RECORD OF DECISION
Meeker Avenue Plume Superfund Site
Brooklyn, Kings County, New York
pro^^
United States Environmental Protection Agency
Region 2
New York, New York
September 2024
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Meeker Avenue Plume Superfund Site
Kings County, New York.
EPA Superfund Site Identification Number: NYN000203407
Operable Unit: 02
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental Protection Agency's (EPA's)
selection of an interim remedy for Operable Unit 2 (OU2) of the Meeker Avenue Plume Superfund
Site (Site), in Kings County, New York, which was 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 (NCP), 40 CFR Part 300. This decision document explains the factual
and legal basis for selecting the OU2 remedy. The attached index (see Appendix III) identifies the
items that comprise the Administrative Record for this action, upon which the selected remedy is
based.
The New York State Department of Environmental Conservation (NYSDEC) was consulted on
the selected remedy in accordance with CERCLA Section 121(f), 42 U.S.C. § 9621(f), and concurs
with the selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances at or from the Site, 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 remedial action described in this document addresses a portion of the Site involving
subsurface vapor intrusion at residential and non-residential structures at the Site. This operable
unit is the second of two operable units for the Site. A broad, comprehensive remedial investigation
and feasibility study (RI/FS) for the Site is currently ongoing, which is referred to as Operable
Unit 1 (OU1). The RI/FS includes the investigation of all media at the Site, including soil, soil gas,
groundwater, surface water, sediment, and air.
This selected remedy is an interim action to address vapor intrusion at residential and non-
residential structures at the Site. It is an interim action rather than a final action because it addresses
risks associated with subsurface vapor intrusion from contaminated groundwater but does not
address contaminated groundwater itself. This selected remedy is intended to encompass all
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residential and non-residential structures within the OU1 study area where EPA has determined or
may determine in the future that remedial action is required to address Site-related vapor intrusion
(see Figure 1).
The major components of the selected remedy include the following:
Vapor intrusion mitigation at residential and non-residential structures where multiple lines
of evidence indicate that subsurface vapor intrusion is occurring, or has potential to occur,
at concentrations that represent a threat, or potential threat, to human health. The vapor
mitigation strategy to be used has the following key components, some or all of which may
be used at any particular property:
o Installation of a sub-slab depressurization system.
o Preventative engineering measures such as the sealing of cracks and gaps in the
lowest level of a structure and installing a concrete slab or comparable membrane
system in instances where only a dirt floor is present.
The operation and maintenance of the vapor mitigation measures for one year, after which
responsibility for operation and maintenance will be turned over to NYSDEC.
The estimated present-worth cost of the selected remedy is $1,145,200.
The environmental benefits of the selected remedy may be improved by consideration, during
remedy design or implementation, of technologies and practices that are sustainable in accordance
with EPA Region 2's Clean and Green Energy Policy.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set forth in CERCLA Section
121, 42 U.S.C. § 9621, because it meets the following requirements: 1) it is protective of human
health and the environment; 2) it complies with federal and state requirements that are applicable
or relevant and appropriate to the limited scope of the interim action; 3) it is cost-effective; and
4) it utilizes alternative treatment or resource recovery technologies to the maximum extent
practicable. The selected remedy is an interim action only and is not intended to be a permanent
solution.
The selected remedy does not satisfy the statutory preference for treatment as a principal element
of the remedy. Vapor intrusion mitigation does not treat the subsurface vapors, rather it serves to
prevent contaminated soil vapors from entering and/or accumulating in structures at
concentrations that represent a threat, or a potential threat, to human health. It is neither
practicable nor cost-effective to treat the small mass of contaminants in the vapors. The ongoing
RI/FS for OU1 will evaluate options for addressing contaminated groundwater, which is the
principal source of the vapors.
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A review of the remedial action pursuant to CERCLA Section 121(c), 42 U.S.C. §9621(c), will be
conducted within five years after the commencement of the remedial action to ensure that the
remedy continues to provide adequate protection to human health and the environment because
this remedy will result in hazardous substances remaining on-Site above health-based levels that
allow for unlimited use and unrestricted exposure.
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 Site.
• Contaminants of concern and their respective concentrations may be found in the
"Summary of Site Characterization" section;
• Current and reasonably anticipated future land use assumptions and current and potential
future beneficial uses of groundwater used in the expedited human health evaluation and
ROD are discussed in the "Current and Potential Future Land and Resource Uses" section;
• Baseline risk represented by the contaminants of concern may be found in the "Summary
of Site Risks" section;
• Cleanup levels established for contaminants of concern and the basis for these levels may
be found in the "Remedial Action Objectives" section;
• Estimated capital, annual operation and maintenance (O&M), and total present-worth costs
are discussed in the "Description of Remedial Alternatives" section;
• A discussion of principal threat waste may be found in the "Principal Threat Waste"
section;
• 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) may be found in the "Comparative Analysis of Alternatives"
and "Statutory Determinations" sections.
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AUTHORIZING SIGNATURE
Evangelista,
Pat Date: 2024.09.27 September 27, 2024
' 09:12:06 -04'00'
Pat Evangelista, Director Date
Superfund and Emergency Management Division
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RECORD OF DECISION
DECISION SUMMARY
Meeker Avenue Plume Superfund Site
Kings County, New York
United States Environmental Protection Agency
Region 2
New York, New York
September 2024
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TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 2
SCOPE AND ROLE OF RESPONSE ACTION (OU2) 2
SUMMARY OF SITE CHARACTERISTICS 3
Overview 3
Geology and Hydrogeology 3
Results of the Remedial Investigation (Vapor Intrusion) 5
Results of the Remedial Investigation (Groundwater) 5
CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES 6
Land Uses 6
Groundwater and Surface Water Use 6
Environmental Justice 6
Climate Change 6
SUMMARY OF SITE RISKS 7
Human Health Risk Assessment 7
Expedited Human Health Risk Evaluation Uncertainties 11
Basis for Action 12
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REMEDIAL ACTION OBJECTIVES 12
Remediation Goals 13
SUMMARY OF REMEDIAL ALTERNATIVES 14
Alternative 1 - No Action 15
Alternative 2 - Vapor Intrusion Mitigation 15
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 16
PRINCIPAL THREAT WASTE 19
SELECTED REMEDY 20
STATUTORY DETERMINATIONS 22
DOCUMENTATION OF SIGNIFICANT CHANGES 23
LIST OF APPENDICES
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
Attachment A Written Comments Submitted During Public Comment Period
Attachment B Proposed Plan
Attachment C Public Notice
Attachment D Public Meeting Transcript
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SITE NAME, LOCATION AND DESCRIPTION
The Site is located in Brooklyn, Kings County, New York and as currently identified spans
approximately 191 acres across several city blocks in the Greenpoint and East Williamsburg area
of Brooklyn. The Brooklyn-Queens Expressway (BQE) roughly bisects the Site in a west-
southwest to east-northeast direction. Newtown Creek also forms a portion of the Site's boundary
roughly in the north-northwest direction. The Site includes a mixture of residential, commercial,
and industrial uses. These land use designations are not anticipated to change in the future. The
total population within the Greenpoint and Williamsburg neighborhoods of Brooklyn where the
Site is located is approximately 160,000 people. Figure 1 shows the Site and the current Study
Area boundary. EPA has divided the Site into separate phases, or operable units (OUs), for
remediation purposes:
Operable Unit 1: Includes the Remedial Investigation/Feasibility Study (RI/FS) of the
entire Study Area. A comprehensive RI/FS for OU1 was initiated in 2023 and is ongoing.
The RI/FS includes the investigation of all media at the Site including soil, soil gas,
groundwater, surface water, sediment and air.
Operable Unit 2: Addresses unacceptable risks in indoor air at residential and non-
residential structures resulting from Site-related contamination.
The Study Area boundary is preliminary and is defined as the area where the OU1 RI/FS activities
are currently focused; the boundary will be refined as the OU1 RI/FS continues and more data are
obtained. The ongoing performance of vapor intrusion sampling to identify additional properties
where the potential for vapor intrusion of Site-related contamination poses unacceptable risks will
continue as part of OU1. EPA's goal is to conduct vapor intrusion sampling at as many properties
as possible at the Site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Site is located in a region of historic petroleum refining and storage operations that have
occupied a significant portion of the Greenpoint area since approximately 1866. Currently, bulk
oil storage terminals exist north of the Site and include the former British Petroleum Terminal
(now Kinder Morgan) and the ExxonMobil Brooklyn Terminal. The former Paragon Oil facility
was located along the northeastern portion of the Site along Newtown Creek, north of Bridgewater
Street, between Meeker Avenue and Apollo Street. The contamination associated with the Site was
discovered by the New York State Department of Environmental Conservation (NYSDEC) during
investigation and remediation of an adjacent and overlapping petroleum groundwater
contamination area, which had resulted from historical petroleum refining and storage operations
along the banks of Newtown Creek. During several rounds of investigation, chlorinated volatile
organic compounds (CVOCs), including but not limited to trichlorethylene (TCE) and
tetrachlorethylene (PCE), were found in subsurface soil gas, soil, and groundwater outside the
petroleum spill area. Upon discovery of the CVOC contamination, NYSDEC initiated
investigations in the area to determine the extent and sources of CVOC contamination, as well as
the potential impacts of this contamination on the community.
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Since 2007, NYSDEC, in conjunction with the New York State Department of Health (NYSDOH),
has conducted multiple investigations related to the Site. These investigations have consisted of
soil, groundwater, soil gas, and soil vapor intrusion sampling. NYSDEC completed nine separate
Site characterization investigations between 2007 and 2016 and ten soil vapor intrusion
investigations between 2007 and 2023. In total, NYSDEC sampled more than 166 properties and
installed sub-slab depressurization systems at approximately 26 structures to address vapor
intrusion throughout the course of their investigations.
On March 17, 2022, the Site was added to EPA's National Priorities List pursuant to CERCLA.
As mentioned above, EPA is currently conducting the OU1 RI/FS for the Site.
Enforcement-related activities have been initiated at the Site, and EPA is in the process of
conducting a search for potentially responsible parties at the Site.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
EPA released the Focused Feasibility Study (FFS) report and the Proposed Plan for the OU2
remedy to the public for comment on April 5, 2024. EPA made these documents available
electronically to the public in the administrative record file for this action at the EPA Superfund
Records Room in Region 2, New York, the information repository at the Greenpoint Library, and
online at: https://www.epa.eov/siiperfimd/meeker-avenue-pliime. The notice of availability for
these documents was published in the Brooklyn Daily Eagle, on the Nowy Dziennik website, and
via the Greenpointers newsletter on April 5, 2024, and in Abecadlo on April 12, 2024. The initial
30-day public comment period on these documents was scheduled from April 5, 2024 to May 10,
2024 and was extended to June 25, 2024 at the request of various community groups. The notice
of extension was published via the Greenpointers newsletter on April 12, 2024 in the Brooklyn
Daily Eagle and in Abecadlo on April 19, 2024, and in Nowy Dziennik on April 20, 2024.
On April 16, 2024, EPA conducted a public meeting at St. Stanislaus Kostka Church, Brooklyn,
New York, to inform local officials and members of the public about the Superfund process,
present the findings of the RI/FS thus far and EPA's Proposed Plan to the community, review
current and planned remedial activities at the Site, and respond to questions from area residents
and other attendees. EPA responses to the comments received at the public meeting and in writing
during the public comment period are included in the Responsiveness Summary (see Appendix
V).
SCOPE AND ROLE OF RESPONSE ACTION (OU2)
Section 300.5 of the NCP, 40 CFR Section 300.5, defines an OU as a discrete action that comprises
an incremental step toward comprehensively addressing a site's contamination. A discrete portion
of a remedial response eliminates or mitigates a release, a threat of release, or pathway of exposure.
The cleanup of a site can be divided into a number of OUs, depending on the complexity of the
problems associated with the site. As noted above, EPA has designated two OUs for the Meeker
Avenue Plume Superfund Site.
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As described above, OU1 currently is broader and more comprehensive than the more focused
OU2. A comprehensive RI/FS for OU1 was initiated in 2023 and is ongoing. That RI/FS includes
the investigation of all media at the Site, including soil, soil gas, groundwater, surface water,
sediment, and air. This ROD identifies an interim remedy for OU2, which is to address
unacceptable risks in indoor air resulting from Site-related contamination. EPA uses interim
actions to address areas or contaminated media that ultimately may be included in the final ROD
for a site. Interim actions include measures to treat contamination in an operable unit and/or
prevent migration of contaminants or further environmental degradation until such time as a final
remedial decision is issued. The RI/FS for OU1 is still in its early stages. As such, the OU2 remedy
is considered interim while EPA's overall conceptual site model of the Site is being developed.
The selected remedy for OU2 will be reviewed on an ongoing basis to determine if any changes
are needed. The ongoing performance of vapor intrusion sampling to identify additional properties
where the potential for subsurface vapor intrusion of Site-related contamination poses
unacceptable risks will continue as part of OU1 of the Site. EPA's goal is to conduct vapor
intrusion sampling at as many properties as possible at the Site. A final action for OU1 will be
developed at the conclusion of the RI/FS.
SUMMARY OF SITE CHARACTERISTICS
Overview
As mentioned previously, since 2007, NYSDEC, in conjunction with NYSDOH, has conducted
multiple investigations related to the Site consisting of soil, groundwater, soil gas, indoor air, and
ambient air sampling. While CVOC contamination has been detected in the subsurface and
indoor air of occupied residential and non-residential structures within the preliminary OU1
Study Area, and several source areas have already been identified, the extent of groundwater,
soil and subsurface vapor contamination associated with the Site and the subsequent impacts to
indoor air have not been fully delineated. As such, EPA is conducting a comprehensive OU1
RI/FS to fully investigate the nature and extent of contamination present at the Site, the risks to
human health and the environment associated with the contamination, and alternatives to address
the risk. Part of this effort will include the identification and investigation of the known and
potential additional sources of contamination. The current preliminary Study Area shown on
Figure 1 was based on the information gathered by NYSDEC to date; EPA will update this map
as needed as the RI/FS continues.
Geology and Hydrogeology
Based on soil borings performed at and near the Site by NYSDEC and other investigators, the
Site is underlain by the Upper Glacial aquifer, the Raritan Formation, and crystalline bedrock.
The primary hydrogeologic unit is the Upper Glacial aquifer, which consists of a terminal
moraine, a ground moraine, and glacial outwash deposits, and is characterized by the United
States Geological Survey as an unsorted and unstratified mixture of clay, sand, gravel, and
boulders. Textural units identified by NYSDEC in the Upper Glacial aquifer at the Site include
fill material, silty sand, sandy silt, sand, and localized clayey silt/silt. Based on slug test results
from several Meeker Avenue Plume Site monitoring wells, the hydraulic conductivity of the
Upper Glacial aquifer ranges from 8.32 x 10"5 centimeters per second (cm/s) to 2.91 x 10"2 cm/s.
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At and near the Site, the Upper Glacial aquifer is underlain by the Raritan Formation unit at an
approximate depth of 100 to 140 feet below ground surface. The Raritan Formation, which
consists of clay, silty clay, and clayey to silty fine sand, exhibits hydraulic conductivity less than
1 x 10"6 cm/s and is recognized as a confining unit. The water table surface occurs in the Upper
Glacial aquifer from approximately 10 to 60 feet below ground surface.
In general, natural groundwater flow in the aquifer is to the east and northeast. However, the
large, off-site groundwater pump and treat system that has been operated since the mid-1990s as
part of an effort to cleanup an overlapping petroleum groundwater contamination area has
produced localized cones of depression. The overall Site hydrogeology is being further explored
through the OU1 RI/FS process.
Vapor Intrusion Description
The soil, soil gas, and groundwater at the Site are contaminated with CVOCs. CVOCs are a
subset of volatile organic compounds (VOCs), which are substances that typically evaporate at
room temperature. They can affect the indoor air of properties located in close proximity to
contaminated areas by entering the indoor air of structures through small cracks, pipes or other
points of entry. Subsurface soil vapor intrusion inside residential and commercial buildings is a
major concern at the Site. VOCs are also commonly found in household products such as
cleaning supplies, building products like paints and air fresheners. Therefore, sampling indoor air
for the presence of Site-related contamination is a complex process that involves sampling both
the indoor air and the air beneath the structure (referred to as sub-slab) over time to understand
how vapors might be migrating indoors. Common household sources of VOCs also need to be
removed during testing so that the results can reliably reflect what may be entering the structure
from the contaminated material beneath it, as opposed to from materials in the building.
The soil vapor intrusion sampling being conducted by EPA as part of the OU1 RI/FS is typically
a three-day process, which can generally be described as follows, though slight modifications to
this approach can be made on an as-needed basis:
• Day 1: EPA inspects the property for any potential sources of VOCs and temporarily
stores any that are found. EPA then installs a sub-slab soil gas port, which involves
drilling an approximately quarter-sized hole through the lowest level floor of a structure.
Day 1 activities typically takes EPA between 1 and 1.5 hours to complete.
• Day 2: EPA returns to make sure the port is functioning properly and, assuming it is,
places sampling devices throughout the lowest one or two levels of the property
(typically, basement and first floor). These sampling devices need to be left in place to
collect air passively for 24 hours for residential properties and at least 8 hours for non-
residential properties. Day 2 activities typically take EPA about 1 hour to complete.
• Day 3: EPA returns to collect the air samplers, which typically takes less than 1 hour to
complete.
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Ideally, this sampling is conducted during the winter heating season, which runs from mid-
November through March in the New York City area, because this is when the greatest potential
for subsurface vapor intrusion is expected to occur.
The results of the sampling are evaluated through multiple lines of evidence to make
recommendations on next steps. The potential recommendations may include (1) that the results
clearly indicate that no action is required; (2) that the results are not clear and additional
sampling is required; or (3) the results indicate that contamination from the soil, groundwater,
and/or soil gas is entering or has the potential to enter the structure above Remedial Action
Levels (further defined below) and, therefore, soil vapor mitigation in the structure is required.
Results of the Remedial Investigation (Vapor Intrusion)
There are currently between 900 and 1,000 properties within the Study Area for the Site that are
potentially impacted by subsurface vapor intrusion of Site-related contamination; the potential
for subsurface vapor intrusion depends on multiple factors, including the condition of the
building itself and the level of contamination beneath and near a structure. As such, EPA's goal
is to conduct vapor intrusion sampling at as many properties as possible within the Study Area.
As part of this effort, EPA has been seeking consent for access to conduct the sampling while
working closely with the community on outreach efforts to help increase awareness about the
Site and encourage the public's overall willingness to provide access.
EPA began soil vapor intrusion sampling activities at the Site as part of OU1 in November 2022.
As of December 2023, EPA has conducted vapor intrusion sampling and fully evaluated the
results at 18 residential structures, 11 public housing buildings, and one public school. Out of
these, EPA has determined that vapor mitigation is not needed at this time at any of the
properties it has sampled, and that further monitoring should be conducted at three of the
residential properties. In addition, in February and March 2024, EPA sampled 18 properties and
is currently evaluating the results, and will be conducting additional sampling in the future.
NYSDEC did, however, identify 26 properties that they determined required the installation of
sub-slab depressurization systems to mitigate risks from vapor intrusion when they were
conducting work prior to the Site being designated as a Superfund site, and two that required the
sealing of cracks/gaps. As such, EPA fully anticipates identifying additional properties that
would require vapor intrusion mitigation during the ongoing OU1 RI/FS process.
Results of the Remedial Investigation (Groundwater)
EPA has recently completed an initial round of groundwater sampling at the Site. This sampling
effort included surveying more than 370 existing groundwater monitoring wells and sampling
344 of these for CERCLA-related hazardous substances including VOCs, semi-volatile organic
compounds, 1,4-dioxane, pesticides, poly chlorinated biphenyls, metals, and per and
polyfluoroalkyl substances. Once the analytical results from the groundwater sampling are fully
available, the data will be used to refine the extent of the preliminary Study Area, to determine
the location of additional wells that need to be installed to fill in data gaps, and to help better
determine areas where future vapor intrusion sampling should be conducted.
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CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
Land Uses
As mentioned previously, the Site currently spans approximately 191 acres across several city
blocks in the Greenpoint and East Williamsburg area of Brooklyn. The BQE, a major highway
that connects Brooklyn and Queens, roughly bisects the Site and Newtown Creek forms a portion
of the Site's boundary. Over 1,000 individual properties are located within the preliminary Study
Area and these properties include a mixture of residential, commercial, and industrial uses.
While the land use on any particular lot may change over time, the general mix of land use
designations is not anticipated to change significantly in the future. The total population within
the Greenpoint and Williamsburg neighborhoods of Brooklyn where the Site is located is
approximately 160,000 people.
Groundwater and Surface Water Use
The groundwater beneath the Site is not currently used as a drinking water source, and there are
no surface water bodies present within the current Study Area. The Site does border Newtown
Creek, which has also been designated a separate National Priorities List Superfund site. Any
potential impacts related to Newtown Creek from the Meeker Avenue Plume Site will be
determined through the OU1 RI/FS process.
