/19/1999
11/2/1999
RESULTS
7/30/2001
No Detections
4 MONITORING WELL
MONITORING WELL STATUS UNKNOWN OR
ABANDONED
Total CVOC*
Concentrations (ug/L)
o
I
o
>10-100
>100-1000
>1000
Total CVOCs- 1,1-DCA, 1,1-DCE,
cis-1,2-DCE (total), TCE, and VC
* - Color coding within data boxes
referes to individual constituents
OBG-19D - Based on last sampling result
|— LOCATION ID
1 RESULTS IN ug/L -
10/24/2006
PARAMETER
RESULTS
12
Benzene
1
cis -1,2-Di chloroethe ne
3700
trans-l,2-Dichloroethene
10
Trichloroethene
1600
Vinyl Chloride
1300
BOLD RESULTS _|
Chemical Name - VOCs
Class GA
1,1-Dichloroethane
5
1,1-Dichloroethene
5
1,2-Dichloroethane
0.6
2-Butanone
50(G)
Acetone
50(G)
Benzene
1
Bromodichlorome thane
50(G)
Chlorobenzene
5
Chloroform
7
cis-1,2-Dichloroethene
5
Ethylbenzene
5
Isopropylbenzene
5
Methylene Chloride
5
Toluene
5
trans-1,2-Dichloroethene
5
Trichloroethene
5
Vinyl Chloride
2
Xylenes (total)
5
Notes
"—" - Indicated compound not analyzed for.
" * * - Blind Duplicate
"B" - Compound found in associated blank
"D" - Diluted Sample
"U" - Not Detected.
"L" - Acceptable value, biased low
"J" - Indicates the compound was detected but below the
reporting limit. The reported concentration is estimated.
"N" - Tentatively Identified
"G" - Guidance Value
Bold - Exceeds GW Class GA
- New York State Department of Environmental
Conservation, Technical and Operational Guidance
Series (TOGS) 1.1.1. Class GA Standards and Guidance
Values, Revised June 1998.
- Routine annual monitoring results for Thinner Wells (T-
13. T-15, T-21, T-24, T-26, T-29, T-33B) are not included
oh this figure.
0 100 200
1 i I Feet
SITE-WIDE DEEP AREA
HISTORIC
GROUNDWATER
SAMPLE RESULTS
VOCS
RACER TRUST
NYSDEC Site #7-34-057
Operable Unit 1
SYRACUSE, NEW YORK
FIGURE 05
O'BRIEN & GERE ENGINEERS, INC.
A RAMBOLL COMPANY
-------
Seivice Layer Creaits: (Sp ^Q23 jMicro^aft Corporation © 2023 Maxar©CNES ^Q23^^rifaution Airbus PS
SHALLOW/DEEP
OBG-23S/D
EXISTING SPDES
TREATMENT SYSTEM
OBG-8SR/DR
¦sshl^Sobgfsid
NORTHERN
RRO'RERiTiYi
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MANUFACTURING
L3MBtsWlNGl
% V
v .
liWiTjPX'AN iTjBRO^RTtWAR'EA-
REMEDIAL ELEMENTS
PERIMETER SHALLOW GROUNDWATER COLLECTION TRENCH (1,800 LINEAR FEET BY 15-FT DEPTH)
SIX PERIMETER AND TWO TARGETED DEEP GROUNDWATER RECOVERY WELLS (35-FT DEPTH,
PROPOSED LOCATION OF WELLS TO BE VERIFIED AFTER THE PDI INVESTIGATION);
RECOVERED GROUNDWATER DISCHARGED TO EXISTING SPDES TREATMENT SYSTEM;
HOT SPOT EXCAVATION OF 38 CUBIC YARDS OF SURFACE SOIL (ASSUMES 1-FT OVER EXCAVATION)
BACKFILL WITH CLEAN MATERIAL AND RESTORE AS VEGETATION;
OFF-SITE DISPOSAL OF SPOILS;
DOWNGRADIENT PERIMETER GROUNDWATER MONITORING (6 WELLS EACH, SHALLOW AND DEEP);
CONTINUED CONSENT ORDER MONITORING.
EXPANSION AND ENHANCEMENT OF THINNER AREA COLLECTION SYSTEM
SSDS EVALUATION
SOUTHEASTERN
PROPERTY
10-ft square from'0-ft.b'gs-to 1 -ft bgs 3 7 cy
CONTINGENCY REMEDIAL ELEMENTS
SSDS UPGRADE WITH SVE BASED ON SSDS EVALUATION
IN-SITU TREATMENT OR PUMP AND TREAT FOR OFF-SITE GROUNDWATER BASED ON GROUNDWATER
MONITORING DATA
FIGURE 6
9
LEGEND
EXISTING MONITORING WELL
* PROPOSED MONITORING WELL
PROPOSED DEEP GROUNDWATER
RECOVERY WELL
DEEP GROUNDWATER DISCHARGE
PIPING
_ PROPOSED SHALLOW GROUNDWATER
RECOVERY TRENCH
¦ PROPOSED EXCAVATION AREA
APPROXIMATE LOCATION OF EXISTING
"THINNER TANK TRENCH
—'SSDS
APPROXIMATE LIMITS OF EXISTING
LANDFILL IRM
APPROXIMATE LIMITS OF EXISTING SOIL
STAGING AREA IRM
PROPERTY AREA LIMITS
RACER TRUST
GENERAL MOTORS -
INLAND FISHER GUIDE SUBSITE
SYRACUSE, NEW YORK
ALTERNATIVE 2
100 200
400
600
! Feet
1940101904
MAY 2023
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
Service'Layer Crecfits: ©^Q2j3 ^icrogoft Corporation © 2023 Maxar ©CNES (2Q23jDistribution Airbus D,S
S-^AiZpVy DEE
EXISTING SPDES
TREATMENT SYSTEM
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IIWiTdR,L7ArSI iTdRRQ'RERfoY/flRQJ
REMEDIAL ELEMENTS
SIX PERIMETER AND TWO TARGETED DEEP GROUNDWATER RECOVERY WELLS (35-FT DEPTH,
PROPOSED LOCATION OF WELLS TO BE VERIFIED AFTER THE PDI INVESTIGATION);
RECOVERED GROUNDWATER TREATMENT AT EXISTING SPDES TREATMENT SYSTEM;
HOT SPOT EXCAVATION OF 38 CUBIC YARDS OF SURFACE SOIL (ASSUMES 1-FT OVER EXCAVATION)
BACKFILL WITH CLEAN MATERIAL AND RESTORE AS VEGETATION;
OFF-SITE DISPOSAL OF SPOILS;
DOWNGRADIENT PERIMETER GROUNDWATER MONITORING (6 WELLS EACH, SHALLOW AND DEEP);
ON-SITE SHALLOW GROUNDWATER MONITORING (6 WELLS);
CONTINUED CONSENT ORDER MONITORING.
EXPANSION AND ENHANCEMENT OF THINNER AREA COLLECTION SYSTEM
SSDS EVALUATION
SOUTHEASTERN
PROPERTY
10-ft square from 0-ft bgs to 1 -ft bgs; 3.7 cy
CONTINGENCY REMEDIAL ELEMENTS
SSDS UPGRADE WITH SVE BASED ON SSDS EVALUATION
IN-SITU TREATMENT OR PUMP AND TREAT FOR OFF-SITE GROUNDWATER BASED ON
GROUNDWATER MONITORING DATA
FIGURE?
9
LEGEND
EXISTING MONITORING WELL
* PROPOSED MONITORING WELL
PROPOSED DEEP GROUNDWATER
RECOVERY WELL
DEEP GROUNDWATER DISCHARGE
PIPING
¦ PROPOSED EXCAVATION AREA
APPROXIMATE LOCATION OF EXISTING
¦THINNER TANK TRENCH
SSDS
APPROXIMATE LIMITS OF EXISTING
LANDFILL IRM
APPROXIMATE LIMITS OF EXISTING SOIL
STAGING AREA IRM
PROPERTY AREA LIMITS
RACER TRUST
GENERAL MOTORS -
INLAND FISHER GUIDE SUBSITE
SYRACUSE, NEW YORK
ALTERNATIVE 3
100 200
400
600
! Feet
1940101904
MAY 2023
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
Seivice Layer Creaits: (Sp ^Q23 jMicro^aft Corporation © 2023 Maxar©CNES ^Q23^^rifaution Airbus PS
PP^MW/D'EEPj
¦EX'I jSjTjl NGIS RBESM
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SOUTH WESTERN
MILITAWi'GIRGJE
WA'N.HJ.frA'BTlS'R'ING
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IWTiP.LfANMBRORE RTiWARE A
IREMEDIAL ELEMENTS
SIX PERIMETER DEEP GROUNDWATER RECOVERY WELLS (35-FT DEPTH, PROPOSED LOCATION OF
WELLS TO BE VERIFIED AFTER THE PDI INVESTIGATION);
RECOVERED GROUNDWATER TREATMENT AT EXISTING SPDES TREATMENT SYSTEM;
IN SITU TREATMENT OF ELEVATED CHLORINATED AND NON-CHLORINATED VOCS;
HOT SPOT EXCAVATION OF 38 CUBIC YARDS OF SURFACE SOIL (ASSUMES 1-FT OVER EXCAVATION)
BACKFILL WITH CLEAN MATERIAL AND RESTORE AS VEGETATION;
OFF-SITE DISPOSAL OF SPOILS;
DOWNGRADIENT PERIMETER GROUNDWATER MONITORING (6 WELLS EACH, SHALLOW AND DEEP);
ON-SITE SHALLOW GROUNDWATER MONITORING (6 WELLS)
CONTINUED CONSENT ORDER MONITORING.
ENHANCEMENT OF THINNER AREA COLLECTION SYSTEM
SSDS EVALUATION
SOUTHEASTERN
PROPERTY
10-ft square from 0-ft bgs to 1 -ft bgs; 3.7 cy
CONTINGENCY REMEDIAL ELEMENTS
SSDS UPGRADE WITH SVE BASED ON SSDS EVALUATION
IN-SITU TREATMENT OR PUMP AND TREAT FOR OFF-SITE GROUNDWATER BASED ON
GROUNDWATER MONITORING DATA
FIGURE 8
LEGEND
EXISTING MONITORING WELL
-------
SHALLOW
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SOUTHEASTERN
PROPERTY
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10-ft square from 0-ft bgs to 1 -ft bgs; 3.7'cy
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cv
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CONT NGENCY REMED AL ELEMENTS:
- SSDS UPGRADE WITh i SVE BASED ON SSDS EVALUATION
- IN-SITU TREATMENT OR PUMP AND TREAT FOR OFF-SITE GROUNDWATER
BASED ON GROUNDWATER MONITORING DATA
REMEDIAL ELEMENTS:
PERIMETER SHALLOW GROUNDWATER COLLECTION TRENCH (1.800 LINEAR FEET BY 15-FT DEPTH);
SIX PERIMETER DEEP GROUNDWATER RECOVERY WELLS (35-FT DEPTH, PROPOSED LOCATION OF
WELLS TO BE VERIFIED AFTER THE PDI INVESTIGATION);
RECOVERED GROUNDWATER TREATMENT AT EXISTING SPDES TREATMENT SYSTEM;
IN SITU TREATMENT OF ELEVATED CHLORINATED AND NON-CHLORINATED VOCS;
HOT SPOT EXCAVATION OF 1,500 CUBIC YARDS OF SURFACE AND SUBSURFACE SOIL; BACKFILL
WITH CLEAN MATERIAL AND RESTORE AS VEGETATION;
OFF-SITE DISPOSAL OF SPOILS;
DOWNGRADIENT PERIMETER GROUNDWATER MONITORING (6 WELLS EACH, SHALLOW AND DEEP);
CONTINUED CONSENT ORDER MONITORING.
ENHANCEMENT OF THINNER AREA COLLECTION SYSTEM
SSDS EVALUATION
bing^
Sen/ice Layer Crecljts:
-------
OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX II
TABLES
-------
Table 1
GM Former Inland Fisher Guide Facility
Surface Soils 0-2 Feet (13 June 1985 - 31 December 2009)
Summary of Detected Concentrations and Part 375 SCO Exceedances
NYSDEC
NYSDEC
Number of
Part 375
Part 375
NYSDEC Part
Unrestricted
Restricted
Number of
Restricted
Number of
Number
Minimum
Maximum
375
Use
Use -
Commercial
Use -
Industrial
of
Number
Detected
Detected
Unrestricted
SCO
Commercial
SCO
Industrial
SCO
Parameter
Samples
of Detects
Cone.
Cone.
Use SCOS
Exceedances
SCOs
Exceedances
SCOs
Exceedances
Volatile Orqanic Compounds (mq/kq
Cis-l,2-Dichloroethylene
43
1
0.34
0.34
0.25
1
500
0
1000
0
TRICHLOROETHYLENE (TCE)
45
5
0.02
46
0.47
2
200
0
400
0
Semivolatile Organic Compounds (m
g/kg)
Acenaphthene
58
16
0.04
40
20
1
500
0
1000
0
Anthracene
58
28
0.041
230
100
1
500
0
1000
0
Benzo|"a"|anthracene
57
49
0.057
350
1
11
5.6
8
11
5
Benzoyl pyrene
56
47
0.046
300
1
14
1
14
1.1
12
BenzoMfluoranthene
57
53
0.039
360
1
16
5.6
9
11
8
Benzo|"q,h,nperylene
54
39
0.043
310
100
1
500
0
1000
0
BenzoMfluoranthene
57
45
0.039
120
0.8
11
56
1
110
1
Chrysene
58
53
0.042
380
1
10
56
1
110
1
Dibenzo|"a,h"|Anthracene
44
11
0.077
39
0.33
5
0.56
4
1.1
3
Dibenzofuran
58
16
0.039
21
7
1
350
0
1000
0
Fluoranthene
58
57
0.04
1200
100
1
500
1
1000
1
Fluorene
58
17
0.039
65
30
1
500
0
1000
0
Indenol" 1,2,3-cdlpyrene
54
40
0.038
190
0.5
14
5.6
4
11
2
Phenanthrene
58
51
0.04
670
100
1
500
1
1000
0
Pyrene
58
57
0.043
1000
100
1
500
1
1000
0
PCBs (mg/kg)
Aroclor-1242
142
1
1.9
1.9
0.1
1
1
1
25
0
Aroclor-1248
142
95
0.002
54
0.1
90
1
71
25
5
Aroclor-1254
44
10
0.03
8
0.1
9
1
2
25
0
Aroclor-1260
142
0
0
0
0.1
0
1
0
25
0
Polychlorinated biphenyls
142
105
0.002
54
0.1
100
1
74
25
5
Metals (mg/kg)
Arsenic
61
61
1.7
92.8
13
6
16
2
16
2
Chromium
64
64
6.5
1220
30
18
1500
0
6800
0
Copper
64
64
5.4
323
50
4
270
1
10000
0
Nickel
32
32
8.3
4000
30
12
310
1
10000
0
Zinc
61
61
13.2
892
109
15
10000
0
10000
0
NOTES
This table presents (1) soil data from 13 June 1985 - 31 December 2009, (2) the detected concentration data only, and (3) only parameters that exceeded
the Part 375 Unrestricted, Restricted-Commercial, and Restricted-Industrial SCOs.
NC = No criteria available.
SCO = Soil Cleanup Objectives; NYSDEC = New York State Department of Environmental Conservation.
2/1/2023
K:\Racer-Trust.l088190\1940101904.2022_Fmr-IFG-Fac_OUl\Docs\Reports\OUl PRAP\Jan 2023 PRAP Support\Soil Data Table Summary QC\Soil Detections
Greater Than SCOs_2023-01-31.xlsx
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Table 2
GM Former Inland Fisher Guide Facility
Soils >2 Feet (13 June 1985 - 31 December 2009)
Summary of Detected Concentrations and Part 375 SCO Exceedances
NYSDEC
NYSDEC
Number of
Part 375
Part 375
NYSDEC Part
Unrestricted
Restricted
Number of
Restricted
Number of
Number
Minimum
Maximum
375
Use
Use -
Commercial
Use -
Industrial
of
Number
Detected
Detected
Unrestricted
SCO
Commercial
SCO
Industrial
SCO
Parameter
Samples
of Detects
Cone.
Cone.
Use SCOS
Exceedances
SCOs
Exceedances
SCOs
Exceedances
Volatile Orqanic Compounds (mq/kc
ACETONE
50
28
0.005
0.1
0.05
1
500
0
1000
0
Cis-l,2-Dichloroethylene
134
51
0.001
11
0.25
11
500
0
1000
0
ETHYLBENZENE
238
55
0.0008
61
1
27
390
0
780
0
METHYLENE CHLORIDE
149
55
0.001
7.8
0.05
8
500
0
1000
0
TOLUENE
239
74
0.001
720
0.7
16
500
1
1000
0
TRICHLOROETHYLENE (TCE)
148
80
0.001
9800
0.47
37
200
2
400
2
VINYL CHLORIDE
149
8
0.002
0.12
0.02
3
13
0
27
0
Xylenes (total)
238
61
0.002
330
0.26
40
500
0
1000
0
Semivolatile Organic Comi
lounds (mg/kg)
2-Methylphenol
86
5
0.1
0.44
0.33
1
500
0
1000
0
3&4-Methylphenol
86
11
0.043
3.9
0.33
7
500
0
1000
0
Acenaphthene
87
5
0.058
21
20
1
500
0
1000
0
Anthracene
87
6
0.043
170
100
1
500
0
1000
0
BenzoManthracene
87
11
0.036
150
1
1
5.6
1
11
1
BenzoMpyrene
87
9
0.035
110
1
1
1
1
1.1
1
BenzoMfluoranthene
87
11
0.047
140
1
1
5.6
1
11
1
Benzo|"q,h,nperylene
87
4
0.039
130
100
1
500
0
1000
0
BenzoMfluoranthene
87
5
0.039
59
0.8
1
56
1
110
0
Chrysene
87
12
0.046
170
1
1
56
1
110
1
Dibenzo|"a,h"|Anthracene
87
2
0.18
65
0.33
1
0.56
1
1.1
1
Dibenzofuran
87
6
0.066
12
7
1
350
0
1000
0
Fluoranthene
87
14
0.038
560
100
1
500
1
1000
0
Fluorene
87
4
0.052
37
30
1
500
0
1000
0
Indenol" 1,2,3-cdlpyrene
87
3
0.28
76
0.5
1
5.6
1
11
1
Phenanthrene
87
18
0.037
450
100
1
500
0
1000
0
Pyrene
87
18
0.04
480
100
1
500
0
1000
0
PCBs (mq/kq)
Aroclor-1016
264
1
0.48
0.48
0.1
1
1
0
25
0
Aroclor-1242
264
7
0.04
1400
0.1
1
5
25
3
Aroclor-1248
265
139
0.002
4300
0.1
111
1
70
25
19
Aroclor-1254
168
5
0.027
99
0.1
1
2
25
2
Aroclor-1260
264
3
0.027
1.6
0.1
1
1
1
25
0
Polychlorinated biphenyls
274
152
0.002
4300
0.1
120
1
77
25
23
Metals (mg/kg)
Arsenic
111
115
1.6
65.7
13
11
16
8
16
8
Chromium
117
122
3.1
17200
30
28
1500
6
6800
2
Copper
112
117
4.8
23200
50
25
270
17
10000
1
Cyanide (total)
85
20
0.68
614
27
8
27
8
10000
0
Lead
111
116
2.8
291
63
6
1000
0
3900
0
Nickel
114
119
5
14400
30
30
310
13
10000
1
Zinc
102
107
11.2
53300
109
19
10000
2
10000
2
NOTES
This table presents (1) soil data from 13 June 1985 - 31 December 2009, (2) the detected concentration data only, and (3) only parameters that exceeded the
Part 375 Unrestricted, Restricted-Commercial, and Restricted-Industrial SCOs.
NC = No criteria available.
SCO = Soil Cleanup Objectives; NYSDEC = New York State Department of Environmental Conservation.
2/1/2023
K:\Racer-Trust.l088190\1940101904.2022_Fmr-IFG-Fac_OUl\Docs\Reports\OUl PRAP\Jan 2023 PRAP Support\Soil Data Table Summary QC\Soil Detections
Greater Than SCOs_2023-01-31.xlsx
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Table 3: Evaluation of Potential ARARs
Medium/Location/
Action
Citation
Requirements
Comments
Potential
ARAR
Alt(s)
Potential Chemical-Specific ARARs
6 New York Codes, Rules and
Regulations (NYCRR) 703 - Class
GA groundwater quality standards
Requires that fresh groundwaters of the
state must attain Class GA standards.
Potentially applicable to facility groundwater.
Yes
All
Groundwater
NYSDEC TOGS 1.1.1 - Ambient
Water Quality Standards and
Guidance Values and Groundwater
Effluent Limitations
This Technical and Operational
Guidance Series (TOGS) presents New
York State Department of
Environmental Conservation (NYSDEC)
Division of Water ambient water quality
standards and guidance values and
groundwater effluent limitations. The
authority for these values is derived
from Article 17 of the Environmental
Conservation law and 6 NYCRR Parts
700-706, Water Quality.
Potentially applicable to facility groundwater.
Yes
All
Soil
6 NYCRR Part 375-6 Remedial
Program Soil Cleanup Objectives
Provides guidance for soil cleanup
objectives for various property uses.
Industrial Use soil cleanup objectives potentially
applicable to facility soil, based on current and
reasonable future property use.
Yes
All
NYSDEC Commissioner's Policy -
Soil Cleanup Guidance
Guidance that provides recommended
soil cleanup levels.
Potentially applicable to facility soil.
Yes
All
Indoor air
NYSDOH - Guidance for Evaluating
Soil Vapor Intrusion
Provides action levels for mitigation of
indoor air influences.
Potentially applicable for on-site buildings. Indoor air
is being addressed as an Interim Remedial Measure
(IRM), separate from this Revised Remedial
Investigation/Feasibility Study. Continued O&M of
the sub-slab depressurization system IRM is a
component for all active alternatives.
Yes
All
Potential Location-Specific ARARs
Wetlands
6 NYCRR 663 - Freshwater wetland
permit requirements
Actions occurring in a designated
freshwater wetland (within 100 ft) must
be approved by NYSDEC or its designee.
Activities occurring adjacent to
freshwater wetlands must: be
compatible with preservation,
protection, and conservation of
wetlands and benefits; result in no
more than insubstantial degradation to
or loss of any part of the wetland; and
be compatible with public health and
welfare.
Potentially applicable based on available mapping
which shows State-mapped wetlands within 100 ft of
the facility (O'Brien and Gere 2010). The wetland in
closest proximity to the facility is State-mapped
wetland SYE 6, which occurs north and south of the
NYS Thruway, north and south side of Factory
Avenue, and east and west of Townline Road.
Yes
2, 3, 4,
5, and
6
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Table 3: Evaluation of Potential ARARs
Medium/Location/
Action
Citation
Requirements
Comments
Potential
ARAR
Alt(s)
Executive Order (EO) 11990 -
Protection of Wetlands
Activities occurring in wetlands must
avoid, to the extent possible, the long-
and short-term adverse impacts
associated with the destruction or
modification of wetlands. The
procedures also require the United
States Environmental Protection Agency
(USEPA) to avoid direct or indirect
support of new construction in wetlands
wherever there are practicable
alternatives or minimize potential harm
to wetlands when there are no
practicable alternatives.
Not applicable based on available mapping which
does not show National Wetlands Inventory (NWI)
habitat within 100 ft of the facility (O'Brien and Gere
2010).
No
None
Wetlands
USEPA Office of Solid Waste and
Emergency Response (OSWER)
Directive 9280.0-02 (August 1985)
- Policy on Floodplains and
Wetlands Assessments for CERCLA
Actions
Superfund actions must meet the
requirements of EO 11990 (Protection
of Wetlands) and EO 11988 (Floodplain
Management).
Not applicable as this directive relates to EO 11990
(Protection of Wetlands). Not applicable based on
available mapping which does not show NWI habitat
within 100 ft of the facility (O'Brien and Gere 2010).
No
None
6 NYCRR 373-2.2 - Location
standards for hazardous waste
treatment, storage, and disposal
facilities -100-yr floodplain
Hazardous waste treatment, storage, or
disposal facilities located in a 100-yr
floodplain must be designed,
constructed, operated and maintained
to prevent washout of hazardous waste
during a 100-yr flood.
Potentially applicable. Northern facility boundary is
located within the 100-year floodplain.
Yes
All
100-year flood
plain
Executive Order 11988 - Floodplain
Management
USEPA is required to conduct activities
to avoid, to the extent possible, the
long- and short- term adverse impacts
associated with the occupation or
modification of floodplains. The
procedures also require USEPA to avoid
direct or indirect support of floodplain
development wherever there are
practicable alternatives and minimize
potential harm to floodplains when
there are no practicable alternatives.
Potentially applicable. Northern facility boundary is
located within the 100-year floodplain.
Yes
2, 3, 4,
5, and
6
USEPA OSWER Directive 9280.0-
02 (August 1985) - Policy on
Floodplains and Wetlands
Assessments for CERCLA Actions
Superfund actions must meet the
requirements of EO 11990 (Protection
of Wetlands) and EO 11988 (Floodplain
Management).
Potentially applicable as this directive relates to EO
11988 (Floodplain Management). Northern facility
boundary is located within the 100-year floodplain.
Yes
2, 3, 4,
5, and
6
Within 61 meters
(200 ft) of a fault
displaced in
Holocene time
40 Code of Federal Regulations
(CFR) Part 264.18
New treatment, storage, or disposal of
hazardous waste is not allowed.
Not applicable. Facility is not located within 200 ft of
a fault displaced in Holocene time, as listed in 40
CFR 264 Appendix VI.
No
None
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2
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Table 3: Evaluation of Potential ARARs
Medium/Location/
Action
Citation
Requirements
Comments
Potential
ARAR
Alt(s)
River or stream
16 use 661 - Fish and Wildlife
Coordination Act
Requires protection offish and wildlife
in a stream when performing activities
that modify a stream or river.
Not applicable. Modifications to Ley Creek are not
anticipated during remedial activities.