Environmental Justice
EPA's EJScreen tool, a tool to evaluate environmental justice impacts, shows that approximately
34% of the community in the vicinity of the Site identifies as non-English speakers. The top
three most frequently used non-English languages are Spanish (14%) Polish (9%), and Chinese
(2%). Approximately 80% of housing units are renter occupied, and approximately 42% of the
population has less than a high school education. Based on the findings of the EJScreen Report
for the Site, EPA determined that the community would benefit from multiple modes of outreach
and educational materials in multiple languages. For example, EPA has conducted outreach
through social media, public meetings, door-to-door engagement, local tabling events, and by
facilitating the creation of a Community Advisory Group (CAG) and attending those meetings.
EPA has also provided site-related fact sheets in multiple languages including English, Polish,
Spanish, and Chinese. The findings of the EJScreen Report also indicated the community is in
the 98th percentile for Superfund proximity, which the community has expressed concerns about.
EPA is actively addressing this concern by discussing the surrounding Superfund sites at CAG
meetings and providing information and educational maps about these sites.
Climate Change
Potential Site impacts from climate change have been assessed, and the performance of the
remedy selected herein is currently not at risk because of the expected effects of climate change
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in the region and near the Site. Potential Site impacts from climate change will be further
evaluated as part of the ongoing OU1 RI/FS.
SUMMARY OF SITE RISKS
EPA typically conducts baseline human health and ecological risk assessments to assess the
potential adverse human health and ecological effects of releases of hazardous substances from a
site in the absence of any actions or controls to mitigate such releases, under current and future
land uses. In this case, there are no completed ecological exposure pathways as the focus of this
action is on subsurface vapor intrusion into structures. As such, an ecological risk assessment
was not performed as part of the OU2 evaluation process.
EPA conducted an expedited human health risk evaluation of the soil vapor intrusion exposure
pathway as part of the FFS for OU2 to estimate the risks and hazards associated with exposure to
Site-related contaminants of potential concern (COPCs) in indoor air. The evaluation utilized
data obtained by both NYSDEC and EPA available at the time. The expedited human health risk
evaluation for OU2 of the Site, formally entitled "Expedited Vapor Intrusion Evaluation and
Estimation of Potential Human Health Risks" is available in Appendix D of the FFS document,
which can be found in the administrative record for the Site.
The approach for the expedited risk evaluation consisted of comparing sub-slab soil vapor and
indoor air concentrations against EPA's current, chemical-specific, risk-based vapor intrusion
screening levels (VISLs). All vapor intrusion data collected by NYSDEC and EPA at the time
the expedited human health risk evaluation was conducted was considered in the evaluation.
Three properties from the NYSDEC data, including two residential properties (P001 and P002)
and one commercial facility (P003), were chosen for this evaluation. These properties were
chosen because, based on a review of the data, they were representative of high-end exposure
conditions to nearby residents, commercial/industrial or mixed-use buildings potentially
impacted by groundwater and soil vapor contamination at the Site. In addition, data from three
residences (P004, P005 and P006) collected during the November 2022 sampling round was also
included in the expedited risk evaluation for overall completeness. The subsequent section
discusses EPA's human health risk assessment process used in the expedited human health risk
evaluation for OU2 in more detail.
Human Health Risk Assessment
A four-step process is utilized for assessing site-related human health risks for a reasonable
maximum exposure scenario:
• Hazard Identification - uses the analytical data collected to identify the contaminants of
potential concern at the Site 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 well-water) by which humans are potentially exposed;
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• Toxicity Assessment - determines the types of adverse health effects associated with
chemical exposures, and the relationship between magnitude of exposure (dose) and
severity of adverse effects (response); and
• 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 which exceed
acceptable levels, defined by the National Contingency Plan (NCP) as an excess lifetime
cancer risk greater than 1 x 10"6 to 1 x 10"4 or a noncancer Hazard Index greater than 1;
contaminants at these concentrations are considered chemicals of concern (COCs) and
are typically those that will require remediation at the Site. Also included in this section
is a discussion of the uncertainties associated with these risks.
Hazard Identification
In this step, the COPCs in sub-slab and indoor air were identified based on such factors as
toxicity, frequency of occurrence, fate and transport of the contaminants in the environment,
concentrations, mobility, persistence, and bioaccumulation. Based on the data collected to date,
TCE, PCE and 1,1,1-trichl or ethane (TCA) were detected with the greatest frequency. Of these
three contaminants, only TCE and PCE exceeded the VISLs for indoor air and sub-slab. Based
on this information, the risk assessment focused on sub-slab and indoor air results from vapor
intrusion sampling and contaminants which may pose significant risk to human health. As shown
in Table 1, the COCs identified for OU2 include PCE and TCE.
Exposure Assessment
Consistent with Superfund policy and guidance, the expedited human health risk evaluation
assumed no remediation has been performed and no institutional controls are in place to mitigate
or remove hazardous substance releases. Cancer risks and noncancer hazard indices were
calculated based on an estimate of the reasonable maximum exposure (RME) expected to occur
under current and future conditions at the Site. The RME is defined as the highest exposure that
is reasonably expected to occur at a site.
As previously mentioned, over 1,000 individual properties are located within the preliminary
Study Area; these properties include a mixture of residential, commercial, and industrial uses.
While the land use on any particular lot may change over time, the general mix of land use
designations is not anticipated to change significantly in the future. The expedited human health
risk evaluation assessed potential risks to populations associated with both current and potential
future land uses. Exposure pathways were identified for each potentially exposed population at
the Site. As such, current/future resident and commercial/industrial workers were evaluated for
inhalation exposures to contaminants in indoor and sub-slab air. A summary of the exposure
pathways included in the expedited human health risk evaluation can be found in Table 2.
Typically, exposures are evaluated using a statistical estimate of the exposure point
concentration, which is usually an upper bound estimate of the average concentration for each
contaminant, but in some cases may be the maximum detected concentration. In the case of the
human health risk evaluation for OU2 of the Site, the maximum detected concentration in indoor
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air and sub-slab at each property (P001- P006) were used to represent reasonable maximum
exposure scenarios. A summary of the exposure point concentrations for COCs in each medium
can be found in Table 1, while a more comprehensive list of the exposure point concentrations
for all COPCs identified for OU2 can be found in the Appendix D of the FFS document.
Toxicity Assessment
In this step, the types of adverse health effects associated with contaminant exposures and the
relationship between magnitude of exposure and 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 due to
exposure to site chemicals are considered separately. Consistent with current EPA policy, it was
assumed that the toxic effects of the 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 expedited human health risk evaluation were provided by the Integrated
Risk Information System database, the Provisional Peer Reviewed Toxicity Value database, or
another source that was identified as an appropriate reference for toxicity values
(https://www.epa.eov/sites/default/files/2015-l 1/documents/ti er3-toxicitvvalue-whitepaper.pdf).
This information is presented in Table 3 (noncancer toxicity data summary) and Table 4 (cancer
toxicity data summary).
Risk Characterization
This step summarized and combined outputs of the exposure and toxicity assessments to provide
a quantitative assessment of Site risks. Exposures were evaluated based on the potential risk of
developing cancer and the potential for noncancer health hazards.
Noncancer risks were assessed using a hazard index (HI) approach, 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) which 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 obtained by adding the hazard quotients for all compounds within a
particular medium that impacts a particular receptor population.
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The HQ for inhalation exposures is calculated as below.
HQ = EC/(RfC*1000|ig/mg)
Where: HQ = hazard quotient
EC = exposure concentration (|ig/m3)
RfC = reference concentration (mg/m3)
1000|ig/mg= conversion factor
The exposure concentration and the RfC will represent the same exposure period (i.e., chronic,
sub chronic, or acute).
The HI is calculated by summing the HQs for all chemicals for likely exposure scenarios for a
specific population. The noncancer HI is a "threshold level," set at an HI of less than 1, below
which noncancer health effects are not expected to occur. An HI greater than 1 indicates that the
potential exists for noncarcinogenic 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. A
summary of the noncarcinogenic risks associated with these chemicals for each exposure
pathway is contained in Table 5.
As shown in Table 5, the HI for noncancer effects stemming from exposure to TCE (HI=6) and
PCE (HI=4) in indoor air exceeded EPA's threshold of 1 at P001 during the 2008/2009 heating
season. This same sampling location, P001, was associated with an HQ of 2 from exposure to
TCE in indoor air during the 2009/2010 sampling round. All other indoor air locations evaluated
were found to be below or at the threshold value of 1 when considering noncancer effects that act
one the same target organ. As for sub-slab results, exceedances of the noncancer hazard for TCE
(HI=4) and PCE (HI=3) were shown in location P001 during the 2008/2009 heating season. TCE
in sub-slab location P002 was associated with a HI of 2 for the 2009/2010 sampling round.
Finally, in the 2020/2021 heating season, the commercial zoned property, P003, showed TCE
concentrations in sub-slab that correlated to a HI exceedance of 99.
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 (mg/kg-day)
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SF = cancer slope factor, expressed as [l/(mg/kg-day)]
These risks are probabilities that are usually expressed in scientific notation (such as 1 x 10"4).
An excess lifetime cancer risk of 1 x 10"4 indicates that one additional incidence of cancer may
occur in a population of 10,000 people who are exposed under the conditions identified in the
assessment. Again, as stated in the National Contingency Plan, the acceptable risk range for site-
related exposure is 10"6 to 10"4.
Results of the expedited human health risk evaluation presented in Table 6 indicate that the
cancer risk estimates from exposure to PCE and TCE in indoor air were all within the acceptable
risk range for the six properties evaluated. The combined cancer risks associated with exposure
to TCE and/or PCE in indoor air ranged from 1,2xl0"6 at location P005 to 4. lxlO"5 at location
POOl. Considering sub-slab results, all cancer risk estimates for the properties evaluated were
below or within EPA's cancer risk range with the exception of sub-slab at P003. Considering
sub-slab data collected during the 2020/2021 heating season for location P003, the resultant
cancer risk estimate exceedance of 2.9 xlO"4 was found to be driven by exposure to TCE in sub-
slab.
In summary, although the cancer risk estimates from exposure to PCE and TCE in indoor air
were within EPA's acceptable cancer risk range of 10"6 to 10"4, the expedited human risk
evaluation found that the noncancer hazard estimates exceeded EPA's threshold of 1 at location
POOl. Indoor air COCs identified at location POOl included TCE and PCE. Similarly, sub-slab
exceedances above an HI of 1 were found stemming from exposure to TCE and/or PCE in POOl,
P002 and P003. Further, cancer risk estimates associated with exposure to TCE in sub-slab of
location P003 exceeded EPA's threshold cancer range of lxlO"4.1
Expedited Human Health Risk Evaluation Uncertainties
The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are
subject to a wide variety of uncertainties. In general, the main sources of uncertainty include:
• environmental chemistry sampling and analysis
• environmental parameter measurement
• fate and transport modeling
• exposure parameter estimation
• toxicological data.
Uncertainty in environmental sampling arises in part from the potentially uneven distribution of
contaminants in the media sampled. Consequently, there is significant uncertainty as to the actual
1 All properties that were identified as having unacceptable risk have sub-slab depressurization systems installed in
them.
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levels present. Environmental chemistry-analysis error can stem from several sources including
the errors inherent in the analytical methods and characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates of how often an individual
would actually come in contact with the contaminants of concern, the period of time over which
such exposure would occur, and in the models used to estimate the concentrations of the
contaminants of concern at the point of exposure. However, the exposure pathways at residential
and commercial/industrial properties assume standard exposure assumptions (USEPA, 2014) and
hence are not expected to underestimate calculated cancer risk and noncancer hazard.
Uncertainties in toxicological data occur in extrapolating both from animals to humans and from
high to low doses of exposure, as well as from the difficulties in assessing the toxicity of a
mixture of contaminants. These uncertainties are addressed by making conservative assumptions
concerning risk and exposure parameters throughout the assessment. As a result, the risk
assessment provides upper-bound estimates of the risks to populations near the Site and is highly
unlikely to underestimate actual risks related to the Site.
A Site-specific uncertainty associated with the expedited risk evaluation is that risks associated
with other contaminants besides PCE, TCE and 1,1,1 -TC A were not evaluated, and this may
result in an underestimate of cancer risks and noncancer HQs. However, the uncertainty is not
expected to be large since TCE and PCE are understood to be the primary Site-related
contaminants based on historical sampling results and records review. Nevertheless, EPA will
be performing additional risk evaluations, and other compounds may be further evaluated as part
of future ¥1 risk assessments.
More specific information concerning public health risks, including a quantitative evaluation of
the degree of risk associated with various exposure pathways, is presented in the expedited risk
evaluation document available in the administrative record (Appendix D of the FFS).
Basis for Action
Based on the results of the expedited human health risk evaluation, actual or threatened releases
of hazardous substances from OU2 of the Site, if not addressed by implementing the response
action selected in the ROD, may present an imminent and substantial endangerment to the public
health, welfare, or the environment.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are specific media-specific goals to protect human health and
the environment; they specify the contaminant(s) of concern, the exposure route(s), receptor(s),
and acceptable contaminant level(s) for each exposure route. These objectives are based on
available information and standards such as ARARs, to-be-considered (TBC) advisories, criteria
and guidance, and site-specific risk-based levels and background (i.e., reference area)
concentrations.
The following remedial action objectives were established for OU2 to address subsurface soil
vapor intrusion at the Site:
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• Prevent exposure by current and future occupants to Site-related PCE and TCE-
contaminated vapors within structures that would result in a noncancer hazard index
greater than 1.
• Prevent the migration of contaminated subsurface vapors into the indoor air of structures
from Site-related PCE and TCE in soil and/or groundwater above remedial action levels
(RALs) based on current and reasonably anticipated future land use.
Vapor intrusion investigations are ongoing as part of the OU1 RI/FS. If other Site-related
CVOCs are detected above levels of concern and/or if additional contaminants of concern are
identified during the OU1 RI/FS and mitigative measures are needed to address their impact, or
potential impact, on indoor air, then they may also be addressed.
Remediation Goals
Achieving the RAOs relies on the remedial alternatives' ability to meet final remediation
goals/cleanup levels derived from preliminary remediation goals (PRGs), which are generally
chemical-specific goals for each medium and/or exposure route that are established to protect
human health and the environment. They can be based on such factors as ARARs, risk, and from
comparison to background levels of contaminants in the environment that occur naturally or are
from other industrial sources.
PRGs become final remediation goals (RGs), or in this case, RALs, when EPA selects a remedy
after taking into consideration all public comments. To achieve the RAOs for OU2, EPA has
identified the following RALs2 for TCE and PCE:
('()('
Residenlml Railed ml
Aclion l.e\els (LltJ 111 )
( ommei'cml 1 nduslI'Kil Rcmcdml
Aclion l.exels (utj in )
Indoor Air
Sub- slab
Indoor Air
Sub- slab
TCE
2.1
70
00
00
290
PCE
42
1,400
180
5,800
The RALs represent current EPA VISLs set at a target HQ = 1, which, for PCE and TCE, falls
midway between EPA's cancer risk range of lxlO"6 to lxlO"4 These RALs will be considered
with other Site-specific lines of evidence such as subsurface geology and hydrogeology,
subsurface contamination levels, the structural characteristics of each building, and proximity to
other impacted structures in determining whether there is a need for remedial action. The need
for remedial action will also be determined in consultation with NYSDEC and the NYSDOH,
2 Consistent with EPA's Technical Guide for Assessing and Mitigating the Vapor Intrusion Pathway (OSWER
9200.2154, 2015), the RALs are developed assuming that there is attenuation as vapors migrate from the sub-slab to
indoor air. EPA's guidance assumes that indoor air concentrations would be 33 times lower than those is the sub-
slab.
3 The commercial/industrial RALs assume an eight-hour workday, which is protective of most non-residential
settings and can be adjusted as needed to account for property-specific conditions.
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including consideration ofNYSDOH's Guidance for Evaluating Soil Vapor Intrusion in the
State of New York.
Whether to apply the residential RAL or Commercial/Industrial RAL will also be determined on
a case-by-case basis, in consultation with NYSDEC and NYSDOH. In general, EPA understands
that many properties that are zoned for non-residential use may be used, either regularly or from
time-to-time, in what would be more consistent with residential exposure assumptions. The
residential RALs may be used at any property, residential or non-residential, if there is reason to
believe the commercial/industrial RALs are not sufficiently protective, either under current or
reasonably anticipated future use scenarios.
Finally, as stated above, if additional contaminants of concern are identified during the ongoing
OU1 RI/FS that may adversely affect indoor air, EPA's VISLs and NYSDOH guidance will be
reviewed and, if warranted, appropriate mitigative actions will be taken.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA Section 121(b)(1), 42 U.S.C. §9621(b)(l), requires that a remedial action be protective
of human health and the environment, 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 which employ,
as a principal element, treatment to permanently and significantly reduce the volume, toxicity, or
mobility of the hazardous 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, which 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).
Potential technologies applicable to subsurface vapor intrusion mitigation were identified and
screened using the effectiveness, implementability, and cost criteria, with emphasis on
effectiveness. Those technologies that passed the initial screening were assembled into
alternatives.
This ROD evaluates in detail two remedial alternatives for addressing the contamination
associated with the Site. The time to implement a remedial alternative reflects only the time
required to construct or implement the remedy and does not include the time required to
negotiate with the responsible parties, design the remedy, procure contracts for design and
construction, or conduct operation and maintenance at the Site. Detailed information regarding
the alternatives can be found in the FFS report.
A review of the remedial action pursuant to CERCLA Section 121(c), 42 U.S.C. §9621(c), will
be conducted five years after the commencement of the remedial action to ensure that the remedy
continues to provide adequate protection to human health and the environment because this
remedy will result in hazardous substances remaining on-Site above health-based levels that
allow for unlimited use and unrestricted exposure.
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Description of Remedial Alternatives
Alternative 1 - No Action
Alternative 1, the "No Action" alternative, is required by the NCP to provide an environmental
baseline against which impacts of the other remedial alternatives can be compared. No action
would be initiated to remediate contaminated media or otherwise mitigate the migration of
contamination that poses unacceptable risks to human health and the environment. This
alternative also does not include monitoring or institutional controls.
Total Capital Cost: $0
Total O&M: $0
Total Present Net Worth: $0
Construction Timeframe: 0 years
Alternative 2 - Vapor Intrusion Mitigation
Under this alternative, subsurface vapor intrusion mitigation would be implemented at structures
where EPA determines that, based on multiple lines of evidence, vapor intrusion of the COCs is
occurring, or has the potential to occur, at concentrations that exceed the RALs. The goal of vapor
intrusion mitigation would be to prevent contaminated soil vapors from entering and/or
accumulating in structures at concentrations that represent a threat, or a potential threat, to human
health. The potential for vapor intrusion to occur at a particular structure is dependent upon several
factors, including subsurface geology and hydrogeology, the structural characteristics of a
building, and the proximity to other impacted structures or sources. Different impacted structures
may therefore require different vapor mitigation strategies based on factors such as age of the
building and construction type, the depth to groundwater beneath a structure, etc. For the purposes
of the cost estimate, the mitigation actions include installing active, sub-slab depressurization
mitigation systems as well as preventative engineering measures such as sealing cracks and gaps
in the lowest level of a structure and installing a concrete slab or comparable membrane system in
instances where only a dirt floor is present.
The cost estimate reflects the estimated costs for mitigation in the event that an estimated 100
structures within the Study Area are found to require vapor mitigation as a result of sampling and
the other lines of evidence described above. This represents approximately 10 percent of the
properties within the interim Study Area. The cost estimate also takes into consideration other
factors including costs for addressing basements and crawl spaces without any existing concrete
floor, as well as larger multi-unit structures that would require more depressurization points than
smaller structures. The cost estimate also reflects one year of estimated costs for operation and
maintenance (O&M) of sub-slab depressurization systems to ensure the systems are operating
properly for the estimated 100 properties. The sampling and mitigation is expected to occur on a
rolling basis over a period of five years. If it is determined that a property requires a sub-slab
depressurization system, EPA will work with the owner to arrange for the installation of the
system. Construction can be completed in as little as one to two days, and it can take up to one
week or longer for the installation of larger commercial systems. The construction time for each
alternative reflects only the actual time required to construct or implement the action and does
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not include the time required to design the remedy, negotiate the performance of the remedy with
any potentially responsible parties, or procure the contracts and funding for design and
construction.
The specific details and cost of the mitigation measures for any particular structure would be
determined during remedial design (Table 7).
Total Capital Cost: $ 1,124,000
Total O&M: $21,200
Total Present Net Worth: $1,145,200
Construction Timeframe: 5 years
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, EPA considered the factors set out in CERCLA Section 121, 42 U.S.C. §
9621, conducting a detailed analysis of the viable remedial alternatives pursuant to the NCP, 40
CFR § 300.430(e)(9), EPA's Guidance for Conducting Remedial Investigations and Feasibility
Studies under CERCLA (OSWER Directive 9355.3-01) and EPA's A Guide to Preparing
Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision
Documents, OSWER 9200.1-23.P. The detailed analysis consisted of an assessment of the
individual alternatives against each of nine evaluation criteria 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 each response measure must meet in order to be eligible for selection as a
remedy:
1. Overall protection of human health and the environment addresses whether or not a
remedy provides adequate protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure scenario) are eliminated,
reduced, or controlled through treatment, engineering controls, or institutional controls.
2. Compliance with ARARs addresses whether or not a remedy would meet all of the
applicable (legally enforceable), or relevant and appropriate (requirements that pertain to
situations sufficiently similar to those encountered at a Superfund site such that their use
is well suited to the site) requirements of federal and state environmental statutes and
requirements or provide grounds for invoking a waiver. Other federal or state advisories,
criteria, or guidance may be identified by EPA as "to be considered", or "TBCs". While
TBCs are not required to be adhered to under the NCP, they may be useful in determining
what is protective or how to carry out certain actions or requirements.
The following "primary balancing" criteria are used to make comparisons and to identify the
major trade-offs between alternatives:
3. Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup goals
have been met. It also addresses the magnitude, effectiveness and reliability of the
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measures that may be required to manage the risk posed by treatment residuals and/or
untreated wastes.
4. Reduction of toxicity, mobility, or volume via treatment refers to a remedial technology's
expected ability to reduce the toxicity, mobility, or volume of hazardous substances,
pollutants or contaminants at the site through treatment.
5. Short-term effectiveness addresses the period of time needed to achieve protection and
any adverse impacts on human health and the environment that may be posed to workers,
the community and the environment during the construction and implementation periods
until cleanup goals are achieved.
6. Implementability refers to the technical and administrative feasibility of a remedy, from
design through construction and operation, including the availability of materials and
services needed, administrative feasibility, and coordination with other governmental
entities.
7. Cost includes estimated capital and operation and maintenance costs, and the net present-
worth costs calculated using a 7% discount rate [per current guidance].
The following "modifying" criteria are considered fully after the formal public comment period
on the Proposed Plan is complete:
8. State acceptance indicates whether, based on its review of the RI/FS and the Proposed
Plan, the State supports, opposes, and/or has identified any reservations with the
preferred alternative.
9. Community acceptance refers to the public's general response to the alternatives
described in the Proposed Plan and the RI/FS reports. Factors of community acceptance
to be discussed include support, reservation, and opposition by the community.
A comparative analysis of the remedial alternatives based upon the evaluation criteria noted
above follows.
• Overall Protection of Human Health and the Environment
Alternative 1 (No Action) would not meet the RAOs and would not be protective of human
health and the environment since no action would be taken.
Alternative 2 (Vapor Intrusion Mitigation) would control exposure to Site-related contaminants
from subsurface vapor intrusion into residential and non-residential structures. Contaminated
sub-slab vapor would be prevented from entering and/or accumulating in buildings at
concentrations that represent a potential threat to human health. Therefore, when implemented at
impacted buildings, Alternative 2 would be protective of human health and the environment.
RAOs would be met immediately after implementation of the mitigative measures at any
particular structure.
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• Compliance with ARARs
In accordance with the NCP (40 CFR § 300.430(f)(l)(ii)(c)(l)), interim actions such as this are
not required to comply with ARARs as long as the final remedial action at the Site will attain
them. Consequently, no ARARs have been identified for this interim action.
• 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. Alternative 2 would be effective in the
long term. Previously installed vapor mitigation systems at other structures in the area have
demonstrated effectiveness in addressing vapor intrusion concerns. Long-term effectiveness of
the vapor intrusion mitigation systems would be provided by establishing and implementing
O&M procedures to ensure that the systems continue to mitigate the potential threat to human
health posed by vapor intrusion at impacted structures at the Site.
• Reduction in Toxicity. Mobility, or Volume via Treatment
Alternatives 1 and 2 would provide no reduction in toxicity, mobility, or volume. However,
under Alternative 2, Site-related contaminants in vapor form would be prevented from entering
into buildings at concentrations that represent a potential threat to human health.
• Short-term Effectiveness
Alternative 1 does not involve any active construction activities that could present a risk to
workers or the public.
Implementation of Alternative 2 would not be expected to result in short-term risks to the
community, the workers installing the vapor intrusion mitigation systems, or the environment in
general. Any potential threats to the workers from inhaling hazardous substances in vapor form
during system installation would be minimized with the implementation of appropriate health
and safety measures.
As for short term impacts, no time is required for construction of Alternative 1. Under
Alternative 2, the installation of sub-slab depressurization systems can be completed in as little
as one to two days and it can take up to one week for the installation of larger commercial
systems. While, for planning purposes, it is estimated that Alternative 2 may take up to five years
to install the estimated 100 systems to address vapor intrusion concerns within the Study Area,
this would not, however, be a continuous five years of effort. Rather, the installations would
happen as the need is determined through the ongoing OU1 RI/FS process.
• Implementabilitv
Alternative 1 does not involve the application of any technology, therefore, there are no issues
relating to feasibility of implementation.
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Alternative 2 is considered to be readily implementable. The installation of vapor mitigation
systems under Alternative 2 would use readily available services and equipment. Such systems
have already been installed at other buildings in the area and have shown to be reliable and
effective in addressing vapor intrusion and mitigating exposures.
• Cost
There is no cost associated with Alternative 1 because no activities are implemented. The
estimated cost of Alternative 2 was developed as a range of costs because the total number of
residential versus non-residential buildings that require vapor mitigation is not currently known.
In addition, the actual costs could vary depending on the particular building and would be
determined during design. The estimated total cost includes capital costs and O&M costs for one
year to ensure the system is operating properly. After one year, O&M of the vapor mitigation
system is turned over to the State.
Note that Alternative 2 provides for the potentiality of designing, installing, and maintaining
vapor mitigation systems, but it does not address the electricity costs to operate the vapor
mitigation system. The operating costs for these systems are minimal, similar to costs to operate
radon mitigation systems, and they would be the responsibility of the property owner. The
estimated total cost for Alternative 2 is $1,145,200.
• State Acceptance
The State of New York concurs with the selected remedy.
• Community Acceptance
Based upon the comments received during on the Proposed Plan, the community is generally
accepting of the EPA's preferred alternative. Several comments and questions related to the
RALs and increasing participation in the sampling program were raised both during the public
meeting to discuss the proposed plan and in writing during the public comment period. These
comments are addressed in Appendix V, Responsiveness Summary.
PRINCIPAL THREAT WASTE
The NCP establishes an expectation that the EPA will use treatment to address the principal
threats posed by a site whenever practicable (NCP Section 300.430(a)(l)(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 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 would present a significant risk to human health or the environment in the event that
exposure should occur. The decision to treat these wastes is made on a site-specific basis through
a detailed analysis of alternatives, using the remedy selection criteria described above. The
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manner in which principal threat wastes are addressed provides a basis for making a statutory
finding that the remedy employs treatment as a principal element.
This response action does not address source materials constituting principal threat wastes
because no such materials are part of this operable unit. The interim action that is being
evaluated in this Record of Decision solely addresses vapor intrusion of contaminants into
structures from subsurface sources of contamination. Soil vapor is neither a source material nor a
principal threat waste.
SELECTED REMEDY
Based upon considerations of the results of the RI/FS, the requirements of CERCLA, the detailed
analyses of the response measures and public comments, EPA has determined that Alternative 2
is the appropriate remedy for the OU2 at the Site because it best satisfies the requirements of
CERCLA Section 121, 42 U.S.C. §9621, and the NCP's nine evaluation criteria for remedial
alternatives, 40 CFR §300.430(e)(9).
Description of the Selected Remedy
The major components of the selected remedy include the following:
Vapor intrusion mitigation at residential and non-residential structures where multiple lines
of evidence indicate that subsurface vapor intrusion is occurring, or has potential to occur,
at concentrations that represent a threat, or potential threat, to human health. The vapor
mitigation strategy to be used has the following key components, some or all of which may
be used at any particular property:
o Installation of a sub-slab depressurization system.
o Preventative engineering measures such as the sealing of cracks and gaps in the
lowest level of a structure and installing a concrete slab or comparable membrane
system in instances where only a dirt floor is present.
The operation and maintenance of the vapor mitigation measures for one year, after which
responsibility for operation and maintenance will be turned over to NYSDEC.
The estimated present-worth cost of the selected remedy is $1,145,200.
Summary of the Rationale for the Selected Remedy
Based upon the information currently available, EPA believes that the selected remedy meets the
threshold criteria to protect human health and the environment by preventing COCs from
entering indoor air at levels that pose an unacceptable risk. The exact number of residential
properties to be remediated will be determined upon completion of additional vapor intrusion
sampling during the ongoing OU1 RI/FS. Based upon the information currently available, EPA
believes that the selected remedy meets the threshold criteria and provides the best balance of
tradeoffs compared to the other alternative with respect to the balancing and modifying criteria
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set forth in the NCP. The selected remedy is considered protective of human health and the
environment in the short-term until a final remedy is implemented for the Site. Although this
interim action is not intended to address fully the statutory mandates, the selected remedy, if
implemented, would satisfy the statutory requirements of CERCLA Section 121(b), namely
being (1) protective of human health and the environment and (2) cost effective. EPA expects the
final remedy for the Site will fully satisfy the statutory requirements. The selected remedy would
be readily implementable using technologies proven to be effective at this Site, as well as similar
sites. The short-term effects of the selected remedy include potential impacts to workers, but
these could be mitigated using appropriate health and safety measures.
Expected Outcomes of the Selected Remedy
The selected remedy will meet the RAOs because it would control exposure to Site-related
contaminants from vapor intrusion into residential and non-residential structures and
contaminated sub-slab vapor would be prevented from entering and/or accumulating in buildings
at concentrations that represent a potential threat to human health.
Green Remediation
EPA Region 2 Clean and Green Policy4 (Policy) provides guidance for the implementation of
green remediation for response actions in the region. The goal of the Policy is to enhance the
environmental benefits of federal cleanup programs by promoting technologies and practices that
are sustainable, while complying with all applicable laws and regulations. The objectives of
green remediation are to: protect human health and the environment by achieving remedial
action goals; support human and ecological use and reuse of remediated land; minimize impacts
to water quality and water resources; reduce air emissions and greenhouse gas production;
minimize material use and waste production; and conserve natural resources and energy.
This Policy establishes touchstone practices that are both quantifiable and reportable. The region
uses reporting requirements in enforcement instruments, grants, and contracts to collect and
report metrics annually. Examples of touchstone practices that may be used during the
implementation of the selected remedy are:
• Use of renewable energy, and energy conservation and efficiency approaches including
Energy Star equipment
• Cleaner fuels and clean diesel technologies and strategies
• Water conservation and efficiency approaches including WaterSense products
• Sustainable site design
• Industrial material reuse or recycling within regulatory requirements
• Recycling applications for materials generated at or removed from the site
• Environmentally Preferable Purchasing
• Greenhouse gas emission reduction technologies
4 See http://www.epa.gov/greenercleanups/epa-region-2cleanand-green-policy
21
-------
Green remediation techniques, as detailed in NYSDEC's Green Remediation Program Policy -
DER-31,5 will also be considered during the implementation of the selected remedy to reduce
short-term environmental impacts.
STATUTORY DETERMINATIONS
As previously noted, CERCLA Section 121(b)(1), 42 U.S.C. § 9621(b)(1), mandates that a
remedial action must be protective of human health and the environment, 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 which employ treatment to permanently and significantly reduce the
volume, toxicity, or mobility of the hazardous substances, pollutants, or contaminants at a site.
CERCLA Section 121(d), 42 U.S.C. § 9621(d), further specifies that a remedial action must
attain a degree of cleanup that satisfies 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).
For the reasons discussed below, EPA has determined that the selected interim remedy meets the
requirements of CERCLA Section 121, 42 U.S.C. §9621.
Protection of Human Health and the Environment
It is expected that the selected remedy will be protective of human health and the environment.
Protection of human health will be achieved by mitigation actions including sealing cracks and
gaps in the slab, installing a concrete slab or comparable membrane system in instances where
only a dirt floor is present, and installing active sub-slab depressurization systems at structures
where EPA has determined that vapor intrusion is occurring, or has the potential to occur, at
concentrations that represent a potential threat to human health. The mitigation actions will
prevent contaminants in vapor form from migrating from the subsurface into indoor air at
concentrations that represent a threat to human health.
Compliance with ARARs
In accordance with the NCP (40 CFR § 300.430(f)(l)(ii)(C)(l)), interim response actions such as
this action are not required to comply with ARARs as long as the final remedial action at the Site
will attain them. Consequently, we have not identified any ARARs that must be attained for this
interim action.
Cost-Effectiveness
A cost-effective remedy is one in which costs are proportional to its overall effectiveness (40
CFR § 300.430(f)(l)(ii)(D)). Overall effectiveness is based on the evaluations of long-term
effectiveness and permanence, reduction in toxicity, mobility, and volume through treatment,
and short-term effectiveness. Overall effectiveness was evaluated by assessing three of the five
balancing criteria in combination (long-term effectiveness and permanence; reduction in toxicity,
5 http://www.dec.ny.gov/docs/remediation_hudson_pdf/der31. pdf
22
-------
mobility, and volume through treatment; and short-term effectiveness). Overall effectiveness was
then compared to costs to determine cost-effectiveness.
Each of the alternatives underwent a detailed cost analysis. In that analysis, capital and operation
and maintenance costs were estimated and used to develop present-worth costs. In the present-
worth cost analysis, operation and maintenance costs were calculated for the estimated life of
each alternative. The total estimated present worth cost for implementing the selected remedy is
$1,145,200.
Based on the comparison of overall effectiveness to cost, the selected remedy meets the statutory
requirement that Superfund remedies be cost effective (40 CFR § 300.430(f)(l)(ii)(D)) in that it
represents reasonable value for the money to be spent. A five-year timeframe was used for
planning and estimating purposes to mitigate vapor intrusion, although mitigation timeframes
could exceed this estimate.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable
The selected remedy is an interim action and is not intended to be a permanent solution. The
remedy uses alternative treatment (or resource recovery) technologies to the maximum extent
practicable. Based on the findings of the OU1 RI/FS, future remedial actions are expected to
address the contaminated groundwater, which will address the underlying cause of vapor
intrusion into structures at OU2 of the Site.
Preference for Treatment as a Principal Element
The selected remedy does not meet the statutory preference for remedies that employ treatment
as a principal element because vapor mitigation technologies do not treat the subsurface vapors,
and treatment of groundwater and/or soil gas is outside the scope of this OU2 interim action.
Five-Year Review Requirements
A review of the remedial action pursuant to CERCLA Section 121(c), 42 U.S.C. §9621(c), will
be conducted five years after the commencement of the remedial action to ensure that the remedy
continues to provide adequate protection to human health and the environment because this
remedy will result in hazardous substances remaining on-Site above health-based levels that
allow for unlimited use and unrestricted exposure. Five-year reviews will continue until a final
remedy is selected, at which point, the five-year review requirement will be re-evaluated.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for OU2 of the Site was released on April 5, 2024. The Proposed Plan
identified Alternative 2 as the preferred alternative for addressing vapor intrusion and solicited
public comment. EPA reviewed all written (including electronic formats such as e-mail) and
verbal comments received during the public comment period and has determined that no
significant changes to the remedy, as originally proposed in the Proposed Plan, are necessary or
appropriate.
23
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The following issues/concerns have been clarified in this Record of Decision from what was
presented in the Proposed Plan:
• Whether to apply the residential RAL or Commercial/Industrial RAL will be determined
on a case-by-case basis, in consultation with NYSDEC and NYSDOH. In general, EPA
understands that many properties that are zoned for non-residential use may be used,
either regularly or from time-to-time, in what would be more consistent with residential
exposure assumptions. The residential RALs may be used at any property, residential or
non-residential, if there is any reason to believe the commercial/industrial RALs are not
sufficiently conservative, either under current or reasonably anticipated future use
scenarios.
• If additional contaminants of concern are identified during the ongoing OU1 RI/FS that
may adversely affect indoor air, EPA's VISLs and NYSDOH guidance will be reviewed
and, if warranted, appropriate mitigative actions will be taken.
24
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APPENDIX I
FIGURES
-------
Norman Avenue
Nassau Avenue
f\\/e nue
1 Avenue
Richardson
Withers
Jackson
Meeker Avenue Plume
Superfund Site
Preliminary Study Area
* " • v ft : T~1 ' . I
Site Location Map
Meeker Avenue Plume
Superfund Site
Preliminary Study Area
Brooklyn, Kings County, NY
-------
APPENDIX II
TABLES
-------
Table 1
Summary of Contaminants of Concern and
Medium-Specific Exposure Point Concentrations
Scenario Timeframe: Current/Future Resident
Medium: Groundwater
Exposure Medium: Indoor Air or Sub-slab
Sampling
Timeframe
Property
Identifier
Exposure
Point
Contaminant of
Concern
Concentration
Detected
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Min
Max
2008/2009
Heating Season
P001
Indoor Air
Tetrachloroethylene (PCE)
NA
170
(ig/m3
170
(ig/m3
Maximum
Trichloroethylene (TCE)
NA
12
(ig/m3
12
(ig/m3
Maximum
Sub-Slab
Tetrachloroethylene (PCE)
NA
4,200
(ig/m3
4,200
(ig/m3
Maximum
Trichloroethylene (TCE)
NA
300
(ig/m3
300
(ig/m3
Maximum
P002
Indoor Air
Tetrachloroethylene (PCE)
NA
20
(ig/m3
20
(ig/m3
Maximum
Trichloroethylene (TCE)
NA
2.8
(ig/m3
2.8
(ig/m3
Maximum
Sub-Slab
Tetrachloroethylene (PCE)
NA
1,400
(ig/m3
1,400
(ig/m3
Maximum
Trichloroethylene (TCE)
NA
120
(ig/m3
120
(ig/m3
Maximum
2009/2010
Heating Season
P001
Indoor Air
Tetrachloroethylene (PCE)
NA
48
(ig/m3
48
(ig/m3
Maximum
Trichloroethylene (TCE)
NA
3.1
(ig/m3
3.1
(ig/m3
Maximum
P002
Indoor Air
Tetrachloroethylene (PCE)
NA
37
(ig/m3
37
(ig/m3
Maximum
Trichloroethylene (TCE)
NA
1.8
(ig/m3
1.8
(ig/m3
Maximum
2022 Heating
Season
P005
Indoor Air
Trichloroethylene (TCE)
NA
0.549
(ig/m3
0.549
(ig/m3
Maximum
P006
Sub-Slab
Trichloroethylene (TCE)
NA
18
(ig/m3
18
(ig/m3
Maximum
Scenario Timeframe: Current/Future Commercial Worker
Medium: Groundwater
Exposure Medium: Indoor Air or Sub-slab
Sampling
Timeframe
Property
Identifier
Exposure
Point
Contaminant of
Concern
Concentration
Detected
Concentration
Units
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure
Min
Max
2020/2021
Heating Season
P003
Indoor Air
Trichloroethylene (TCE)
NA
7.1
(ig/m3
7.1
(ig/m3
Maximum
Sub-Slab
Trichloroethylene (TCE)
NA
29,000
(ig/m3
29,000
(ig/m3
Maximum
Notes:
(ig/m3 = microgram per cubic meter
NA= not applicable/available
-------
Table 2
Selection of Exposure Pathways
Scenario
Timeframe
Medium
Exposure
Medium
Exposure
Point
Receptor
Population
Receptor
Age
Exposure
Route
Type of
Analysis
Rationale for Selection or
Exclusion of Exposure Pathway
Sub-slab
Sub-slab
Residents
Child and
Inhalation
Quantitative
Residents could be exposed to contaminants in
indoor air via migration from sub-slab soil gas. The
investigation of chemical vapors that may be
Current/ Future
Groundwater
Indoor Air
Indoor Air
Adult
entering residential homes from contaminated
groundwater below the structures associated with
Meeker Avenue Plume Superfund Site are ongoing.
Sub-slab
Sub-slab
Commercial/Industrial
Adult
Inhalation
Quantitative
Commercial/industrial workers could be exposed to
contaminants in indoor air via migration from sub-
slab soil gas. The investigation of chemical vapors
that may be entering commercial buildings from
contaminated groundwater below the structures
associated with Meeker Avenue Plume Superfund
Site are ongoing.