No
None
Habitat of an
endangered or
threatened
species
6 NYCRR 182
Provides requirements to minimize
damage to habitat of an endangered
species.
Not applicable, as no endangered or threatened
species or their habitat were found at the facility
No
None
Endangered Species Act
Provides a means for conserving various
species of fish, wildlife, and plants that
are threatened with extinction.
Not applicable, as no endangered or threatened
species or their habitat were found at the facility.
No
None
Historical property
or district
National Historic Preservation Act
Remedial actions are required to
account for the effects of remedial
activities on any historic properties
included on or eligible for inclusion on
the National Register of Historic Places.
Not applicable, as the facility is not identified as a
historic property.
No
None
Potential Action-Specific ARARs
Construction in a
floodplain
6 NYCRR 500 - Floodplain
management regulations
development permits
Hazardous waste treatment, storage, or
disposal facilities located in a 100-yr
floodplain must be designed,
constructed, operated and maintained
to prevent washout of hazardous waste
during a 100-yr flood.
Potentially applicable. Northern facility boundary is
located within the 100-year floodplain.
Yes
All
Treatment actions
6 NYCRR 373 - Hazardous waste
management facilities
Provides requirements for managing
hazardous wastes.
Potentially applicable to extracted groundwater and
excavated soil.
Yes
All
General
excavation
6 NYCRR 257-3 - Air Quality
Standards
Provide limitations for generation of
constituents including particulate
matter.
Not applicable because dust emissions would not be
from a point source. May be useful for consideration
during dust generating activities such as earth
moving, grading and excavation of soil.
Yes
2, 3, 4,
5, and
6
40 CFR 50.1 through 50.12 -
National Ambient Air Quality
Standards.
Provides air quality standards for
pollutants considered harmful to public
health and the environment. The six
principle pollutants include carbon
monoxide, lead, nitrogen dioxide,
particulates, ozone, and sulfur oxides.
Potentially applicable during dust generating
activities such as earth moving, grading, and
excavation of soil.
Yes
2, 3, 4,
5, and
6
Generation and
disposal of
hazardous
material and
treatment
residuals
6 NYCRR 360 - Solid Waste
Management Facilities
Provides requirements for management
of solid wastes, including disposal and
closure of disposal facilities.
Potentially applicable. Treatment residuals would
require management.
Yes
All
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3
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Table 3: Evaluation of Potential ARARs
Medium/Location/
Action
Citation
Requirements
Comments
Potential
ARAR
Alt(s)
Land disposal
6 NYCRR 376 - Land disposal
restrictions
Provides treatment standards to be met
prior to land disposal of hazardous
wastes.
Potentially applicable.
Yes
2, 3, 4,
5, and
6
Construction
29 CFR Part 1910 - Occupational
Safety and Health Standards -
Hazardous Waste Operations and
Emergency Response
Remedial activities must be in
accordance with applicable OSHA
requirements.
Applicable for construction phase of remediation
Yes
2, 3, 4,
5, and
6
29 CFR Part 1926 - Safety and
Health Regulations for
Construction
Remedial construction activities must be
in accordance with applicable OSHA
requirements.
Applicable for construction phase of remediation
Yes
2, 3, 4,
5, and
6
Transportation
6 NYCRR 364 - Waste Transporter
Permits
Hazardous waste transport must be
conducted by a hauler permitted under
6 NYCRR 364.
Potentially applicable.
Yes
All
6 NYCRR Part 372 - Hazardous
Waste Manifest System and
Related Standards for Generators,
Transporters, and Facilities
Substantive hazardous waste generator
and transportation requirements must
be met when hazardous waste is
generated for disposal. Generator
requirements include obtaining an
USEPA Identification Number and
manifesting hazardous waste for
disposal.
Potentially applicable.
Yes
All
49 CFR 172-174 and 177-179 -
Department of Transportation
(DOT) Regulations
Hazardous waste transport to off-site
disposal facilities must be conducted in
accordance with applicable DOT
requirements
Potentially applicable.
Yes
All
Discharge to
surface water and
injection to
groundwater
6 NYCRR 750 through 758 - State
Pollutant Discharge Elimination
System (SPDES) Regulations
Substantive requirements associated
with discharge to a water body
(limitations and monitoring
requirements) would be set by NYSDEC.
Applicable to treated groundwater discharge to Ley
Creek and injection of in situ treatment
amendments.
Yes
All
Injection to
groundwater
40 CFR 144 - Underground
Injection Control (UIC) Program
Permit not required for Class V wells,
which are approved by rule under
federal UIC program. Substantial
compliance with Class V permit
requirements must be demonstrated.
Applicable for injection of in situ treatment
amendments.
Yes
4, 5,
and 6
Generation of air
emissions
NYS Air Guide 1
Provides annual guideline
concentrations (AGLs) and short-term
guideline concentrations (SGCs) for
specific chemicals. These are property
boundary limitations that would result
in no adverse health effects.
Potentially applicable.
Yes
2, 3, 4,
5, and
6
K:\RACER-TRUST.1088190\1940101904.2022_FMR-IFG-FAC_OU1\DOCS\REPORTS\OU1 FS REPORT\TABLES\TABLE 3-1 ARARS 06-17-22. DOCX
-------
Table 3: Evaluation of Potential ARARs
Medium/Location/
Action
Citation
Requirements
Comments
Potential
ARAR
Alt(s)
NYS TAGM 4031 - Dust
Suppressing and Particle
Monitoring at Inactive Hazardous
Waste Disposal Sites
Provides limitations on dust emissions.
Potentially applicable.
Yes
2, 3, 4,
5, and
Construction
storm water
management
NYSDEC General permit for storm
water discharges associated with
construction activities. Pursuant to
Article 17 Titles 7 and 8 and Article
70 of the Environmental
Conservation Law.
The regulation prohibits discharge of
materials other than storm water and
all discharges that contain a hazardous
substance in excess of reportable
quantities established by 40 CFR 117.3
or 40 CFR 302.4, unless a separate
NPDES permit has been issued to
regulate those discharges. A permit
must be acquired if activities involve
disturbance of 5 acres or more. If the
project is covered under the general
permit, the following are required:
development and implementation of a
storm water pollution prevention plan;
development and implementation of a
monitoring program; all records must
be retained for a period of at least 3
years after construction is complete.
Potentially applicable.
Yes
2, 3, 4,
5, and
Notes:
AGL - Annual Guideline Concentrations
ARAR - Applicable or Relevant and Appropriate Requirements
CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act
CFR - Code of Federal Regulations
DOT - Department of Transportation
EO - Executive Order
IRM - Interim Remedial Measure
NPDES - National Pollutant Discharge Elimination System
NYCRR - New York Codes, Rules and Regulations
NYSDEC - New York State Department of Environmental Conservation
NYSDOH - New York State Department of Health
NWI - National Wetlands Inventory
OSHA - Occupational Safety and Health Administration
OSWER - Office of Solid Waste and Emergency Response
SGC - Short-term Guideline Concentrations
SPDES - State Pollutant Discharge Elimination System
TAGM - Technical and Administrative Guidance Memorandum
TOGS - Technical and Operational Guidance Series
UIC - Underground Injection Control
USEPA - United State Environmental Protection Agency
K:\RACER-TRUST.1088190\1940101904.2022_FMR-IFG-FAC_OU1\DOCS\REPORTS\OU1 FS REPORT\TABLES\TABLE 3-1 ARARS 06-17-22. DOCX
-------
Table 4: Facility Risk and Hazard Summary
Timeframe
Receptor
Exposure Medium
Cancer Risk
Non-Cancer Hazards
Reasonable Maximum Exposure
Central Tendency
Reasonable Maximum Exposure
Central Tendency
Current
Older Child Trespasser
Surface Soil
l.E-04
5.E-05
4.E-01
l.E-01
Outdoor Air
l.E-08
l.E-08
5.E-03
4.E-03
All Media
l.E-04
5.E-05
4.E-01
l.E-01
Current
Adult Trespasser
Surface Soil
2.E-04
2.E-05
3.E-01
9.E-02
Outdoor Air
7.E-08
2.E-08
5.E-03
4.E-03
All Media
2.E-04
5.E-05
3.E-01
l.E-01
Current
Industrial Worker
Surface Soil
l.E-03
2.E-04
2
1
Outdoor Air
4.E-07
l.E-07
3.E-02
3.E-02
All Media
l.E-03
2.E-04
2
1
Current
Construction Worker
Surface and Subsurface Soil
l.E-04
l.E-04
30
30
Outdoor Air
2.E-05
2.E-05
8
8
Shallow Groundwater
4.E-05
2.E-05
4
2
All Media
2.E-04
l.E-04
40
40
Future
Older Child Trespasser
Surface Soil
2.E-05
7.E-06
l.E-01
4.E-02
Outdoor Air
3.E-08
2.E-08
7.E-03
5.E-03
All Media
2.E-05
7.E-06
l.E-01
4.E-02
Future
Adult Trespasser
Surface Soil
4.E-05
3.E-06
9.E-02
3.E-02
Outdoor Air
l.E-07
3.E-08
4.E-02
5.E-03
All Media
4.E-05
3.E-06
l.E-01
l.E-01
Future
Industrial Worker
Surface Soil
2.E-04
3.E-05
6.E-01
3.E-02
Outdoor Air
6.E-07
2.E-07
4.E-02
4.E-02
All Media
2.E-04
3.E-05
7.E-01
3.E-01
Future
Construction Worker
Surface and Subsurface Soil
4.E-05
2.E-05
20
8
Outdoor Air
4.E-05
6.E-06
7
7
Shallow Groundwater
4.E-05
2.E-05
4
2
All Media
l.E-04
4.E-05
30
20
Notes:
1. Surface Soil is defined as the top 2 feet.
2. Chemicals that exceed a 1E-04 cancer risk or a hazard index of 1 are typically those that will require
remedial action at a site.
-------
EBHfiS
Table 5
GM - IFG 0U1 PRAP
Alternative 4
ENVIRONMENT
& HEALTH
Perimeter deep groundwater extraction and treatment, in situ treatment, and surface soil excavation and off-site disposal
Proposed Alternative
Contingency Alternative
UNIT
UNIT COST
Q.TY
TOTAL COST
Q.TY
TOTAL COST
Notes
DIRECT CAPITAL CONSTRUCTION COSTS - 2010 Dollars
2010 Dollars
General Conditions, Surveys, & Permits
mo
$2,080
37
$76,960
41
$85,280
Trailer, electrical and maintenance
Surveys, & Permits
Is
$6,000
1
$6,000
1
$6,000
Applies to entire site
Erosion Control
If
$2
2,000
$4,000
2,000
$4,000
Double layer silt fence and hay bales
Deed restriction
LS
$20,000
1
$20,000
1
$20,000
Restricts groundwater uses
Pre-Design Investigation (Perimeter Extraction System)
Treatment process evaluation; groundwatersampling
ea
$1,125
8
$9,000
8
$9,000
Assumes VOC, metals, pH, alkalinity and hardness analyses
Pumpingtest Investigation
LS
$71,000
1
$71,000
1
$71,000
2 wells/6 piezometers to 40-ft; inc. 2 72-hr pump test
Perimeter Collection System
Assumes discharge to SPDES Treotment System
Deep GW Wells
Install 4-inch diameter recovery well to 35-ft
ea
$23,000
6
$138,000
6
$138,000
Inc. casing, screen, development, manhole and pump
Discharge Piping (common header)
If
$50
1,650
$82,500
1,650
$82,500
4-ft wide; 4-inch solid pipe; Inc discharge connection
Discharge Piping connection vault
ea
$2,500
6
$15,000
6
$15,000
4-ft dia manhole, 4-ft depth valve and fittings
Electrical Service; conduit
If
$45
1,650
$74,250
1,650
$74,250
Excavation, backfill, conduit, hand holes and cable.
Valve Vault with connection to SPDES wet well
ea
$5,000
1
$5,000
1
$5,000
6-ft dia; 6-ft deep; inc. valves on connection piping
Electrical Connection
Is
$10,000
1
$10,000
1
$10,000
Assumes connection to SPDES building panel
Install Monitoring Wells - Shallow
ea
$1,400
2
$2,800
2
$2,800
2-inch diameter; screened from 5 to 15-ft bgs
Install Monitoring Wells - Deep
ea
$3,200
1
$3,200
1
$3,200
2-inch diameter; screened from 25 to 35-ft bgs
Thinner Collection System Enhancement
Flow Meters
ea
$849
2
$1,698
2
$1,698
Totalizer, flow readout, battery power, paddle wheel with bronze housing
Valves and fittings
Is
$400
1
$400
1
$400
4 ball valves and carbon steel fittings
Installation
Is
$1,700
1
$1,700
1
$1,700
Assumes 2 days labor
Hot Spot Excavation and Off-Site Disposal
Excavate hot-spot material
cy
$15
38
$570
38
$570
Assumes 1-ft over-excavation
Off-site disposal of excavated material
cy
$75
38
$2,850
38
$2,850
Trucking and disposal fee as non-hazardous
Place indicator layer
sf
$0.30
500
$150
500
$150
Geotextile
Backfill excavations
cy
$35
38
$1,330
38
$1,330
Confirmation Sampling
ea
$300
25
$7,500
25
$7,500
1 sample each wall and floor (5 per exc.)
Restoration - Asphalt Concrete
sf
$5
100
$500
100
$500
Assumes 6-inch thickness
Restoration - Topsoil and Seeding
sf
$0.12
400
$48
400
$48
6-inch depth over impacted area
Residual Source Area Treatment (Thinner Area and Northeast Area)
Bench-Scale Treatability Study (Pre-design)
Is
$50,000
1
$50,000
1
$50,000
Install injection well points (15-ft depth)
ea
$315
1,432
$451,080
1,432
$451,080
5-ft grid; 1-inch diameter PVC; assumes 10-ft of screen
Install injection well points (35-ft depth)
ea
$735
2,248
$1,652,280
2,248
$1,652,280
5-ft grid; 1-inch diameter PVC; assumes 10-ft of screen
Inject Chemical oxidant
cy
$57
54,889
$3,136,508
54,889
$3,136,508
Volume reflectes 2 rounds of injection
Post-Injection Monitoring (existing wells)
ea
$700
24
$16,800
24
$16,800
Monthly for 6 wells; to 12 mos beyond 2nd injection
TOTAL DIRECT CAPITAL COST (2010 Dollars)
$5,841,124
$5,849,444
2010 Dollars
Escalation Rate
47%
Based on ENR CCI Oct 2010 to June 2022
ESCALATED DIRECT CAPITAL COST
$8,583,918
$8,596,145
2022 Dollars
-------
Tables ENVIRONMENT
« , ir- A, ,
GM - IFG OU1 PRAP & HEALTH
Alternative 4
Perimeter deep groundwater extraction and treatment, in situ treatment, and surface soil excavation and off-site disposal
Proposed Alternative
Contingency Alternative
UNIT
UNIT COST
Q.TY
TOTAL COST
Q.TY
TOTAL COST
Notes
DIRECT CAPITAL CONSTRUCTION COSTS - 2021 DOLLARS
2021 Dollars
Pre-Design Investigation (ISCO under Building)
Adapted from June 2022 FS Costs
Structure and Process Sewer Evaluation
Is
$4,000
1
$4,000
1
$4,000
Evaluate available record drawings of foundation and slab construction and
sub-slab utilities
Subsurface VOC delineation
Work Plan
Is
$5,000
1
$5,000
1
$5,000
Letter WP
MIP-HTP Borings and Soil Borings
Is
$25,500
1
$25,500
1
$25,500
Track mounted Geoprobe rig and MIHPt system; 10 soil borings and 20 MIP
borings to approx. 15 ft bgs
Soil and Groundwater Sampling
Is
$14,000
1
$14,000
1
$14,000
20 soil samples (VOCS, TOC, % moisture), 10 groundwater samples (VOCs)
Survey
Is
$1,700
1
$1,700
1
$1,700
Investigation Derived Wastes
Characterization
Is
$1,100
1
$1,100
1
$1,100
Sample collection and analysis of 1 soil sample
Transportation and Disposal
Is
$1,500
1
$1,500
1
$1,500
8 drums
Reporting
Is
$7,500
1
$7,500
1
$7,500
Identify whether enhancements to the SSDS system could effectively
SSDS System Enhancement Evaluation
Is
$35,000
1
$35,000
1
$35,000
improve VOC source removal in the unsaturated soil beneath the
former manufacturing building
Pre-Design Investigation (SSDS Upgrade)
Adapted from June 2022 FS Costs
Structure and Process Sewer Evaluation
Is
$4,000
1
$4,000
Evaluate available record drawings of foundation and slab construction and
sub-slab utilities
Subsurface VOC delineation
Work Plan
Is
$5,000
1
$5,000
Letter WP
MIP-HTP Borings and Soil Borings
Is
$25,500
1
$25,500
Track mounted Geoprobe rig and MIHPt system; 10 soil borings and 20 MIP
borings to approx. 15 ft bgs
Soil and Groundwater Sampling
Is
$14,000
1
$14,000
20 soil samples (VOCS, TOC, % moisture), 10 groundwater samples (VOCs)
Survey
Is
$1,700
1
$1,700
Investigation Derived Wastes
Characterization
Is
$1,100
1
$1,100
Sample collection and analysis of 1 soil sample
Transportation and Disposal
Is
$1,000
1
$1,000
5 drums
Reporting
Is
$7,500
1
$7,500
Identify whether natural attenuation is suitable to address off-
MNA Evaluation (Off-property Groundwater)
Is
$30,000
1
$30,000
1
$30,000
property groundwater contamination (following operation of
perimeter groundwater extraction system for a period up to five
years)
Technology Evaluation - GW Extraction and Treatment
or In Situ Treatment
Is
$40,000
1
$40,000
In situ treatment assumed selected technology for cost purposes
Pre-Design Investigation (Off-Property Groundwater)
Adapted from June 2022 FS Costs
Subsurface VOC delineation
Work Plan
Is
$5,000
1
$5,000
Letter WP
MIP-HTP Borings and Soil Borings
Is
$50,000
1
$50,000
Track mounted Geoprobe rig and MIHPt system; 5 soil borings and 11 MIP
borings to approx. 25-35 ft bgs
Soil and Groundwater Sampling
Is
$14,000
1
$14,000
5 soil samples (VOCS, TOC, % moisture), 5 groundwater samples (VOCs)
Survey
Is
$1,800
1
$1,800
Investigation Derived Wastes
Characterization
Is
$1,100
1
$1,100
Sample collection and analysis of 1 soil sample
Transportation and Disposal
Is
$1,500
1
$1,500
8 drums
Reporting
Is
$7,500
1
$7,500
TOTAL DIRECT CAPITAL COST (2021 DOLLARS)
$125,300
$306,000
2021 Dollars
Escalation Rate
8%
Based on ENR CCI June 2021 to June 2022
ESCALATED DIRECT CAPITAL COST
$135,624
$331,214
2022 Dollars
-------
mSfiS
Table 5
GM - IFG 0U1 PRAP
Alternative 4
ENVIRONMENT
& HEALTH
Perimeter deep groundwater extraction and treatment, in situ treatment, and surface soil excavation and off-site disposal
Proposed Alternative
Contingency Alternative
UNIT
UNIT COST
Q.TY
TOTAL COST
Q.TY
TOTAL COST
Notes
DIRECT CAPITAL CONSTRUCTION COSTS - 2022 DOLLARS
Residual Source Area Treatment (assumes "hot zone" 25% of total currently
dentified area)
Bench-Scale Treatability Study (Pre-design) Is
Install injection well via directional drill - 15-ft depth ea
$50,000
$185,000
1
10
$50,000
$1,850,000
1
10
$50,000
$1,850,000
4-inch perf. PVC, 500 LF installed via directional boring. Adapted from 2010
Quote, Escalated based on ENR CCI Oct 2010 to August 2022.
Chemical oxidant (including injection) cy
$84
9,722
$816,648
9,722
$816,648
Adapted from PRAP Alt 6 under building, Rnd 1:100% in]; Rnd 2 = 75* ins
Post-Injection Monitoring Wells Is
$19,000
1
$19,000
1
$19,000
Swells.
Off-Prooertv Groundwater Implementation
Groundwater Treatment (downgradient of OBG-23D)
in Situ Treatment (ISCO)
Bench-Scale Treatability Study (Pre-design) Is
$50,000
1
$50,000
For both OBG-23D and OBG-6D/7D areas
Install injection well points (35-ft depth) ea
$735
60
$44,100
Transect layout (60 points); 1-inch diameter PVC; assumes 10-ft of screen
Chemical oxidant (including injection) cy
$84
6,179
$519,036
Adapted from 2022 FS Alt 5 (1/4 volume for NE area); Rnd 1:100% in]; Rnd 2 »
75% in; unit price updated.
Groundwater Treatment (downgradient of OBG-6D/7D)
in Situ Treatment (ISCO)
Install injection well points (35-ft depth) ea
$735
60
$44,100
transect layout (60 points); 1-inch diameter PVC; assumes 10-ft of screen
Chemical oxidant (including injection) cy
$84
6,179
$519,036
Adapted from 2022 FS Alt 5 (1/4 volume for NE area); Rnd 1:100% in]; Rnd 2 »
75% in; unit price updated.
SSDS Enhancement (Soil Vatjor ^tra^gn (SVE)^
Horizontal SVE piping Is
$185,000
1
$185,000
4-inch perf. PVC, 500 LF installed via directional boring. Adapted from 2010
Quote, Escalated based on ENR CCI Oct 2010 to August 2022.
Off-gas Treatment System Is
$145,000
1
$145,000
Package system: 350 SCFM at 50" WC, knockout tank, and 2 10001b carbon
units.
Installation (Electrical, Piping, Rigging, Startup) Is
$105,000
1
$105,000
Modeling Is
$4,000
1
$4,000
Screening level modeling, assuming carbon off-gas treatment.
Permit Is
$6,000
1
$6,000
TOTAL DIRECT CAPITAL COST (2022 DOLLARS)
$11,455,191
$13,284,279
Escalated 2010 and 2021 Dollars to June 2022 and 2022 Dollars
Engineering/Design/Oversight
15%
$1,718,279
$1,992,642
Legal
5%
$572,760
$664,214
Contingency
20%
$2,291,038
$2,656,856
TOTAL ALTERNATIVE CAPITAL COST (escalated and rounded)
$16,037,300
$18,598,000
2022 Dollars
OPERATION AND MAINTENANCE COSTS
Annual Costs fYears 1-3)
Post-injection groundwater monitoring (on-property) Is
$50,000
1
$50,000
1
$50,000
5 wells, baseline CSIA, analytical (VOCs, TOC, ethenes, inorganics) 4 rounds per
year, reporting.
Post-injection groundwater monitoring (off-property) Is
$50,000
1
$50,000
5 wells, baseline CSIA, analytical (VOCs, TOC, ethenes, inorganics) 4 rounds per
year, reporting.
Annual Costs fYears 1-30)
Perimeter Collection Monitoring
Downgradient well groundwater monitoring and labor ea
$900
12
$10,800
12
$10,800
6 Shallow and 6 Deep wells for VOC/PCB; 4 hr labor per well
Well/Pump Maintenance ea
$1,200
8
$9,600
8
$9,600
8 recovery wells
Shallow Groundwater Monitoring
Onsite well groundwater monitoring and labor ea
$900
6
$5,400
6
$5,400
6 Shallow wells for VOC/PCB; 4 hr labor per well
SPDES IRM/Consent Order Monitoring
Includes the following: LS
$145,000
1
$145,000
1
$145,000
based on average 5-year costs incurred years 2014-2018 and 2022 annual
budget for power
Annual Monitoring/Inspection, labor and analytical; SPDES system sampling, inspection and ope
ational maintena
Thinner Area andSurflmp ttl Wells - Sampling, Labor and Analytical; Annual;
VOCs and 1 PCB
Thinner System and Sump Inspection; Weekly Control Inspection; Bi-monthly sumps inspection
Treatment system power
direct bill for power from SIP to RACER
SSDS IRM Operation and Maintenance
Includes the following: LS
$32,400
1
$32,400
1
$32,400
based on average 5-year costs incurred years 2014-2018 and 2022 budget for
power
Monitoring/Inspection for VI Systems 1 and 2; Weekly labor and reporting
Labor, Mote riots and analytical (as needed); Repair/replacement; VOCs sampling 3x per 5 years approx.