Indoor Air
Indoor Air
Worker
-------
Table 3
Non-Cancer Toxicity Data Summary
Pathway: Inhalation
Contaminant
of Concern
Chronic/
Subchronic
Inhalation
RfC
Inhalation
RfC Units
Primary
Target Organ
Combined
Uncertainty
/Modifying
Factors
Sources
of RfC Target
Organ
Dates of RfC
Tetrachloroethylene (PCE)
Chronic
0.04
mg/m3
Neurotoxicity (reaction time,
cognitive effects, color vision)
in occupationally- exposed
adults
1000
IRIS
2/10/2012
Trichloroethylene (TCE)
Chronic
0.002
mg/m3
Multiple (listed below)
Multiple (listed
below)
IRIS
9/28/2011
0.0019
mg/m3
Decreased thymus weight in
mice
100
0.0021
mg/m3
Increased fetal heart
malformations in rats
10
Notes:
IRIS = EPA's Integrated Risk Information System
mg/m3 = milligram per meter cubed
RfC = reference concentration
-------
Table 4
Cancer Toxicity Data Summary
Pathway: Inhalation
Contaminant of
Concern
Inhalation Unit Risk
Units
Weight of
Evidence/
Cancer
Guideline
Mutagen
(Y/N)
Source
Date
T etrachloroethylene
(PCE)
2.6 x 10-7
(lig/m3)"1
Likely to be
carcinogenic to
humans
N
IRIS
2/10/2012
Trichloroethylene (TCE)
4.1 x 10"6
(lig/m3)-1
Carcinogenic
to humans
Y*
IRIS
9/28/2011
Notes:
IRIS = EPA's Integrated Risk Information System (https://www.epa.gov/iris)
((ig/m3)"1 = per micrograms per cubic meter
* EPA has concluded that TCE is carcinogenic by a mutagenic mode of action (i.e, it is a mutagen). Application of age-
dependent adjustment factors (ADAFs) to the inhalation unit risk was done to account for early life susceptibility
-------
Table 5
Risk Characterization Summary
- Non-Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P001 (Residential)
Medium
Sampling
Exposure
Exposure
Contaminant of Concern
Primary target Organ
Non
-Carcinogenic Hazard Quotient
Timeframe
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
2008/2009
Indoor Air
Indoor Air
Tetrachloroethylene (PCE)
Nervous system, Ocular
-
4
-
4
Heating Season
Trichloroethylene (TCE)
Developmental, Immune
-
6
-
6
Indoor Air Hazard Index (HI) 1
in
Nervous Systen
4
Ocula
4
Developmenta
(»
Immune Systen
(»
Sub-slab
Sub-slab
Tetrachloroethylene (PCE)
Nervous system, Ocular
-
3
-
3
Trichloroethylene (TCE)
Developmental, Immune
-
4
-
4
Sub-slab Hazard Index (HI) Total=
7
Nervous System HI=
3
Ocular HI=
3
Developmental HI=
4
Immune System HI=
4
2009/2010
Indoor Air
Indoor Air
Tetrachloroethylene (PCE)
Nervous system, Ocular
-
1
-
1
Heating Season
Trichloroethylene (TCE)
Developmental, Immune
-
1.5
-
1.5
Indoor Air Hazard Index (HI) 1
: ?
Nervous Systen
Ocula
Developmenta
:
Immune Systen
:
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P002 (Residential)
Medium
Sampling
Exposure
Exposure
Contaminant of Concern
Primary target Organ
Non
-Carcinogenic Hazard Quotient
Timeframe
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
2008/2009
Indoor Air
Indoor Air
Tetrachloroethylene (PCE)
Nervous system, Ocular
-
0.5
-
0.5
Heating Season
Trichloroethylene (TCE)
Developmental, Immune
-
1
-
1
Indoor Air Hazard Index (HI) Total=
1.5
Nervous System HI=
0.5
Ocular HI=
0.5
Developmental HI=
1
Immune System HI=
1
Sub-slab
Sub-slab
Tetrachloroethylene (PCE)
Nervous system, Ocular
-
1
-
1
Trichloroethylene (TCE)
Developmental, Immune
-
2
-
2
Sub-slab Hazard Index (HI) Total=
3
Nervous System HI=
1
Ocular HI=
1
Developmental HI=
2
Immune System HI=
2
2009/2010
Indoor Air
Indoor Air
Tetrachloroethylene (PCE)
Nervous system, Ocular
-
0.9
-
0.9
Heating Season
Trichloroethylene (TCE)
Developmental, Immune
-
0.9
-
0.9
Indoor Air Hazard Index (HI) Total=
1.8
Nervous System HI=
0.9
Ocular HI=
0.9
Developmental HI=
0.9
Immune System HI=
0.9
Scenario Timeframe: Current/Future
Receptor Population: Commercial Worker (adult)
Property Identifier: P003 (Commercial)
Medium
Sampling
Exposure
Exposure
Contaminant of Concern
Primary target Organ
Non
-Carcinogenic Hazarc
Quotient
Timeframe
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
2020/2021
Indoor Air
Indoor Air
Trichloroethylene (TCE)
Developmental, Immune
-
0.8
-
0.8
Heating Season
Indoor Air Hazard Index (HI) Total=
0.8
Developmental HI=
0.8
Immune System HI=
0.8
Sub-slab
Sub-slab
Trichloroethylene (TCE)
Developmental, Immune
--
99
--
99
Sub-slab Hazard Index (HI) Total=
99
Developmental HI=
99
Immune System HI=
99
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P005 (Residential)
Medium
Sampling
Exposure
Exposure
Contaminant of Concern
Primary target Organ
Non-Carcinogenic Hazard Quotient
Page 5 of 9
-------
Timeframe
Medium
Point
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
2022 Heating
Season
Indoor Air
Indoor Air
Trichloroethylene (TCE)
Developmental, Immune
-
0.3
-
0.3
Indoor Air Hazard Index (HI) Total=
0.3
Developmental HI=
0.3
Immune System HI=
0.3
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P006 (Residential)
Medium
Sampling
Timeframe
Exposure
Medium
Exposure
Point
Contaminant of Concern
Primary target Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
2022 Heating
Season
Sub-slab
Sub-slab
Trichloroethylene (TCE)
Developmental, Immune
-
0.3
-
0.3
Sub-Slab Hazard Index (HI) Total=
0.3
Developmental HI=
0.3
Immune System HI=
0.3
Bolded cells indicate noncancer risk estimates exceedances (HI>1) associated with indoor air or sub-slab exposure
Shaded cells indicate exceedances of the noncancer hazard threshold of 1 for indoor air
Page 6 of 9
-------
Table 6
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P001 (Residential)
Medium
Sampling
Timeframe
Exposure
Medium
Exposure
Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
2008/2009
Fleating
Season
Air
Indoor Air
Tetrachloroethylene (PCE)
-
1.57E-05
-
1.57E-05
Trichloroethylene (TCE)
-
2.51E-05
-
2.51E-05
Indoor Air Cancer Risk=
4.1E-05
Sub-slab
Tetrachloroethylene (PCE)
-
1.17E-05
-
1.17E-05
Trichloroethylene (TCE)
-
1.88E-05
-
1.88E-05
Sub-slab Cancer Risk=
3.1E-05
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P001 (Residential)
Medium
Sampling
Timeframe
Exposure
Medium
Exposure
Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
2009/2010
Fleating
Season
Air
Indoor Air
Tetrachloroethylene (PCE)
-
4.44E-06
-
4.44E-06
Trichloroethylene (TCE)
-
6.48E-06
-
6.48E-06
Indoor Air Cancer Risk=
1.1E-05
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P002 (Residential)
Medium
Sampling
Timeframe
Exposure
Medium
Exposure
Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
2008/2009
Fleating
Season
Air
Indoor Air
Tetrachloroethylene (PCE)
-
1.85E-06
-
1.85E-06
Trichloroethylene (TCE)
-
5.85E-06
-
5.85E-06
Indoor Air Cancer Risk=
7.7E-06
Sub-slab
Tetrachloroethylene (PCE)
-
3.89E-06
-
3.89E-06
Trichloroethylene (TCE)
-
7.53E-06
-
7.53E-06
Sub-slab Cancer Risk=
1.1E-05
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P002 (Residential)
Medium
Sampling
Timeframe
Exposure
Medium
Exposure
Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
2009/2010
Fleating
Season
Air
Indoor Air
Tetrachloroethylene (PCE)
-
3.43E-06
-
3.43E-06
Trichloroethylene (TCE)
-
3.76E-06
-
3.76E-06
Indoor Air Cancer Risk=
7.2E-06
Scenario Timeframe: Current/Future
Receptor Population: Commercial Worker (adult)
Property Identifier: P003 (Commerciall)
Medium
Sampling
Timeframe
Exposure
Medium
Exposure
Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
2020/2021
Fleating
Season
Air
Indoor Air
Trichloroethylene (TCE)
-
2.37E-06
-
2.37E-06
Indoor Air Cancer Risk=
2.4E-06
Sub-slab Trichloroethylene (TCE) — 2.91E-04
2.91E-04
Sub-slab Cancer Risk=
2.9E-04
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P005 (Residential)
Medium
Sampling
Timeframe
Exposure
Medium
Exposure
Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Page 7 of 9
-------
Groundwater
2022 Heating
Season
Air
Indoor Air Trichloroethylene (TCE) — 1.15E-06
1.15E-06
Indoor Air Cancer Risk=
1.2E-06
Scenario Timeframe: Current/Future
Receptor Population: Resident (adult/child)
Property Identifier: P006 (Residential)
Medium
Sampling
Timeframe
Exposure
Medium
Exposure
Point
Contaminant of Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
2022 Heating
Season
Air
Sub-slab
Trichloroethylene (TCE)
-
1.13E-06
-
1.13E-06
Sub-Slab Cancer Risk=
1.1E-06
Bolded cells indicate cancer risk estimate exceedances (cancer risk>10"4) associated with indoor air or sub-slab exposure
Page 8 of 9
-------
Table 7
Cost Estimate
Description
Quantity
Unit
Unit Cost
Cost
Construction Activities
Vapor Intrusion Sampling, Testing and
Analysis
2
Events
$52,500
$105,000
Professional and Technical Services
Remedial Design
1
LS
$10,000
$10,000
Project and Construction Management
1
LS
$15,000
$15,000
Vapor Intrusion Mitigation Systems
Residential Installations
100
EA
$7,215
$721,500
Capital Costs Subtotal
$851,500
10% Legal, Administrative, Engineering Fees
$85,200
20% Contingencies
$187,300
Capital Cost Total
$1,124,000
Annual O&M Costs
Average Annual O&M
10
EA
$1,608
$16,100
Annual Cost Subtotal
$16,100
10% Legal, Administrative, Engineering Fees
$1,600
20% Contingencies
$3,500
Annual Cost Total
Total Cost
$21,200
| $1,145,200
Note: Costs included in this estimate were obtained from EPA personnel experienced with vapor intrusion
projects, mitigation system installations, and maintenance of those systems.
Key:
EA = Each
LS = Lump Sum
-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
09/27/2024
REGION ID: 02
Site Name: MEEKER AVENUE PLUME
CERCLIS ID
OUID
SSID
Action
NYN000203407
02
A29M
DocID:
Doc Date:
Title:
Image
Count:
Doc Type:
Addressee Name/Organization:
Author Name/Organization:
701406
09/27/2024
ADMINISTRATIVE RECORD INDEX FOR OU2 FOR THE
MEEKER AVENUE PLUME SITE
3
Administrative Record Index
(US ENVIRONMENTAL PROTECTION
AGENCY)
190145
06/01/2015
OSWER TECHNICAL GUIDE FOR ASSESSING AND
MITIGATING THE VAPOR INTRUSION PATHWAY FROM
SUBSURFACE VAPOR SOURCES TO INDOOR AIR
267
Laws/Regulations/Guidance
543567
09/01/2021
HRS DOCUMENTATION RECORD FOR THE MEEKER
AVENUE PLUME SITE
270
Report
DESIR,JAMES (US ENVIRONMENTAL
PROTECTION AGENCY)
543568
09/01/2021
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ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
09/27/2024
REGION ID: 02
Site Name: MEEKER AVENUE PLUME
CERCLIS ID
OUID
SSID
Action
NYN000203407
02
A29M
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ADMINISTRATIVE RECORD INDEX OF DOCUMENTS
FINAL
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REGION ID: 02
Site Name: MEEKER AVENUE PLUME
CERCLIS ID
OUID
SSID
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02
A29M
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FINAL QUALITY ASSURANCE AND PROJECT PLAN
ADDENDUM FOR THE VAPOR INTRUSION
INVESTIGATION SAMPLING FOR OU2 FOR THE MEEKER
AVENUE PLUME SITE
204
Work Plan
(AECOM)
718459
03/31/2024
DRAFT FINAL FOCUSED FEASIBILITY STUDY FOR OU2
FORTHE MEEKER AVENUE PLUME SITE
60
Report
(US ENVIRONMENTAL PROTECTION
AGENCY)
701407
04/05/2024
PROPOSED PLAN FOR OU2 FORTHE MEEKER AVENUE
PLUME SITE
13
Publication
(US ENVIRONMENTAL PROTECTION
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APPENDIX IV
STATE LETTER OF CONCURRENCE
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NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
Division of Environmental Remediation, Office of the Director
625 Broadway, 12th Floor, Albany, New York 12233-7011
P: (518) 402-9706 I F; (518) 402-9722
www.dec.ny.gov
September 18, 2024
Mr. Pat Evangelista - Director
Superfund and Emergency Management Division
U.S. Environmental Protection Agency
290 Broadway, 19th Floor
New York, NY 10007
RE: Meeker Avenue Plume Superfund Site
Operable Unit 2, Kings County, New York
NYSDEC Site ID No.: 224121
Dear Mr. Evangelista:
The New York State Departments of Environmental Conservation (NYSDEC) and
Health (NYSDOH) have reviewed the United States Environmental Protection Agency's
September 2024, Draft Superfund Record of Decision for the Meeker Avenue Plume
Operable Unit 2 (OU2), Kings County, New York. Based on that review, we understand
that the selected remedy is an interim action to address the potential for exposure via
the soil vapor intrusion pathway while the Remedial Investigation/Feasibility Study for
Operable Unit 1 is ongoing, and that this does not constitute the final remedy for the
site.
Based on the information currently available, NYSDEC agrees that the selected
Alternative 2 of this Superfund Record of Decision meets the threshold criteria and is
protective of human health and the environment. Therefore, the NYSDEC concurs with
the EPA's selected alternative.
ec: Janet Brown, ianet.brown@dec.nv.gov
Scott Deyette, scott.devette@dec.nv.gov
Heide-Marie Dudek, heidi.dudek@dec.ny.gov
Michael Haggerty, michael.haggertv@dec.nv.gov
Wendy Kuehner (DOH) wendv.kuehner@health.nv.gov
Sincerely,
Andrew 0. Guglielmi, Director
Division of Environmental Remediation
YORK Department of
STATE Environmental
¦£» Conservation
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Scarlett McLaughlin (DOH) sara boqardus@health nv gov
Shaun Surani (DOH, shaun.syrani@health.nv.gov
Angela Carpenter (EPA) carpenter.angela@epa.gov
Stephanie Vaughn (EPA) vaughn.stephanie@epa.gov
Rupika Ketu (EPA) Ketu.Rupika@epa.gov
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APPENDIX V
RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
Meeker Avenue Plume Superfund Site
Operable Unit 2
Brooklyn, New York
INTRODUCTION
This Responsiveness Summary provides a summary of the public's comments and concerns
regarding the Proposed Plan for Operable Unit 2 (OU2) of the Meeker Avenue Plume Superfund
site (site), and the U.S. Environmental Protection Agency's (EPA's) responses to those
comments. All comments summarized in this document have been considered in EPA's decision
for the selection of a remedy for OU2 at the site under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA).
This Responsiveness Summary is divided into the following sections:
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
This section provides the history of community involvement and interests regarding the site.
II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS,
COMMENTS, CONCERNS, AND RESPONSES
This section contains summaries of written and verbal comments received by EPA at the public
meeting and during the public comment period, and it contains EPA's responses to these
comments.
The last section of this Responsiveness Summary includes attachments which document public
participation in the remedy selection process for this site. They are as follows:
Attachment A contains the Proposed Plan that was distributed to the public for review and
comment;
Attachment B contains the public notice that was published in the Brooklyn Daily Eagle, on the
Nowy Dziennik website, and via the Greenpointers newsletter on April 5, 2024, and in Abecadlo
on April 12, 2024. It also includes the notice of extension published via the Greenpointers
newsletter on April 12, 2024, in the Brooklyn Daily Eagle and in Abecadlo on April 19. 2024, and
in Nowy Dziennik on April 20, 2024. The notices were published in English, as well as in Spanish
and Polish for the non-English speaking communities within and surrounding the Meeker Avenue
Plume site;
Attachment C contains the public comments received during the public comment period; and
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Attachment D contains the transcript of the public meeting held on April 16, 2024 at the St.
Stanislaus Kostka Church, Brooklyn, New York.
I. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Since the inclusion of the site on the National Priorities List in 2022, public interest in the site
has been high. EPA has strongly encouraged and received public input since the listing of the
site. EPA published a Community Involvement Plan in 2023. This 2023 Community
Involvement Plan outlines specific outreach tools to facilitate transparent and accessible
communication with the community in the decision-making process and to solicit public input on
site activities. EPA also sends out monthly email updates to the community to keep them
informed of ongoing activities at the site.
In 2023, EPA provided Technical Assistance Services for Communities (TASC) support to the
Meeker Avenue Plume Community Advisory Group (CAG) for strategy, engagement, and
outreach. The TASC contract was amended in 2024 to provide the CAG with technical support,
interpretation and translation services, and administrative support on an as-needed basis.
EPA also provides the support of a neutral facilitator to the CAG. The neutral facilitator assisted
in the formation of the CAG, including development of the mission statement, structure, and
operating procedures. The neutral facilitator also assists the CAG in planning and conducting
meetings.
The CAG holds its meetings in the surrounding community and serves in a technical review and
advocacy capacity on behalf of the community. The CAG membership includes representatives
from local businesses, environmental organizations, community residents, and other interested
parties from Brooklyn. The CAG regularly conducts outreach in the community to encourage
public participation in site-related activities and engages social-media outlets to ensure project
information is broadcast widely. In addition, the CAG maintains a webpage and an email list to
disseminate project-related information, including the dates of upcoming meetings and site
updates.
II. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS,
CONCERNS AND RESPONSES
Comments and/or questions were received at the public meeting, in addition to two written letters
(via email), one from the Meeker Avenue Plume Community Advisory Group (CAG) and one
from Brooklyn Community Board No. 1. North Brooklyn Neighbors, a local environmental group,
also indicated their support for the CAG's comments via email. In addition, one comment was
received via email during the comment period. Copies of the comment letters and emails are
provided in Attachment A, and a copy of the public meeting transcript is provided in Attachment
D. A summary of the significant comments provided at the public meeting and in writing, as well
as EPA's responses to those comments, are provided below.
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The sign-in sheets indicate that approximately 25 people attended the April 16, 2024 public
meeting. The meetings' attendees included residents, Community Advisory Group members, local
business representatives, interested community members, journalists, elected officials, and
representatives from the New York State Department of Environmental Conservation and the New
York State Department of Health.
Part 1: Written Comments
A comment letter (via electronic format) was submitted by the Meeker Avenue CAG. The letter
contained several comments, which are summarized below, along with EPA responses. A
representative of North Brooklyn Neighbors sent a separate email reiterating the CAG's
concerns and expressing general support for the action.
Comment 1: The CAG is concerned that access for testing is being granted at too slow of a rate
and would like to know how EPA intends to improve its success rate at getting access to test
buildings at risk of vapor intrusion within the Study Area. They would like to see new strategies
for outreach, including to non-residential properties.
EPA Response 1: EPA is actively exploring ways to improve the outreach approach at
the site. The Community Involvement Plan is being updated and further developed and
the Region intends to discuss it with the community prior to the next winter heating
season to explore additional strategies for increasing participation. EPA appreciates the
CAG's offer to continue helping with outreach and understands that our mission is to
protect the community from elevated risks posed by site-related contamination. Cleanup
efforts at the site are being conducted in an expedited fashion on parallel tracks to (i)
address the immediate risks posed by vapor intrusion and (ii) determine the full nature
and extent of contamination at the site so that the sources of the contamination leading to
vapor intrusion can be addressed. Signature of this ROD will give the Region the ability
to quickly mitigate any vapor intrusion concerns that are discovered, and the ongoing
groundwater investigation will help to better focus ongoing outreach efforts on areas
where vapor intrusion is most likely to occur. The discovery and mitigation of
unacceptable risks in indoor air at residential and non-residential structures resulting from
site-related contamination is the Region's top priority for the site.
Comment 2: The CAG would like clarity on how realistic it would be for EPA to compel testing
in a systematic way.
EPA Response 2: EPA will consider the need for use of its enforcement authorities at
every property where access is sought and not granted. EPA has the ability to compel
access to properties to conduct vapor intrusion sampling and is trying to do so in a
systematic and balanced manner, taking into consideration our current understanding of
the nature and extent of contamination at the site, as well as people's individual rights to
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privacy and autonomy. As mentioned in the response to Comment 1, cleanup efforts at
the site are being conducted on two tracks. As we gain a better understanding of where
contamination concentrations are elevated in the subsurface, we can use that information
to better focus our outreach efforts, including our use of access authorities if determined
to be appropriate. Other reasons EPA may decide to utilize legal authority to gain access
include, but are not necessarily limited to, the construction characteristics of a building
and the presence of sensitive receptors in the building (e.g., day care facilities, schools or
senior centers). While multiple lines of evidence can and will be used by EPA in making
determinations about where and when to use our access authorities, it must be noted that
vapor intrusion issues do not necessarily follow a clear pattern and two adjacent buildings
can have different results (i.e., one could be found to have a vapor intrusion concern and
the neighboring building could not). While testing as many properties as possible
overlying the plume of contamination is ideal, note that vapor intrusion impacts occur on
a structure-by-structure basis and the lack of testing at any individual property will not
impact EPA's ability to mitigate concerns at the neighboring properties, if needed.
Comment 3: The CAG would like to know the number of properties where access was refused.
EPA Response 3: EPA has been going through a systematic process of reaching out to
potentially impacted properties within the Study Area. A review of lot and block tax
maps shows that there are an estimated 943 lots within the preliminary Study Area. Not
every one of these lots necessarily has a structure, so this would be an outside estimate of
how many structures are potentially impacted. Lot and block maps also do not tell us how
many individual units or businesses are potentially impacted (for example, any individual
lot could have multiple basement and first floor units that require testing). Of these lots,
we know that prior to EPA's direct involvement with the site in March 2022, NYSDEC
had tested 166 buildings and mitigated 26 of them for vapor intrusion impacts. If we very
conservatively assume that NYSDEC did not reach out to any other properties during
their time as lead agency for the site from 2007 to 2022 (which is not actually the case),
then this leaves approximately 700 structures that may or may not have ever been
contacted by NYSDEC or EPA at the time that the site listed on the National Priorities
list in March 2022.
EPA has been working with the City of New York to compile mailing addresses for these
remaining properties and has sent informational postcards and/or letters to more than 500
properties since March 2022. EPA has also tried several additional ways to obtain
voluntary access to these properties, including going door-to-door on multiple occasions,
making phone calls, participating in public meetings, tabling at a local farmer's market
and library, and speaking with local sources of news and information. We have also
reached out via social media. Several members of the community have assisted with these
efforts, which EPA greatly appreciates.
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EPA estimates that we have communicated in some direct way (i.e., through mailings,
door-to-door, meetings, calls, in-person) with occupants and/or owners of approximately
700 individual properties in or near the preliminary study area since the site was listed in
2022. Unfortunately, we have gained access to only 40 individual units in 35 structures
through these efforts to date, plus all 11 buildings of Cooper Park Houses and P.S. 110.
That said, the vast majority of properties that we have not yet gained access to have not
denied access - they have simply not granted it yet. The number of outright denials,
which might be counted as people explicitly saying or writing they would not provide
access, as well as people that have hung up the phone on us, is relatively small; only
approximately 25 individuals have fallen into the outright denial category thus far.
Comment 4: The CAG submitted several comments regarding the Remedial Action Levels
(RALs) included in this decision document. In particular, the CAG asked that different (lower)
RALs be considered for use at the site.
EPA Response 4: The individual comments regarding RALs submitted by the CAG are
summarized and responded to below. In general, EPA wants to clarify that the RALs are
only one line of evidence that are being used in determining if mitigation is needed at any
individual property. As is stated in the ROD, the RALs represent current EPA Vapor
Intrusion Screening Levels (VISLs) set at a target Hazard Quotient (HQ) of 1, which falls
midway between EPA's cancer risk range of lxlO-6 to lxlO-4. They are developed using
health-protective assumptions and toxicity information for each individual chemical that
is intended to be protective of all individuals, including sensitive subgroups such as
pregnant women, children and the elderly, so that they may be exposed without adverse
effects over a lifetime or part of a lifetime, incorporating an adequate margin of safety.
The VISLs, and thus the RALs, are only screening values. They will be considered with
other Site-specific lines of evidence such as subsurface geology and hydrogeology,
subsurface contamination levels, the structural characteristics of each building, and
proximity to other impacted structures in determining whether there is a need for
remedial action. The need for remedial action will also be determined in consultation
with NYSDEC and the NYSDOH, including consideration of NYSDOH's Guidance for
Evaluating Soil Vapor Intrusion in the State of New York.
The RALs will not be used as a discrete line to determine if mitigation is needed or not;
rather, each individual property will be evaluated on a case-by-case basis to determine if
mitigation is warranted based on current and reasonably anticipated future use. EPA will
err on the side of protectiveness when making these determinations and the determination
to mitigate at any individual property could be made even if there are no RAL
exceedances if the other lines of evidence, such as those described in the previous
paragraph, suggest it would be appropriate, in consultation with NYSDEC, NYSDOH
and EPA's risk assessor.
Comment 5: The CAG asks that applicable or relevant and appropriate requirements (ARARs)
be taken into consideration when establishing RALs for the site. They note that Section 121(d) of
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the Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA) requires that on-site remedial actions attain or waive federal environmental ARARs,
or more stringent state environmental ARARs, upon completion of the remedial action, and point
out that NYSDEC's action levels are more stringent than EPA's RALs. The CAG also makes the
point that Region 9 uses lower values than Region 2 for RALs.
EPA Response 5: In October 2006, NYSDOH published "Guidance for Evaluating Soil
Vapor Intrusion in the State of New York"
(https://www.health.nv.gov/environmental/indoors/vapor intrusion/docs/2006 guidance,
pdf). The preface to this document, which has been updated over the years, most recently
in February 2024, states that it has been prepared by NYSDOH in consultation with
NYSDEC and that is intended as "general guidance for parties evaluating soil vapor
intrusion in the State of New York." The guidance goes on to state directly that it is not
"a regulation, rule or requirement." As such, this document would not be considered an
ARAR for the site. Further, EPA Region 9 guidelines would not be considered ARARs
for EPA Region 2. However, the guidance documents referred to in the comment are to
be considered (TBC) in the Superfund remedy selection process. As such, EPA will
consider these values in remedial decision making along with the multiple lines of
evidence discussed above.
Comment 6: The CAG stated that the residential RAL for TCE should be set to 2 ug/m3 or
below based on EPA Region 9 recommendations found in this document:
https://archive.epa.gov/region9/superfund/web/pdf/r9-tce-interim-action-levels-response-recs-
mem ; and the NYSDOH recommendation that "TCE concentrations in the air not
exceed 2 ug/m3.
EPA Response 6: The EPA Region 9 memo that is referenced by the CAG is an archived
document from 2014 and does not include the most up to date methodology/exposure
parameters for calculating VISLs, which are typically updated twice a year by EPA.
Current VISLs can be found here: https://www.epa.gov/vaporintrusion/vapor-intrusion-
screening-level-calculator
Region 2's current residential VISL for TCE is 2.1 ug/m3, which is only slightly higher
than the Region 9 number and the NYSDOH numbers referenced by the CAG, and is
consistent with EPA's current Vapor Intrusion guidelines. Further, as is explained in
EPA's response to Comment 4, above, the decision of whether to mitigate any particular
property will be made based on multiple lines of evidence and in consultation with
NYSDEC, NYSDOH and EPA's risk assessor.
Comment 7: The CAG thinks the commercial/industrial RAL should be more stringent for both
TCE and PCE. The commercial/industrial RALs in the Proposed Plan are based on an 8-hour
workday. Instead, they recommend that a 10-hour workday be assumed, particularly because of
the number of people who both live and work in the neighborhood, and the frequency with which
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people work greater than 8-hour workdays. In addition, the CAG notes that assuming a 10-hour
workday would bring the RAL for TCE closer to the Region 9 recommendation referenced in
Comment 6, above.
EPA Response 7: EPA's commercial RALs are based on atypical workday and are
considered protective for most workers including sensitive subpopulations, such as
pregnant women and the elderly. Response #20 discusses in more detail the conservative
exposure parameters used to calculate commercial/industrial RALs. As stated in the
proposed plan and ROD, the commercial/industrial RALs assume an eight-hour workday,
which is protective of most non-residential settings and can be adjusted as needed to
account for property-specific conditions. If the Region were to become aware of a
situation where 10 or 12-hour workdays were the norm, the RAL could be adjusted to
account for that. A RAL for a 10-hr workday would be 7.0 ug/m3 for TCE and 140 ug/m3
for PCE. Assuming a 12-hr workday, the RALs would be 5.8 ug/m3 and 120 ug/m3 for
TCE and PCE, respectively. The indoor air RALs for both TCE and PCE based on an
8hr, lOhr and 12hr days are displayed in the table below. The Region understands and
agrees that many workers spend more than 8 hours a day at their place of business and, in
addition, that many people both live and work in the neighborhood, often in the same
space (i.e., they work from home), in which case a residential RAL might be more
appropriate. Property-specific determinations will be made on a property-specific basis
based on multiple lines of evidence. As is stated in the ROD, "whether to apply the
residential RAL or Commercial/Industrial RAL will also be determined on a case-by-case
basis, in consultation with NYSDEC and NYSDOH. In general, EPA understands that
many properties that are zoned for non-residential use may be used, either regularly or
from time-to-time, in what would be more consistent with residential exposure
assumptions. The residential RALs may be used at any property, residential or non-
residential, if there is reason to believe the commercial/industrial RALs are not
sufficiently conservative, either under current or reasonably anticipated future use
scenarios." These decisions will also be made in consultation with EPA's risk assessor.
Contaminant
of
Concern
Commercial/Industrial Remedial
Action Level, Indoor Air
(ug/m3)
8hr
lOhr
12hr
TCE
8.8
7
5.8
PCE
180
140
120
Comment 8: The CAG thinks the residential RAL should be more stringent for PCE and notes
that it seems to correspond not to a one-in-a-million cancer risk, but instead are pegged to non-
cancer risk. The CAG expressed that the community deserves to be granted the utmost protection
and they are concerned that the EPA allows a cancer risk range of lxlO-4 and lxlO-6, but the
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RALs do not correspond to the most stringent standard. The CAG requests that the RAL for PCE
be set to the NYSDOH value of 30 ug/m3 or less.
EPA Response 8: EPA's current residential VISL based on a 10"6 cancer risk for PCE is
42 ug/m3, which is consistent with EPA's current Vapor Intrusion guidelines and based
on the most up-to-date methodology/exposure parameters for calculating VISLs. As
stated in the Role of the Baseline Risk Assessment in Superfund Remedy Selection
(https://www.epa.gov/sites/default/files/2015-ll/documents/baseline.pdf):
"Generally, where the baseline risk assessment indicates that a cumulative site risk to an
individual using reasonable maximum exposure assumptions for either current or future
land use exceeds the 10"4 lifetime excess cancer risk end of the risk range, action under
CERCLA is generally warranted at the site. For sites where the cumulative site risk to an
individual based on reasonable maximum exposure for both current and future land use is
less than 10"4, action generally is not warranted, but may be warranted if a chemical
specific standard that defines acceptable risk is violated or unless there are
noncarcinogenic effects or an adverse environmental impact that warrants action. A risk
manager may also decide that a lower level of risk to human health is unacceptable and
that remedial action is warranted where, for example, there are uncertainties in the risk
assessment results. Records of Decision for remedial actions taken at sites posing risks
within the 10"4 to 10"6 risk range must explain why remedial why remedial action is
warranted."
The noncancer hazard falls within the risk range established in the National Contingency
Plan (NCP) for taking action. As such, it serves as a useful benchmark for determining an
action is necessary; however, as is explained in EPA's response to Comment 4, above,
the decision of whether to mitigate any particular property will be made based on
multiple lines of evidence and in consultation with NYSDEC, NYSDOH and EPA's
team, including the risk assessor.
Comment 9: At the May 30, 2024, presentation by the EPA, results of some of the well
sampling were presented. A select list of contaminants found in the groundwater was presented,
many of which are known to be harmful to human health. While the CAG applauds the
investigation of PCE and TCE in the area, given the profusion of other harmful contaminants, the
CAG is concerned that other contaminants that may negatively affect our public health are not
being properly considered. When the EPA does indoor air sampling, does it test for other
contaminants? If so, which ones? If levels of these contaminants are found at harmful
concentrations, what is done? The CAG requests that the EPA take full advantage any time they
have access to a property and ensure the inhabitants are protected not just from PCE and TCE,
but also from other potentially harmful compounds, especially those that have been found to be
present in the groundwater sampling.
EPA Response 9: When EPA conducts vapor intrusion sampling in residential and non-
residential buildings, EPA analyzes the samples collected for multiple volatile organic
compounds (VOCs). The contaminant list can vary depending on which laboratory is
selected to conduct the analysis. However, there are typically 50 to 55 VOCs that are
analyzed for during each event. All of these compounds are evaluated to see if they are
related to the Site and compared to EPA's vapor intrusion screening levels in the same
fashion as TCE and PCE.
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The full list of contaminants is available at the following link:
https://www3.epa.gov/ttn/amtic/files/ambient/airto> f.
EPA understands the community would like EPA to evaluate contaminants other than
TCE and PCE, but it is important to note this is an interim remedial decision based on the
information currently available for the site, which shows TCE and PCE as the primary
contaminants in groundwater contributing to vapor intrusion risk. As is stated in the
ROD, if additional contaminants of concern are identified during the ongoing 0U1 RI/FS
that may adversely affect indoor air, EPA's VISLs and NYSDOH guidance will be
reviewed and, if warranted, appropriate mitigative actions will be taken.
Comment 10: The CAG thinks it is vital that ARARs be applied for this decision even though
they understand they are not required since this is an interim decision. They go on to explain that
EPA has stated numerous times that the reason that it is addressing vapor intrusion now is
because it is an immediate health risk, but, as of yet, there is no timeline or plan for an
underlying cleanup or removal action. As such, it is unknown for how long the community will
exist with only this proposed plan to protect its health. Because of all these unknowns and the
EPA's own indications that the health risks are immediate, the CAG believes that the standards
of ARARs should apply. Additionally, the CAG went on to note that the community has been
very supportive of and even pushed for the site to move from a state-level site to the National
Priorities List, but are concerned now if this move means less protective health standards than
were used under the state cleanup will be applied, stating that this goes against all the reasons
that the site was elevated to a national status.
EPA Response 10: The proposed plan is an interim remedial action that is intended to
reduce site risks early in the Superfund site remediation process. EPA's preferred
alternative includes engineering measures and vapor intrusion mitigation systems that do
not treat the subsurface vapor source, but rather serve to prevent contaminated soil vapors
from entering and/or accumulating in structures at concentrations that represent a threat,
or a potential threat, to human health. Because the remedy for OU2 is considered an
interim remedy, identification of ARARs is not required at this time. That said, ARARs
and TBCs will be considered in decision making. Regarding the CAG's comment on the
health standards, please refer to EPA responses 4 through 8. To summarize, the RALs
are just one line of evidence that will be considered in concert with other factors
including site-specific, and property-specific, lines of evidence such as subsurface
geology and hydrogeology, subsurface contamination levels, the structural characteristics
of each building, and proximity to other impacted structures in determining whether there
is a need for mitigation. The need mitigation will also be determined in consultation with
NYSDEC and the NYSDOH, including consideration of NYSDOH's Guidance for
Evaluating Soil Vapor Intrusion in the State of New York, and the EPA risk assessor will
be consulted on each individual decision.
A timeline for the OU1 RI/FS has not yet been established. However, vapor intrusion and
groundwater investigations are currently in progress. Given the scope of the
investigation, EPA expects that the OU1 RI/FS process will take a number of years to
complete. EPA acknowledges community's frustration with the process, however, EPA's
goal is to complete the OU1 RI/FS as thoroughly and quickly as possible on two parallel
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tracks, as described in the response to Comment 1. Regarding the CAG's comment on the
health standards, please refer to EPA responses 4 through 8. To summarize, the RALs
are just one line of evidence that will be considered in concert with other factors
including site-specific, and property-specific, lines of evidence such as subsurface
geology and hydrogeology, subsurface contamination levels, the structural characteristics
of each building, and proximity to other impacted structures in determining whether there
is a need for mitigation. The need mitigation will also be determined in consultation with
NYSDEC and the NYSDOH, including consideration of NYSDOH's Guidance for
Evaluating Soil Vapor Intrusion in the State of New York, and the EPA risk assessor will
be consulted on each individual decision.
Comment 11: The CAG believes that soil gas vapor testing should be implemented in addition
to soil vapor intrusion, since it can be done in the public right of way and would provide some
data on how likely a vapor intrusion risk is at a particular property, even if access to that property
is denied. This would provide additional information to help the EPA determine whether it is
vital to consider using additional measures to gain access to the property for testing. Depending
on the underlying properties of soil in different parts of the neighborhood, the well sampling
might not be a good proxy for soil gas vapor and potential vapor intrusion. Without a larger data
set of results from indoor air testing, The CAG doesn't feel confident that a plan based on such a
small sample of properties is the best for the community. For example, soil gas vapor testing
could be used at residences where tenants have requested testing, but the property owner has not
granted access, should the EPA be unwilling to use its administrative authority to force access.
EPA Response 11: NYSDEC has collected nearly 1,000 soil gas samples and has made
that data available to EPA for evaluation, which EPA considers a substantial dataset.
EPA is in the process of evaluating this soil gas data and will collect additional samples if
needed. Collecting soil vapor samples from outside of buildings does not provide a 1:1
correlation to soil vapor concentrations beneath an adjacent building. As indicated in
EPA's Technical Guide for Assessing and Mitigating the Vapor Intrusion Pathway from
Subsurface Vapor Sources to Indoor Air (https://www.epa.gov/sites/default/files/2015-
09/documents/oswer-vapor-intrusion-technical-guide-final.pdf), "individual exterior soil
gas samples cannot generally be expected to accurately estimate sub-slab or indoor air
concentrations." Therefore, EPA's priority thus far has been to conduct sub-slab and
indoor air sampling to address any immediate health concerns and groundwater sampling
to determine the nature and extent of the groundwater plume.
Comment 12: The CAG requests that the EPA be willing to test apartments on upper floors in
elevator buildings and buildings with other vertical conduits. It has been found that elevators can
increase the movement of vapors throughout a building. The EPA has stated on numerous
occasions that testing every building within the investigation area would be an aspirational goal.
Since there is evidence that upper-level apartments in elevator buildings may have greater risk of
indoor air issues due to vapor intrusion, the CAG sees no reason why the EPA should turn away
willing participants of this type
EPA Response 12: The soil, soil gas, and groundwater at the Site are contaminated with
CVOCs. CVOCs are a subset of volatile organic compounds (VOCs), which are
substances that typically evaporate at room temperature. They can affect the indoor air of
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properties located in close proximity to contaminated areas by entering the indoor air of
structures through small cracks, pipes or other points of entry. Based on how soil vapors
usually enter a building , indoor air samples collected from the lowest level floor and
basement typically exhibit the highest concentrations of vapors. If EPA were to find that
the concentration of contaminants on the first floor are unusually elevated, EPA could
elect to collect additional samples from higher floors to ensure that these locations are not
presenting an unacceptable risk to those living on those floors. EPA is aware that in
some situations that elevators and elevator shafts can provide preferential pathways for
vapors and will consider testing of upper floors in buildings with elevators.
Comment 13: The CAG believes the EPA should do vapor intrusion sampling outside of the
winter heating season. The EPA should identify test sites where indoor air is sampled during the
winter heating season and at other times as well, especially during times of heavy rainfall to
assess whether winter heating season testing is indeed the best method for determining risk of
vapor intrusion. Seasonal variability of factors such as weather and rainfall can affect vapor
intrusion. From a June 2015 document of the EPA's Office of Solid Waste and Emergency
Response, "Because fluctuations in water table elevation can lead to elevated vapor
concentrations in the vadose zone, EPA also recommends that "near source" soil gas sampling
(and possibly a soil gas survey) be considered in different seasons that coincide with
groundwater fluctuations."
EPA Response 13: Indoor air samples are typically collected during the winter heating
season because soil vapor intrusion is more likely to occur when a building's heating
system is in operation, doors and windows are closed and buildings are generally less
ventilated. When buildings are closed up and heated, a difference in temperature
between the inside and outdoor air induces a stack effect, pulling warm air from lower to
higher floors. Vapor intrusion can be enhanced as the air is replaced in the lower parts of
the building. In New York State, heating systems are generally expected to be operating
routinely from November 15th to March 31st. However, these dates are not absolute.
EPA can collect vapor intrusion samples outside of the winter heating season if EPA
determines the circumstances warrant testing. However, these samples could not be used
to rule out exposure. Samples during the heating season would still be necessary to verify
indoor concentrations under a worst-case scenario.
Comment 14: The CAG believes that given that TCE exposure during the first few weeks of
pregnancy increases the risk of heart damage to a developing fetus, testing should be done in
homes at any season if there is a person of childbearing age living in the home. The risk is
greatest between weeks 2 and 8 of pregnancy, which is often before a person may even know
that they are pregnant. Thus, to reduce the risk of birth defects, it would make sense to ensure
safe living and working conditions for any person who may become pregnant.
EPA Response 14: EPA evaluates each situation on a case-by-case basis and would
consider vapor intrusion sampling if the circumstances warrant testing. Additionally,
Region 2 has a long-standing process for reviewing vapor intrusion data so that
expeditious decisions regarding mitigation can be made, especially in situations where
TCE is a contaminate of concern.
Comment 15: The CAG has questions about how long the results of vapor intrusion testing are
valid. Given that the condition of the foundation, for example, can change with construction
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projects, earthquakes, etc, we are concerned that while initial testing may deem a location "safe,"
the status may change in the future. The CAG would like to see a schedule under which
properties can be retested or a list of changes that would make a property eligible to be retested.