SSDS power
direct bill for power from SIP to RACER
-------
EBEEfll
Table 5
GM - IFG 0U1 PRAP
Alternative 4
ENVIRONMENT
& HEALTH
Perimeter deep groundwater extraction and treatment, in situ treatment, and surface soil excavation and off-site disposal
Proposed Alternative
Contingency Alternative
UNIT UNIT COST
QTY TOTAL COST
QTY TOTAL COST
Notes
Other
Site Mowing ea $3,000
Landfill O&M - Cover Inspections/Reporting LS $6,000
Pump Power KWH $0.15
SVE Operation and Maintenance
Includesthefollowing: Is $32,400.00
Monitoring/Inspection for Contingency SVE (System 3); Weekly lobor and reporting
Lobor, Materials and analytical (as needed); Repair/replacement;
SVE power
Off-gas treatment Is $12,000
TOTAL ANNUAL O&M COST (Updated 2022)
2 $6,000
1 $6,000
26,000 $3,900
$219,100
2 $6,000
1 $6,000
26,000 $3,900
1 $32,400
1 $12,000
$263,500
2x annually
Annual
Assumes 8 0.5 HP pumps at 80% eff.
based on current SSDS system O&M
2000 lbs vapor phase activated carbon/yr at $3.5/lb to replace and $5K in
Periodic Costs (Years 5.10.15.20. 25.30»
5-yr reviews ea $5,000
Periodic Costs fYears 10.20. 30)
Well rehab ea $2,500
Pump Replacement ea $2,100
1 $5,000
2 $5,000
2 $4,200
1 $5,000
2 $5,000
2 $4,200
Surge/pump wells every 10 years
Submersible well pumps
PRESENT WORTH ANALYSIS fYEARS 1-301 Discount
Cost Type Factor (7%)
Capital Cost - YearO 1.000
Annual O&M -Years 1-3 2.624
Annual O&M -Years 1-30 12.4081
Periodic Costs-Years 5, 10,15, 20,25, 30 2.1577
Periodic Costs - Years 10, 20, 30 0.8981
TOTAL PROJECT PRESENT WORTH (escalated and rounded)
Cost Per Yr PresentValue
$16,037,300 $16,037,300
$50,000 $131,200
$219,100 $2,718,600
$5,000 $10,800
$9,200 $8,300
$18,906,000
Cost Per Yr Present Value
$18,598,000 $18,598,000
$100,000 $262,400
$263,500 $3,269,500
$5,000 $10,800
$9,200 $8,300
$22,149,000
-------
OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
Administrative Record Index
Operable Unit 1 of the General Motors - Inland Fisher Guide
(New York State Inactive Hazardous Waste Disposal Site #7-34-057)
RI/FS Activities Documents
Pre-Remedial
Investigation
Information
Citizen Participation Plan for the Onondaga Lake National Priority
List Site (January 1996)
Preliminary Remedial Investigation/Feasibility Study Report
Former IFG Facility and Ley Creek Deferred Media (October
1997)
Remedial
Investigation/Feasibility
Study Work Plans
Final Supplemental RI/FS Work Plan Former IFG Facility and Ley
Creek Deferred Media (October 1999)
Human Health Risk Assessment Approach Former IFG Facility
and Ley Creek Deferred Media (October 1999)
Baseline Ecological Risk Assessment Former IFG Facility and Ley
Creek Deferred Media (June 2001)
Supplemental Remedial Investigation - Additional Sampling Work
Plan (May 2003)
Final Vapor Intrusion Investigation Work Plan (February 2006)
Revised Additional Groundwater Evaluation Work plan (July
2006)
Vapor Intrusion Investigation Work Plan - Additional Sampling
(November 2007)
Supplemental Remedial Investigation - Site Surface Soil Sampling
Work Plan (September 2008)
Former Syracuse IFG Facility and Deferred Media - OU 1
Groundwater Sampling Work Plan (December 2020)
Remedial Investigation
Reports
Supplemental Remedial Investigation Former IFG Facility and Ley
Creek Deferred Media (April 2000)
-------
Revised Remedial Investigation/Feasibility Study (October 2010)
Human Health Risk Assessment (October 2010)
Fish and Wildlife Impact Analysis (May 2013)
Revised Remedial Investigation Report (March 2017)
OU 1 Groundwater Summary Report (August 2021)
Feasibility Study Report
GM-IFG-OU1 Feasibility Study Report (June 2022)
GM-IFG-OU1 Contingency Remedy and Revised Feasibility Cost
(August 2022)
Proposed Plan Released
Start of Public
Comment Period
Proposed Plan and Listserv Notice (July 28, 2023)
Notice of Public Meeting and Opportunity to Comment (July 28,
2023)
Public Meetings Held
Documentation and Transcript of August 16, 2023 Public Meeting
(Attached to the Record of Decision as Appendix V-d)
Written Comments on Proposed Plan (Attached to the Record of
Decision as Appendix V-e)
Record of Decision
Issued
Operable Unit 1 of the General Motors - Inland Fisher Guide
Record of Decision and Responses to Comments (Responsiveness
Summary) (September 2023)
Enforcement
Documents
Administrative Order on Consent (September 1997)
Administrative Order on Consent RI/FS Addendum (November
1999)
Administrative Order on Consent (September 2015)
Environmental Easement (September 2020)
-------
OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX IV
NEW YORK STATE DEPARTMENT OF HEALTH LETTER OF CONCURRENCE
-------
york Department
^state of Health
KATHY HOCHUL
Governor
james v. Mcdonald, m.d., m.p.h.
Commissioner
MEGAN E. BALDWIN
Acting Executive Deputy Commissioner
July 26, 2023
Andrew Guglielmi, Director
Division of Environmental Remediation
NYS Department of Environmental Conservation
625 Broadway
Albany, New York 12233
Dear Andrew Guglielmi,
We reviewed the New York State Department of Environmental Conservation and United
States Environmental Protection Agency's July 2023 Proposed Plan for the referenced site to
determine whether the proposed remedy is protective of public health. Based on that review, I
understand that on-site soil and groundwater is contaminated with volatile organic compounds
(VOCs), semivolatile organic compounds, metals, and polychlorinated biphenyls above
applicable standards, criteria, and guidance. Soil vapor is contaminated with VOCs.
Chlorinated VOC non-aqueous phase liquids are suspected on-site as well. Human exposures
to contamination at this site will be addressed by the proposed remedy as outlined below.
• SoN: Soils that exceed 6 NYCRR Part 375 Industrial Soil Cleanup Objectives in areas
not currently addressed by an approved Interim Remedial Measure or covered by paved
surfaces or building footprint will be excavated and removed from the site. Following
confirmatory soil sampling, the excavated areas will be backfilled with clean fill meeting
the requirements of 6 NYCRR Part 375-6.7(d). A site management plan will be putin
place and future excavations at the site will conducted in accordance with an approved
excavation plan to properly manage human exposures to remaining contaminated soil.
• Groundwater: Three residual source areas where VOC contamination exists (i.e.,
Former Thinner Tanks Area and beneath and northeast of the former manufacturing
building) will be addressed using in-situ treatment technologies. Contaminated
groundwater will be collected from the deeperzone along the northern perimeter of the
facility property and treated prior to being discharged to Ley Creek. Use of groundwater
at the site, without appropriate water quality treatment, will be restricted by an
environmental easement placed on the site.
Re: Proposed Plan-OperableUnit 1
General Motors - Fisher Guide
Site #734057
Salina (T), Onondaga County
Empire State Plaza, Corning Tower, Albany, NY 12237 | health.ny.gov
-------
• Soil Vapor: The site's existing sub-slab depressurization systems will be evaluated to
determine if enhancements to the system could effectively improve the removal of
elevated VOCs in unsaturated soil beneath the former manufacturing building. In
addition, a soil vapor intrusion evaluation will be completed, and appropriate actions
implemented, for any buildings developed on the site.
Periodic reviews will be completed to certify that these elements of the remedy are being
implemented and remain effective. Based on this information, I believe this remedy is protective
of public health and concur with the Proposed Plan. If you have any questions, please contact
Scarlett Messier-McLaughlin at (518) 402-7874.
Sincerely,
i ft-tiS'Un'- l tw-i -
Christine N. Vooris, P.E., Director
Bureau of Environmental Exposure Investigation
ec: K. Malone/W. Kuehner/S. Messier-McLaughlin/M. Sergott/e-File
J. Strepelis- NYSDOH CRO
L. Letteney- OCHD
D. Harrington / J. Pelton / J. Luo - NYSDEC Central Office
G. Priscott- NYSDEC Region 7
-------
OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR THE
RECORD OF DECISION
FORMER FACILITY AND GROUNDWATER PORTION OF THE
GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
TOWN OF SALINA, ONONDAGA COUNTY, NEW YORK
INTRODUCTION
This Responsiveness Summary provides a summary of the public's comments and
concerns received during the public comment period related to the former facility and
groundwater portion of the General Motors - Inland Fisher Guide Subsite (Subsite) of the
Onondaga Lake Superfund Site Proposed Plan and provides the New York State
Department of Environmental Conservation (NYSDEC) and U.S. Environmental
Protection Agency's (EPA's) responses to those comments and concerns. All comments
summarized in this document have been considered in NYSDEC and EPA's final decision
in the selection of a remedy to address the contamination at the noted portion of the
Subsite.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
From 1990 through 2015, General Motors (GM) and the Revitalizing Auto Communities
Environmental Response Trust (RACER Trust)1 (following GM's bankruptcy in 2009),
conducted field investigations at the Subsite under NYSDEC's oversight. This effort
culminated in the completion of a remedial investigation (Rl)2/feasibility study (FS)3 in
2022. RI/FS reports and a Proposed Plan,4 which identified NYSDEC and EPA's
preferred remedy for the former facility and groundwater portion of the Subsite and the
basis for that preference, were released to the public for comment on July 28, 2023. These
documents were made available to the public on NYSDEC's website,
https://www.dec.nv.qov/data/DecDocs/734057/. and at information repositories
maintained at Atlantic States Legal Foundation, 658 West Onondaga Street, Syracuse,
New York; NYSDEC, Division of Environmental Remediation, 625 Broadway, Albany,
New York and NYSDEC Region 7, 5786 Widewaters Parkway, Syracuse, New York. A
NYSDEC listserv bulletin notifying the public of the availability for the above-referenced
documents, the comment period commencement and completion dates, and the date of
the planned public meeting was issued on July 28, 2023. A notice providing the same
1 RACER Trust was created by a U.S. Bankruptcy Court to clean up and position for
redevelopment former GM properties.
2 An Rl determines the nature and extent of the contamination at a site and evaluates the
associated human health and ecological risks.
3 An FS identifies and evaluates remedial alternatives to address the contamination.
4 A Proposed Plan describes the remedial alternatives considered for a site and identifies the
preferred remedy with the rationale for this preference.
V-1
-------
information was published in The Syracuse Post-Standard on July 30, 2023. The public
comment period ended on August 27, 2023.
On August 16, 2023, NYSDEC held an open house and conducted a public meeting at
the Salina Town Hall Court Room to inform local officials and interested citizens about the
Superfund process, present the Proposed Plan, and respond to questions and comments
from the public. One person attended the public meeting.
SUMMARY OF COMMENTS AND RESPONSES
Comments were received at the public meeting and in writing from the owner of the former
facility, Mr. Robert Lieberman. Mr. Lieberman's written comments were received via an
August 25, 2023 letter.
The transcript from the public meeting can be found in Appendix V-d.
The written comments submitted during the public comment period can be found in
Appendix V-e.
A summary of the comments provided at the public meeting and comments that were
received during the public comment period, as well as NYSDEC and EPA's responses to
them, are provided below.
Communication
Comment #1: Mr. Lieberman asked for continuous, open communications with NYSDEC,
EPA, and RACER regarding the plans for remediation of the former facility and
groundwater portion of the Subsite.
Response #1: All work on the property will be coordinated with the property
owner. Future work plans and design documents related to the former facility and
groundwater portion of the Subsite will be provided to the property owner.
It should be noted that while the RACER Trust will continue to maintain the Interim
Remedial Measure (IRMs)5 and will perform the operation and maintenance (O&M)
related to the remedy that will be implemented, RACER Trust will not actively participate
with the remedial design (RD) and remedial action (RA).
5 An IRM is a New York State law term for an environmental response that is synonymous with
the Comprehensive Environmental Response, Compensation, and Liability Act, as amended, 42
U.S.C. §9601 et seq. (CERCLA, more commonly known as Superfund) environmental response
term "removal action." The use of the term "IRM" in this document is used solely for consistency
with underlying documents, but references actions that are in fact removal actions under
CERCLA.
V-2
-------
Remedial Action
Comment #2: Mr. Lieberman stated that the GM-IFG-OU1 property is 78.46 acres and
that the 65 acres included in the Proposed Plan only account for the parcel located in the
Town of Salina and does not include the parcel located in the Town of DeWitt.
Response #2: The site acreage will be corrected and updated in all future document
submittals.
Comment #3: Mr. Lieberman asked for clarification of the volume that would be
excavated under the selected remedy (Alternative 4) because one portion of the
Proposed Plan indicated that approximately 1,500 cubic yards (CY) of contaminated soils
would be excavated and another section of the Proposed Plan indicated that
approximately 38 CY of unsaturated soil would be excavated.
Response #3: Under the selected remedy, approximately 38 CY of contaminated soil will
be excavated. Contaminated soils that are located under cover systems or pavement will
not be excavated under the selected remedy. The reference to 1,500 CY of contaminated
soil in the Proposed Plan comprises contaminated materials located under cover systems
and paved surfaces. The excavation of this 1,500 CY of soil is part of Remedial
Alternative 5 in the Proposed Plan; this alternative was not selected.
Comment #4: Mr. Lieberman asked for clarification as to how excavated soils will be
handled under the selected remedy. He also inquired as to how exposure to on-property
tenants and visitors will be prevented and how contaminated surface water runoff will be
controlled. He also requested that soil excavation work be performed at a time that will
minimize impacts to tenants, visitors, and overall use of the property.
Response #4: Soil excavation, stockpiling, and transportation details will be provided in
the future design documents. These documents will detail the excavation areas, volumes,
process for handling and staging contaminated soil, backfilling the excavation, site
restoration, air monitoring, and the project schedule. Potential impacts related to dust,
volatile emission, and contaminated surface runoff will be mitigated through appropriate
control measures and adherence to a Community Air Monitoring Plan (CAMP).6 NYSDEC
will work with the property owner to minimize the disturbance to the tenants' business
operations.
6The purpose of a CAMP is to provide protection to potential receptors {i.e., remediation workers,
tenants, and visitors) from potential airborne contaminant releases as a result of remedial work
activities performed at the site.
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Comment #5: Mr. Lieberman noted that the selected remedy includes the installation of
horizontal wells for the injection of amendments, which will necessitate using directional
drilling beneath the former manufacturing building, but few details are provided. To fully
understand the potential impacts to business operations, he asked that additional details
be provided.
Response #5: Pre-RD activities will be necessary to determine the need for horizontal
directional drilling beneath the former manufacturing building and, if needed, the actual
installation of the horizontal injection wells will need to be designed. Specifically, the RD
will determine the total number, depths, lengths, spacing, etc. between the horizontally-
drilled injection wells. The RD will include a geotechnical evaluation to determine the
subsurface conditions beneath the building and to prevent disturbances to the building
foundation, utilities, and other subsurface features.
Potential Adverse Impacts
Comment #6: Mr. Lieberman asked that the full scope of "potential adverse impacts" to
the property, tenants, and visitors to the property associated with the selected remedy be
identified. Additionally, he asked that the steps that will be taken to mitigate the potential
impacts be identified.
Response #6: Because potential adverse impacts could occur to remediation workers
and tenants and visitors during the on-property remediation, a site-specific Health and
Safety Plan (HASP) will be prepared. A HASP, which is a requirement of the federal
Occupational Safety and Health Administration, outlines the safety measures and
procedures that will be implemented by remediation workers. In addition, a CAMP will be
prepared (see Response #4) to ensure that the public living and working near the
property, as well as employees or visitors on the property, are protected from exposure
to site contaminants during investigatory, RA, and O&M activities.
Comment #7: Mr. Lieberman noted that the Proposed Plan contained a general
discussion as to how the selected remedy will include the collection and treatment of
contaminated groundwater, but provided few details. He noted that during times of heavy
rainfall, the existing stormwater collection basin that was installed as part of an IRM nearly
overflows and has resulted in on-property flooding that could be exacerbated with the
increased flow attributable to the groundwater collection and treatment system
component of the selected remedy. He inquired as to how the existing water treatment
system will be modified to accommodate the additional capacity associated with the
collection of the contaminated groundwater.
Response #7: The stormwater collection basin that is referenced collects all the water
that accumulates in the storm sewers or abandoned process sewers on the former facility
property. The basin water is then intermittently pumped and sent to the on-property
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treatment plant prior to being discharged to Ley Creek. As part of the selected remedy,
deep groundwater extraction wells will be installed along the northern perimeter of the
property. These wells will be used to pump water through underground piping directly
into a sump for the existing water treatment system, not into the noted stormwater
collection basin. Based on initial pumping tests completed during the Rl, groundwater
withdrawal from the deep extraction wells is expected to be fairly low and the volume of
water requiring treatment is not expected to adversely impact the stormwater collection
basin. However, the deep groundwater extraction system and the associated impact on
the stormwater collection basin will be evaluated as part of the RD.
Comment #8: Mr. Lieberman inquired as to whether the existing Environmental
Easement will be modified and, if so, asked that NYSDEC provide information as to the
anticipated changes and how it may impact use/operations {i.e., tenant restrictions or
notifications) of the property.
Response #8: Under the selected remedy, the existing Environmental Easement will not
need to be modified.
Comment #9: Mr. Lieberman asked for information regarding the anticipated contents of
the Site Management Plan (SMP), including how it may impact use/operations of the
property.
Response #9: The SMP will include an Institutional and Engineering Control Plan, a
provision for the periodic certification of the institutional control and engineering controls,
and a Site Monitoring Plan and Operation & Maintenance Plan. Because contamination
will remain on-site, the SMP will be in place in perpetuity. It is not expected that actions
required as part of the SMP will impact use/operations of the property. It should be noted
that many of these activities already occur on the property under an Interim SMP.
Restoration of the Property
Comment #10: Mr. Lieberman asked for an assurance that following the completion of
the RA, the property will be restored at no cost to the property owner.
Response #10: The RD will detail how the construction contractors will restore the
property. Site restoration will be performed as part of the RA and will be funded as part
of that effort.
Schedule
Comment #11: Mr. Lieberman asked who will be implementing the RD and RA, what
contractors will be involved, and about the RD and RA timeframes. He also asked when
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NYSDEC and EPA anticipate sharing documents related to design and implementation
of the remedy.
Response #11: Shortly after the selection of the remedy in a Record of Decision,
NYSDEC will issue a work assignment to a NYSDEC standby engineering contractor to
perform the necessary pre-RD work and the RD. These contractors have not yet been
identified. It is anticipated that the work assignment will be issued late in 2023 and that
the pre-RD and RD work will be completed in late 2024/early 2025. Following the
completion of the RD, an RA construction contractor will be selected. It is anticipated that
the RA construction will take a year to complete. As was noted in Response #1, RACER
Trust will continue to maintain the IRMs and will perform the O&M related to the remedy
that will be implemented.
As was noted in Response #1, future work plans and design documents related to the
former facility and groundwater portion of the Subsite will be provided to the property
owner.
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OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-a
JULY 28, 2023 PROPOSED PLAN
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Proposed Plan
General Motors - Inland Fisher Guide Site
Operable Unit 1 Site Code: 734057
Subsite of the Onondaga Lake Superfund Site
Towns of Salina and DeWitt, Onondaga County, New York
NEW
YORK
STATE
Department of
Environmental
Conservation
vvEPA
July 28, 2023 Region 2
PURPOSE OF THIS DOCUMENT & SUMMARY OF PREFERRED CLEANUP PLAN
This Proposed Plan describes the remedial alternatives considered for the contaminated soil/fill material, groundwater, and
soil vapor at Operable Unit (OU) 1, the former plant property and groundwater portion of the General Motors - Inland Fisher
Guide (GM-IFG) subsite (Subsite), which is part of the Onondaga Lake Superfund site, and identifies the preferred remedial
alternative with the rationale for this preference.
This Proposed Plan was developed by the New York State Department of Environmental Conservation (NYSDEC) and the
U.S. Environmental Protection Agency (EPA) in consultation with the New York State Department of Health (NYSDOH).
NYSDEC and EPA are issuing this Proposed Plan as part of their public participation responsibilities under Section 117(a) of
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended, and Section
300.430(f)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The nature and extent of the
contamination at OU1 is described in the Remedial Investigation General Motors Inland Fisher Guide Operable Unit 1 (Rl) and
the remedial alternatives summarized in this Proposed Plan are described in the General Motors Inland Fisher Guide Operable
Unit 1 Feasibility Study Report (FS), contained in the Administrative Record file for OU1. NYSDEC and EPA encourage the
public to review these documents to gain a more comprehensive understanding of the Subsite and the Superfund activities
that have been conducted in connection with OU1.
This Proposed Plan is being provided as a supplement to the reports listed above to inform the public of NYSDEC and EPA's
preferred remedy and to solicit public comments pertaining to all the remedial alternatives evaluated, including the preferred
remedy.
NYSDEC and EPA's preferred remedy includes a combination of removal and off-site disposal of soils that exceed 6 NYCRR
Part 375 Soil Cleanup Objectives (SCOs) for industrial use, in-situ treatment to address residual source areas (i.e., Former
Thinner Tanks Area and beneath and northeast of the former manufacturing building), groundwater collection and treatment
along the northern perimeter of the former GM-IFG facility property, evaluation of the sub-slab depressurization system (SSDS)
to determine if it can be supplemented with a soil vapor extraction (SVE) system to enhance removal of source material in soil
beneath the former manufacturing building, treatment of the contaminated groundwater that is collected by the existing State
Pollution Discharge Elimination System (SPDES) treatment system prior to being discharged to Ley Creek, development of a
Site Management Plan (SMP), implementation of institutional controls (ICs), and long-term operation and maintenance (O&M)
of these actions and previously-performed cleanup actions identified as Interim Remedial Measures (IRMs).1
The remedy described in this Proposed Plan is the preferred remedy for OU1. Changes to the preferred remedy, or a change
from the preferred remedy to another remedy, may be made if public comments or additional data indicate that such a change
will result in a more appropriate and effective remedial action. The final decision regarding the selection of a remedy will be
made after NYSDEC and EPA have taken into consideration all public comments. NYSDEC and EPA are soliciting public
comment on all the alternatives presented in this Proposed Plan and in the detailed analysis section of the FS report because
NYSDEC and EPA may ultimately select a remedy other than the preferred remedy.
1 An IRM is a New York State law term for an environmental response that is synonymous with the CERCLA environmental response term
"removal action." The use of the term "IRM" in this document is used solely for consistency with underlying documents, but references
actions that are in fact removal actions under CERCLA.
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Community Role in the Selection Process
NYSDEC and EPA rely on public input to ensure that the concerns of the community are
considered in selecting an effective remedy for each Superfund site. To this end, this
Proposed Plan has been made available to the public for a public comment period which
begins on July 28, 2023 and concludes on August 27, 2023.
As noted above, an open house and a public meeting will be held during the comment
period. At the public meeting, NYSDEC will present the conclusions of the Rl and FS,
elaborate further on the rationale for recommending the preferred remedy, and receive
public comments.
The open house will be less formal and will provide the public a chance to receive printed
information and discuss the cleanup options with NYSDEC and EPA representatives on a
one-on-one basis.
Comments received at the public meeting and in writing during the comment period will be
documented in the Responsiveness Summary Section of the Record of Decision (ROD),
the document that formalizes the selection of the remedy. Written comments on this
Proposed Plan should be addressed to:
Jacky Luo
New York State Department of Environmental Conservation
625 Broadway
Albany, NY 12233-7013
E-mail: jacky.luo@dec.ny.gov
MARK YOUR CALENDAR
Public comment period on
the Proposed Plan: July 28,
2023 - August 27, 2023
Open House: 5:00-6:00 PM
on Wednesday. Auqust 16.
2023
Public Meeting: 6:00 PM on
Wednesday. Auqust 16.
2023
Location: Town ofSalina
Town Hall.
201 School Road. Liverpool.
New York 13088
INFORMATION REPOSITORIES
The administrative record file, which contains copies of the Proposed Plan and supporting documentation, are available
online through the DECinfo Locator at: and at the following locations:
Onondaga County Public Library Syracuse Branch at the Galleries
447 South Salina Street
Syracuse. NY 13204
315-435-1800
Salina Libraiy
100 Belmont Street
Mattydale. NY 13211
315-454-4524
Atlantic States Legal Foundation
658 H/esf Onondaga Street
Syracuse. NY 13204
315-475-1170
New York State Department of EnvironmentalConseivation
5786 Widewaters Parkway
Syracuse. NY 13214-1867
315-426-7400
New York State Department of Environmental Conseivation
Attn.: Jacky Luo
625 Broadway
Albany. NY 12233-7013
518-402-9676
E-mail: jacky.luo@dec.ny.gov
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SUBSITE BACKGROUND
On June 23, 1989, the Onondaga Lake site was added to the New York State Registry of Inactive Hazardous Waste Disposal
Sites. On December 16, 1994, Onondaga Lake, its tributaries and the upland hazardous waste sites which have contributed or
are contributing contamination to the lake (subsites) were added to EPA's National Priorities List (NPL). This NPL listing means
that the lake system is among the nation's highest priorities for remedial evaluation and response under the federal Superfund
law for sites where there has been a release of hazardous substances, pollutants, or contaminants.
In 1997, General Motors Corporation (GM), the facility's owner at the time, and NYSDEC entered into an Administrative Order
on Consent to conduct an RI/FS for the Subsite (NYSDEC site code 734057). Following GM's filing for bankruptcy in 2009, an
RI/FS Order on Consent was executed between the Revitalizing Auto Communities Environmental Response Trust2 (RACER)
and NYSDEC in 2015. The Order requires RACER to conduct an RI/FS and risk assessments for the Subsite. The Subsite was
classified by NYSDEC as a Class 2 Site in the New York State Registry of Inactive Hazardous Waste Disposal Sites (a Class 2
site represents a signification threat to public health orthe environment; action is required). The Subsite includes two OUs. OU1,
which is the focus of this Proposed Plan, addresses the former GM-IFG facility property soil and soil vapor and on- and off-
property contaminated groundwater; OU2 addresses off-property contaminated sediments and floodplain soils. A remedy was
selected for OU2 in March 2015; however, based on a significant increase in the overall volume of soil requiring remediation in
the OU2 area, and the associated cost, after considering alternatives to the selected remedy, two separate Explanations of
Significant Differences (ESDs) were issued by EPA and NYSDEC in September 2022 and April 2023 memorializing the
increased volume and cost. The design of the OU2 remedy is currently underway; it is anticipated that it will be completed in
late 2023.
OU1 Description and History
Location: The former GM-IFG property comprises approximately 65 acres that include the 800,000 square foot (sf) former GM
manufacturing building located at 1 General Motors Drive in the Towns of Salina and Dewitt, Onondaga County, New York
(collectively, facility). See Figure 1, Site Location.
Features: Various paved parking lots and green spaces are present at the facility. These areas surround the former
manufacturing building and related outbuildings. The facility is bounded to the south by CSX railroad tracks, a wood pallet
recycling facility, and an automobile dealership; to the east and northeast by Military Circle (formerly GM Circle) and Townline
Road; to the west by a National Grid (formerly Niagara Mohawk Power Corporation) electrical transfer station and the state
regulated wetland SYE-6; and to the north by Factory Avenue and the Ley Creek PCB Dredging subsite (NYSDEC site code;
734044). Many of these features can be seen on Figure 2, Property Areas of the Former GM-OU1 Site.