The CAG has seen it suggested that if soil gas vapor tests above a certain threshold, perhaps
mitigation should be suggested in locations even if the indoor air tests "safe" in the event of
future changes to the building.
EPA Response 15: EPA does not have a schedule under which properties would be
retested. Each request that is submitted to EPA for testing is evaluated on a case-by-case
basis, including those requests made when a property has already been tested. Situations
that may lead EPA to retest a property can include, but are not limited to, the
concentrations of compounds detected during a previous sampling event, new vapor
intrusion testing data at neighboring and adjacent properties, significant changes to a
building's construction (i.e., significant remodeling) and/or foundation (i.e., new cracks),
and changes in EPA's understanding of groundwater flow direction and/or groundwater
contaminant concentrations. Also, keep in mind that EPA's long-term goal is to address
the source and/or sources of contamination to reduce the likelihood of vapor intrusion
concerns at the site. As mentioned in EPA Response 10, EPA looks at multiple lines of
evidence when determining whether there is a need for mitigation, including subsurface
geology and hydrogeology, subsurface contamination levels, the structural characteristics
of each building, and proximity to other impacted structures. For example, if EPA finds
that contamination levels in the sub-slab significantly exceed the RALs, but first floor
contamination levels do not exceed the RALs, then EPA may consider whether
mitigation is required.
Comment 16: The CAG is concerned that not all available information is being collected and
analyzed. In particular, the EPA should use all data and wells from the National Grid site to
determine the extent of the plume given that groundwater analysis presented at the May 30,
2024, CAG meeting showed that contamination exists right up against the current boundary of
the plume and the National Grid property. The CAG also believes that there should be better
coordination with the Newtown Creek site in order to gain further information about how the two
sites affect one another.
EPA Response 16: EPA is actively coordinating with property owners in the area to gain
access to sample existing wells and/or to install new wells, including National Grid. EPA
anticipates sampling several of the existing wells on their property in the upcoming fall
2024 groundwater sampling effort. This is a dynamic process and as more data is
collected, it may become apparent that additional sampling locations should be tested.
EPA will continue to keep the CAG informed as more information is developed. EPA's
Meeker Avenue Plume Site proj ect managers work with the EPA's Newtown Creek
project managers to eliminate any duplication of effort, ensure coordination between both
teams, and share data across both sites. EPA also regularly meets with and coordinates
with NYSDEC and NYSDOH.
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A comment letter (via electronic format) was submitted by Brooklyn Community Board No. 1.
Comment 17: Brooklyn Community Board No.l requested that EPA adhere to the more
stringent NYSDEC vapor intrusion chemical contamination thresholds that 1) are lower for TCE
and PCE than those used by EPA and 2) require residential and commercial spaces utilize the
same RALS instead of using higher levels for commercial spaces.
Their letter also voiced that this project is of the utmost concern, not only due the breadth,
severity and complexity of the Meeker Avenue Plume contamination, but because this Superfund
site resides solely within the confines of Brooklyn Community District #1, a district that has a
long history of exposure to toxic sites. The letter expressed concern with the protectiveness of
the RALs that EPA is using and asked that EPA not seek waivers to override the State
guidelines. The letter also explained that it is both normal and pervasive for workers in
commercial work environments to spend more time (very often more than 10 hours) at their
workplace than at their home, and reiterated that it is imperative that residents and workers in the
district receive the same level of protection that the state would provide.
EPA Response 17: EPA appreciates the long history of contamination that is present in
the neighborhoods represented by Community Board No. 1 and understands the distress
this has caused to so many in the area. Very similar concerns regarding the appropriate
RALs to use and the need to follow State regulations were also raised by the Meeker
Avenue Plume CAG. Please see EPA Responses 4 through 10 above.
A member of the community submitted a comment to EPA via e-mail, which is provided below,
along with EPA 's response.
Comment 18: The community member is concerned about access to residential properties for
vapor intrusion sampling. They think that having to get landlord permission to get their
apartment tested makes this testing program useless. As someone with health problems living on
the Meeker Superfund site who wanted to get our building tested, they were unable to do so
because they couldn't get landlord permission. Their building is an old building with many
visible cracks in the facade and ground floor where vapors could easily get through, and there is
also a basement unit. The community member feels that in order for this program to work, a
court order needs to be put in place immediately requiring testing, because when left with a
choice, the overwhelming majority of landlords will not choose to get the space tested. They feel
it is completely unrealistic to think that landlords will comply voluntarily. They voiced that
delays continue to jeopardize the health of the community who actually lives in the superfund
site (the renters).
EPA Response 18: Consent is the preferred method for EPA to obtain property access
for various CERCLA activities including vapor intrusion sampling. However, EPA has
the ability to use other enforcement options, including administrative or judicial orders or
warrants to compel access when consent is not forthcoming or otherwise is denied and
access is necessary. As such, while EPA always seeks access for the purposes of
sampling or mitigation through consent from property owners, a decision by EPA that
access is necessary leading to the use of its access authorities will depend on the facts of
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the situation, including the levels of contamination and exposure scenarios. Please also
see EPA's response to Comment 2 above.
Part 2: Verbal Comments
EPA received a number of verbal comments from community members during the public meeting
held on April 16, 2024. The comments are provided below, along with EPA's responses.
Comment 19: A community member asked EPA to identify and describe briefly the sources of
pollution?
EPA Response 19: EPA is still in the process of identifying source areas for the site as
part of the ongoing OU1 RI/FS. Prior to the site being added to the Superfund list,
NYSDEC had already identified at least six likely source areas and another ten to twenty
additional probable source areas. The uses of these properties vary and will be explored
further during the RI/FS process, but at least one was a used for dry cleaning and another
was a drum reconditioner. EPA is investigating all of these areas and others as part of the
OU1 RI/FS.
To expand upon information provided at the meeting, the properties already designated
by NYSDEC as likely source areas include:
• Former Spic and Span Cleaners and Dyers, Inc. (NYSDEC No. 224129)
• Former Klink Cosmo Cleaners (NYSDEC No. 224130)
• Former Acme Steel / Metal Works (NYSDEC No. 224131)
• Former Acme Steel / Brass Foundry (NYSDEC No. 224132)
• Former Lombardy Street Lacquer and Soap (NYSDEC No. ID No. 224182)
• Former Goodman Bros. Steel Drum Co. Inc (NYSDEC No. 224211)
• 291 Richardson Street Site (NYSDEC No. C224292)
Comment 20: A community member, who also identified as a resident and a member of
Evergreen, asked EPA to explain why the RALs are different between residential and
commercial properties and whether it has to do with how much time people spend in one place
versus the other. They also asked whether the RALs offer the same level of protection and if
more TCE or PCE intrusion is allowed in a space that's commercial because people might spend
less time there.
EPA Response 20: The primary difference between EPA's residential and commercial
RAL calculations is the exposure time per day (residential at 24 hours per day;
commercial at 8 hours per day), the number of days exposed per year (residential at 350
days per year; commercial at 250 days per year) and the number of years exposed
(residential at 26 years; commercial at 25 years).
To expand upon what was said at the meeting, in order for there to be risk, there needs to
be exposure and the longer the exposure, the higher the risk. In general, people spend less
time at their job than they do at home. Therefore, just based on the math, somewhat
higher concentrations for non-residential properties would result in similar risk levels for
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somewhat lower concentrations at residential properties. However, as is noted in EPA
Response 7, the determination of the most appropriate RAL to use for any particular
property will be determined on a case-by-case basis. The residential RALs may be used
at any property, residential or non-residential, if there is reason to believe the
commercial/industrial RALs are not sufficiently conservative, either under current or
reasonably anticipated future use scenarios, and these decisions will be made in
consultation with NYSDEC, NYSDOH and EPA's risk assessor.
Receptor Population
Resident
Commercial/Industrial Worker
Exposure Parameter
Value
Source/Rationale
Value
Source/Rationale
Exposure Time
24 hours/day
whole day
8 hours/day
typical workday; may
be adjusted based on
site-specific
considerations
Exposure Duration
26 years
EPA, 2011; 90th
percentile for current
residence time
25 years
EPA, 1991; 95th
percentile; Bureau of
Labor Statistics, 1990
Exposure Frequency
350 days/year
EPA, 1991; 365
days/year minus 15
days/year spent away
from home
250 days/year
EPA, 1991; assumes
5 days/week for 50
weeks/year (assumes
2 weeks of vacation)
Sources:
EPA, 1991. Human health evaluation manual, supplemental guidance: Standard default exposure factors. OSWER
Directive 9285.6-03
EPA, 2011. Exposure Factors Handbook: 2011 Edition. EPA/600/R-090/052F, September 2011
Comment 21: A community member asked why the Proposed Plan assumes 100 buildings will
require mitigation.
EPA Response 21: In order to develop a cost estimate for the mitigation measures, EPA
used best professional judgement to develop a reasonable estimate of how many
properties may require mitigation. The estimate was based on the number of properties
within the Study Area, as well as the number of properties that have required mitigation
thus far. That said, if more properties require mitigation, they will still be addressed. One
of the assumptions of Superfund decision documents is that the cost estimates used to
support RODs are expected to be accurate within a range of +50 to -30 percent. Further,
even if we do end up going outside of this range (i.e., if we need to mitigate more than
about 150 properties or fewer than about 70) we can modify the decision document so
that we can still complete the work.
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Comment 22: A community member, who also identified as the chair of the Environmental
Protection Committee at Brooklyn Community Board No. 1, asked if EPA could look at the
proximity of a property to other properties that require mitigation and/or to known areas of
elevated concentrations in the soil and/or groundwater, to determine where to focus future vapor
intrusion sampling. The community member pointed out that this type of approach could be
helpful to minimize adverse effects to property owners from testing.
EPA Response 22: EPA will use the information it gathers from the ongoing
groundwater investigation, additional investigations that will be conducted as part of the
OU1 RI/FS, and the State's data, including the extensive network of soil gas wells they
installed mostly in sidewalks to help focus ongoing vapor intrusion testing efforts within
or adj acent to the Study Area.
To supplement what was stated at the meeting, EPA's Technical Guide for Assessing and
Mitigating the Vapor Intrusion Pathway from Subsurface Vapor Sources to Indoor Air
recommends a buffer zone, or distance, of 100 feet (laterally or vertically) for identifying
buildings that are close to a subsurface vapor source or an area with vapor intrusion
concerns that may warrant indoor air sampling. However, this distance is not absolute for
several reasons stated in the guidance document, assumes that significant surface covers
are not present, and assumes that preferential vapor migration routes are absent.
Regardless of the distance every property that EPA evaluates for vapor intrusion testing
is reviewed on a case-by-case basis as discussed in the guidance document. EPA
estimates that there are between 900 and 1,000 properties located within EPA's current
study area.
Comment 23: The same community member asked EPA to clarify approximately how many
residential properties are with the Study Area right now.
EPA Response 23: EPA estimates that there are between 900 and 1,000 properties within
the preliminary Study Area.
Comment 24: A community member, who also identified as a resident within the Study Area,
asked if similar sites exist, in the city or elsewhere, with similar concerns, and if depressurization
systems have been successfully deployed in these other situations. They also asked if there are
other neighborhoods that have similar contaminants with similar concentrations.
EPA Response24: Sub-slab depressurization is a proven mitigation technology that has
been shown to be effective at this Site, as well as at similar sites in EPA Region 2 and
throughout the country (for examples of similar decisions at other sites, see
https://semspub.epa.gov/src/document/02/630395, which relates to the Facet
Enterprises, Inc. site in EPA Region 2, and https://semspub.epa.gov/src/
document/05/986651, which relates to the Keystone Corridor Groundwater
Contamination site in EPA Region 5).
NYSDEC has been working on this Site since 2007 and has used the same technology to
effectively mitigate approximately 26 properties. A section supervisor at NYSDEC in
attendance at the meeting confirmed there are many places within New York City and
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New York State that have soil vapor plumes and that they have been mitigated using the
same technology. They noted that it is a well-documented, standard approach.
Comment 25: A community member, who also identified as an individual that lives and works
in the area, asked if the testing area has remained the same, expanded or contracted based on the
testing EPA has completed thus far.
EPA Response 25: The preliminary Study Area remains the same at this time.
Comment 26: A resident asked if there is currently or will there be an oversight body that
coordinates the various sites in the area, particularly as boundaries of sites may shift, and if so,
who this oversight body would be?
EPA Response 26: The Newtown Creek and Meeker Avenue Plume sites are managed in
the same section at EPA. EPA shares information between the sites and, for example, we
recently coordinated groundwater sampling efforts at both sites. The other Federal
Superfund sites in New York City, including the Wolff-Alport and Gowanus Canal sites,
are also managed in the same office and we coordinate on those sites as well. A section
supervisor at NYSDEC in attendance at the meeting also confirmed that EPA and
NYSDEC coordinate regularly, particularly on the Newtown Creek and Meeker Avenue
Plume sites.
To expand upon what was said at the meeting, NYSDEC also oversees several non-
Federal sites in the area and coordinates regularly with NYSDEC and NYSDOH as well.
Comment 27: A resident asked if there are any conflicts of interest between the responsible
parties and the cleanup efforts, especially since they think NYS is a responsible party.
EPA Response 27: EPA has not yet named any responsible parties for the Meeker
Avenue Plume site. This is a process we are working on and can take some time. The
State of New York is considered our Partner Agency and is not a responsible party for
this site. They asked EPA to take the lead on this site after investigating it for a number
of years. As the responsible party search continues, we may have to figure out how to
address any potential conflicts, particularly if common responsible parties are found
between multiple sites. EPA has a longstanding policy to pursue "enforcement first"
throughout the Superfund cleanup process. This policy promotes the "polluter pays"
principle and helps to conserve the resources of the Hazardous Substance Trust Fund for
the cleanup of those sites where viable responsible parties do not exist.
Comment 28: A member of the Newtown Creek Alliance asked EPA a series of questions
relating to the RALs. The questions/comments can be summarized as:
a. How did EPA arrive at the RALs that are included in the Proposed Plan?
b. While the residential RALs seem to be based on the conservative assumption that people are
in their homes 24 hours a day, 7 days a week, the commercial RALs do not seem
conservative enough. The commenter pointed out that he knows lots of people that work
more than 40 hours per week and that, therefore, having a RAL that is four times less
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protective for non-residential workers is unacceptable, especially given the large number of
commercial/industrial properties in the area.
EPA Response 28: EPA noted that the EPA risk assessor was not able to attend the
meeting so, therefore, detailed, full responses would be provided in the responsiveness
summary. In general, however, EPA pointed out that each property is looked at
holistically and decisions are made on how best to proceed on a case-by-case basis based
on multiple lines of evidence. The RALs are not bright lines that EPA will use to
determine if mitigation and/or additional monitoring is needed.
A representative from NYSDOH that was present at the meeting confirmed that while
they do not necessarily draw a distinction between residential and non-residential uses,
EPA, NYSDEC and NYSDOH will coordinate regularly on making property-by-property
determinations. The section supervisor from NYSDEC also commented that the decision
document memorializing the cleanup plan for this action will be written with sufficient
flexibility to allow for case-by-case decisions to be made.
Please see EPA Responses 4 through 10, above, for further detail in response to these
questions.
Comment 29: A meeting attendee asked a series of questions related to access, testing rate and
outreach. He specifically wanted to know how many properties EPA received access to, how
many owners are on the lower floors (versus tenants), and if overall EPA is happy with the
amount of access we have received. He noted that he spent a day helping the outreach team and
saw how difficult it is to get access to properties with absentee landlords. He also asked
specifically about Cooper Park Houses and the testing there.
EPA Response 29: EPA explained that there are between 900 and 1,000 properties
within the preliminary Study Area. Prior to the site being designated as a Superfund site
in March 2022, NYSDEC had sampled more than 160 of those properties (over a 15 year
period from 2007 and 2022). As of December 2023, EPA has conducted vapor intrusion
sampling and fully evaluated the results at 18 residential structures, 11 public housing
buildings (Cooper Park Houses), and one public school. Out of these, EPA has
determined that vapor mitigation is not needed at this time at any of the properties it has
sampled, and that further monitoring should be conducted at three of the residential
properties. In addition, in February and March 2024, EPA sampled 18 properties and is in
the process of evaluating the results. EPA agrees that outreach has been a struggle and it
is something we are working very hard on. The representative from NYSDOH concurred
obtaining access was their biggest hurdle to sampling as well. He noted that they sent out
close to 1,000 letters requesting access to test in the 2021 to 2022 heating season. Out of
that batch of letters, they received access to just 60 properties.
All that said, the outreach and access efforts are ongoing and will continue for at least the
next several years. The decision described in the ROD will give EPA the ability to
mitigate vapor intrusion issues as we discover them prior to fully understanding the
nature and extent of contamination in groundwater. We are still working to access as
many properties as we can to conduct vapor intrusion sampling. To supplement what was
said at the meeting, EPA's outreach has included meetings and telephone calls with
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individual tenants and property owners, door-to-door efforts, tabling at multiple
community events, written correspondence (direct mailing) and social media outreach in
four languages, regular updates to the Site's EPA website, in-person community and
public meetings, meetings and information sharing with elected officials, radio
interviews, targeted meetings at the Cooper Park Houses and with PS-110 staff and the
PTA, media interviews (paper, on-line and television outlets), and interviews with local
podcasts. With that said, EPA's goal is to improve on our outreach efforts and
correspond with as many people as possible and this will be the focus of the updated
Community Involvement Plan. Please refer to EPA Response #1 for additional detail.
Regarding Cooper Park Houses, EPA was able to test all 11 of the buildings when we did
the sampling in 2023. There are no residences on the ground floor of any of the buildings,
but there are offices, lunch areas, community rooms, etc. Each building is unique. We
were able to test these common spaces. We also tested sub-slab soil gas under the
buildings and outdoor air near the buildings. The results showed that none of the Cooper
Park Houses buildings require mitigation.
Comment 30: A meeting attendee asked if denying access would put a landlord at legal risk of
being sued by tenants in the future if, for example, the kids grow up and develop an illness.
EPA Response 30: EPA stated that we cannot provide legal advice to members of the
public. EPA went on to clarify that we have the authority under Superfund law to access
properties for sampling and response actions. While voluntary consent is our preference,
we are able to require access through administrative or judicial means.
Comment 31: A community member, who identified as an individual that lives and works in the
community, asked if EPA would go back and retest properties.
EPA Response 31: EPA evaluates each property on a case-by-case basis, including those
properties that have already been tested. EPA has reviewed the properties tested by the
state and has not seen the need to revisit any of those yet. If someone contacts us and lets
us know of a changed situation, such as a structural change to the building or a change in
usage, then we would evaluate if re-testing is needed. In addition, based on the results
from the initial round of sampling, EPA may determine it makes sense to re-test a
structure. For example, if property-specific review of the multiple lines of evidence that
are gathered are inconclusive, re-testing may be warranted. And to expand upon what
was said at the meeting, other situations that may lead EPA to retest a property can
include, but are not limited to, new vapor intrusion testing data at neighboring and
adjacent properties and changes in EPA's understanding of groundwater flow direction
and/or groundwater contaminant concentrations.
Comment 32: A community member and representative of North Brooklyn Neighbors asked if
the commercial RALs account for the most vulnerable populations, such as pregnant women and
people who are elderly, and noted that the makeup of the current workforce can change over time
(i.e., people may become pregnant).
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EPA Response 32: EPA reiterated that we look at each property individually and use
multiple lines of evidence to determine whether mitigation is needed. To supplement
what was said at the meeting, EPA's commercial RALs are considered protective for all
workers including sensitive subpopulations, such as pregnant women and the elderly.
Please refer to EPA Response 7 for more information.
Comment 33: The same resident asked how the venting for mitigation systems is designed so
that nearby properties are not adversely affected.
EPA Response 33: EPA acknowledged the question and looked into this further after the
meeting. EPA will follow the NYSDOH's guidance to the extent practicable.
NYSDOH's guidance requires the exhaust or vent pipe to extend vertically through the
building floors and to terminate at least 12 inches above the surface of the roof, in a
location at least 10 feet away from any window or other opening into the conditioned
spaces of the building that is less than two feet below the exhaust point, and 10 feet from
any adjoining or adjacent buildings.
Comment 34: A community member, who also identified as a resident in the area, asked about a
tenant/renters right to information regarding vapor intrusion sampling, including whether a
tenant can find out if testing has been conducted and have access to the results.
EPA Response 34: EPA explained that all data will be shared with the property owner
and the tenants of any units tested. From a larger perspective, we are also working to
develop maps (called cluster maps) that will display how many properties have been
tested in smaller subsets of the Study Area and the overall results (i.e., how many of the
tested properties required mitigation versus not) without revealing any particular
addresses or otherwise personally identifiable information. EPA is working to develop
these maps in an effort to balance the community's desire for transparency with
individual rights to privacy.
The representative from NYSDOH went on to explain that New York has tenant
notification laws which require building owners to share any results that are above state
guidelines with tenants, and the state encourages property owners to share the results with
all building occupants and tenants.