Geology and Hydrogeology: The local geology for the Subsite consists of fill, glaciolacustrine deposits, and lodgment till
underlain by red shale bedrock. Beneath the facility, the thickness of the glaciolacustrine unit increases toward the facility's
northern boundary. The glaciolacustrine deposit has three units: the upper unit (silt and fine-grained sand); the middle unit (silt
and clay); and the lower unit (silt and fine-grained sand).
The Subsite has two distinct groundwater zones:
• A shallow groundwater zone (at a depth of approximately 1 foot to 15 feet [ft] below ground surface [bgs]) within the fill layer
and the upper glaciolacustrine unit; and
• A deep groundwater zone (at a depth of approximately 20 to 45 ft bgs) within the lower glaciolacustrine unit and the sand
and gravel layer.
Between the two groundwater zones is the middle glaciolacustrine layer, which acts as a low permeability zone that separates
the shallow and deep groundwater zones. This low permeability glaciolacustrine layer extends from near the northern edge of
the former manufacturing building to the northern portion of the facility. The deep and shallow groundwater zones are connected
in the vicinity of the building where the glaciolacustrine layer is absent. Shallow and deep groundwater generally flow in a
northeast direction across the facility toward Ley Creek.
History of the GM-IFG Facility: GM built the facility to manufacture metal automotive trim components such as bumpers, grills,
wheel disks, and hubcaps. The facility began operations in 1952 as GM's Brown-Lipe-Chapin Division. Facility operations
included metal die casting; nickel, chromium, and copper cyanide electroplating; stamping; polishing; buffing; painting; and
machining. In 1961, Brown-Lipe-Chapin merged with another GM division, Ternstedt, and in 1968 became part of GM's Fisher
Body Division. During the early 1960s, injection molding operations were added to the metal operations. Metal finishing and
2 RACER was created by a U.S. Bankruptcy Court to clean up and position for redevelopment former GM properties.
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diecasting were subsequently reduced and replaced by plastic injection molding by the early 1970's. The facility operated as
the Fisher Body Division until 1984, when it became the Fisher Guide Division. The facility then operated as GM's IFG Division
from 1989 until it ceased manufacturing operations in 1993. After the cessation of manufacturing operations, the facility was
reassigned to GM's North American Operations Property Management Group, later re-designated the Worldwide Facilities
Group. Beginning in 1997, GM implemented a facility cleanup program to decontaminate surfaces and decommission unneeded
systems. GM redeveloped the facility, starting in 2000, as commercial/light industrial multi-tenant spaces; use of these spaces
continues today. In 2009, GM filed for bankruptcy and, soon after, RACER took over the ownership and remediation activities
of the facility.
Interim Remedial Measures: IRMs are activities to address both emergency and nonemergency site conditions, which can be
undertaken without extensive investigation and evaluation, to prevent, mitigate, or remedy environmental damage or the
consequences of environmental damage attributable to a site before a final remedy is selected. Many IRMs have already been
completed at the facility. Based on the operational history and compounds identified, several components of the IRMs address
media of concern at the facility, including the Former Thinner Tanks Area Groundwater IRM, the low permeability landfill cover
installed as part of the Former Landfill IRM, facility stormwater treatment, and the Soil Staging Area and Soil Consolidation Area
soil covers installed as part of the SPDES Treatment System IRM, the former manufacturing building Sub-Slab Depressurization
System/Vapor Intrusion Mitigation IRM, soil removals completed as part of the Drainage Swale IRM and various Redevelopment
IRMs, and closure of Surface Impoundment #1. The IRMs, all of which have been performing as designed and constructed, are
described in more detail below:
• Oil/Water Collection Sump System - In the 1980s, oil containing polychlorinated biphenyls (PCBs) was discovered in the
facility's discharge to Ley Creek and within the underground storm sewer system beneath the former manufacturing building.
The storm sewers beneath the former manufacturing building were decommissioned and collection pumps were installed at
locations where the sewers formerly exited the building. These sumps collected residual oil/water present within the sewer
lines.
• Storm Sewer Rehabilitation - GM rehabilitated select storm sewers located outside the facility buildings. The effort included
cleaning the sewer lines and abandonment and repair/replacement of some storm sewer sections on the west side of the
facility. This work was completed in 2001.
• Former Thinner Tanks Area Groundwater Recovery System - Following a spill in the conveyance piping of three
underground storage tanks in 1987, GM installed a groundwater collection system to collect shallow overburden
groundwater with elevated concentrations of toluene, ethylbenzene, and xylenes in the Former Thinner Tanks Area. The
recovery system consists of two groundwater collection trenches. The collected groundwater is piped to the facility
stormwater treatment system and treated using filtration and granulated activated carbon prior to discharge to Ley Creek
under a SPDES permit. To assess the effectiveness of this IRM, RACER implements an annual monitoring program
including the collection and laboratory analysis of groundwater samples from eight monitoring wells for toluene,
ethylbenzene, and xylene.
• Former Landfill IRM - An industrial landfill located at the facility contains chromium and PCB-contaminated material. Areas
within the landfill with high concentrations of contaminants were excavated and transported off-site for disposal at a licensed
facility and the landfill was capped in 2004. RACER maintains the landfill integrity by performing operation and maintenance
(O&M) activities, including inspections and repairs, as needed, and mowing the vegetative cover.
• Former Drainage Swale IRM - GM used a drainage swale in the 1950s-60s as a conduit for the discharge of liquid process
waste to Ley Creek. The swale was subsequently filled in, but highly contaminated soil remained. This IRM involved the
removal of the contaminated soil from the former drainage swale in 2004. As part of this IRM, GM removed over 26,000
tons of soil containing PCBs from this area of the facility. Soils with PCB concentrations less than 50 parts per million (ppm)
were placed in the landfill (described above) before it was capped. Soils with PCB concentrations greater than 50 ppm were
transported off-site for disposal at a licensed facility.
• Surface Impoundment #1 closure - In 1989, GM closed and covered Surface Impoundment #1 with a clay and soil cover
consistent with Resource Conservation and Recovery Act requirements and this area was subsequently paved. The cover
in this area limits infiltration and prevents direct contact with subsurface soil in this area. To evaluate the effectiveness of
this IRM, RACER conducts annual monitoring of two wells for volatile organic compounds (VOCs) and PCBs.
• SPDES Treatment System IRM - The purpose of this IRM was to stop the intermittent discharge of PCBs and other
contaminants originating from the Subsite to Ley Creek during storm events. This IRM involved GM's construction of a
retention basin and associated water treatment system that was completed in 2003. This retention basin collects surface
water runoff that accumulates on the GM-IFG property in the storm sewers or abandoned process sewers. The basin water
is treated by RACER at the treatment plant prior to discharge to Ley Creek. As part of this IRM, vegetated soil covers were
placed over the Soil Staging Area and the Soil Consolidation Area.
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• Vapor Intrusion Mitigation IRM - In 2011, RACER completed the installation of two sub-slab depressurization systems
beneath the facility's concrete slab to prevent the migration of soil vapors containing VOCs into the building. Since operation
began, RACER has performed routine O&M of the system and periodic air monitoring.
• Redevelopment IRMs - Multiple IRMs have been performed over the years to facilitate the redevelopment of the facility.
These IRMs include the removal of soil and surface paving at the former temporary hazardous waste storage area located
west of the Mold Storage building, removal of surface soil containing high concentrations of site contaminants south of the
former Industrial Wastewater Treatment Plant (IWTP), demolition of the IWTP clarifiers, construction of two truck loading
docks, and regrading at the former CDM Outdoor Storage Area.
• Decommissioning Activities IRM - Following a facility assessment, decommissioning activities were performed in the early
2000s that consisted of cleaning the floors (and applying epoxy floor coating in some areas) and aboveground surfaces,
cleaning and dismantling various process systems, and removing residue from facility sumps and drains. The demolition of
the IWTP on the facility's south side was completed in 2006.
As described above, many of these IRMs have and continue to address potential risks identified in media at the Subsite through
removal, control, and/or treatment. It should also be noted that as part of a property transfer in 2020, an environmental easement
under Article 71, Title 36 of New York State Environmental Conservation Law (ECL) was recorded for the property. This
environmental easement controls future activities at the property, limits land use to industrial, and prohibits the use of
groundwater.
Current Zoning and Land Use: The facility is located in an area zoned for industrial use in the Town of Salina; a small portion
of the facility (entrance gate area and a portion of the parking lot) is located in the Town of DeWtt. Currently, the former
manufacturing building is occupied by a variety of tenants performing commercial and light industrial activities. The area
surrounding the facility can generally be characterized as commercial/industrial. The general area is characterized by a high
degree of industrial activity, as evidenced by the presence of past/current manufacturing facilities. Numerous small industrial
businesses are present along Factory Avenue and Route 298. Syracuse International Airport-Hancock Field is located
approximately 1.5 miles north of the facility.
RESULTS OF THE REMEDIAL INVESTIGATION
To evaluate the nature and extent of contamination at the Subsite, the Rl included the collection and laboratory analysis of soil
and groundwater samples from several areas at the facility. Also, as documented in the Rl, investigations spanned many years
and included analysis of soil, soil vapor, groundwater, and indoor air. As shown on Figure 2, for purposes of NYSDEC and EPA
management, the facility is divided into six areas plus the former manufacturing building. These areas are the Northern,
Northeast, Southeast, former IWTP, Southwest, and Former Thinner Tanks Areas. Based on a comparison to Title 6 New York
Code of Rules and Regulations (6 NYCRR) Part 375 soil cleanup objectives (SCOs) for Industrial Use, Protection of
Groundwater, New York State Class GA groundwater standards, and New York State's Guidance for Evaluating Soil Vapor
Intrusion the following was concluded:
Soil
The sampling activities and associated results from various investigations conducted facility-wide indicate that surface and
subsurface soils in certain locations on the site contained PCBs, VOCs, semi-volatile organic compounds (SVOCs) and site-
related metals (i.e., arsenic, chromium, copper, nickel, and zinc) exceeding Standards, Criteria, and Guidance (SCGs). Figure
3 shows the sample locations where there are exceedances of SCOs in the surface and subsurface soil. Table 1 and Table 2
summarize the detected concentrations and frequency of SCO exceedances for surface and subsurface soil, respectively.
Surface Soil
PCBs were detected above their Part 375 Industrial Use SCO (25 ppm) in the Northern Property Area at maximum
concentrations 37 ppm.
SVOCs were detected above the Part 375 Industrial Use SCOs in the Former Thinner Tanks Area and Northern Property Area.
Specifically, in the Former Thinner Tanks Area, benzo(a)pyrene (SCO of 1.1 ppm), chrysene (SCO of 110 ppm), and
fluoranthene (SCO of 1,000 ppm) were detected at maximum concentrations of 300 ppm, 380 ppm, and 1,200 ppm, respectively.
In the Northern Property Area, benzo(a)anthracene (SCO of 11 ppm), and benzo(a)pyrene were detected at maximum
concentrations of 1.8 ppm, and 1.7 ppm respectively.
In the Southeast Property Area, arsenic was detected above the Part 375 Industrial Use SCO (16 ppm) at a maximum
concentration of 92.8 ppm.
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Subsurface Soil
PCBs were detected in subsurface soil in different areas of the facility at concentrations above Part 375 Protection of
Groundwater SCO (3.2 ppm). Specifically, PCBs were detected in the northeast area at a maximum concentration of 24 ppm,
in the IWTP area at a maximum concentration of 190 ppm, beneath the former manufacturing building at a maximum
concentration of 4,300 ppm, in the Northern Property Area at maximum concentration of 79 ppm beneath the landfill. Field
screening using ultraviolet irradiation suggested that Non-Aqueous Phase Liquid (NAPL) may be present in three soil sample
locations along an abandoned sewer under the former manufacturing building. The area beneath the building may represent a
potential source area for PCBs.
VOCs detected above Part 375 Protection of Groundwater SCOs were limited to toluene (SCO of 0.7 ppm), xylene (SCO of 1.6
ppm), ethylbenzene (SCO of 1 ppm), methylene chloride (SCO of 0.05 ppm), trichloroethene ((TCE) (SCO of 0.47 ppm)), cis-
1,2-dichloroethene ((cis-1,2-DCE) (SCO of 0.25 ppm)), and vinyl chloride (SCO of 0.02 ppm), across the facility. Specifically,
toluene, xylene, and ethylbenzene were detected respectively at maximum concentrations of 720 ppm, 317 ppm, and 61 ppm
in subsurface soil samples collected from the Former Thinner Tanks Area. Methylene chloride, ethyl benzene, toluene, xylene,
cis-1,2-DCE, and vinyl chloride were detected respectively at maximum concentrations of 0.14 ppm, 11 ppm, 110 ppm, 110
ppm, 0.45 ppm, and 0.12 ppm in the northern property area. TCE was detected at a maximum concentration of 1.5 ppm in the
northeast property area. Methylene chloride, TCE, cis-1,2-DCE, and vinyl chloride were detected at a maximum concentration
of 7.8 ppm, 9,800 ppm, 5.1 ppm, and 7.8 ppm, respectively, beneath the former manufacturing building at depths ranging from
0.5 ft to 15 ft below the concrete slab, generally in the center of the building in the vicinity of the former paint room.
SVOCs were detected above the Part 375 Protection of Groundwater SCOs in subsurface soil beneath the transformer/switch
area located in the Former Thinner Tanks Area, former landfill in the Northern Property Area, and in the Northeast Property
Area. Benzo(a)anthracene (SCO of 1 ppm), benzo(a)pyrene (SCO of 22 ppm), and benzo(b)fluoranthene (SCO of 1.7), were
detected respectively at maximum concentrations of 150 ppm, 110 ppm, and 140 ppm, in the Former Thinner Tanks Area. P-
Cresol (SCO of 0.33 ppm) was found at a maximum concentration of 3.9 ppm in the Northern Property Area.
Benzo(a)anthracene, benzo(b)fluoranthene, and chrysene (SCO of 1 ppm) were detected at maximum concentrations of 9.3
ppm, 16 ppm, and 11 ppm, respectively, in the Northeast Property Area.
Site-related metals (i.e., arsenic, chromium, copper, lead, nickel, zinc, and cyanide) were detected above the Part 375 Protection
of Groundwater SCOs in limited areas in subsurface soil near the Northern, Northeast, Southeast, Southwest, IWTP Property
Areas, and beneath the former manufacturing building. Specifically, arsenic (SCO of 16 ppm), chromium (SCO of 19 ppm),
copper (SCO of 1,720 ppm), lead (SCO of 450 ppm), nickel (SCO of 130 ppm), and zinc (SCO of 2,480 ppm) were detected
respectively at a maximum concentration of 65 ppm, 17,200 ppm, 3,920 ppm, 7,940 ppm, 243 ppm, and 53,300 ppm in the
Northern Property Area beneath the landfill IRM cover. Arsenic was detected at a maximum concentration of 16.3 ppm in the
Northeast Property Area. Arsenic was detected at a maximum concentration of 16.4 ppm in the Southeast Property Area.
Chromium was at maximum concentrations of 1,220 ppm the Southwest Property Area. Chromium was detected at a maximum
concentration of 44 ppm in the IWTP Property Area. Chromium, cyanide (SCO of 40 ppm), and nickel were detected respectively
at a maximum concentration of 120 ppm, 247 ppm, and 4,000 ppm beneath the former manufacturing building.
The majority of subsurface soil locations identified as having site contaminants at concentrations exceeding SCOs are located
beneath covers/caps within the Former Landfill, Soil Staging Area, or Soil Consolidation Area and were previously addressed
by the earlier IRMs (discussed above).
Groundwater
The groundwater analytical results indicate that the shallow overburden groundwater contains VOCs and PCBs at
concentrations exceeding SCGs and the deep overburden groundwater contains VOCs, SVOCs, and metals at concentrations
exceeding SCGs.
Shallow Groundwater Zone
PCBs were detected above New York State Class GA groundwater standard (0.09 parts per billion [ppb]) in groundwater
samples collected from monitoring wells located in the Northeast Property Area at a maximum concentration of 0.72 ppb. An
elevated concentration of PCBs was detected in groundwater immediately north of the former manufacturing building at a
maximum concentration of 55 ppb in the vicinity of a closed surface impoundment. Otherwise, PCBs are present at
concentrations marginally above New York State Class GA groundwater standard in a few localized areas in the shallow
overburden groundwater zone.
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Chlorinated VOCs, consisting mainly of TCE (SCG of 5 ppb), cis-1,2-DCE (SCG of 5 ppb), and vinyl chloride (SCG of 2 ppb)
were detected in facility groundwater at maximum concentrations of 25,000 ppb, 4,700 ppb, 23 ppb, respectively, in samples
collected from beneath the former manufacturing building (see Figure 4). Field screening techniques suggest that residual VOC
NAPL may exist beneath the former manufacturing building and may be a continuing source for groundwater contamination.
The TCE detected may be associated with the former TCE storage area/IWTP previously located south of the former
manufacturing building and possible solvent storage and usage within the former manufacturing building. Figure 4 provides site-
wide shallow groundwater sample results for VOCs. As shown on Figure 4, the possible residual VOC NAPL beneath the
building has not resulted in a shallow overburden groundwater plume north of the former manufacturing building.
Non-chlorinated VOCs, including toluene, ethylbenzene, and xylene, are present in the shallow groundwater zone in the Former
ThinnerTanks Area at concentrations above the SCG of 5 ppb forthese compounds. Specifically, the 2021 annual groundwater
sampling detected these constituents at maximum concentrations of 3,400 ppb, 39,000 ppb, and 190,000 ppb, respectively.
While residual NAPL is suspected to be present in the Former Thinner Tanks Area based on these groundwater concentrations,
this groundwater is contained by the two recovery trenches and is not migrating off-property.
Arsenic was detected above the groundwater SCG in the Northern Property Area and Chromium was detected above the
groundwater SCG beneath the former manufacturing building. In addition, other non-site-related metals, including iron,
magnesium, manganese, and sodium, were also detected at concentrations above groundwater SCGs.
Deep Groundwater Zone
PCBs (i.e., Aroclor 1242) were detected above New York State Class GA groundwater standard (0.09 ppb) in the Northeast
Property Area at a maximum concentration of 0.18 ppb.
TCE, cis-1,2-DCE, and vinyl chloride were detected in the deep overburden groundwater at concentrations exceeding SCGs
immediately north of the former manufacturing building, in the Northern Property Area, and off-property beneath the Ley Creek
floodplain area (see Figure 5). North of the former manufacturing building and in the Northern Property Area, TCE, cis-1,2-
DCE, and vinyl chloride were detected in the deep overburden groundwater at maximum concentrations of 170,000 ppb, 11,000
ppb and 120 ppb, respectively, compared to their respective groundwater standards of 5 ppb for TCE and cis-1,2-DCE and 2
ppb for vinyl chloride.
Off-property, TCE, cis-1,2-DCE, and vinyl chloride were detected at maximum concentrations of 3,500 ppb, 570 ppb and 140
ppb, respectively in monitoring wells located approximately 200 ft. north of the property. NAPL source material may be present
at areas between the northern extent of the former manufacturing building and the northern facility perimeter based upon the
suspected movement of the TCE plume along the top of the till and the concentrations of TCE detected in deep groundwater.
Figure 5 provides site-wide deep groundwater zone sample results for VOCs.
SVOCs and site-related metals were not detected above SCGs in the deep groundwater.
Soil Vapor
As part of the June 16, 2010 Vapor Intrusion Mitigation IRM, sub-slab vapor and indoor air samples were collected. The
investigation identified elevated levels of chlorinated VOCs above air guidelines and other criteria referenced in the State's
Guidance for Evaluating Soil Vapor Intrusion (NYSDOH, 2006 w/ updates). The data required the installation of an SSDS to
address the soil vapor intrusion. The sub-slab and indoor air sampling results are summarized below:
Sub-Slab
1,1,1-Trichloroethane (1,1,1-TCA), Tetrachloroethene (PCE), TCE, and cis-1,2-DCE were detected in the sub-slab vapor
samples at concentrations exceeding NYSDOH guidance beneath the former manufacturing building at maximum
concentrations of 1,400 micrograms per cubic meter (jjg/m3), 2,800 |jg/m3, 1,900,000 |jg/m3, and 270 |jg/m3, respectively.
Indoor Air
PCE, TCE and cis-1,2-DCE were detected in the indoor air at concentrations exceeding NYSDOH guidance at maximum
concentrations of 540 |jg/m3, 130 |jg/m3, and 0.23 |jg/m3, respectively.
Suspected Nonaqueous Phase Liquids
Chlorinated VOC NAPLs may be present in some areas of the facility property based on the elevated concentrations (TCE at
25,000 ppb) that were detected in the shallow groundwater beneath the former manufacturing building and in the deep
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groundwater near the property boundary (TCE at 160,000 ppb). Chlorinated VOC NAPLs, if present beneath the former
manufacturing building, would be expected to flow along the till down into the deep groundwater unit. In fact, and as described
above, analytical results from the shallow overburden groundwater north of the former manufacturing building show that the
residual VOC NAPL under the building has not resulted in a shallow overburden groundwater plume.
Suspected PCB NAPL may be present underneath the former manufacturing building due to past releases of PCB-containing
hydraulic fluid to sumps and to leaking process sewers during the manufacturing processes.
A past leak from the underground paint thinner storage tanks/piping in the Former Thinner Tanks Area is a potential source of
non-chlorinated VOC NAPL that may be present in this area. As part of the Thinner Tanks System Area Groundwater Recovery
IRM, GM installed two groundwater collection trenches and associated piping to collect and treat the contaminated groundwater.
While the IRM has contained the plume, there may be a residual source (e.g., NAPL) that remains based on contaminant levels
in groundwater in this area (including concentrations of total xylenes greater than 100,000 ppb since 1999).
If present, chlorinated NAPLs would be a principal threat waste (for an explanation of a principal threat waste, see the textbox,
"What is a Principal Threat?" below). It should be noted that actual VOC-related NAPL was not observed during the Rl. While
PCB-related NAPL was observed during field screening, widespread PCB contamination in groundwater was not observed
during the Rl. These areas are discussed in detail in the Rl and FS reports.
"What is a Principal Threat?"
The NCP establishes an expectation that EPA will use treatment to address the principal threats posed by a Site wherever
practicable (NCP Section 300.430(a)(1)(iii)(A)). The "principal threat" concept is applied to the characterization of "source
materials" at a Superfund site. A source material is material that includes or contains hazardous substances, pollutants, or
contaminants that act as a reservoir for migration of contamination to ground water, surface water, or air. or acts as a source
for direct exposure. Contaminated groundwater generally is not considered to be a source material: however. NAPLs in
groundwater may be viewed as source material.
Principal threat wastes are those source materials considered to be highly toxic or highly mobile that generally cannot be
reliably contained or would present a significant risk to human health or the environment should exposure occur. The
decision to treat these wastes is made on a site-specific basis through a detailed analysis of the alternatives using the nine
remedy selection criteria. This analysis provides a basis for making a statutory finding that the remedy employs treatment
as a principal element.
Natural Attenuation
In 2001, GM conducted a preliminary evaluation of natural attenuation at the facility as part of a supplemental Rl. The evaluation
analyzed for VOCs, dissolved oxygen, oxidation-reduction potential, dissolved light hydrocarbons (i.e., methane, ethane, and
ethene), dissolved carbon dioxide gas, volatile fatty acids, sulfide, sulfate, nitrate, nitrite, and total iron in seven deep wells. This
evaluation found that limited natural attenuation processes were evident in the groundwater and TCE daughter products, such
as cis-1,2-DCE and vinyl chloride, were observed.
Remedial Investigation Conclusions
Based on the results of the various iterations of the Rl from 2010 through 2022 and prior investigations, the contamination at
OU1 is summarized as follows:
• Approximately 2,580 cubic yards (CY) of soil has been identified as exceeding the Industrial Use SCOs and/orthe Protection
of Groundwater SCOs for PCBs and VOCs. All but approximately 340 CY of this material is currently covered as part of
completed IRMs or located below the building. Of the material not covered by IRMs, approximately 241 CY is covered by
paving (roadways or parking lots). Of the remaining uncovered soil exhibiting concentrations greater than the Protection of
Groundwater SCO, approximately 15 CY are located in the top 1 ft and 84 CY are at depths greater than 1 ft. Approximately
38 CY of material is to be removed in the surface soil and 1500 CY of material is to be removed in the surface and subsurface
soil with the assumption of over excavation of 10 ft for locations shallower than 5ft and extended 20 ft for locations between
5 and 15 ft bgs.
• Three residual source areas may exist at the facility: potential residual non-chlorinated VOC NAPL in shallow overburden
soil within the Former Thinner Tanks Area; potential residual chlorinated VOC NAPL and PCB NAPL in shallow/deep
overburden soil beneath the former manufacturing building; and potential residual chlorinated VOC NAPL in deep
overburden soil within the Northeast Property Area. From calculations based on the groundwater data, the Former Thinner
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Tanks Area VOC residual source area is approximately 35,800 sf by 10 ft thick, the former manufacturing building VOC
residual source area is approximately 115,100 sf by 10 ft thick, and the VOC residual source in the Northeast Property Area
is approximately 56,200 sf by 1 -ft thick.
• Shallow and deep groundwater is contaminated with chlorinated VOCs and PCBs and there are high concentrations of
toluene, ethylbenzene, and xylene in the Former Thinner Tanks Area. Specifically:
o Residual VOC NAPL is potentially located under the former manufacturing building but has not resulted in a shallow
overburden groundwater plume,
o In general, PCBs are present at concentrations above New York State Class GA groundwater standards in a few
localized areas in the shallow overburden groundwater zone (PCBs up to 55 ppb as compared to the groundwater
standard of 0.09 ppb) and in one location in the deep overburden groundwater zone. Given that most of the PCB
detections were associated with PCBs observed in subsurface soils, the groundwater detections are likely indicative
of localized conditions.
o Chlorinated VOCs were detected at elevated concentrations (TCE up to 25,000 ppb as compared to the groundwater
standard of 5 ppb) in the shallow overburden groundwater beneath the former manufacturing building,
o Chlorinated VOCs were detected at elevated concentrations (TCE up to 170,000 ppb as compared to the groundwater
standard of 5 ppb) in the deep overburden groundwater north of the former manufacturing building and off-property
beneath the Ley Creek floodplain area,
o Toluene, ethylbenzene, and xylene contamination in the shallow overburden groundwater are contained by operation
of the Former Thinner Tanks Area Groundwater Recovery System.
SCOPE OF ACTION
As part of the cleanup of the Onondaga Lake NPL site, the following subsites are being addressed:
• General Motors - Inland Fisher Guide (the subject of this Proposed Plan) (site code 734057);
• Geddes Brook/Ninemile Creek (site code 734030);
• LCP Bridge Street (site code 734049);
• Ley Creek PCB Dredgings (site code 734044);
• Lower Ley Creek (site code 734123);
• Niagara-Mohawk Hiawatha Blvd (site code 734059);
• Onondaga Lake Bottom (which includes Geddes Brook/Ninemile Creek as an OU) (site code 734030);
• Salina Landfill (site code 734036);
• Semet Residue Ponds (site code 734008);
• Wastebeds 1-8 (site code 734081);
• Wastebed B/Harbor Brook (site code 734075); and
• Willis Avenue (site code 734072).
Remedial actions have been fully implemented at the Semet Residue Ponds, Wastebeds 1-8 OU1, Wastebed B/Harbor Brook
OU1, Geddes Brook/Ninemile Creek, Niagara-Mohawk Hiawatha Boulevard, LCP Bridge Street, Ley Creek PCB Dredgings,
Onondaga Lake Bottom, and Salina Landfill subsites. These subsites are undergoing long-term site management. Remedial
activities for portions of the Wastebeds 1-8, GM-IFG, and Wastebed B/Harbor Brook subsites have been completed or are in
progress. The Lower Ley Creek and Willis Avenue subsites are in the Remedial Design (RD) phase.
The scope of the action for OU1 of this Subsite is to incorporate actions undertaken as IRMs as final actions, address the
contaminated soil/fill material and shallow and deep groundwater not addressed under the IRMs discussed above, and
implement additional actions where needed. NYSDEC and EPA expect this remedy to be a final, comprehensive remedy for
OU1.
The 2015 ROD for OU2 of this Subsite called for, among other things, excavation of approximately 9,600 CY of contaminated
upper Ley Creek channel sediments and approximately 2,900 CY of adjacent contaminated floodplain soil/dredged materials in
the reach from Townline Road to the Route 11 bridge. The remedy also included excavating contaminated soils/sediments in
an adjacent wetland called the National Grid Wetland and roadway shoulders near the facility and on the northern side of Factory
Avenue in the vicinity of LeMoyne Avenue. In 2016, RACER excavated and disposed of at a licensed facility contaminated
floodplain soil from residential properties (located adjacent to the creek) and in 2017 performed the remediation of the Factory
Avenue and National Grid Wetland soils. Based on the results of pre-RD investigation (PDI) sampling, it was determined that
the ROD-estimated volume of contaminated soil/dredged materials requiring excavation and off-site disposal increased from
approximately 15,000 CY to approximately 142,500 CY. In September 2022, an ESD was issued by EPA and NYSDEC
regarding OU2 of this Subsite. The modified soil remedy includes the excavation and off-site disposal of floodplain soils
exhibiting contaminant concentrations greater than restricted SCOs and is adjusted to reflect increased soil volumes and
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associated remedial costs, consistent with current and reasonably anticipated future land use. This modification did not address
a 13.9-acre forested area because, at that time, an alternative in-situ remedial approach was being evaluated for this area.
Following the completion of the evaluation, EPA and NYSDEC concluded that it is unlikely that the in-situ treatment would be
an effective remedy in the forested area. Therefore, the soil remedy selected in the ROD remains the most suitable approach
for addressing the forested area, notwithstanding the increased soil volumes and associated remedial costs. This decision was
documented in an April 2023 ESD. The design of the sediment and soil remedy is currently underway; it is anticipated that it
will be completed in late 2023.
Summary of Quantitative Subsite OU1 Risk Assessments
As part of the original 2010 Rl and in subsequent iterations of the Rl, baseline quantitative risk assessments were conducted
for OU1 to estimate the potential risks to human health and the environment (see the "What is Human Health Risk and How is
it Calculated?" and "What is Ecological Risk and How is it Calculated?" textboxes below). The baseline risk assessments
consisted of a human health risk assessment (HHRA), which evaluated potential risks to humans, and a fish and wildlife impact
analysis (FWIA), which evaluated potential risks to ecological receptors, analyzed the potential for adverse effects caused by
hazardous substance releases assuming no further actions to control or mitigate exposure to these hazardous substances are
taken.
Human Health Risk Assessment
OU1 is zoned industrial and exposure scenarios were developed based on this current and likely future land use. The baseline
HHRA considered exposure to soil, outdoor air (via dusts) and groundwater through several current and future exposure
scenarios. Receptors and pathways that were evaluated included the following: exposure to surface soil and outdoor air by
older children and adult trespassers as well as industrial workers and construction workers; and exposure to shallow
groundwater by construction workers; and exposures to groundwater used as drinking water by future child and adult residents.
Exposure scenarios were developed for these populations and considered exposure through incidental ingestion and inhalation
of and dermal contact with surface and, subsurface soil, and ingestion of groundwater as a hypothetical drinking water source
in the future. Human health risks associated with the ingestion of groundwater are based on groundwater data from the Rl.
Risks from exposure to volatile contaminants within indoor air via vapor intrusion were also evaluated in the HHRA.
Total cancer risk for the adult trespasser, industrial worker and construction worker exceeded the 10-4- 10 6 risk range (see the
Risk Characterization discussion in the "What is Human Health Risk and How is it Calculated?" textbox, below), primarily driven
by exposure to polycyclic aromatic hydrocarbons (particularly benzo(a)pyrene) in surface soil. Noncancer hazard for the
industrial worker and construction worker also exceeded the threshold of 1 due primarily to PCBs in surface soil. For the
construction worker, exposure to ethylbenzene in groundwater also contributed to elevated hazard. Furthermore, hypothetical
future residential exposure to groundwater as potable water resulted in elevated cancer risk and noncancer hazards. These
estimates were driven by exposure to ethylbenzene, TCE, cis-1,2-DCE, xylenes, vinyl chloride, arsenic, chromium, and PCBs
in groundwater. A summary of the cancer risks and noncancer hazards above threshold levels for each population in each of
the OU1 areas, along with the contaminants of concern (COCs) that contribute the most to the risk or hazard can be found in
the Facility Risk and Hazard Summary table of the HHRA.
As referenced above, however, the vapor mitigation system as installed, operated, and maintained by RACER continues to
prevent vapor intrusion from the soil and groundwater beneath the former manufacturing building into the building's indoor air.
The HHRA included a recommendation that, based on the vapor intrusion screening presented in the HHRA, a vapor intrusion
evaluation should be conducted if any buildings (new or existing) will be occupied on the facility property. The vapor intrusion
screening identified chemicals with a potential to migrate to indoor air, based on factors such as the chemical- specific vapor
pressure. Because these factors apply to chemicals present in media such as soil, fill material, and groundwater, all media with
these chemicals have the potential for future vapor intrusion concerns. A full discussion of the HHRA evaluation and conclusions
is presented in the HHRA Report (Appendix I of Rl report).
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WHAT IS HUMAN HEALTH RISK AND HOW IS IT CALCULATED?
A Superfund baseline human health risk assessment is an analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of any actions to control or mitigate these under current- and
future-land uses. A four-step process is utilized for assessing site-related human health risks for reasonable maximum
exposure scenarios.
Hazard Identification: In this step, the Contaminants of Potential Concern (COPCs) at the site in various media (i.e., soil,
groundwater, surface water, and air) are identified based on such factors as toxicity, frequency of occurrence, and fate and
transport of the contaminants in the environment, concentrations of the contaminants in specific media, mobility,
persistence, and bioaccumulation.
Exposure Assessment: In this step, the different exposure pathways through which people might be exposed to the
contaminants in air, water, soil, etc. identified in the previous step are evaluated. Examples of exposure pathways include
incidental ingestion of and dermal contact with contaminated soil and ingestion of and dermal contact with contaminated
groundwater. Factors relating to the exposure assessment include, but are not limited to, the concentrations in specific
media that people might be exposed to and the frequency and duration of that exposure. Using these factors, a "reasonable
maximum exposure" (RME) scenario, which portrays the highest level of human exposure that could reasonably be
expected to occur, is calculated.
Toxicity Assessment: In this step, the types of adverse health effects associated with chemical exposures and the
relationship between magnitude of exposure (dose) and severity of adverse effects (response) are determined. Potential
health effects are chemical-specific and may include the risk of developing cancer over a lifetime or other non-cancer health
hazards, such as changes in the normal functions of organs within the body (e.g., changes in the effectiveness of the
immune system). Some chemicals can cause both cancer risks and non-cancer health hazards.
Risk Characterization: This step summarizes and combines outputs of the exposure and toxicity assessments to provide a
quantitative assessment of site risks for all COPCs. Exposures are evaluated based on the potential risk of developing
cancer and the potential for non-cancer health hazards. The likelihood of an individual developing cancer is expressed as
a probability. For example, a 1CH cancer risk means a "one-in-ten-thousand excess cancer risk"; or one additional cancer
may be seen in a population of 10,000 people because of exposure to site contaminants under the conditions identified in
the Exposure Assessment. Current Superfund regulations for exposures identify the range for determining whether remedial
action is necessary as an individual excess lifetime cancer risk of 10 4 to 10 6, corresponding to a one-in-ten-thousand to a
one-in-a-million excess cancer risk. For non-cancer health effects, a "hazard index" (HI) is calculated. An HI represents the
sum of the individual exposure levels compared to their corresponding reference doses. The key concept for a non-cancer
HI is that a threshold (measured as an HI of less than or equal to 1) exists below which non-cancer health hazards are not
expected to occur. The goal of protection is 10-6 for cancer risk and an HI of 1 for a non-cancer health hazard. Chemicals
that exceed a 10-4 cancer risk or an HI of 1 are typically those that will require remedial action at the site and are referred
to as COCs in the ROD.
Ecological Risk Assessment
The industrialized nature of OU1 (i.e., presence of buildings, paved surfaces, and stormwater management facilities) minimizes
its value as fauna habitat. The undeveloped portions of OU1 consist primarily of turf grass that is periodically mowed, minimizing
its availability and suitability for wildlife use, such as nesting and foraging. The grassed habitats of OU1 range in value to wildlife
in relation to their sizes and locations. Grassed areas surrounding facility-related structures are not likely frequently used by
wildlife. Larger open lawns provide invertebrate and vegetative food sources for a limited number of small mammals and birds,
such as mice, voles, American robin, and killdeerthat may forage there. Waterfowl, reptiles, and small mammals may forage
and/or rest in the grass areas adjacent to the retention basin and bats may forage on insects flying above the basin. However,
given the limited habitat and utilization by area wildlife, the FWIA concludes that site-related impacts to ecological receptors are
minimal within OU1. A full discussion of the FWIA evaluation and conclusions is presented in the FWIA Report (Appendix J of
Rl report)
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WHAT IS ECOLOGICAL RISK AND HOW IS IT CALCULATED?
A Superfund baseline ecological risk assessment is an analysis of the potential adverse health effects to biota caused by
hazardous substance releases from a site in the absence of any actions to control or mitigate these under current and
future land and resource uses. The process used for assessing site-related ecological risks includes:
Problem Formulation: In this step, the contaminants of potential ecological concern (COPECs) at the site are identified.
Assessment endpoints are defined to determine what ecological entities are important to protect. Then, the specific
attributes of the entities that are potentially at risk and important to protect are determined. This provides a basis for
measurement in the risk assessment. Once assessment endpoints are chosen, a conceptual model is developed to provide
a visual representation of hypothesized relationships between ecological entities (receptors) and the stressors to which
they may be exposed.
Exposure Assessment: In this step, a quantitative evaluation is made of what plants and animals are exposed to and to
what degree they are exposed. This estimation of exposure point concentrations includes various parameters to determine
the levels of exposure to a chemical contaminant by a selected plant or animal (receptor), such as area use (how much of
the site an animal typically uses during normal activities): food ingestion rate (how much food is consumed by an animal
over a period of time): bioaccumulation rates (the process by which chemicals are taken up by a plant or animal either
directly from exposure to contaminated soil, sediment or water, or by eating contaminated food): bioavailability (how easily
a plant or animal can take up a contaminant from the environment): and life stage (e.g. juvenile, adult).
Ecological Effects Assessment: In this step, literature reviews, field studies or toxicity tests are conducted to describe the
relationship between chemical contaminant concentrations and their effects on ecological receptors, on a media-, receptor-
and chemical-specific basis. To provide upper and lower bound estimates of risk, toxicological benchmarks are identified
to describe the level of contamination below which adverse effects are unlikely to occur and the level of contamination at
which adverse effects are more likely to occur.
Risk Characterization: In this step, the results of the previous steps are used to estimate the risk posed to ecological
receptors. Individual risk estimates for a given receptor for each chemical are calculated as a hazard quotient (HQ), which
is the ratio of contaminant concentration to a given toxicological benchmark. In general, an HQ above 1 indicates the
potential for unacceptable risk. The risk is described, including the overall degree of confidence in the risk estimates,
summarizing uncertainties, citing evidence supporting the risk estimates and interpreting the adversity of ecological effects.
Summary of Human Health and Ecological Risks
The results of the human health risk assessment indicate that the contaminated soil, indoor air, and groundwater present current
and/or potential future exposure risks. Based on the industrial nature of OU1 and its limited habitat available for area wildlife,
the ecological risk assessment indicates that site-related impacts to ecological receptors is minimal. Many of the risks to human
health associated with contaminated soil have been mitigated, in part, by the implemented IRMs. While potential ecological and
human health risks have been mitigated by OU1 IRMs, long-term O&M will be necessary to maintain protectiveness. Also, as
noted above, ICs in the form of an environmental easement have been recorded for the property controlling and limiting site use
and prohibiting groundwater use in its current state.
Based upon the results of the Rl and the risk assessments, NYSDEC and EPA have determined that actual or threatened
releases of hazardous substances at or from OU1, if not addressed by the preferred remedy or one of the other active measures
considered, may present a current or potential threat to human health and the environment.
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REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are specific goals to protect human health and the environment. These objectives are based
on available information and standards, such as Applicable or Relevant and Appropriate Requirements (ARARs), To-Be-
Considered guidance, and site-specific risk-based levels established using the risk assessments.
The following RAOs have been established for OU1:
• Prevent ingestion/direct contact with contaminated soil/fill material.
• Prevent inhalation of or exposure to contaminants volatilizing from contaminants in soil/fill material.
• Prevent ingestion of groundwater with contaminant levels exceeding drinking water standards.
• Restore groundwater to levels that meet state and federal standards.
• Prevent contact with, or inhalation of, volatiles from contaminated groundwater.
• Prevent the discharge of contaminants to surface water and sediment in Ley Creek.
• Prevent contaminants in soil/fill material from impacting groundwater above drinking water standards.
NYSDEC's SCOs have been identified as remediation goals for soil to attain these RAOs. SCOs are risk-based criteria that
have been developed by New York State following methods consistent with EPA's methods/protocols/guidance and they are
set at levels consistent with EPA's acceptable levels of risk that are protective of human health, ecological exposure, or the
groundwater depending upon the existing and anticipated future use of the Subsite. The land use of the Subsite has historically
been industrial, and current and anticipated future uses can be reasonably expected to remain industrial. Groundwater remedial
goals are the lower of the federal Maximum Contaminant Levels (MCLs) and the New York State Ambient Water Quality
Standards. The lower of the New York State Guidance Values and EPA's Vapor Intrusion Screening Levels will be used to
evaluate future potential for vapor intrusion.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA § 121(b)(1), 42 U.S.C. § 9621(b)(1), mandates that remedial actions must be protective of human health and the
environment, cost-effective, and utilize permanent solutions and alternative treatment technologies and resource recovery
alternatives to the maximum extent practicable. Section 121(b)(1) also establishes a preference for remedial actions which
employ treatment, as a principal element, to permanently and significantly reduce the volume, toxicity, or mobility of the
hazardous substances, pollutants and contaminants at a site. CERCLA § 121(d), 42 U.S.C. § 9621(d), further specifies that a
remedial action must attain a level or standard of control of the hazardous substances, pollutants, and contaminants, which at
least attains ARARs under federal and state laws, unless a waiver can be justified pursuant to CERCLA § 121(d)(4), 42 U.S.C.
§ 9621(d)(4).
Based on anticipated future development at OU1, expectations of the reasonably anticipated land use, as described above,
were considered in the FS to facilitate the development and evaluation of remedial alternatives. Given current zoning and the
present and historical use of the property, the reasonably anticipated land use is to remain an industrially zoned property.
All the alternatives, other than Alternative 1, No Further Action, include the long-term site management of the IRMs.3 The long-
term site management would include maintenance activities and performance monitoring to ensure that the IRMs are operating
effectively and efficiently and to identify the need to implement corrective action(s) specific to the IRMs. Corrective actions for
the IRM covers, as well as the existing paved surfaces (i.e., roadways or parking lots) and the former manufacturing building
that currently serve as a cover for impacted shallow soils, may consist of repair in areas of disturbance or re-application of
vegetation in areas of non-survival.
Each active remedial alternative (Alternatives 2 through 5 below) includes the following common components:
Environmental Easement An existing environmental easement would be maintained that requires land use and groundwater
use restrictions for the facility. Land use restrictions would restrict activities that could result in unacceptable exposure to
contaminated soil. Groundwater use restrictions would preclude the use of groundwater without prior notification and approval
3 The annual site management cost estimates are included in the cost estimates for each of the alternatives.
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from NYSDEC. The existing environmental easement also includes requirements that necessary engineering controls be
operated, maintained, and monitored to provide protectiveness to human health and the environment.
Site Management Plan: A SMP would guide future activities at the facility by addressing use restrictions and by developing
requirements for periodic reviews; operation, maintenance, and monitoring of engineering controls; and groundwater monitoring.
The periodic site management reviews would focus on evaluating the on-site conditions regarding the continuing protection of
human health and the environment as evidenced by information such as groundwater monitoring and documentation of field
inspections.
Soil Management Plan: A soil management plan would be implemented to outline the implementation of engineering and
institutional controls for the handling and management of soil during remedial, maintenance, or site redevelopment activities.
The soil management plan would detail the implementation of on-site consolidation (temporary or permanent), off-site disposal,
soil characterization procedures, and hot spot excavation.
Shallow and Deep Groundwater Monitoring: A monitoring program for shallow and deep groundwater and/or adjacent surface
water would be performed to determine effectiveness of the implemented remedy.
Excavation and Off-Site Disposal of Soil: Excavation would be conducted to remove contaminated surface and/or subsurface
soil that would be required by the alternative. Excavated soils would be disposed of at an offsite permitted facility.
The remedial alternatives are as follows:
Alternative 1 - No Further Action
The Superfund program requires that the "no action" alternative be considered as a baseline for comparison with the other
alternatives. The no further action remedial alternative would not include any additional remedial measures to address the soil
and groundwater contamination at OU1.
As this alternative does not involve further actions, there are no estimated capital, annual, and present-worth costs. The costs
of this alternative are as follows
Capital Cost: $0
Annual O&M Cost: $0
Present-Worth Cost: $0
Alternative 2 - Perimeter and Targeted Shallow Groundwater Collection and Treatment, Perimeter and Targeted Deep
Groundwater Extraction and Treatment, and Soil Excavation with Off-Site Disposal
This alternative would include the construction of a perimeter shallow groundwater collection trench (approximately 1,800 ft in
length and 15 ft deep) and the installation of deep groundwater extraction wells (approximately 35 ft deep) along the northern
perimeter of the facility property. These two systems would collect contaminated groundwater and prevent further off-property
migration. This alternative would also include targeted deep groundwater extraction to address the contamination beneath and
immediately northeast of the former manufacturing building, excavation and off-site disposal of contaminated soil, restoration of
the excavated areas with clean fill, and an enhancement and expansion of the Former Thinner Tanks Area Groundwater
Recovery System to target the shallow groundwater contamination in that area. All collected groundwater would be treated at
the current SPDES treatment system to meet discharge criteria prior to being discharged to Ley Creek. Groundwater monitoring
would be performed to evaluate the effectiveness of the groundwater extraction systems.
This alternative would also include the excavation and off-site disposal of unsaturated surface soil exhibiting contaminant
concentrations greater than the Industrial Use SCOs in areas not currently addressed by an approved IRM or covered by facility
paved surfaces (roadways or parking lots) or the former manufacturing building. The approximate volume of material associated
with this excavation would be 38 CY. The excavated areas would be restored to grade with certified clean fill following
confirmatory sampling.
The enhancement to the Former Thinner Tanks Area Groundwater Recovery System would include the installation of a flow
meter with a totalizer on each of the two existing collection trenches to monitor effluent withdrawn from each trench and
conveyed to the SPDES treatment system. The Former Thinner Tanks Area Groundwater Recovery System would be expanded
with the installation of an additional collection trench or groundwater extraction wells to help increase the removal of VOC (i.e.,
xylene, ethylbenzene, and toluene) mass and to restore groundwater quality in this area. While the FS cost estimate assumes
that two wells would be installed, the appropriate method for extracting the groundwater would be determined during the RD.
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During the RD, studies would be performed to determine the well placement, pumping rates, and drawdown levels that would
allow for optimal capture for the three groundwater extraction systems (perimeter shallow, perimeter deep, and the targeted
deep northeast of the former manufacturing building).
This alternative would also include an evaluation of the existing SSDS during the RD to determine whether enhancements to
the system could effectively improve the removal of elevated VOCs in the unsaturated soil beneath the former manufacturing
building.
As part of the long-term groundwater quality monitoring, COC concentration and natural attenuation data would be collected
from the shallow and deep groundwater throughout the Subsite. Following the operation of the new perimeter groundwater
extraction system for a period up to five years, an evaluation would be performed to determine whether the system is effectively
reducing COC concentrations in off-property groundwater. If it is determined that continued groundwater extraction at the
property perimeter alone would not achieve the remediation goals for the off-property groundwater within a reasonable
timeframe, then off-property in-situ treatment and/or extraction and treatment would be considered and incorporated into the
remedy as determined to be appropriate.
The evaluations of the SSDS, targeted groundwater extraction system, and perimeter extraction system would be documented
and the implementation of any of the contingent remedies (e.g., SSDS enhancement and off-property groundwater treatment)
would be documented via an ESD.
Imposition of an IC in the form of the existing environmental easement for the controlled property which would:
• require the submission of a periodic certification of institutional and engineering controls in accordance with Part 375-1.8
(h)(3);
• restrict the use and development of the property to industrial use as defined by Part 375-1.8(g), subject to local zoning
laws;
• restrict the use of groundwater as a source of potable or process water without appropriate treatment as determined by
the NYSDOH or the Onondaga County Health Department; and
• require compliance with the approved SMP.
Under this alternative, a SMP would be required that would include the following components:
1) An Institutional and Engineering Control Plan that identifies all use restrictions and engineering controls for the site and
details the steps and media-specific requirements necessary to ensure the following institutional and/or engineering
controls remain in place and effective:
o an excavation plan that details the provisions for management of future excavations in areas of remaining contamination;
o a provision for further investigation and remediation should large-scale redevelopment occur, if any of the existing
structures are demolished, or if the subsurface is otherwise made accessible. The nature and extent of contamination in
areas where access was previously limited or unavailable would be immediately and thoroughly investigated pursuant
to an approved plan. Based on the investigation results and a determination of the need for a remedy, a Remedial Action
Work Plan (RAWP) would be developed for the final remedy for the site, including removal and/or treatment of any
source areas to the extent feasible. Citizen Participation Plan (CPP) activities would continue through this process. Any
necessary remediation would be completed prior to, or in association with, redevelopment. This includes the former
manufacturing building;
o descriptions of the provisions of the environmental easement including any land use and groundwater use restriction;
o provisions for the management and inspection of the identified engineering controls;
o maintain site access controls and notification; and
o steps necessary for the periodic reviews and certification of the institutional and/or engineering controls.
2) A Monitoring Plan to assess the performance and effectiveness of the remedy. The plan includes, but may not be limited
to:
o monitoring of groundwater to assess the performance and effectiveness of the remedy;
o a schedule of monitoring and frequency of submittals;
o monitoring for vapor intrusion for any buildings on the facility property, as may be required by the Institutional and
Engineering Control Plan described above.
3) An O&M Plan to ensure continued operation, maintenance, optimization, monitoring, inspection, and reporting of any
mechanical or physical components of the remedy. The plan includes, but is not limited to:
o procedures for operating and maintaining the remedy;
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o compliance monitoring of treatment systems to ensure proper O&M, as well as providing the data for any necessary
permit or permit equivalent reporting;
o maintaining site access controls and required notification; and
o provide access to the site and O&M records.
Because this alternative would result in contaminants remaining above levels that would otherwise allow for unrestricted use
and unlimited exposure, CERCLA requires that the Subsite be reviewed at least once every five years. A conceptual depiction
of Alternative 2 is presented in Figure 6.
The estimated construction time for this alternative is one year.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Capital Cost: $5,560,000
Annual O&M Cost: $264,000
Present-Worth Cost: $8,990,000
Alternative 3 -Targeted Shallow Groundwater Collection and Treatment, Perimeter and Targeted Deep Groundwater
Extraction and Treatment and Soil Excavation with Off-Site Disposal
Alternative 3 is similar to Alternative 2, except there would be no shallow groundwater trench installed at the property perimeter.
Alternative 3 would rely on a deep groundwater extraction and treatment system at the property perimeter combined with a
targeted deep groundwater extraction system to address the contamination in the areas beneath and immediately northeast of
the manufacturing building combined with the enhancements to the Former Thinner Tanks Area Groundwater Recovery System
to target shallow groundwater in this area. A conceptual depiction of Alternative 3 is presented in Figure 7.