To expand upon what was stated at the meeting, when EPA conducts vapor intrusion
sampling at a property, EPA will provide the results to both the tenant whose unit was
sampled and the landlord. If a common area is sampled, that data will be provided to any
tenant that has access to that common area. A copy of the data and EPA's assessment
will be provided to any / all other tenants in the building proactively if EPA determines
that mitigation is required for the building based on indoor air testing data impacts from a
public space inside of the building (i.e., common laundry room or basement).
Alternatively, a tenant may ask the building owner for a copy of the vapor intrusion data.
Also note that all of the vapor intrusion data that EPA collects or generates will
eventually be shared in the Remedial Investigation report that is developed for the site.
However, the data will not be reported with any personally identifiable information
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shared. The exact details of how the data will be reported in the report has not yet been
determined.
Comment 35: A community member asked EPA to explain broadly what the cancer and non-
cancer health risks are for TCE and PCE. A separate request was made that EPA explain the
risks in easy-to-understand terms when a written response is provided.
EPA Response 35: TCE is classified by EPA as carcinogenic to humans by all routes of
exposure and can cause effects to the central nervous system, kidneys, liver, immune
system and to developing fetus. PCE is classified by EPA as likely to be carcinogenic to
humans by all routes of exposure and can cause nervous system and ocular effects.
To expand upon what was said at the meeting, EPA quantifies risk at a Superfund Site by
conducting an analysis of the potential adverse health effects caused by hazardous
substance releases from the Site in the absence of any actions to control or mitigate these
releases under current and anticipated future land use. A four-step process is utilized for
assessing site-related human health risks for a reasonable maximum exposure scenario:
• Hazard Identification - uses the analytical data collected to identify the
contaminants of potential concern at the Site 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 well-water) 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 adverse effects (response); and
• 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
which exceed acceptable levels, defined by the NCP as an excess lifetime
cancer risk greater than 1 x 10"6 to 1 x 10"4 or a noncancer Hazard Index greater
than 1; contaminants at these concentrations are considered chemicals of
concern and are typically those that will require remediation at the Site. Also
included in this section is a discussion of the uncertainties associated with these
risks.
For more information on risk and how it's quantified, please see the "What is Risk and
How is it Calculated" information box on page 6 of the proposed plan or the "Summary
of Site Risks" section of the ROD.
Overall, in order for risk to occur, there needs to be exposure. So if there is contamination
under the ground but the vapors are not entering a structure and it is not otherwise
available for exposure, then there is no risk from that contamination. The NCP defines
site-related cancer risks that exceed 1 x 10~4 (or one in ten thousand) as unacceptable. To
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help visualize what a 1 x 10~4 risk means, consider a pool that is filled with ten thousand
green marbles and a single red marble; the red marble would represent the one in a ten
thousand excess cancer cases.
Comment 36: A member of the Newtown Creek Alliance asked what EPA is actually proposing
here and whether any steps towards any real remediation of the contamination as opposed to just
getting the vapors out of structures.
EPA Response 36: The action described in the Proposed Plan is a mitigative action to
prevent exposure to site-related contamination in indoor air. It is an interim measure to
protect people's health who are being impacted by the contamination while a long-term
solution to addressing the sources is being developed. The site is being investigated on
two parallel tracks, one related to the sources of the contamination and the other related
to mitigation. This Record of Decision gives EPA the ability to take mitigative measures
while the sources of the contamination are investigated and remedial alternatives are
developed.
As of the time of the meeting, EPA had not yet identified any properties that required
mitigation. It was noted that EPA's removal program could be used as a stop-gap
measure, if needed, to conduct mitigative measures until a ROD is signed. Since the time
of the meeting two properties were identified that require the installation of sub-slab
mitigation systems, and EPA's removal program will be installing those early this fall.
Comment 37: Community members asked about timing, in particular the timeline is for the full
OU1 RI/FS and why EPA estimated a 5-year time period for this action.
EPA Response 37: EPA does not yet have a final timeline for the full OU1 RI/FS
process, but it will take a time to reach a decision and then implement the selected
remedy. An initial round of groundwater sampling from existing wells was conducted in
2023 and the results of this will help to determine data gaps and where additional wells
need to be installed. The RI/FS will proceed in a stepwise manner like this, and we will
develop and continue to refine the overall schedule as we go.
The OU2 Proposed Plan and ROD state that sampling and mitigation will be conducted
on an ongoing basis for a period of at least five years. A five-year time period was
selected for budgetary purposes. However, this does not limit EPA from sampling and
mitigating properties beyond the five-year timeframe.
Comment 38: A community member representing North Brooklyn Neighbors commented that
they very much appreciate EPA saying that they look at things on an individual basis but asked
that this be recognized in a more formal way, particularly for those that may not trust EPA
completely.
EPA Response 38: EPA acknowledges the community's concern. To supplement what was
said at the meeting, language has been added to the ROD stating this more clearly.
Specifically, the ROD includes the following text:
• Whether to apply the residential RAL or Commercial/Industrial RAL will be
determined on a case-by-case basis, in consultation with NYSDEC and NYSDOH. In
general, EPA understands that many properties that are zoned for non-residential use
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may be used, either regularly or from time-to-time, in what would be more consistent
with residential exposure assumptions. The residential RALs may be used at any
property, residential or non-residential, if there is any reason to believe the
commercial/industrial RALs are not sufficiently conservative, either under current or
reasonably anticipated future use scenarios.
• While stated in the Proposed Plan, this Record of Decision memorializes that RALs
will be considered with other Site-specific lines of evidence such as subsurface
geology and hydrogeology, the structural characteristics of each building, and
proximity to other impacted structures in determining whether there is a need for
remedial action. The need for remedial action will also be determined in consultation
with NYSDEC and the NYSDOH, including consideration of NYSDOH's Guidance
for Evaluating Soil Vapor Intrusion in the State of New York.
Comment 39: A community member asked whether EPA tests strictly in the winter months or is
it possible to test a basement where there's not much air flow even during warmer weather?
EPA Response 39: EPA noted that testing can occur outside of the winter heating season
but that the results are not definitive. If elevated concentrations are found, then there is
likely an issue, but if elevated concentrations are not found, additional testing would still
be needed in the winter. Please also refer to EPA Response 13.
Comment 40: A community member asked EPA if there are any limitations on the amount of
testing that can be done during a given time period, particularly due to laboratory constraints.
EPA Response 40: Since vapor intrusion sampling is generally conducted during a
limited time of year, laboratory capacity can be an issue. However, since the sampling for
this site is being planned in advance, EPA is working with the laboratories to secure
sufficient space ahead of time to minimize any potential delays.
Comment 41: A community member asked if cost plays a factor in our selection of RALs that
differ from the State's RALs.
EPA Response 41: Cost did not play a factor in our selection of RALs for this site.
Comment 42: A community member asked EPA who will physically install the mitigation
systems if they are required at a property. They asked if EPA does it directly, if EPA has a
contractor, or can the property owner do it themselves under the guidance of the agency?
EPA Response 42: Any mitigation systems will be installed by a qualified contractor
who is conducting the work under EPA oversight.
Comment 43: A community member commented that there were only two remedies looked at
and asked EPA if there are other options that exist or technologies.
EPA Response 43: The use of a sub-slab depressurization system is a proven technology
that has shown to be effective at mitigating vapor intrusion at both residential and
commercial properties. The alternative includes additional mitigative measures, like the
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sealing of cracks, which may be needed/appropriate. Other approaches would not be as
effective and were not considered.
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APPENDIX V
RESPONSIVENESS SUMMARY
Attachment A- Written Comments Submitted During Public Comment Period
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SIMON WEISER
FIRST VICE-CHAIRMAN
DEL TEAGUE
SECOND VICE-CHAIRPERSON
GINA BARROS
THIRD VICE-CHAIRPERSON
DAVID HEIMLICH
FINANCIAL SECRETARY
SONIA IGLESIAS
RECORDING SECRETARY
PHILIP A. CAPONEGRO
MEMBER-AT-LARGE
COMMUNITY BOARD No. 1
435 GRAHAM AVENUE - BROOKLYN, NY 11211- 8813
PHONE: (718) 389-0009
FAX: (718) 389-0098
Email: bk01@cb.nyc.gov
Website: www.nyc.gov/brooklyncb1
HON. ERIC L. ADAMS
BROOKLYN BOROUGH PRESIDENT
DEALICE PULLER
CHAIRPERSON
JOHANA PULGARIN
DISTRICT MANAGER
HON. LINCOLN RESTLER
COUNCILMEMBER, 33rd CD
HON. JENNIFER GUTIERREZ
COUNCILMEMBER, 34th CD
cjr con point
June 21, 2024
Rupika Ketu
Remedial Project Manager
US Environmental Protection Agency
290 Broadway, 18th Floor,
New York, NY 10007
ketu.rupika@epa. gov
Re: Comments regarding a proposed cleanup plan
for potential indoor air contamination at
the Meeker Avenue Plume Superfund Site
Dear Ms. Ketu,
At the regular meeting of Brooklyn Community Board No. 1 held the evening of June 18, 2024,
the board members voted to support sending this letter.
The vote was as follows: 33" YES" 0" NO"; 0" Abstentions".
Please accept the following comments regarding a proposed cleanup plan for potential indoor air
contamination at the Meeker Avenue Plume Superfund Site.
This project is of the utmost concern, not only due the breadth, severity and complexity of the
Meeker Avenue Plume contamination, but because this Superfund site resides solely within the
confines of Brooklyn Community District #1. This concern is bolstered by the long history of
toxic sites that have existed and presently exist in this district which includes the Greenpoint Oil
Spill, the Newtown Creek Superfund site, the Nuhart Factory Superfund site, the extensive fossil
contamination needing remediation at Bushwick Inlet Park, several manufactured gas plant
cleanups and the seemingly endless stream of brownfield cleanup sites here. Generations of
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district residents are fed up and feel beaten down from weathering through this hazardous and
damaging legacy.
Therefore, Brooklyn Community Board #1 takes issue with what we feel are weak parameters set
in place related to the proposed remedy for potential contaminated indoor spaces. EPA Remedial
Action Levels (RALs) being used for the 2 primary contaminants of concern, Trichloroethene
(TCE) and Tetrachloroethene (PCE), are 1) lower than New York State Department of
Environmental Conservation (NYSDEC) RALs for TCE and PCE and 2) are less stringent for
commercial properties where NYSDEC uses one RAL for both residential and commercial
properties, in creating the threshold in which the proposed remedy of installing a sub-slab
depressurization system would be deployed.
We feel strongly that EPA must use the more stringent RALs that New York State provides and
not seek waivers to override them. It is normal and pervasive for workers in commercial work
environments to spend more time (very often more than 10 hours) at their workplace than at their
home. It is imperative that residents and workers in our district receive the same level of
protection.
Considering our district's epic environmental history, we urge the EPA to work with the deepest
level of safety and remedy possible which lends itself to the use of the state's more stringent and
further reaching contamination level limits.
Working for a Safer Williamsburg/ Greenpoint.
Cc: Congresswoman Nydia Velazquez
Senator Kristen Gonzalez
Assemblymember Emily Gallagher
Borough President Antonio Reynoso
Council Member Lincoln Restler
Council Member Jennifer Gutierrez
Sincerely,
Dealice Fuller
Chairperson
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COMMUNITY BOARD No. 1
435 GRAHAM AVENUE - BROOKLYN, NY 11211- 8813
PHONE: (718) 389-0009
FAX: (718) 389-0098
Email: bk01@cb.nyc.gov
Website: www.nyc.gov/brooklyncb1
HON. ANTONIO REYNOSO
BROOKLYN BOROUGH PRESIDENT
SIMON WEISER
FIRST VICE-CHAIRMAN
DELTEAGUE
SECOND VICE-CHAIRPERSON
GINA BARROS
THIRD VICE-CHAIRPERSON
DAVID HEIMLICH
FINANCIAL SECRETARY
SONIA IGLESIAS
RECORDING SECRETARY
PHILIP A. CAPONEGRO
MEMBER-AT-LARGE
DEALICE FULLER
CHAIRPERSON
JOHANA PULGARIN
DISTRICT MANAGER
HON. LINCOLN RESTLER
COUNCILMEMBER, 33rd CD
HON. JENNIFER GUTIERREZ
COUNCILMEMBER, 34th CD
gre«mp®int —
Williamsburg
June 18, 2024
COMMITTEE REPORT
Environmental Protection Committee
TO: Chairperson Fuller and CB1 Board Members
FROM: Mr. Stephen Chesler, Committee Chair
Environmental Protection Committee
RE: Committee Report from June 6, 2024
The Committee met on the Evening of June 6, 2024, at 6:00 PM at McCarren Play Center, 776
Lorimer St, Brooklyn, NY 11222.
Members: Chesler, Chair; Bruzaitis; Costa; Horowitz; Peterson; Sabel; Vega; Hofmann*;
Stewart* (*) Non board committee member.
Present: Chesler, Bruzaitis, Vega, Weiser (Ad Hoc), Hofmann*
Absent: Costa, Horowitz, Peterson, Sabel, Stewart*
5 members present. A quorum was achieved.
MEETING
1) NATIONAL GRID - NEWTOWN CREEK RESOURCE RECOVERY FACILITY
RENEWABLE NATURAL GAS SYSTEM - Operational update provided by the National
Grid team. - On June 4th, 2024, National Grid informed the board that they would not be
attending the meeting due to other obligations. Per the board's request, they submitted a report
regarding the functionality of the Renewable Natural Gas System (RNG). It was not received in
time to discuss at the meeting.
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Discussion:
Willis Elkins (Executive Director, Newtown Creek Alliance): National Grid is the midst of a rate
case with the state. Included in their funding requirement is investment in the RNG system at the
DEP Newtown Resource Recovery Facility (NCRRF). It also includes creating 4 new RNG
systems at other facilities in the City. Rate payers would subsidize these. Newtown Creek Alliance
is involved with the case. Environmental justice issues are at play here. Regular community
meetings about these facilities should be a requirement vs just an annual report that is currently
being provided. Air quality monitoring should be a requirement both for the system when it is
offline and online. DEP provides a very general system status on their website. He suggested the
City article covering this issue being included in the letter to our elected officials.
Steve Chesler: Is state and or city legislation required to force the DEP and NG to be more
thoroughly accountable, transparent and compliant?
Christine Holowacz: This has been a 10-year project. They should be able to transform energy into
electricity. Steve Chesler: Is it a lack of will? Money? Christine Holowacz: Probably a lack of
technology. Many elements are not working. Steve Chesler: Should the board write to our elective
officials about this? We are getting nowhere communicating with DEP and National Grid directly.
Willis Elkins: Yes and attach The City article that covered this issue. Steve Chesler: ...and the
meeting letter. Laura Hofmann: Require transparency including a detailed list of items.
Laura Hofmann: What are our elected officials doing to increase standards for air quality? They
seem to be biased towards developers instead of the community.
Also, attached is a status report from National Grid sent to the board 20 minutes prior to the
meeting start.
Motion made by Steve Chesler - To recommend the board submit the attached letter as
written, to our elected officals at the federal, state, and city levels, to demand the Department
of Environmental Protection and National Grid provide regular details on the functionality
and repair of the Newtown Creek Resource Recovery Facility and air quality analysis there,
and if necessary initiate legislation to enforce the providing of this data to the public and
Brookly Community Board #1.
Second: William Vega
The vote was as follows:
3 "YES"; 0 "NO"; 0 "ABS"
Consensus recommendation passes.
2) ENVIRONMENTAL PROTECTION AGENCY SEEKS PUBLIC COMMENT ON A
PROPOSED CLEANUP PLAN FOR POTENTIAL INDOOR AIR CONTAMINATION AT
THE MEEKER AVENUE PLUME SUPERFUND SITE - Public Comment Period extended
through June 25, 2024. Review the proposal and recommend comments. See the attached
supporting summary documentation.
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Due to the complexity of the contamination, two years ago the Meeker Avenue Plume site was
accepted to the Environmental Protection Agency's (EPA) National Priorities List after existing
as a state superfund site for many years prior. Composed of approximately 900 properties, a mix
of residential, commercial and industrial uses, the site's current extent is generally bordered by
Bridgewater Street to the north, Monitor Street to the west, Frost Street, Withers Street and
Lombardy Street to the south and Newtown Creek to the east. The two primary contaminants of
concern are Trichloroethylene (TCE) and Tetrachloroethylene (PCE), both chlorinated volatile
organic compounds. Both chemicals pose a significant threat to human health and are known as
carcinogens and endocrine disruptors. It is estimated that prime sources of contamination were
industrial dry-cleaning operations. As part of the project Remedial Investigation (RI) the EPA has
been performing extensive testing through existing DEC monitoring wells and is considering
creating additional ones. Based on this analysis they will be presenting a new site map with
adjusted borders. Property testing has had a very low participation rate as property owners are not
volunteering to opt in. Since residents and tenants are at great risk, the EPA is considering
measures to gain access to these properties.
For indoor contamination the EPA has proposed a remedy for which they are seeking public
comment until June 25, 2024. They are offering installation of sub-slab depressurization systems
in the basements of site properties determined to exceed Remedial Action Levels, whereby air
under building slabs is forced up and out through a ventilation system above affected buildings.
Steve Chesler reported that during the EPA's remedy proposal presentation on April 16, 2024,
Willis Elkins noted that the EPA's Remedial Action Levels for TCE and PCE were less stringent
than DEC's levels. And, that EPA allows for higher levels of these compounds on commercial
sites versus residential sites. DEC does not have different thresholds set for residential and
commercial sites. Christine Holowacz noted at that meeting and during our meeting, that the time
many workers spend on the job at a commercial property is probably at least the same amount of
time spent at home or more, often more than the 10-hour threshold that the EPA uses for
commercial properties.
William Vega reported that at least 5 property owners he encountered were approached by EPA
contractor workers who did not have identification to verify who they were. This poses a security
risk.
Motion made by Steve Chesler - to recommend the board submit the attached comment to
the Environmental Protection Agency regarding their proposed Meeker Avenue Plume
Superfund remedy for interior spaces, requesting they adhere to the more stringent NYS
Department of Environmental Conservation vapor intrusion chemical contamination
thresholds that 1) require using their deeper New York Stater Remedial Actions Levels for
TCE and PCE instead of the higher levels allowed and used by the EPA, and 2) require
residential and commercial spaces utilize the same Remedial Action Levels instead of using
higher levels for commercial spaces.
Second by William Vega.
The vote was as follows:
Discussion:
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3 "YES"; 0"NO"; 0"ABS"
Consensus recommendation passes.
3) EXXONMOBIL GREENPOINT PETROLEUM REMEDIATION PROJECT
(EMGPRP) SPDES PERMIT MODIFICATION - The Proposed Project will consolidate two
existing groundwater treatment facilities associated with the EMGPRP into a new groundwater
treatment facility to be constructed at 38 Varick Street, Brooklyn, NY 11222. Review the proposal
and recommend comments. Presentation file is attached.
ExxonMobil and its environmental contractor Roux have been remediating the Greenpoint Oil
Spill in eastern Greenpoint since 1978 when the spill was discovered leaking into Newtown Creek
covering more than 50 acres of land along the creek. Since the settlement of a lawsuit brought on
by a group of residents, Riverkeeper and the New York State Attorney General in 2010, this
process has been expedited. Approximately 13.45 million gallons of an estimated 17 million
gallons of oil have been removed.
Representatives from ExxonMobil and Roux presented and spoke about their State Pollution
Discharge Elimination System (SPDES) modification proposal (file attached). Madelyn Wilson,
Environmental Project Manager, ExxonMobil; Kevin Thompson, Public & Government Affairs,
ExxonMobil; Courtney Lind, Staff Assistant Engineer, Roux Associates; Justin Kennedy, Senior
Engineer, Roux Associates.
Full remediation process involves 20 recovery wells for removing oil products, groundwater
treatment and discharge, and soil vapor extraction.
Product recovery has decreased from a high of over 800,000 gallons of product extracted in 2009
to approximately 50,000 gallons in 2023. Out of the 13.45 million gallons of product removed to
date, ExxonMobil has removed 9.5 million gallons.
Regarding groundwater treatment, two existing groundwater treatment systems, one at 400
Kingsland Avenue and the other located at 5 Bridgewater Street, extract groundwater with
dissolved hydrocarbons and treat the water to NYSDEC standards. The treated groundwater is then
discharged into Newtown Creek at two permitted outfalls: Outfall 001 at 400 Kingsland Avenue
and Outfall 002 at the foot of Meeker Avenue. The groundwater systems treat and discharge
approximately 1,000,000 gallons of groundwater per day, with treatment consisting of: metals
removal (aeration, sand filters, filter press); air stripping and process air treatment.
SPDES permit modification proposal:
• Modify the SPDES permit to account for changes to the treatment and discharge process
for treated water from the product recovery system.
• Relocate and consolidate the two existing groundwater treatment systems into a new
system at 38 Varick Street.