The estimated construction time of this alternative is one year.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Capital Cost: $3,890,000
Annual O&M Costs: $266,000
Present-Worth Cost: $7,340,000
Alternative 4 - In-Situ Treatment of Residual Source Areas, Perimeter Deep Groundwater Extraction and Treatment,
and Soil Excavation with Off-Site Disposal
Alternative 4 is similar to Alternative 2, except there would be no shallow groundwater collection trench installed at the property
perimeter, no expansion of the Former Thinner Tanks Groundwater Recovery System, and in-situ treatment would be employed
instead of groundwater extraction and treatment to significantly reduce contaminant concentrations in the residual source areas
(the Former Thinner Tanks Area, northeast of the manufacturing building, and beneath the former manufacturing building). In-
situ treatment would involve injecting amendment(s) using horizontal drilling techniques to promote contaminant degradation in
the residual source area present beneath the building. Injection points would be positioned at the perimeter of the manufacturing
building and extended horizontally to target the contamination beneath the building. A conceptual depiction of Alternative 4 is
presented in Figure 8.
The estimated construction time of this alternative is one year.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Capital Cost: $18,600,000
Annual O&M Costs: $264,000
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Present-Worth Cost: $22,200,000
Alternative 5 - In-Situ Treatment of Residual Source Areas, Perimeter Shallow Groundwater Collection and Deep
Groundwater Extraction and Treatment, and Soil Excavation with Off-Site Disposal
Alternative 5 includes the same elements as Alternative 4, except, instead of using horizontal in-situ injection techniques at the
building perimeter to address site contaminants present beneath the building, vertical injection techniques would be used to
address the site contaminants present beneath the building. As such, Alternative 5 would require drilling through the former
manufacturing building floor. In addition, a shallow groundwater collection trench at the property perimeter would be installed
as described under Alternative 2.
Alternative 5 would also include the excavation and off-site disposal of surface and subsurface soil exhibiting concentrations
greater than the Industrial Use SCOs, including areas currently covered by an approved IRM, or paved surfaces (roadways or
parking lots). The approximate total volume of material associated with this excavation would be 1,500 CY. The excavated areas
would be restored to grade with certified clean fill following confirmatory sampling. A conceptual depiction of Alternative 5 is
presented in Figure 9.
The estimated construction time of this alternative is one year.
The estimated capital, annual, and present-worth costs of this alternative are as follows:
Capital Cost: $22,600,000
Annual O&M Costs: $259,200
Present-Worth Cost: $26,000,000
COMPARATIVE ANALYSIS OF ALTERNATIVES
The detailed analysis of alternatives consists of an assessment of the individual alternatives against each of the nine evaluation
criteria (see box below) set forth in the NCP and a comparative analysis focusing upon the relative performance of each
alternative against those criteria.
A comparative analysis of these alternatives based upon the evaluation criteria noted below follows.
NINE EVALUATION CRITERIA FOR FEDERAL SUPERFUND REMEDIAL ALTERNATIVES
Overall protection of human health and the environment means a determination of whether an alternative eliminates,
reduces, or controls threats to public health and the environment through institutional controls, engineering controls, or
treatment.
Compliance with ARARs means an evaluation whether the alternative would meet all the applicable or relevant and
appropriate requirements of federal and state environmental statutes and other requirements that pertain to the site or
provide grounds for invoking a waiver.
Long-term effectiveness and permanence means the ability of an alternative to maintain protection of human health and
the environment overtime.
Reduction of toxicity, mobility, or volume through treatment means the anticipated performance of the treatment
technologies an alternative may employ.
Short-term effectiveness means the period of time needed to implement an alternative and the risks the alternative may
pose to workers, residents, and the environment during implementation.
Implementability means the technical and administrative feasibility of implementing the alternative, including the availability
of materials and services.
Cost means the estimated capital and annual O&M costs, as well as present-worth costs. Present worth cost is the total cost
of an alternative overtime in terms of today's dollar value. Cost estimates are expected to be accurate within a range of+50
to -30 percent.
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State acceptance means whether NYSDOH (the support agency for NYSDEC) concurs with, opposes, or has no comments
on the preferred remedy.
Community acceptance will be assessed in the ROD and refers to the public's general response to the alternatives
described in this Proposed Plan and the RI/FS reports. Comments received on the Proposed Plan are an important indicator
of community acceptance.
Overall Protection of Human Health and the Environment
Alternative 1 would not be protective of human health and the environment because it would not address contaminated soil or
groundwater. Alternatives 2 through 5 would be protective of human health and the environment because each of these
alternatives would rely upon remedial strategies and/or treatment technologies capable of eliminating exposure to contaminated
soil and groundwater. The ICs under Alternatives 2 through 5 would provide protection of public health.
Compliance with Applicable or Relevant and Appropriate Requirements
SCOs are identified in 6 NYCRR Part 375, Environmental Remediation Programs, Subpart 375-6, effective December 14, 2006.
Because the contaminated soils would not be addressed under Alternative 1, this alternative would not achieve the cleanup
objectives for soil. Alternatives 2 through 5 would provide active measures for meeting the SCOs. Because Alternatives 2
through 5 would involve the excavation of contaminated soils, these alternatives would require compliance with fugitive dust
and volatile organic compound emission requirements in accordance with an approved Community Air Monitoring Plan (CAMP).
EPA and NYSDOH have promulgated health-based protective MCLs (40 CFR Part 141, and 10NYCRR, Chapter 1), which are
enforceable standards for various drinking water contaminants (chemical-specific ARARs). Although the groundwater at the
Subsite is not presently being utilized as a potable water source, achieving groundwater MCLs is an applicable standard.
Alternative 1 would not provide for any direct remediation of groundwater and would, therefore, not achieve chemical-specific
ARARs for groundwater. Alternatives 2 through 5 would be more effective in reducing groundwater contaminant concentrations
below MCLs because each option includes active remediation of the contaminated groundwater.
There are no action or location-specific ARARs that were identified for Alternative 1. With regard to location-specific ARARs for
Alternatives 2 through 5, they would be conducted in a manner consistent with federal and state freshwater wetlands and
floodplain requirements. ICs would be implemented under Alternatives 2 through 5 in general conformance with NYSDEC's
DER-33 guidance. Additionally, continued maintenance of cover systems included as part of Alternatives 2 through 5 (and
existing cover systems) would prevent erosion and exposure to contaminated soil. Cover systems would be implemented in
general conformance with NYSDEC's DER-10 guidance. Procedures would be implemented to adhere to the location-specific
ARARs related to federal and state requirements for cultural, archeological, and historical resources. The need for a scope of
cultural resources survey, as required by the National Historic Preservation Act, would be evaluated during the RD. With respect
to action-specific ARARs, proposed cover systems and excavation activities would be conducted consistent with applicable
standards; earth moving/excavation activities would be conducted consistent with air quality standards; transportation and
disposal activities would be conducted in accordance with applicable state and federal requirements by licensed and permitted
haulers.
Compliance with action-specific ARARs related to hazardous waste management requirements for treatment residuals and
SPDES requirements for treated water discharged to Ley Creek would be addressed in Alternatives 2 through 5 during the
continued operation of the Former Thinner Tanks Area shallow groundwater collection and SPDES Treatment System IRM.
Action-specific ARARs related to subsurface injection of chemical oxidation amendments under Alternatives 4 and 5 would be
met during remedy implementation.
The provisions of ECL Section 27-1318, Institutional and Engineering Controls, is applicable to the environmental easement
under Alternatives 2 through 5.
Long-Term Effectiveness and Permanence
Alternative 1 would involve no active remedial measures and, therefore, would not be effective in eliminating the potential
exposure to contaminants in the soil and groundwater and would allow for the continued release of contaminants from the soil
to the groundwater and the continued migration of contaminated groundwater.
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Alternatives 2 through 5 would be effective in the long term and would provide permanent remediation by removing the
contaminated soil and treating/disposing of the contaminated soil at a licensed disposal facility. Alternatives 2 and 3 would be
effective in the long term because there would be continuous extraction and treatment of the source material in the groundwater.
Alternatives 4 and 5 would be more effective at removing the source material in the groundwater than Alternatives 2 and 3
through the application of in-situ treatment techniques. Use of in-situ techniques under Alternative 4 and 5 would also reduce
the need to continuously operate groundwater extraction and treatment systems. Alternatives 4 and 5 would also be more
effective than Alternatives 2 and 3 at removing contamination beneath the former manufacturing building through the use of in-
situ treatment techniques. By actively addressing site contamination, Alternatives 2 through 5 would maintain reliable protection
of human health and the environment over time. Under Alternatives 2 through 5, the groundwater treatment residues would
have to be appropriately handled by the on-site SPDES Treatment Facility. Alternative 1 would not generate such treatment
residual. Alternative 4 would generate the least amount of greenhouse gases in the long term because there would only be the
perimeter deep groundwater extraction and treatment system operating as part of site management compared to the other
alternatives with multiple extraction and treatment systems; thereby increasing the use of energy and the production of
greenhouse gas emissions. The long-term performance of Alternatives 2 through 5 could be at risk during severe storms/weather
events and associated flooding. Potential flooding-related threats to the in-situ treatment injection and groundwater extraction
and treatment systems would need to be evaluated during the RD to ensure adequate resiliency to the potential effects of
climate change.
Reduction in Toxicity. Mobility, or Volume Through Treatment
There would be no reduction in toxicity, mobility, or volume under Alternative 1. Alternatives 2 through 5 would afford similar
reductions in toxicity, mobility, and volume through the collection and treatment of contaminated groundwater, thereby satisfying
CERCLA's preference for treatment. Alternatives 4 and 5, and possibly Alternatives 2 and 3 (should contingencies be needed),
would rely upon in-situ treatment techniques to address the contamination in certain portions of the groundwater.
In-situ treatment, a remedial element included in Alternatives 4 and 5 and a possible treatment technology under Alternatives 2
and 3, would address contaminants in areas where high concentrations of site contaminants exist. In-situ treatment relies on a
chemical reaction or biological processes to permanently destroy VOC contamination. Therefore, it would effectively reduce the
toxicity, mobility, and volume of the site contamination.
Short-Term Effectiveness
Because Alternative 1 does not include any physical construction measures in any areas of contamination, it would not present
any potential adverse impacts to remediation workers or the community as a result of its implementation.
There could be potential adverse impacts to remediation workers and nearby employees and visitors at the former manufacturing
building under Alternatives 2 through 5 through dermal contact, incidental ingestion, and inhalation related to the removal,
handling, and processing of contaminated groundwater and soil. Noise from the soil excavation work associated with these
alternatives could present some limited adverse impacts to remediation workers and nearby employees. In addition, soil and
groundwater sampling activities would pose some risk. The risks to remediation workers and nearby employees under all of the
action alternatives could, however, be mitigated by following appropriate health and safety protocols, exercising standard
construction and engineering practices, and utilizing proper protective equipment.
Potential environmental impacts related to dust, volatile emission, and surface runoff would be mitigated through appropriate
control measures and adherence to a CAMP.
Implementation of Alternative 1 would result in the smallest environmental footprint, as no remediation would be performed.
There is an environmental footprint inherent in implementation of each of the action alternatives as it relates to construction and
long-term operation. The implementation installation and long-term use of a shallow groundwater collection trench included in
Alternatives 2 and 5 would result in greater direct emissions and fuel consumption needed for construction equipment,
transporting necessary material, and long-term extraction and treatment of groundwater from the shallow groundwater collection
trench as compared to the other action alternatives. Under Alternatives 4 and 5, in-situ treatment would have higher initial
greenhouse gas emissions than Alternatives 2 and 3, due to the use of heavy construction equipment needed for drilling and
introducing in-situ amendments. Alternatives 2, 3, 4, and 5 would be able to utilize the existing SPDES treatment system.
Specifically, instead of constructing a new treatment plant, these Alternatives would be able to upgrade and retrofit the existing
treatment system to accommodate the additional volume of extracted groundwater. Green remediation techniques would be
considered to help minimize the environmental footprint related to the implementation of the remedial alternatives.
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For all the action alternatives, there is a potential for stormwater runoff and erosion during construction and excavation activities
that would have to be properly managed to prevent or minimize any adverse impacts. For these alternatives, appropriate
measures would have to be taken during excavation activities to prevent transport of fugitive dust and exposure of remediation
workers and employees at the former manufacturing building and surrounding community.
Alternatives 2 through 5 would address exposure-related RAOs upon implementation. Alternatives 2 through 5 are expected to
address the off-property migration RAO within approximately one year of implementation of the remedies. Alternative 1 would
not address the RAO associated with adult trespassers or groundwater use.
The former manufacturing building is currently being utilized by tenants conducting commercial and light industrial activities. Out
of Alternatives 2 through 5, Alternative 5, would be the most disruptive to these businesses, as it would likely necessitate
intrusive actions within the building to treat the underlying contamination.
Because no actions would be performed under Alternative 1, there would be no implementation time. It is estimated that
Alternatives 2 through 5 would require one year to implement.
Although it would likely take greater than 30 years to attain groundwater standards for each of the alternatives, Alternatives 4
and 5, which include the use of in-situ treatment to address areas with elevated VOC concentrations combined with groundwater
extraction and treatment, would likely achieve the groundwater standards in the shortest amount of time relative to the other
alternatives. Alternative 4 would achieve groundwater standards with less disruption to the businesses than Alternative 5.
Implementabilitv
Alternative 1 would be the easiest alternative to implement, as there are no activities to undertake. Soil excavation would be
readily implementable under Alternatives 2 through 5.
Construction of the shallow perimeter trench under Alternatives 2 and 5 would require excavation in the vicinity of utilities,
including a National Grid high pressure gas line that runs the length of the property border along Factory Ave; National Grid
overhead power lines along the property line along Factory Avenue; National Grid overhead high voltage power lines that
traverse Factory Avenue from the former landfill at the facility; an Onondaga County sanitary sewer located on the southern
shoulder of Factory Avenue; and the former landfill (and associated low permeability membrane). Construction in the vicinity of
the above-noted utilities would require offsets and are likely to require measures to protect workers and the utilities during
construction activities. These measures would not be necessary under Alternative 3 and 4, which do not include the installation
of the shallow groundwater collection system. Installation of the extraction wells associated with the perimeter deep groundwater
extraction system under Alternatives 2 through 5, would, to a lesser extent, require measures to protect workers and the utilities
during construction activities, as compared to the construction of the shallow groundwater perimeter extraction system included
under Alternatives 2 and 5.
In-situ treatment, a remedial element of Alternatives 4 and 5, and a possible treatment technology under Alternatives 2 and 3,
would require a treatability study. Subsurface soil conditions and the presence of underground utilities would need to be
evaluated as they might interfere with the injection of reagents.
The former manufacturing building is currently being utilized by tenants conducting commercial and light industrial activities.
Implementation of Alternative 5, which would necessitate intrusive actions within the building to treat the underlying
contamination, would be more difficult to implement than Alternatives 2, 3, and 4.
Each alternative would require coordination with EPA, NYSDEC, Onondaga County, the Town of Salina, the Town of DeWitt,
and the former manufacturing building's tenants.
Off-site facilities for treatment, storage, and disposal of treatment residuals and excavated soil would be readily available for
each alternative. The necessary equipment, specialists, and materials would be readily available.
Cost
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The estimated present-worth costs were calculated using a discount rate of seven percent and a 30-year4 time interval for the
post-construction monitoring and maintenance period.
The estimated capital, annual O&M, and present-worth costs using a 7% discount factor for each of the alternatives are
presented in the table below.
Alternatives
Capital
Annual O&M
Total Present Worth
1 - No Further Action
$0
$0
$0
2 - Perimeter and Targeted Shallow Groundwater
Collection; Perimeter and Targeted Deep
Groundwater Extraction and Treatment; and Soil
Excavation and Disposal
$5,560,000
$264,000
$8,990,000
3 - Targeted Shallow Groundwater Collection;
Perimeter and Targeted Deep Groundwater
Extraction and Treatment; Soil Excavation and
Disposal
$3,890,000
$266,000
$7,340,000
4 - In-Situ Treatment of Residual Source Areas;
Perimeter Deep Groundwater Extraction and
Treatment; Soil Excavation and Disposal
$18,600,000
$264,000
$22,200,000
5 - In-Situ Treatment of Residual Source Areas;
Perimeter Shallow Groundwater Collection and
Treatment; Perimeter Deep Groundwater Extraction
and Treatment; Soil Excavation and Disposal
$22,600,000
$259,000
$26,000,000
Support Aaencv Acceptance
NYSDOH has reviewed this Proposed Plan and concurs with the preferred alternative.
Community Acceptance
Community acceptance of the preferred alternative will be addressed in the ROD following review of the public comments
received on this Proposed Plan.
PREFERRED ALTERNATIVE
Based upon an evaluation of the various alternatives, NYSDEC and EPA recommend Alternative 4 - In-Situ Treatment of Three
Residual Source Areas, Perimeter Deep Groundwater Extraction and Treatment, and Soil Excavation with Off-Site Disposal, as
the preferred alternative. The components of the proposed remedy are described below. A conceptual depiction of the preferred
alternative is presented in Figure 8.
Under this alternative, three areas where high concentrations of residual VOC contamination exist would be addressed using
in-situ treatment. These three areas contain contaminants at concentrations greater than 10,000 ppm and represent continuing
sources of groundwater contamination. Specifically, these areas include the Former Thinner Tanks Area, where non-chlorinated
VOC residual contamination remains, and areas beneath and northeast of the former manufacturing building where residual
chlorinated VOC contamination remains. As part of the RD, pre-design investigations will be performed in each of these areas
to determine the volumes requiring treatment and the most-effective type of in-situ treatment(s).
4 Although O&M would continue as needed beyond the 30-year period, 30 years is the typical period used when estimating costs for a
comparative analysis.
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This alternative would also include the installation of deep (approximately 20 to 35 feet beneath the ground surface; the exact
depth intervals would be determined during the RD) extraction wells along the northern perimeter of the facility property. These
extraction wells would be designed to collect contaminated groundwater that has migrated from the source areas identified
above and to prevent off-property migration. Following extraction, the contaminated groundwater would be treated at the existing
SPDES water treatment system (using filtration and granulated activated carbon) prior to being discharged to Ley Creek. The
groundwater extraction system would be designed with a capture zone sufficient to address the areal and vertical extent of the
contamination. During the RD, a study would be performed to determine the extraction well placement, groundwater pumping
rates, and drawdown levels necessary to achieve optimal capture. To evaluate the effectiveness of the extraction system, a
groundwater monitoring program would be implemented as part of this remedy.
Approximately 38 CY of unsaturated surface soil would be excavated and disposed of off-site at a licensed disposal facility. The
soils requiring excavation contain contaminants at concentrations greater than the Industrial Use SCOs and are located in areas
not currently addressed by an approved IRM or covered by facility paved surfaces (roadways or parking lots) or the former
manufacturing building. Following confirmatory soil sampling to demonstrate that the SCOs have been achieved, the excavated
areas would be restored to grade with clean fill meeting the requirements of 6 NYCRR Part 375-6.7(d).
The existing SSDS beneath the former manufacturing building includes two sub-slab vapor extraction systems that withdraw air
at a rate of approximately 195 cubic feet per minute for System 1 and 94 cubic feet per minute for System 2. An evaluation of
the SSDS would be performed during the RD to determine whether enhancements to the system could further improve the
removal of elevated VOCs in the unsaturated soil beneath the former manufacturing building. Data would be collected to
determine if the existing SSDS can be upgraded to not only continue to prevent sub-slab vapors from entering the former
manufacturing building, but to enhance the removal of chlorinated VOC contamination present in the vadose zone soil beneath
the building.
As part of a long-term monitoring program, shallow and deep groundwater samples would be collected from monitoring wells
throughout the Subsite to evaluate the performance of the groundwater extraction and treatment system, and the effectiveness
of the in-situ treatment in the three residual source areas where high concentrations of site contaminants exist. The details of
the monitoring program would be developed as part of the RD/Remedial Action and outlined in a Monitoring Plan.
The remedy would also include the imposition of an IC in the form of the existing environmental easement for the controlled
property which would:
• require the submission of a periodic certification of institutional and engineering controls in accordance with Part 375-1.8
(h)(3);
• restrict the use and development of the property to industrial use as defined by Part 375-1.8(g), subject to local zoning
laws;
• restrict the use of groundwater as a source of potable or process water without appropriate treatment as determined by
the NYSDOH or the Onondaga County Health Department; and
• require compliance with the approved SMP.
A SMP would be required which includes the following components:
1) An Institutional and Engineering Control Plan that identifies all use restrictions and engineering controls for the site and
details the steps and media-specific requirements necessary to ensure the following institutional and/or engineering controls
remain in place and effective:
o an excavation plan that details the provisions for management of future excavations in areas of remaining
contamination;
o a provision for further investigation and remediation should large-scale redevelopment occur, if any of the existing
structures are demolished, or if the subsurface is otherwise made accessible. The nature and extent of contamination
in areas where access was previously limited (beneath the 800,000 sf former manufacturing building) or unavailable
will would be immediately and thoroughly investigated pursuant to an approved plan. Based on the investigation
results and a determination of the need for possible additional remedial actions, a RAWP would be developed for
the site, including removal and/or treatment of any source areas to the extent feasible. Citizen Participation activities
will continue through this process. Any necessary remediation would be completed prior to, or in association with,
redevelopment. This includes the former manufacturing building;
o descriptions of the provisions of the environmental easement including any land use or groundwater use restriction;
o provisions for the management and inspection of the identified engineering controls;
o maintain site access controls and notification; and
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o steps necessary for the periodic reviews and certification of the institutional and/or engineering controls.
2) A Monitoring Plan to assess the performance and effectiveness of the remedy. The plan includes, but may not be limited
to:
o monitoring of groundwater to assess the performance and effectiveness of the remedy;
o a schedule of monitoring and frequency of submittals; and
o monitoring for vapor intrusion for any buildings on the facility property, as may be required by the Institutional and
Engineering Control Plan described above.
3) An O&M Plan to ensure continued operation, maintenance, optimization, monitoring, inspection, and reporting of any
mechanical or physical components of the remedy. The plan includes, but is not limited to:
o procedures for operating and maintaining the remedy;
o compliance monitoring of treatment systems to ensure proper O&M, as well as providing the data for any necessary
permit or permit equivalent reporting;
o maintaining site access controls and required notification; and
o provide access to the site and O&M records.
Long-term O&M would be performed for the above-noted remedial actions as well as for the previously implemented IRMs,
including the Former Landfill IRM; Surface Impoundment Cover #1 IRM; Former Thinner Tanks Groundwater Recovery System
IRM; SPDES Treatment System IRM; and the Vapor Intrusion Mitigation IRM (i.e., sub-slab depressurization system).
Maintenance activities and performance monitoring would be conducted to ensure that the remedial elements and IRMs are
operating effectively and efficiently and to identify the need to implement corrective action(s). Corrective actions for the IRM
covers, as well as the existing paved surfaces (i.e., roadways or parking lots) and the former manufacturing building that
currently serve as a cover for impacted shallow soils, may consist of repair in areas of disturbance or re-application of vegetation
in areas of non-survival.
As part of the long-term groundwater quality monitoring, COC concentration and natural attenuation data would be collected in
the shallow and deep groundwater throughout the Subsite. Following the operation of the perimeter groundwater extraction and
treatment system for a period up to five years, an evaluation would be performed to determine whether the system is effectively
reducing COC concentrations in the off-property groundwater. If it is determined that continued groundwater extraction at the
property perimeter alone would not achieve the remediation goals for the off-property groundwater within a reasonable
timeframe, then off-property in-situ treatment techniques and extraction and treatment would be considered and incorporated
into the remedy as determined to be appropriate.
The evaluations of the SSDS and perimeter extraction system would be documented and the implementation of any of the
contingent remedies would be documented via an ESD.
Because this alternative would result in contaminants remaining above levels that allow for unrestricted use and exposure,
CERCLA requires that the Subsite be reviewed at least once every five years.
Green remediation techniques, as detailed in NYSDEC's Green Remediation Program Policy-DER-31,5 and EPA Region 2's
Clean and Green Policy6 would be considered during the implementation of the preferred alternative to reduce short-term
environmental impacts. Green remediation best practices such as the following may be considered:
• Use of renewable energy and/or purchase of renewable energy credits to power energy needs during construction and/or
O&M of the remedy.
• Reduction in vehicle idling, including both on and off-road vehicles and construction equipment during construction and/or
O&M of the remedy.
• Design of cover systems, to the extent possible, to be usable for alternate uses, require minimal maintenance (e.g., less
mowing), and/or be integrated with the planned use of the property.
• Beneficial reuse of material that would otherwise be considered a waste.
• Use of ultra-low sulfur diesel.
5 See http://www.dec.nv.qov/docs/remediation hudson pdfZder31.pdf
6 See http://epa.gov/reqion2/superfund/qreen remediation
23
-------
BASIS FOR THE REMEDY PREFERENCE
Alternative 1 does not satisfy the threshold criteria because it does not provide protection of human health or the environment
or provide a means to attain ARARs. Alternative 3 is similar to Alternative 2, except there would be no shallow groundwater
collection trench installed along the northern perimeter of the facility property (only a deep groundwater extraction and treatment
system). Alternative 4 is similar to Alternative 2, except there would be no shallow groundwater collection trench installed at the
property perimeter, no expansion of the Former Thinner Tanks Groundwater Recovery System, and in-situ treatment techniques
would be employed instead of groundwater extraction and treatment to address residual VOC contamination in the Former
ThinnerTanks Area, northeast of and beneath the former manufacturing building. Alternative 5 is similarto Alternative 4, except
Alternative 5 would use traditional vertical well installation for the in-situ treatment remedy instead of horizontal wells and
Alternative 5 would also include the installation of a shallow groundwater collection trench at the facility perimeter and soil
removal beneath the cover systems and paved areas (parking lots and roads).
While approximately $1.65 million more expensive than Alternative 3, Alternative 2 would directly address contaminated shallow
groundwater along the northern perimeter of the facility property, whereas Alternative 3 would not. Alternatives 4 and 5 are
more costly ($22,200,000 and $26,000,000, respectively) than Alternative 2 ($8,990,000), but both Alternatives would be more
effective than Alternative 2 in addressing the three residual source areas.
Alternative 4 includes active treatment of three separate residual source areas with in-situ treatment, therefore it does not include
a shallow groundwater collection trench to address the low concentrations of shallow groundwater contamination at the property
perimeter. Alternatives 4 and 5 would be equally effective in addressing the residual source area underthe former manufacturing
building. However, Alternative 5 would be more disruptive to the tenants because installing traditional vertical wells for the in-
situ treatment would require drilling through the building concrete floor within tenant-occupied spaces inside of the former
manufacturing building. Alternative 4 would rely on horizontal wells/directional drilling outside of the building footprint for the in-
situ treatment. In summary, both Alternatives 4 and 5 would be more protective and significantly more costly than Alternatives
2 and 3. In comparing Alternative 4 and 5, however Alternative 4 would be less disruptive to building occupants and would cost
approximately $3.8 million less than Alternative 5.
Based on information currently available, NYSDEC and EPA believe that Alternative 4 is the most appropriate alternative to
address contamination at the OU1 portion of the GM IFG Subsite. This preferred alternative meets the threshold criteria and
provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria.
NYSDEC and EPA expect the preferred alternative to satisfy the following statutory requirements of CERCLA Section 121(b):
1) be protective of human health and the environment; 2) comply with ARARs; 3) be cost-effective; 4) utilize permanent solutions
and alternative treatment technologies or resource recovery technologies to the maximum extent practicable; and 5) satisfy the
preference for treatment as a principal element (or justify not meeting the preference).
24
-------
Table 1
GM Former Inland Fisher Guide Facility
Surface Soils 0-2 Feet (13 June 1985 - 31 December 2009)
Summary of Detected Concentrations and Part 375 SCO Exceedances
NYSDEC
NYSDEC
Number of
Part 375
Part 375
NYSDEC Part
Unrestricted
Restricted
Number of
Restricted
Number of
Number
Minimum
Maximum
375
Use
Use -
Commercial
Use -
Industrial
of
Number
Detected
Detected
Unrestricted
SCO
Commercial
SCO
Industrial
SCO
Parameter
Samples
of Detects
Cone.
Cone.
Use SCOS
Exceedances
SCOs
Exceedances
SCOs
Exceedances
Volatile Orqanic Compounds (mq/kq
Cis-l,2-Dichloroethylene
43
1
0.34
0.34
0.25
1
500
0
1000
0
TRICHLOROETHYLENE (TCE)
45
5
0.02
46
0.47
2
200
0
400
0
Semivolatile Organic Compounds (m
g/kg)
Acenaphthene
58
16
0.04
40
20
1
500
0
1000
0
Anthracene
58
28
0.041
230
100
1
500
0
1000
0
Benzo|"a"|anthracene
57
49
0.057
350
1
11
5.6
8
11
5
Benzoyl pyrene
56
47
0.046
300
1
14
1
14
1.1
12
BenzoMfluoranthene
57
53
0.039
360
1
16
5.6
9
11
8
Benzo|"q,h,nperylene
54
39
0.043
310
100
1
500
0
1000
0
BenzoMfluoranthene
57
45
0.039
120
0.8
11
56
1
110
1
Chrysene
58
53
0.042
380
1
10
56
1
110
1
Dibenzo|"a,h"|Anthracene
44
11
0.077
39
0.33
5
0.56
4
1.1
3
Dibenzofuran
58
16
0.039
21
7
1
350
0
1000
0
Fluoranthene
58
57
0.04
1200
100
1
500
1
1000
1
Fluorene
58
17
0.039
65
30
1
500
0
1000
0
Indenol" 1,2,3-cdlpyrene
54
40
0.038
190
0.5
14
5.6
4
11
2
Phenanthrene
58
51
0.04
670
100
1
500
1
1000
0
Pyrene
58
57
0.043
1000
100
1
500
1
1000
0
PCBs (mg/kg)
Aroclor-1242
142
1
1.9
1.9
0.1
1
1
1
25
0
Aroclor-1248
142
95
0.002
54
0.1
90
1
71
25
5
Aroclor-1254
44
10
0.03
8
0.1
9
1
2
25
0
Aroclor-1260
142
0
0
0
0.1
0
1
0
25
0
Polychlorinated biphenyls
142
105
0.002
54
0.1
100
1
74
25
5
Metals (mg/kg)
Arsenic
61
61
1.7
92.8
13
6
16
2
16
2
Chromium
64
64
6.5
1220
30
18
1500
0
6800
0
Copper
64
64
5.4
323
50
4
270
1
10000
0
Nickel
32
32
8.3
4000
30
12
310
1
10000
0
Zinc
61
61
13.2
892
109
15
10000
0
10000
0
NOTES
This table presents (1) soil data from 13 June 1985 - 31 December 2009, (2) the detected concentration data only, and (3) only parameters that exceeded
the Part 375 Unrestricted, Restricted-Commercial, and Restricted-Industrial SCOs.
NC = No criteria available.
SCO = Soil Cleanup Objectives; NYSDEC = New York State Department of Environmental Conservation.
2/1/2023
K:\Racer-Trust.l088190\1940101904.2022_Fmr-IFG-Fac_OUl\Docs\Reports\OUl PRAP\Jan 2023 PRAP Support\Soil Data Table Summary QC\Soil Detections
Greater Than SCOs_2023-01-31.xlsx
-------
Table 2
GM Former Inland Fisher Guide Facility
Soils >2 Feet (13 June 1985 - 31 December 2009)
Summary of Detected Concentrations and Part 375 SCO Exceedances
NYSDEC
NYSDEC
Number of
Part 375
Part 375
NYSDEC Part
Unrestricted
Restricted
Number of
Restricted
Number of
Number
Minimum
Maximum
375
Use
Use -
Commercial
Use -
Industrial
of
Number
Detected
Detected
Unrestricted
SCO
Commercial
SCO
Industrial
SCO
Parameter
Samples
of Detects
Cone.
Cone.
Use SCOS
Exceedances
SCOs
Exceedances
SCOs
Exceedances
Volatile Orqanic Compounds (mq/kc
ACETONE
50
28
0.005
0.1
0.05
1
500
0
1000
0
Cis-l,2-Dichloroethylene
134
51
0.001
11
0.25
11
500
0
1000
0
ETHYLBENZENE
238
55
0.0008
61
1
27
390
0
780
0
METHYLENE CHLORIDE
149
55
0.001
7.8
0.05
8
500
0
1000
0
TOLUENE
239
74
0.001
720
0.7
16
500
1
1000
0
TRICHLOROETHYLENE (TCE)
148
80
0.001
9800
0.47
37
200
2
400
2
VINYL CHLORIDE
149
8
0.002
0.12
0.02
3
13
0
27
0
Xylenes (total)
238
61
0.002
330
0.26
40
500
0
1000
0
Semivolatile Organic Comi
lounds (mg/kg)
2-Methylphenol
86
5
0.1
0.44
0.33
1
500
0
1000
0
3&4-Methylphenol
86
11
0.043
3.9
0.33
7
500
0
1000
0
Acenaphthene
87
5
0.058
21
20
1
500
0
1000
0
Anthracene
87
6
0.043
170
100
1
500
0
1000
0
BenzoManthracene
87
11
0.036
150
1
1
5.6
1
11
1
BenzoMpyrene
87
9
0.035
110
1
1
1
1
1.1
1
BenzoMfluoranthene
87
11
0.047
140
1
1
5.6
1
11
1
Benzo|"q,h,nperylene
87
4
0.039
130
100
1
500
0
1000
0
BenzoMfluoranthene
87
5
0.039
59
0.8
1
56
1
110
0
Chrysene
87
12
0.046
170
1
1
56
1
110
1
Dibenzo|"a,h"|Anthracene
87
2
0.18
65
0.33
1
0.56
1
1.1
1
Dibenzofuran
87
6
0.066
12
7
1
350
0
1000
0
Fluoranthene
87
14
0.038
560
100
1
500
1
1000
0
Fluorene
87
4
0.052
37
30
1
500
0
1000
0
Indenol" 1,2,3-cdlpyrene
87
3
0.28
76
0.5
1
5.6
1
11
1
Phenanthrene
87
18
0.037
450
100
1
500
0
1000
0
Pyrene
87
18
0.04
480
100
1
500
0
1000
0
PCBs (mq/kq)
Aroclor-1016
264
1
0.48
0.48
0.1
1
1
0
25
0
Aroclor-1242
264
7
0.04
1400
0.1
1
5
25
3
Aroclor-1248
265
139
0.002
4300
0.1
111
1
70
25
19
Aroclor-1254
168
5
0.027
99
0.1
1
2
25
2
Aroclor-1260
264
3
0.027
1.6
0.1
1
1
1
25
0
Polychlorinated biphenyls
274
152
0.002
4300
0.1
120
1
77
25
23
Metals (mg/kg)
Arsenic
111
115
1.6
65.7
13
11
16
8
16
8
Chromium
117
122
3.1
17200
30
28
1500
6
6800
2
Copper
112
117
4.8
23200
50
25
270
17
10000
1
Cyanide (total)
85
20
0.68
614
27
8
27
8
10000
0
Lead
111
116
2.8
291
63
6
1000
0
3900
0
Nickel
114
119
5
14400
30
30
310
13
10000
1
Zinc
102
107
11.2
53300
109
19
10000
2
10000
2
NOTES
This table presents (1) soil data from 13 June 1985 - 31 December 2009, (2) the detected concentration data only, and (3) only parameters that exceeded the
Part 375 Unrestricted, Restricted-Commercial, and Restricted-Industrial SCOs.
NC = No criteria available.
SCO = Soil Cleanup Objectives; NYSDEC = New York State Department of Environmental Conservation.
2/1/2023
K:\Racer-Trust.l088190\1940101904.2022_Fmr-IFG-Fac_OUl\Docs\Reports\OUl PRAP\Jan 2023 PRAP Support\Soil Data Table Summary QC\Soil Detections
Greater Than SCOs_2023-01-31.xlsx
-------
FIGURE 1
Hinsdale
Fue Sta maldch
Radio Towtrs
* ; HANCOCK lFIpy). Ur.S AIRJX3RC.K
Mattydale
Riordln
^KSKRVK
TRA1NIM.
CENTER
rnRUW*Y_
yno^
Service"
Facilities /
Court jjie" 5
Lysvcourt
Brickkilns
taryi.
spiUI V
<" f
Wfhatrr
L-JMm
14^ 'Ii
rftt
fowMl
prfEfv
Nichols
Sch X
st wood
Copyright:© 2013 National GeograpMe Society, iicufred
- I I jy —M
1940101904
JUNE 2022
RACER TRUST
GM - IFG OU1
SYRACUSE, NEW YORK
SITE LOCATION
0 1,000 2,000 4,000
I Feet
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
Sefvice Layer Credtfe: feource: Esri, Maxar, Earthstar Geographies, and the dfts User Community
NORTHERN
PROPERTY
FORMER THINNER
4 TANK AReMI
NORTHEASTERN
PROPERTY
SOUTHWESTERN
MANUFACTURING
*^|bi!!ji JmNcJ ¦
AREA
SOUTHEASTERN
PROPERTY**!
FIGURE 2
Q
LEGEND
PROPERTY AREA LIMITS
RACER TRUST
FORMER IFG FACILITY
SYRACUSE, NEW YORK
PROPERTY AREAS OF THE
FORMER GM-OU1 SITE
100 200
400
600
I Feet
1940101904
JANUARY 2023
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
Service Layer CrecMsr © 2022 Microsoft Corporation © 2022 Maxar ©CNES (2022) Distribution Airbus QS.
rA%BSfft'BlI*ANDFIl35
NORTHEASTERN
proper™
WutaeMirgII
[SOUTHWESTERN
jbJTm
¦bh5^
lBH^S
BH-48'
MANUFACTURING
BUIlJDING?fO|
SOUTHEASTERN
R^0PER^M|
FIGURE 3
LEGEND
APPROXIMATE LIMITS OF LANDFILL
APPROXIMATE LIMITS OF SOIL STAGING
AREA
PROPERTY AREA
SAMPLE LOCATION WITH
EXCEEDANCE
SUBSURFACE SAMPLE > IND/PROT GW
SCO
+ SURFACE SAMPLE > IND/PROT GW SCO
RACER TRUST
GM - IFG OU1
SYRACUSE, NEW YORK
LOCATIONS GREATER THAN
SCOs
100 200
400
600
5 Feet
1940101904
JUNE 2022
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
11/1/2006 | 8/25/2011 | 8/2/2016 | 4/9/2019
10/31/2006 I 8/24/2011 | 8/2/2016 | 4/11/2019
11/10/1999 | 8/2/2016
8/3/20161
11/10/1999
10/31/2006 | 8/24/2011
8/3/2016
RESULTS
No Detections
11/4/1999 I 10/27/2006 | 4/10/2019
10/31/2006 | 8/3/2016
10/31/2006 | 8/3/2016
11/10/1999 | 10/30/2006 | 8/24/2011 | 8/2/2016
RESULTS
| Ace tone
11/9/1999
10/30/2006 | 8/16/2011 | 8/2/2016
No Detections
10/24/2006 | 4/10/2019
RESULTS
OBG W6SR DP.
1996 to September 1996 | 3/17/1997 | 6/12/1997 | 1997 to 1999 | 11/8/1999 | 2000 to 2006
3/20/1996
10/24/2006
|lMo detection!
[OBGT9SR/DRj
|Trichloroether
10/25/2006 | 4/11/2019
10/27/2006
11/3/1999 | 10/26/2006 | 4/10/2019
11/10/1999 | 11/10/1999
No Detections
10/23/2006
11/8/1999 | 10/23/2006
RESULTS
No Detections
1995 to 1996 I 3/17/1997
6/2/2000 | 4/11/2001 | 4/11/2002 12003 to 2006 | 5/8/2007 |2008to2009 | 6/23/2010
8/18/1999
11/8/1999 [ 10/25/2006
11/11/1999
RESULTS
,,2-Dichloroethene
|Methylene Chl(
11/8/1999
|Trichloroether
RESULTS
11/8/1999
No Detections
11/8/1999
No Detections
11/3/1999
10/9/2003
RESULTS
8/18/1999
11/3/2006
11/4/1999
8/18/1999
| PARAMETER
RESULTS
-Dichloroether
|TrichU
-1,2-Dichloroether
MONITORING WELL
MONITORING WELL STATUS UNKNOWN OR
ABANDONED
Total CVOC*
Concentrations (ug/L)
O
r—i
o
>10 -100
>100 -1000
>1000
Total CVOCs -1,1 -DCA, 1,1 -DCE,
cis-1,2-DCE (total), TCE, and VC
* - Color coding within data boxes refers to
individual constituents
OBG-26S - Based on last sampling result
|— LOCATION ID
j RESULTS IN ug/L -
0BG-23D
10/24/2006
PARAMETER
RESULTS
1,1-Dichloroethene
12
Benzene
1
3700
tra ns-l,2-Dichloroethene
10
Trichloroethene
1600
Vinyl Chloride
1300
BOLD RESULTS _J
Chemical Name - VOCs
Class GA
1,1-Dichloroethane
5
1,1-Dichloroethene
5
1,2-Dichloroethane
0.6
2-Butanone
50(G)
Acetone
50(G)
Benzene
1
Bromodichlorome thane
50(G)
Chlorobenzene
5
Chloroform
7
cis-l,2-Dichloroethene
5
Ethylbenzene
5
Isopropylbenzene
5
Methylene Chloride
5
Toluene
5
trans-l,2-Dichloroethene
5
Trichloroethene
5
Vinyl Chloride
2
Xylenes (total)
5
Notes
"—" - Indicated compound not analyzed for.
" * * - Blind Duplicate
"B" - Compound found in associated blank
"D" - Diluted Sample
"U" - Not Detected.
"L" - Acceptable value, biased low
"J" - Indicates the compound was detected but below the
reporting limit. The reported concentration is estimated.
"N" - Tentatively Identified
"G" - Guidance Value
Bold - Exceeds GW Class GA
- New York State Department of Environmental
Conservation, Technical and Operational Guidance
Series (TOGS) 1.1.1. Class GA Standards and Guidance
Values, Revised June 1998.
- Routine annual monitoring results for Thinner Wells (T-
13. T-15, T-21, T-24, T-26, T-29, T-33B) are not included
oh this figure.
0 100 200
1 i I Feet
SITE-WIDE SHALLOW
AREA HISTORIC
GROUNDWATER
SAMPLE RESULTS
VOCS
RACER TRUST
NYSDEC Site #7-34-057
Operable Unit 1
SYRACUSE, NEW YORK
FIGURE 04
O'BRIEN & GERE ENGINEERS, INC.
A RAMBOLL COMPANY
-------
11/9/1999 | 8/24/2011
4/9/2019
10/25/2006 | 4/11/2019
RESULTS
No Detections
7/30/2001 I 11/1/2006 | 8/3/2016 | 4/11/2019
RESULTS
4/10/2019 I 4/29/2021
10/30/2006
8/24/2011 | 8/1/2016 | 4/28/2021
10/24/2006 I 4/9/2019
[OBG-W6DR
,,2-Dichloroethene
RESULTS
PARAMETER
Acetone
cis-l,2-Dichloroethene
Trichloroethene
6/19/2000 I 10/27/2006 | 4/29/2021
RESULTS
| PARAMETER
-1,2-Dichloroethene
10/24/2006
No detections
Trichloroethei
1,1-Dichloroethei
3/20/1995
9/21/1995 I 12/6/1995 | 3/20/1996 | 6/12/1996 | 9/10/1996
3/17/1997
3/20/1995 | 6/12/1997 | 10/27/1997 | 4/28/1998
10/29/1998 | 4/21/1999 | 11/8/1999
10/27/2006 | 4/29/2021
11/3/1999 | 6/19/2000 | 10/26/2006 | 4/10/2019
11/9/1999 | 6/20/2000
RESULTS
7/8/1999
11/8/1999 I 6/20/2000 | 10/23/2006
RESULTS
10/23/2006
RESULTS
6/20/2000
11/1/2006
11/8/1999
10/25/2006
7/8/1999
RESULTS
[Ethyl ber
iropylbenzei
IXylenes (total)
k^*WT:3Rl
7/8/1999
7/19/1999
11/2/1999
RESULTS
7/30/2001
No Detections
4 MONITORING WELL
MONITORING WELL STATUS UNKNOWN OR
ABANDONED
Total CVOC*
Concentrations (ug/L)
o
I
o
>10-100
>100-1000
>1000
Total CVOCs- 1,1-DCA, 1,1-DCE,
cis-1,2-DCE (total), TCE, and VC
* - Color coding within data boxes
referes to individual constituents
OBG-19D - Based on last sampling result
|— LOCATION ID
1 RESULTS IN ug/L -
10/24/2006
PARAMETER
RESULTS
12
Benzene
1
cis -1,2-Di chloroethe ne
3700
trans-l,2-Dichloroethene
10
Trichloroethene
1600
Vinyl Chloride
1300
BOLD RESULTS _|
Chemical Name - VOCs
Class GA
1,1-Dichloroethane
5
1,1-Dichloroethene
5
1,2-Dichloroethane
0.6
2-Butanone
50(G)
Acetone
50(G)
Benzene
1
Bromodichlorome thane
50(G)
Chlorobenzene
5
Chloroform
7
cis-1,2-Dichloroethene
5
Ethylbenzene
5
Isopropylbenzene
5
Methylene Chloride
5
Toluene
5
trans-1,2-Dichloroethene
5
Trichloroethene
5
Vinyl Chloride
2
Xylenes (total)
5
Notes
"—" - Indicated compound not analyzed for.
" * * - Blind Duplicate
"B" - Compound found in associated blank
"D" - Diluted Sample
"U" - Not Detected.
"L" - Acceptable value, biased low
"J" - Indicates the compound was detected but below the
reporting limit. The reported concentration is estimated.
"N" - Tentatively Identified
"G" - Guidance Value
Bold - Exceeds GW Class GA
- New York State Department of Environmental
Conservation, Technical and Operational Guidance
Series (TOGS) 1.1.1. Class GA Standards and Guidance
Values, Revised June 1998.
- Routine annual monitoring results for Thinner Wells (T-
13. T-15, T-21, T-24, T-26, T-29, T-33B) are not included
oh this figure.
0 100 200
1 i I Feet
SITE-WIDE DEEP AREA
HISTORIC
GROUNDWATER
SAMPLE RESULTS
VOCS
RACER TRUST
NYSDEC Site #7-34-057
Operable Unit 1
SYRACUSE, NEW YORK
FIGURE 05
O'BRIEN & GERE ENGINEERS, INC.
A RAMBOLL COMPANY
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PROPOSED LOCATION OF WELLS TO BE VERIFIED AFTER THE PDI INVESTIGATION);
RECOVERED GROUNDWATER DISCHARGED TO EXISTING SPDES TREATMENT SYSTEM;
HOT SPOT EXCAVATION OF 38 CUBIC YARDS OF SURFACE SOIL (ASSUMES 1-FT OVER EXCAVATION)
BACKFILL WITH CLEAN MATERIAL AND RESTORE AS VEGETATION;
OFF-SITE DISPOSAL OF SPOILS;
DOWNGRADIENT PERIMETER GROUNDWATER MONITORING (6 WELLS EACH, SHALLOW AND DEEP);
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SSDS EVALUATION
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SSDS UPGRADE WITH SVE BASED ON SSDS EVALUATION
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MONITORING DATA
FIGURE 6
9
LEGEND
EXISTING MONITORING WELL
* PROPOSED MONITORING WELL
PROPOSED DEEP GROUNDWATER
RECOVERY WELL
DEEP GROUNDWATER DISCHARGE
PIPING
_ PROPOSED SHALLOW GROUNDWATER
RECOVERY TRENCH
¦ PROPOSED EXCAVATION AREA
APPROXIMATE LOCATION OF EXISTING
"THINNER TANK TRENCH
—'SSDS
APPROXIMATE LIMITS OF EXISTING
LANDFILL IRM
APPROXIMATE LIMITS OF EXISTING SOIL
STAGING AREA IRM
PROPERTY AREA LIMITS
RACER TRUST
GENERAL MOTORS -
INLAND FISHER GUIDE SUBSITE
SYRACUSE, NEW YORK
ALTERNATIVE 2
100 200
400
600
! Feet
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RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
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RECOVERED GROUNDWATER TREATMENT AT EXISTING SPDES TREATMENT SYSTEM;
HOT SPOT EXCAVATION OF 38 CUBIC YARDS OF SURFACE SOIL (ASSUMES 1-FT OVER EXCAVATION)
BACKFILL WITH CLEAN MATERIAL AND RESTORE AS VEGETATION;
OFF-SITE DISPOSAL OF SPOILS;
DOWNGRADIENT PERIMETER GROUNDWATER MONITORING (6 WELLS EACH, SHALLOW AND DEEP);
ON-SITE SHALLOW GROUNDWATER MONITORING (6 WELLS);
CONTINUED CONSENT ORDER MONITORING.
EXPANSION AND ENHANCEMENT OF THINNER AREA COLLECTION SYSTEM
SSDS EVALUATION
SOUTHEASTERN
PROPERTY
10-ft square from 0-ft bgs to 1 -ft bgs; 3.7 cy
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SSDS UPGRADE WITH SVE BASED ON SSDS EVALUATION
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GROUNDWATER MONITORING DATA
FIGURE?
9
LEGEND
EXISTING MONITORING WELL
* PROPOSED MONITORING WELL
PROPOSED DEEP GROUNDWATER
RECOVERY WELL
DEEP GROUNDWATER DISCHARGE
PIPING
¦ PROPOSED EXCAVATION AREA
APPROXIMATE LOCATION OF EXISTING
¦THINNER TANK TRENCH
SSDS
APPROXIMATE LIMITS OF EXISTING
LANDFILL IRM
APPROXIMATE LIMITS OF EXISTING SOIL
STAGING AREA IRM
PROPERTY AREA LIMITS
RACER TRUST
GENERAL MOTORS -
INLAND FISHER GUIDE SUBSITE
SYRACUSE, NEW YORK
ALTERNATIVE 3
100 200
400
600
! Feet
1940101904
MAY 2023
RAMBOLL AMERICAS
ENGINEERING SOLUTIONS, INC.
A RAMBOLL COMPANY
-------
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FIGURE 8
LEGEND
EXISTING MONITORING WELL
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bing^
Sen/ice Layer Crecljts:
-------
OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-b
PUBLIC NOTICE PUBLISHED IN THE
SYR A CUSE POST STANDARD
ON JULY 30, 2023
-------
Ad NumbenOM 0706053-01
— 1
Date
Position
Description
P.O. Number
Ad Size
07/30/2023 Other Legals NY NEW YORK STATE DEPARTMENT
OF ENVIRONMENTAL
1 x 112.00 CL
NEW YORK STATE DEPART-
MENT OF ENVIRONMENTAL
CONSERVATION INVITES PUBLIC
COMMENT ON A PROPOSED
PLAN FOR GENERAL MOTORS-
INLAND FISHER GUIDE OPERA-
BLE UNIT 1 SITE SUBSITE OF
ONONDAGA LAKE SUPERFUND
SITE The New York state De-
partment of Environmental
Conservation (NYSDEC) will
hold an open house from 5:00 -
6:00 p.m. and a public meeting
at 6:00 p.m. on August 16, 2023
at the Salina Town Hall, located
at 201 School Road, Liverpool,
to discuss the Proposed Plan
for the General Motors-inland
Fisher Guide Operable Unit 1
site, a subsite of the Onondaga
Lake Superfund site. The site is
located on Military Circle Drive
and Townline Road. The Pro-
posed Plan provides a summary
of the findings of the Remedial
investigation and Feasibility
Study (ri/fs) conducted to de-
termine the nature and extent
of the contamination at the
site, whether this contamina-
tion poses a threat to public
health and the environment,
and to identify and evaluate
cleanup alternatives. The Pro-
posed Plan also identifies
NYSDEC and the U.S. Environ-
mental Protection Agency's
(EPA's) preferred remedial al-
ternative to address the con-
tamination at the site and the
basis for this preference. The
preferred remedial alternative
includes in-place or in-situ
treatment of three residual
source areas, perimeter deep
groundwater extraction and
treatment, contaminated soil
excavation with off-site dispos-
al, enhancements of the exist-
ing sub-slab depressurization
system under the former manu-
facturing building, development
of a site management plan, im-
plementation of institutional
controls, and long-term opera-
tion, maintenance, and moni-
toring. NYSDEC and EPA are so-
liciting public comments on all
the remedial alternatives evalu-
ated, including the preferred al-
ternative. changes to the pre-
ferred alternative or selection
of a remedial alternative other
than the preferred alternative
may be made if public com-
ments or additional data indi-
cate that curh a rhanoo ra.
U VYIII I U
suit in a more appropriate clean
up action. The final decision re-
garding the selected plan will
be made after nysdec and EPA
have taken into consideration
all public comments. The Pro-
posed Plan, Rl report, and FS
report are available at the loca-
tions noted below, information
is also available on nysdec's
website at https://www.dec.ny.
gov/data/DecDocs/734057/ At-
lantic States Legal Foundation
658 West Onondaga Street Syr-
acuse, New York 13204 315
475 1170 NYSDEC 5786 Wide-
waters Parkway Syracuse, NY
13214-1867 (315) 426-7400
Please call for an appointment
NYSDEC, DER 625 Broadway,
12th Floor Albany, New York
12233 7013 518 402 9676
Please call for an appointment
Written comments received
during the public comment pe-
riod, which ends on August 27,
2023, as well as oral comments
received at the public meeting,
will be documented and ad-
dressed in the Responsiveness
Summary section of the Record
of Decision, the document
which formalizes the selection
of the cleanup. All written com-
ments should be addressed
to: Jacky Luo, Project Manager
NYS Department of Environ-
mental Conservation 625
Broadway, 12th Floor Albany,
NY 12233 7013 jacky.luo@dec.n
y.gov (Please indicate "General
Motors-inland Fish Guide Oper-
able Unit 1 Proposed Plan Com-
ments" in the subject line of
the e-mail)
-------
OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-c
AUGUST 16, 2023 PUBLIC MEETING TRANSCRIPT
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Page 1
STATE OF NEW YORK ONONDAGA COUNTY
In the Matter of:
PUBLIC COMMENT PERIOD AND PUBLIC MEETING ANNOUNCED
HEARING IN REGARDS TO THE
REMEDY PROPOSED FOR STATE SUPERFUND SITE
HELD AT: Salina Town Hall
201 School Road
Liverpool, New York 13088
Au gust 16, 2023
APPEARANCES:
JASON PELTON, P.G., Section Chief
New York State Division of Enviromental Remediation
6 2 5 B r o a dwa y
Albany, New York 12233-7013
JACKY LUO, Project Manager
New York State Division of Environmental Conservation
625 Broadway, 12th Floor
Albany, New York 12233-7013
MARK SERGOTT, P.G., Project Manager
New York State Department of Health
Empire State Plaza - Corning Tower, Room 1787
Albany, New York 12237
Cynthia M. Belmonte,
Court Reporter.
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Page 2
1 MR. PELTON: Great. I just wanted to say a
2 few quick words here, before we get started. I'm
3 Jason Pelton. I'm a section chief with the New
4 York State Department of Environmental
5 Conservation, out of Albany. Jacky Luo is to my
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Page 3
1 July 28th. That started a 30-day comment period.
2 So, right now we're about in the middle of that
3 comment period. It's going to end on August 27th.
4 At the conclusion of the comment period, we're
5 going to finalize the remedy for the GM-IFG site,
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Page 4
1 conditions; the site contaminations; the soil type;
2 the ground water contaminants. All those, kind of,
3 get factored into us evaluating what options would
4 work best for this site and this site's
5 characteristics. With that, I will let Jacky get
6 into, you know, some background on the history.
7 He's got an outline here that he'll walk through
8 and he'll talk about. He will present our
9 preferred plan for the site. Thank you. Good
10 evening and thank you for coming. My name is
11 Jacky. And I am the New York State Department of
12 Environmental Conservation Project Manager for the
13 GM-IFG Site. I'm just going to go through a little
14 bit of the site background, the clean up options
15 that we evaluated, the preferred remedy. And then
16 New York State DOH is going to, kind of, talk a
17 little bit. And, finally, the next steps. Please
18 hold off questions until the end of the
19 presentation. So, a little bit of the background.
20 The GM-IFG is a subsite of the Onondaga Lake. As
21 you can see over here, on to the left, you can see
22 is Onondaga Lake. The National Priorities List is,
23 basically, the Nation's higher profile sites across
24 the United States. As you can see over here, we
25 have the OU1 and the New York State Thruway. The
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Page 5
1 sites has two operable units. An operable unit is
2 how a site is split up based on the types of
3 contaminates or the media — contaminated media.
4 For example, 0U1 are address as groundwater. And
5 then 0U2 addresses off site sediments and
6 floodplain soils. Outlined in the blue here is 0U1
7 and then outlined in red is 0U2. A remedy has
8 already been selected for 0U2 and it's under EPA
9 lead. For the focus of this proposed plan is 0U1.
10 As we take a zoomed in look of this figure, you see
11 that 1-90 is right over there; we have Ley Creek,
12 which flows east to west just right over there; the
13 site is located on Factory Avenue, Townline Road
14 and Military Circle. The site is, approximately, 65
15 acres. And there's a 800 square foot former
16 manufacturing company located in the middle. We
17 talked about groundwater at the site. So, just
18 that everyone is aware, groundwater flows north
19 toward Ley Creek. Groundwater from the site is not
20 used and the site and surrounding areas are served
21 by municipal drinking water. So, GM — or General
22 Motors operated the facility from the early 1950's
23 to 1990's. They manufactured metal and plastic
24 automotive trims such as bumpers, grills, wheel
25 disks and hubcaps. And then in the late 90's,
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Legal Services
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Page 6
1 there was a facility cleanup program where we, kind
2 of, cleaned up and decontaminated the interior of
3 the former manufacturing building. And then in
4 2009, General Motors filed for bankruptcy. And
5 shortly after Revitalizing Auto Communities
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Page 7
1 the underlying geology, going from the left to
2 right you can see the manufacturing building. And
3 on the right is Factory Avenue. This slide just
4 shows that there are two groundwater intervals such
5 as shallow and deep. Shallow is groundwater is
6 found at the 10 to 15 feet deep and deep
7 groundwater is found at 30 to 40 feet deep. In
8 between there is also a clay/silt layer that
9 separates these two layers. So, this figure shows
10 a summary of the larger interim remedial measures
11 that were done on the site. IRM is remedial
12 activities completed to prevent immediate human
13 health and environmental exposure. As you can see
14 in the green or number 1, that's the former thinner
15 tank area groundwater recovery system. This is
16 where non-ch1orinated VOCs is pumped and treated at
17 the number 2. That's the water treatment plant.
18 The treatment plant was built as part of the SPDES
19 treatment system IRM to address groundwater and
20 storm water across the site. And then number 3 we
21 have the retention basin. The retention basin was
22 built after the former drainage swale I RM. It's,
23 basically, where a bunch of contaminated PCBs was
24 excavated and put at a disposal offsite or put onto
25 the landfill at #4. Number 4 is the former
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Page 8
1 landfill IRM where PCBs were placed and capped on
2 site with a low permeability cover. And at number
3 5 we have the Vapor Intrusion Mitigation IRM. The
4 redline shows the sub-slab depressurization system
5 that was install to address soil vapors beneath the
6 building. This is to prevent volatile contaminants
7 from entering the building. And then number 6 we
8 have decommissioning activities. So, these
9 included dismantling old process systems within the
10 building and cleaning and coating of the floors
11 within the building. And number 7 we have
12 redevelopment IRM where we removed a former
13 industrial water treatment plant in the back, as
14 well as placement of pavement across the site. So,
15 the big take home message from this slide is that
16 there is a lot of contamination that has been
17 addressed as part of our IRMs. And now were just
18 addressing the remaining contamination at the site,
19 which is in the groundwater. Here is a list of the
20 remedial action objectives. I'm not going to read
21 through them. But the main purpose is to prevent
22 unacceptable human exposure and ecological impacts
23 and prevent the migration of contaminants. In
24 evaluating potential cleanup alternatives, we used
25 the following nine criterias: The first two
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Page 9
1 criterias are known as threshold criteria and must
2 be satisfied in order for an alternative to be
3 considered for selection at the site. The rest of
4 the seven criterias are considered balancing
5 criteria and modifying criteria are used to compare
6 the positive and negative aspects of each of the
7 remedial strategies. Basically, we weigh the pros
8 and cons of these different criteria with each of
9 the alternatives. So, these are the five
10 alternatives that were considered to address the
11 contamination at the site, based off of the
12 remedial action objectives and a review of
13 applicable technologies as well as their associated
14 costs. The alternative range from alternative 1,
15 no further action, which we are required to
16 evaluate as a baseline or basis for comparison to
17 other potential alternatives to alternative 5,
18 which is more of a full removal back to predisposal
19 conditions. And then in between are alternatives
20 that use a variety of different technologies, such
21 as groundwater extraction and treatment and in-situ
22 treatment. Based on the nine evaluation criterias,
23 we are proposing alternative 4. So, here's the
24 preferred alternative number 4. We're going to
25 have in-situ treatment of three residual source
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Page 10
1 areas. As you can see 1, 2, and 3. In-situ
2 treatment or in-place treatment involves injecting
3 an amendment to promote contaminant degradation.
4 This alternative would utilize horizontal drilling
5 to target materials beneath, at number 2, the
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Page 11
1 Enviromental Exposure Investigation. I work with
2 Jacky and the Department of Conservation on this
3 particular site. Tonight, I just have a couple of
4 quick slides to go over. It's just to, kind of, go
5 over the role of the New York Health Department on
6 sites, like we're discussing here tonight. And
7 then I will also go over some exposure related
8 information that's applicable to this site that
9 we're discussing here tonight. So, the State
10 Health Department, we're involved with the review
11 and the approval of the various investigative and
12 remedial work plans that are associated with any of
13 the environmentally contaminated sites that are
14 located throughout New York State. We've work
15 intimately with the New York State Department of
16 Enviromental Conservation on identifying the nature
17 and extent of contamination at the site. And,
18 basically, at that point, evaluating potential
19 exposures to the enviromental contaminates that
20 area associated with these sites. And, really,
21 from the State Health Department's standpoint it's
22 our focus is to really determine whether or not —
23 how the public can get in to contact with
24 enviromental contaminates that are associated with
25 these sites. From the day that it's generated, we
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1 make various recommendations and various actions
2 that we feel should be taken in the event that we
3 feel that there are unnecessary exposures occurring
4 because of enviromental contaminants. Ultimately,
5 we want to ensure that any remedy that's selected
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1 that's associated with the site. Now, it's
2 important to note that one or more of these
3 physical contacts must occur before a chemical has
4 the potential to cause a health problem. And
5 equally important to note is that just because
6 there's a particular exposure doesn't necessarily
7 mean that there's going to be an associated
8 negative health effect. And this last slide is
9 really — now, that we've gone over the potential
10 exposure pathways, I just, kind of, want to tie
11 these in now and discuss how the components of the
12 remedy are, more or less, going to be addressing
13 these exposure scenarios. Quite honestly, right
14 now there's really minimal opportunities to
15 encounter site contaminates in — at the site and
16 in its present condition. Reason being is that a
17 lot of the contamination right now is currently at
18 depth or it's largely covered by the building slab
19 and largely by the miles of paved surfaces out
20 there at this lake. So, there are limited
21 opportunities to encounter a lot of the residual
22 contamination that's still in place. In terms of
23 the inhalation exposure pathway, as Jacky
24 mentioned, there are two operating sub-slab
25 depressurization systems that are currently in
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1 place that are operating to minimize solvent —
2 (Inaudible) — from occurring. The operations of
3 these particular systems, along with future
4 maintenance, along with some timeframe of periodic
5 indoor air monitoring program likely will occur.
6 That will all be in accordance with the site
7 management plan, as Jacky mentioned, moving
8 forward, which the site will be following. In
9 terms of the potential of inhaling contaminants
10 largely associated with the outside sub-surface
11 excavation. When those are occurring, then the
12 exteriorities of the site, we will be conducting
13 what's known as a community air monitoring plan,
14 which will be in place during the remediation to,
15 basically, to ensure that the work is not
16 negatively effecting the surrounding air quality of
17 the surrounding area. Direct contact, there's
18 really limited opportunities for the public right
19 now to be in contact with contaminants at the site.
20 In terms of direct contact with the materials.
21 This is, more or less, mostly a concern for the
22 contractors and the various workers on site that
23 will be conducting the remediation. That being
24 said, there will still be strict security measures
25 in place during the remediation to ensure that the
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1 public does not have access to these particular
2 remediation areas when the work is occurring.
3 Following the excavation, a site cover system will
4 be constructed in the excavated areas to prevent
5 contact with any residual contamination that
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1 are developed on the property. And that's really
2 all I have, folks. At this point, I'll hand it
3 back over to Jacky to wrap up tonight's
4 presentation and open it up to any questions that
5 people may have. Thank you very much.
6 MR. LUO: So, like Jason said, for the next
7 step, we have a public commentary that ends on
8 August 27th. You can email me, write me questions
9 here, mail me questions, or even give me a call, if
10 you have any questions. All those questions and
11 comments will be incorporated as part of our rod,
12 which will be issued, hopefully, shortly after in
13 September. And then shortly after that, we will
14 begin remedial design as of late 2023. And after
15 that remedial construction will begin. Thank you.
16 If you have guys have any questions, please feel
17 free just state your name and ask the question.
18 AUDIENCE MEMBER: Hi, I'm Robert. I'm here
19 representing Syracuse, as the manager of this
20 property. There are a few questions that come to
21 mind. But a few comments to share before the
22 questions. On an opening slide, Jacky, you're
23 indicated that the property is 65 acres. That is
24 just part of the Town of Salina. The total is 78
25 acres. There are three partials that are pavement
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1 for the park and are in the Town of DeWitt. I
2 would like to share and point out that in the three
3 years that we've been operating in the building,
4 we've had an upwards of 500 to 525 people working
5 in the building every single day. I'm not aware of
6 anyone ever reporting any sort of illness or reason
7 to not come to work due to air, the water or soil.
8 I am a little concerned hearing from Mr. Sergott's
9 presentation where there will be the excavation
10 work that's pointed out in figure eight. The
11 people will not have access. How will that impact
12 the companies that are doing business here during
13 that timeframe?
14 MR. LUO: We can reroute or we can excavate
15 at a time where there's minimal, I guess, traffic
16 ongoing. Because there are times that you guys
17 don't — I'm pretty sure — I'm not sure of the
18 operations of the people at the facility. But if
19 we can try to accommodate you guys and work around
20 you guys, where we would try to do the excavation
21 work during a time period and where there won't be
22 a lot of people on the site.
23 AUDIENCE MEMBER: I think that this is a
24 perfect timeframe to communicate that as the owner
25 of the property that we will have a seat at the
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1 table and have more than an hour's notice before
2 someone appears on site to start working. We would
3 like to have some notifications as to who is going
4 to do the work? Who is going to do the predesign?
5 Is it the folks that we are familiar with the
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1 of the work. And then during that time, you can
2 raise an issue for your tenants or discuss with us
3 if you have any issues.
4 AUDIENCE MEMBER: Great. Thank you. I do
5 have a specific question from the — (inaudible) —
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1 alternative, we're only going for three or four
2 spots that have contaminants that we want to
3 address at the surface level.
4 AUDIENCE MEMBER: So, of those three spots,
5 the one that just — (Inaudible) — is of less
6 concern because there's nothing there?
7 MR. LUO: Yes.
8 AUDIENCE MEMBER: Is there a spot somewhere
9 around the pond?
10 MR. LUO: Yes, a little bit up north over
11 there, to the left.
12 AUDIENCE MEMBER: Just outside of the
13 property usage?
14 MR. LUO: Yes.
15 AUDIENCE MEMBER: It's not a concern. But
16 the one on the west side, is an area for active
17 driving for incoming and outgoing product. And I
18 understand tonight is not the night to drill you
19 for details. But if you're going to be taking out
20 concrete of that driveway, I would like to know
21 that the concrete will be restored.
22 MR. LUO: Yes, that is the intent. If there
23 is anything — if there is anything, if we're going
24 to remove pavement, it will be restored. That's
25 part of our back filing, basically.
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1 AUDIENCE MEMBER: And that's one areas of
2 concern. We have tenants that have to be able to
3 pass through.
4 MR. PELTON: We met earlier today at your
5 property. (Inaudible) — design and action
6 standpoint. And that's a big step in our
7 recommendation. (Inaudible). We're going to
8 excavate that soil and put it back to the right
9 conditions. We're not just going to show up with a
10 backhoe on a trailer and start working. We will
11 give you notice. Absolutely. And we will put it
12 back to its current condition and make sure there's
13 nothing exposed. (Inaudible) .
14 AUDIENCE MEMBER: I think you can appreciate
15 where I'm coming from.
16 MR. PELTON: Absolutely.
17 AUDIENCE MEMBER: I have a lot to learn, as
18 well.
19 MR. PELTON: It's just a couple of days of
20 work. It's not, like, we were going to open up ten
21 thousands cubic yards and it's going to be open
22 for the use of your tenants for weeks.
23 AUDIENCE MEMBER: You've been working on
24 this for months, years. And I have a lot to learn.
25 I appreciate the opportunity to meet with you and
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1 to have a tour with you. But, hopefully, we can
2 keep the lines of communication open for when
3 questions arise.
4 MR. PELTON: Of course.
5 MR. SERGOTT: Agreed. I agree with what
6 Jason said. Our next phase of work will impact how
7 much soil we will remove, with the lawn. I don't
8 know if you've had a bad experience. You said you
9 were given one hour's notice. I don't know if
10 there was a miscommunication with you. But we
11 strive to better keep you informed.
12 AUDIENCE MEMBER: As I do to you. If I
13 receive something from you folks, I will do my
14 best. I really appreciate that and anything else
15 that I might or could ask, I think we should put in
16 writing during the next week or so. The last thing
17 I would like to share with you all, as an owner who
18 lives in this community, I'm committed to being in
19 the best — (Inaudible) — of property. We look
20 forward to being as cooperative as we can. And not
21 a thorn in your side. Thank you for the
22 opportunity.
23 MR. LUO: Any other questions or comments?
24 (Whereupon, there were no further
25 comments or questions.)
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1
MR .
LUO: No? All right. Okay. Thank you.
2
That will
conclude the meeting.
3
MR .
PELTON: Thank you everyone for coming
4
out tonight
•
5
(Whereupon, the Hearing was concluded.)
6
-X
-X
-X
-X
-X
7
Q
0
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1
2
3 CERTI FICATE
4
5 STATE OF NEW YORK )
6 : SS . :
7 COUNTY OF ONEIDA )
8
9 CERTI FICATE
10
11 I, Cynthia Belmonte, a Notary Publi c
12 and Court Reporter, in and for the County of
13 Oneida, State of New York, do hereby certify
14 that the foregoing is a true and
15 of the above-entitled matter.
16
17 Date: September 9 , 2 0 2 3
18
19 Cynthi a Belmonte
2 0 Court Reporter
21
22
23
24
25
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OPERABLE UNIT 1 OF THE GENERAL MOTORS - INLAND FISHER GUIDE
SUBSITE OF THE ONONDAGA LAKE SUPERFUND SITE
RECORD OF DECISION
APPENDIX V-d
WRITTEN COMMENTS RECEIVED DURING THE COMMENT PERIOD
-------
RAV
PR
pn
PROPERTIES
PO Box 247
Jamesville, NY 13078
August 25, 2023
Jacky Luo
New York State Department of
Environmental Conservation
RAVproperties.com
315.403.9000
625 Broadway, 12th Floor
Albany, New York 12233-7013
RE: General Motors - Inland Fisher Guide Site (Site Code: 734057)
Proposed Remedial Action Plan for OU-1
Dear Jacky:
Please accept this letter as SIP Syracuse, LLC's ("SIP Syracuse") formal written comments
on the Proposed Remedial Action Plan for OU-1. As you know, SIP Syracuse is the owner of the
Salina Industrial PowerPark, which it purchased from RACER in August, 2020. These written
comments are being offered in addition to those that I made at the public meeting held on August
16, 2023.
First and foremost, as I discussed at the public meeting, what is of paramount importance
to SIP Syracuse is that there be a clear line of open communications between DEC, EPA, RACER
and SIP Syracuse regarding the plans for remediation of OU-1. This is to ensure that, among other
things, any remedial work is coordinated with us as the property owner, and to ensure there are no
surprises that could adversely impact operations of the property or that could complicate SIP Sy-
racuse's relationship with its tenants. As you know, SIP Syracuse has made a tremendous invest-
ment of capital and time to ensure the continued success of the Salina Industrial PowerPark and
has been an exemplary cooperative owner and steward of the property. In fact, earlier this month
we were honored with the 2023 RACER's Edge Award in recognition of our investment and stew-
ardship of the Salina Industrial PowerPark. Yet, in the PRAP, SIP Syracuse, LLC, or simply "the
Owner," is not identified, nor are we mentioned on page 20 of the PRAP as a party to be coordi-
nated with during implementation of the remedy.
While we look forward to the continued remediation of the property, we ask that we be
provided with the courtesy of open communications, including advanced pre-publication access to
proposed remediation documents to allow for our meaningful review and comment before they are
issued publicly. That way we can provide relevant input regarding potential impacts to the prop-
erty and/or speak with our tenants, if necessary, before they learn of something that may cause
concern. As I explained, this did not happen with the PRAP. Despite assurances that we would be
provided with an advanced copy, we only received it about an hour before it was released for
public comment. We hope and expect that can be avoided in the future.
With that said, we offer the following comments and questions on the PRAP for consider-
ation and response by DEC and EPA.
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1. Soil Excavation
In our review of the PRAP, it is ambiguous as to the full extent of the soils to be excavated
as part of the Preferred Alternative. The discussion of excavation associated with Alternative 4
mentions "approximately 38 CY of unsaturated soil would be excavated" on page 22 of the PRAP,
but earlier on page 8 of PRAP it mentions "1500 CY of material is to be removed." While certain
clarification was offered at the public meeting, we would prefer written confirmation of this im-
portant issue. Please clarify and confirm the total volume of excavation associated with the Pre-
ferred Alternative.
Also, please clarify how excavated soils will be handled. Please explain how the excava-
tion process is intended to occur and whether excavated soils will be stockpiled on-site or hauled
directly to an authorized disposal site. If the soils are proposed to be stockpiled on-site prior to
disposal, please clarify where the soils are proposed to be stockpiled and for how long. It is im-
portant to operations of the site that soils not be stockpiled in any area that could interfere with
tenant and visitor use of the property. If the soils are to be stockpiled, please also advise as to the
procedures and protections to be implemented to avoid exposure to persons and the environment
and what measures will be put into place to avoid issues relating to stormwater runoff, for example.
Any excavation should be done at a time to minimize impacts to tenants, visitors and overall use
of the property.
2. Horizontal Wells/Directional Drilling
While the Preferred Alternative discusses the installation of horizontal wells and need for
directional drilling, there are few details offered. We understand that certain details will be devel-
oped during the Remedial Design phase, but in order to fully understand the potential impacts we
ask that additional details be provided to the extent they are available at this time. For example,
the PRAP contains no details regarding the proposed locations and methods for well development
and directional drilling. Please provide at least possible locations for review and anticipated/con-
ceptual methods for directional drilling and well development.
With any horizontal well development or directional drilling occurring near, at or under
the building, potential impacts to the building structure, foundational components, underground
utilities and other subsurface features are a concern. Please provide information regarding the
steps that will be taken to ensure that there will be no adverse impacts to the building, foundation,
utilities or subsurface as a result. We would request that a geotechnical investigation be performed
during the RD phase to avoid any potential issues.
3. "Potential Adverse Impacts"
Page 19 of the PRAP contains a discussion regarding "potential adverse impacts" associ-
ated with the Preferred Alternative. Please elaborate on this discussion so that we can understand
the full scope of "potential adverse impacts" to the property, tenants, and other visitors to the
property and what steps will be taken to specifically mitigate these potential impacts. Along these
lines, we want to be sure that any property damage that may occur during the course of the imple-
mentation of the remedy will be satisfactorily repaired and restored at no cost to SIP Syracuse.
Please confirm.
4. Collection and Treatment of Contaminated Groundwater
-------
The PRAP contains a general discussion regarding how the Preferred Alternative will in-
volve the collection and treatment of contaminated groundwater, but there are few details provided.
There is a discussion in the PRAP regarding how contaminated groundwater will be collected and
treated at the existing SPDES water treatment system (PRAP, p. 22). Please provide details on
how the existing pond system will be designed and modified to accommodate this additional need
for capacity associated with the collection of contaminated groundwater. Currently, it is question-
able that the existing SPDES pond system has sufficient capacity now to accommodate storm-
water. In fact, it has been increasingly observed during times of heavy rainfall that the stormwater
ponds have nearly overflowed, causing backups in the piping which, in turn, causes flooding
concerns that could be exacerbated as part of the proposed remedy. Please explain what will be
done to address our current concerns, and potential future issues during implementation of the
remedy.
5. Environmental Easement
Please clarify whether the existing Environmental Easement is proposed to be modified.
Please provide information as to anticipated changes and how it may impact use/operations (i.e.,
tenant restrictions or notifications) of the property.
We reserve our right to submit additional comments on the Environmental Easement when
it is available in draft form.
6. Site Management Plan
Please provide additional information regarding anticipated contents of the SMP including
how it may impact use/operations of the property.
We reserve our right to submit additional comments on the SMP when it is available in
draft form.
7. Remedy Design and Implementation
Please clarify the next anticipated personnel, contractors, steps and timeframes associated
with design of the remedy and implementation of the remedy. Please also clarify when DEC and
EPA anticipate sharing additional documents related to design and implementation of the remedy
for our review and comment.
Thank you for having hosted the August 16th public comments meeting, and for the oppor-
tunity to submit these comments and questions regarding the PRAP. Please include this comment
letter as part of the record of DEC and EPA's consideration of the PRAP and remedial alternative
selection. We look forward to receiving DEC and EPA's responses.
If you have any questions, please do not hesitate to contact me.
Sincerely,
Robert Lieberman
Managing Member
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