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• This single treatment facility will be designed to handle the combined flow from all
existing recovery wells and maintain compliance with the SPDES discharge limits.
• Discharge of the treated water will occur through the existing Outfall 002 at the northern
end of Meeker Avenue.
Objectives are the optimization of the long-term operational efficiency of the groundwater
treatment system and reducing operational footprint of the ExxonMobil remedial systems.
Potential Impacts:
New Facility Construction from November 2024 - April 2026 (approximately 1.5 years) plus
Long-term Operations & Maintenance.
During construction: impacts are expected to be typical of new building construction
• Intermittent periods of increased traffic
• Traffic management plan to be utilized
• Potential nuisance, dust, odors and noise produced by intermittent heavy construction
equipment
• Community Air Monitoring Program (CAMP) to be utilized
Long-term:
• Operations and Maintenance activities will produce background mechanical noise.
• All equipment will be installed within the walls of the new facility, the potential for
nuisance noise to exist outside of the facility is minimal.
• Periodic material deliveries and operational waste removal will result in an intermittent
increase in activity at the 38 Varick Street property.
As is required by the state permitting process, ExxonMobil must hold public meetings and compile
public comments. After submission of their application that includes public input, DEC will open
its own public comment period. No set timeline for either.
Steve Chesler: Is the discharged groundwater replaced? Is there a concern that subsidence will
occur above treated areas? Keving Thompson: It is not being replaced. Groundwater is pervasive.
Courtney Lind: They are monitoring this.
Laura Hofmann: What kind of odors are being noticed? How are they being monitored? Courtney
Lind: Through the CAMP system. If odors are significant during construction, foam treatment will
be used.
Laura Hofmann: What does long term groundwater treatment mean? Kevin Thompson: DEC will
determine when completion is reached. Liquid product recovery extraction is slowing and has
leveled, but still continuing. Justin Kennedy: We will continue until DEC makes a determination.
Discussion:
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Kelly McCabe: Will nuisance noise from construction be severe? Courtney Lind: No.
Christine Holowacz: Regarding future use of 400 Kingsland Avenue site after that groundwater
treatment facility is decommissioned? Have you determined a future use of the site? Kevin
Thompson: This issue is beyond the scope of this meeting and the permit modification, but we will
report this question back to the company and DEC. Kevin LaCherra: Would argue that the future
use of 400 Kingsland is very relevant, and dependent is a way, to the SPDES permit modification
application. It is approximately 10 acres that could be repurposed for something other than it being
sold for industrial or manufacturing uses. Its severe contamination rightly causes intense concern.
There is an ongoing environmental justice fight in this neighborhood. We should take pause if
resilient design or purpose is not a prime consideration. Madelyn Wilson: We have nothing else to
share about this. Kevin Thompson: The consolidation is happening, but we will take these
comments back to ExxonMobil. Christine Holawacz: Exxon should consider community needs
and what is honorable. Not more trucks. We have been so impacted by the spill. Kevin Thompson:
All comments made must be included in their report to Exxon and DEC. Jason Sinopoli: What
agencies will help decide (the use of this land)? Heidi Vanderlee: This feels wrong. Simon Weiser:
Exxon has already paid for the cleanup. Why do they need to do more? Laura Hofmann: She
disagrees. She and her family have experienced years of health issues. She was one of the original
plaintiffs (in the suit against Exxon).
Shangton Lee (Newtown Creek Alliance): Has an analysis been performed on the carbon footprint
and sustainability of the old facilities and the new one? Floodplain analysis for 400 Kingsland vs
38 Varick new facility location? Kevin Thompson: Lessons have been learned that are informing
the design of the new facility.
Bess: Have you evaluated flood considerations? Erosion? Justin Kennedy: Exxon stabilized the
Meeker Ave Street end.
Steve Chesler: Are the 2 existing systems dependent on one another, especially during
maintenance of one of the systems? Justin Kennedy: the new system will have redundancy built
into it.
Willis Elkins: Will construction result in the removal of trees and/or planted areas? Kevin
Thompson: Removed species will be replaced.
Steve Chesler: Appeals to Exxon to consider the community considering the Greenpoint-
Williamsburg rezoning and commitments not fulfilled, and Exxon's history (required remediation
of the undeveloped sections of Bushwick Inlet Park from Standard Oil contamination footprint, its
pollution footprint with the Newtown Creek Superfund site and the oil spill. Climate mitigation is
a primary concern for this district, especially since the US Army Corps of Engineers' NYNJHATS
Storm Risk Management Plan fell significantly short in its design for our district.
Kevin LaCherra: Recovered product is being repurposed by state requirement. 9.5 million gallons
since 1979. Multi Millions in return. Kevin Thompson: Enormous burden in recovering product
results in no profit for Exxonmobil. Madelyn Wilson: 100-year-old product results in intense
degradation. It is not being utilized, only recycled or disposed of. Kevin Thompson: It is valueless
to Exxon, to pay to have it taken off their hands.
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Shangton Lee: Regarding OU2, have potential negative impacts of the new facility been analyzed?
Justin Kennedy: An evaluation must be submitted. Shangton Lee: What is the life expectancy of
the new equipment? Justin Kennedy: Approximately 25 years. Shangton Lee: Will another facility
be needed at that point? Justin Kennedy: If necessary. Kevin Thompson: DEC will determine what
we will need to do here.
Sarah Durand: Current is in a floodplain. Is this being considered? Kevin Thompson: The entire
site is. Yes. Sarah Durand: A tidal wetland was filled in here in 1982? Kevin Thompson: 1982.
William Vega: No profit should be made (on the 400 Kingsland Ave site). There should be a public
benefit. Residents paid with blood (for the negative effects of this site). Willis Elkins: We have
been on divergent paths for a long time, but we are better now than we were 20 years ago. 400
Kingsland Ave offers an opportunity for collaboration between ExxonMobil and the community.
Motion by Steve Chesler to recommend the board submit the following comment along with
a copy of the June 6th, 2024 the Environmental Protection Committee report, to ExxonMobil
and NYSDEC regarding the SPDES Permit Modification Proposal to consolidate
ExxonMobil's Greenpoint Oil Spill Product Recovery Operation, copying federal, state and
city elected representatives:
1) ExxonMobil perform due diligence and beyond with mitigating potential construction
operation hazards including but limited to air monitoring, noise, dust, odors and
construction related traffic
2) ExxonMobil replace all trees and planted areas removed and damaged during
construction of the new treatment facility at 38 Varick Street
3) ExxonMobil strongly consider future public and resilient uses for 400 Kingsland Ave
after its water treatment facility there is dismantled, that will help sustain and heal
the community from decades of environmental degradation at multiple sites currently
and previously owned by ExxonMobil and its historic acquired subsidiaries in
Brooklyn Community District #1
4) ExxonMobil work to be a better partner and to improve its relations with the
community
Second by William Vega.
The vote was as follows:
5 "YES"; 0 "NO"; 0 "ABS"
Motion carries.
Meeting adjourned.
7
V.
J
-------
&EPA
United States
Environmental Protection
Agency
EPA SEEKS PUBLIC COMMENT ON A PROPOSED CLEANUP
PLAN FOR POTENTIAL INDOOR AIR CONTAMINATION AT
THE MEEKER AVENUE PLUME SUPERFUND SITE
BROOKLYN, NEW YORK
APRIL 2024
NY
PR
USVl
The U.S. Environmental Protection Agency (EPA) is asking
the public for input on its proposed plan to address the
potential vapors that may be entering into residential and
commercial buildings at the Meeker Avenue Plume
Superfund site, which is located on approximately 191 acres
across several city blocks in the East Williamsburg and
Greenpoint neighborhoods of Brooklyn, New York. The soil,
soil gas and groundwater at the site are contaminated with
chlorinated volatile organic compounds (CVOCs), including
tetrachloroethylene (PCE) and trichloroethylene (TCE).
EPA's Proposed Cleanup Plan
EPA's proposed cleanup plan for addressing indoor air
concerns due to site-related vapors that may be entering
structures (vapor intrusion) involves installing mitigation
systems called sub-slab depressurization systems where
needed. Under the proposed plan, where EPA's evaluations
determine it is necessary, EPA would install sub-slab
depressurization systems and may also take preventative
measures such as the sealing of cracks and gaps in the
lowest level of a structure, where necessary. Sub-slab
depressurization involves connecting an electric fan to a
small suction pit dug into the slab that will vent vapors
outdoors above the building's roofline.
EPA developed this plan in consultation with the New York
State Department of Environmental Conservation
(NYSDEC) and the New York State Department of Health.
Chlorinated volatile organic compounds
(CVOCs) including tetrachloroethylene (PCE),
trichloroethylene (TCE), cis-1,2-dichloroethylene (DCE),
and vinyl chloride, are man-made chemicals that
evaporate at room temperature and are associated with
a higher risk of reproductive effects and cancer after
prolonged exposure.
Learn more about PCE, TCE, DCE, and vinyl chloride
from the New York State Department of Health.
~ ~ ~
Sflfi Get Involved!
Public Meeting Date:
Tuesday, April 16, 2024, 6:00 p.m.
Location:
St. Stanislaus Kostka Lower Church
607 Humboldt St., Brooklyn, NY
More information:
https://www.epa.gov/superfund/meeker-avenue-
plume
Contact: Anna Drabek, 212-637-3586,
drabek.anna@epa.gov
Public Comment Period
The proposed cleanup plan is available for public
comment from April 5 to May 10,2024. The
public is encouraged to review the plan, attend
the public meeting, and comment on the cleanup
alternatives.
To provide comments to EPA:
Read the document online at
www.epa.gov/superfund/meeker-avenue-plume
Send your comments to Rupika Ketu,
ketu.rupika@epa.gov, or 290 Broadway, 18th
Floor, New York, NY 10007
EPA must receive your comments by
May 10, 2024.
744534
www.epa.gov/superfund/meeker-avenue-plume | https://www.facebook.com/eparegion2/ | https://twitter.com/EPA region2
-------
Past Cleanup Activities
EPA added the Meeker Avenue site to the Superfund
National Priorities List (NPL) in March 2022. NYSDEC
sampled over 160 properties since 2007, before EPA's
involvement. EPA is assessing the level of
contamination and its impacts to people's health.
As of December 2023, EPA sampled underneath and
inside of 18 residential structures, 11 public housing
buildings, and one public school. EPA has results that
show no further action is needed at 15 of the residential
properties, the 11 public housing buildings, and the
public school. Three of the residential properties will
require additional monitoring. In addition, in February
and March 2024, EPA sampled 18 properties and will
be evaluating the results, and will be conducting
additional sampling in the future. Because prior
sampling from NYSDEC did detect CVOC vapors
inside several dozen properties, the state installed
mitigation systems to handle the vapors.
Where to Find More Information
EPA keeps site project information and reference
materials for the public to read online and at local
information repositories.
Copies of cleanup documents for the Meeker Avenue
Plume Superfund site will be available at:
EPA Region 2 Superfund Records Center
290 Broadway, 18th Floor
New York, New York
Greenpoint Library
107 Norman Avenue
Brooklyn, NY
& ~
CHARACTERIZATION
Remedial Investigation/
Feasibility Study & Proposed
Plan
SELECTION OF REMEDY
Record of Decision
CLEANUP
I Remedial Design
Remedial Action
POST-CONSTRUCTION
Operation and Maintenance
NPL Deletion
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Rev 04.09.2024
ExxonMobil Greenpoint Petroleum Remediation Project
SPDES Permit Modification
Fact Sheet
¦ Project: ExxonMobil Greenpoint Petroleum Remediation Project (EMGPRP)
¦ Applicant: ExxonMobil Oil Corporation.
¦ Facility: 38 Varick Street, Brooklyn, New York 11222.
¦ NYSDEC Application Number: SPDES NY 0267724
¦ A Public Participation Plan (PPP) has been developed in accordance with NYSDEC
Commissioner Policy 29, Environmental Justice and Permitting (CP-29)
What is the Proposed Project?
The Proposed Project will consolidate two existing groundwater treatment facilities associated with the
EMGPRP into a new groundwater treatment facility to be constructed at 38 Varick Street, Brooklyn, NY
11222. To implement the proposed project, ExxonMobil Oil Corporation has submitted an application
for a modification to its existing State Pollutant Discharge Elimination System (SPDES) permit to the
New York State Department of Environmental Conservation (NYSDEC). The applicant is also going to
submit an application for modification of its existing Long Island Well permit to allow for the relocation
of certain recovery wells. The purpose of this fact sheet is to inform the public about this proposed
project and to involve the community during the NYSDEC permit application review process.
ExxonMobil Oil Corporation proposes to modify its existing SPDES permit to allow for the modified
discharge resulting from the relocation and consolidation of the two active groundwater treatment
systems to a new groundwater treatment facility to be located at 38 Varick Street. Subsequent to the
consolidation, treated effluent will only discharge from Outfall 002. ExxonMobil Oil Corporation also
proposes to modify its Long Island Well permit to reflect the operational status and locations of recovery
wells associated with the EMGPRP.
How might the project affect the surrounding community?
The potential impacts surrounding the construction of a new groundwater treatment facility at 38 Varick
Street are expected to be typical of a new building construction. The existing RCS and ORS treatment
buildings will be decommissioned following construction and start-up of the new facility. The new
system will support long-term operations and remediation activities in accordance with the Site's
Consent Decree. For clarity, the potential impacts have been categorized based on construction
impacts (construction of new facility) and operational impacts (long-term operation of the new treatment
facility):
The construction-based impacts are expected to be typical of new building construction and are
expected to conclude within 1.5 years of groundbreaking. Impacts are expected to include:
• Potential intermittent periods of increased traffic due to equipment and material deliveries, as
well as disposal of excavated soils and construction debris.
• Potential nuisance, dust, odors and noise produced by intermittent heavy construction
equipment use during demolition and construction activities.
o A Community Air Monitoring Program (CAMP) will be developed for all phases of the new
facility's construction. The program will outline monitoring, response, and mitigation
procedures to be implemented during construction. This program is intended to reduce the
-------
Rev 04.09.2024
likelihood of potential nuisance dust, odor or noise events occurring that would potentially
affect the public.
The long-term operational impacts potentially include:
• Operations and Maintenance activities (once operational) will produce background mechanical
noise. However, as all equipment will be installed within the walls of the new facility, the
potential for nuisance noise to exist outside of the facility is minimal.
• Periodic material deliveries and operational waste removal will result in an intermittent increase
in activity at the 38 Varick Street property.
How can I participate in the permit review process?
¦ Attend the upcoming virtual public meeting scheduled for May 9th, 2024 at 6:30 pm to learn about
the project, ask questions and/or express concerns about the project.
¦ Ask questions, express concerns, provide input or submit by comments in writing, by phone or
email to the project contact person identified below.
Where can I get more information about the proposed project?
¦ Visit the online document repository at: https://bit.lv/3vlqlWW to obtain application materials,
relevant documents, and information about the project.
¦ Contact Kevin M. Thompson by phone at: (718) 404-0675, by email at:
kevin.m.thompson@exxonmobil.com or in writing at: 38 Varick Street, Brooklyn, New York
11222 for information on the project, instructions on how to attend the upcoming virtual public
meeting, or to find out about the status of the permit application and public comment period.
Who is responsible for reviewing the Permit Application?
¦ NYSDEC Region 2 Headquarters, 47-40 21st St., Long Island City, NY 11101, is responsible for
reviewing and issuing the required permit modification. Tel: (718) 482-4997; email:
DEP.R2@dec.nv.gov
-------
E^onMobil
June 6, 2024
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MANHATTAN ' ¦ ' *'
Industrial SPDES Permit Modification
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ExxonMobil Green point Petroleum Remediation Project
-------
Introductions / Agenda
Introductions
• Madelyn Wilson-ExxonMobil
• Kevin Thompson - ExxonMobil
• Courtney Lind - Roux
• Justin Kennedy-Roux
Agenda:
• EMGPRP Project Overview
• SPDES Permit Modification
• Project Overview & Background
• Proposed Scope of Work
• Potential Impacts, Mitigation
Measures and Project Schedule
• Questions & Answers
400 Kingsland Ave
38 Varick St iV
5 Bridge water St
LEGEND
EMGPRP SITE BOUNDARY
-------
EMGPRP Remediation Project Overview
• ExxonMobil is conducting the remediation project to address releases of petroleum products from
its historical operations. All work is performed under the regulatory oversight of the New York
State Department of Environmental Conservation (NYSDEC)
• Liquid product recovery is accomplished via a system of recovery wells which extract hydrocarbons
in liquid form and send the liquid product to recycling facilities
• Groundwater containing dissolved product is also recovered and sent to two different groundwater
treatment systems for treatment to NYSDEC standards, then discharged into Newtown Creek under
an existing SPDES permit issued by NYSDEC
• Soil vapor containing hydrocarbons is extracted and treated in a Soil Vapor Extraction (SVE) unit
located at 38 Varick Street
-------
Product Recovery System
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-------
Groundwater Treatment Systems
• Two existing groundwater treatment systems, one at 400 Kingsland Avenue and the other located
at 5 Bridgewater Street, extract groundwater with dissolved hydrocarbons and treat the water to
NYSDEC standards
• The treated groundwater is then discharged into Newtown Creek at two permitted outfalls
• Outfall 001 at 400 Kingsland Avenue
• Outfall 002 at the foot of Meeker Avenue
• The groundwater systems treat and discharge approximately 1,000,000 gallons of groundwater per
day, with treatment consisting of:
• Metals removal (aeration, sand filters, filter press)
• Air stripping
• Process air treatment
-------
Groundwater
Treatment
Systems
• 400 Kingsland
Avenue
• 5 Bridgewater Street
-------
Soil Vapor Extraction
LEGEND
ACTIVE SOIL VAPOR EXTRACTION WELL USED
FOR THE FULL SCALE SYSTEM
A ACTIVE VACUUM-ENHANCED RECOVERY (VER)
~ WELL
% * %
2
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-------
SPDES Permit Modification - Proposed Scope of Work
• Modify the SPDES permit to account for
changes to the treatment and discharge
process for treated water from the product
recovery system
• Relocate and consolidate the two existing
groundwater treatment systems into a new
system at 38 Varick Street
• This single treatment facility will be designed to
handle the combined flow from all existing
recovery wells and maintain compliance with
the SPDES discharge limits.
• Discharge of the treated water will
occur through the existing Outfall 002 at the
northern end of Meeker Avenue
Draft Rendering
-------
Groundwater
Treatment
Facility Consolidation
Objectives
• Optimization of the long-term
operational efficiency of the
groundwater treatment
system
• Reducingoperational
footprint of the ExxonMobil
remedial systems
-------
Groundwater from
Recovery Wells
I
SPDES Permit Modification
| Atmosphere
Treatment Technologies
Preliminary Design Basis and Objectives
• Maintain treatment train similarto existing
GW treatment systems
• Provide redundancy and additional capacity
for all key system components to maximize
system runtime and operational flexibility
• Reuse existing force main piping to handle
groundwater feed and discharge operations
• I ncorporate lessons learned from existing
systems to optimizefuture operations and
maintenance
-------
SPDES Permit Modification - Potential Impacts, Mitigation and
Project Schedule
During construction: impacts are expected to be
typical of new building construction
• I ntermittent periods of increased traffic
• Traffic management plan to be utilized
• Potential nuisance, dust, odors and noise produced
by intermittent heavy construction equipment
• Community Air Monitoring Program (CAMP) to
be utilized
Long-term:
• Operations and Maintenance activities will
produce background mechanical noise. However,
as all equipment will be installed within the walls
of the new facility, the potential for nuisance
noise to exist outside of the facility is minimal.
• Periodic material deliveries and operational waste
removal will result in an intermittent increase in
activity at the 38 Varick Street property.
New Facility Construction
November2024 - April 2026
(approximately 1.5 years)
Long-term Operations & Maintenance
-------
SPDES Permit Modification - Application Status/Timeline
December 11,2023
SPDES Permit
Application Submitted
to NYSDEC
April 9, 2024
Public Participation
Plan Approved
Additional
application
documentation to
be uploaded to the
repository on an
ongoing basis2
~
~
~
n
~
~
February 16, 2024
Response to
Comments Letter
Submitted to
NYSDEC
May 9, 2024
Virtual Public
Meeting1
NYSDEC Final
Decision on SPDES
Permit
Notes:
1. ExxonMobil to receive public comments during the meeting and on an ongoing basis thereafter. Comments received prior to the Final Summary
Report will be captured within the report.
2. Example documentation includes, but is not limited to, Long Island Well Permit Application, NYSDEC Notice of Complete Application and Draft
SPDES Permit (30-day NYSDEC public comment period), and the Final Summary Report and Written Certification.
-------
For More Information
Online document repository:
Notice of Complete Application (pending):
• To be published in local newspaper
• To be provided in online document repository
• Contact Project Liaison to receive a copy by
email, mail, ortelephone
Project Liaison- Kevin M. Thompson
Public & Government Affairs Advisor
(718)404-0675
kevin.m.thompson@exxonmobil.com
38 Varick Street, Brooklyn, New York 11222
-------
Questions?
To submit questions, comments, and concerns after the meeting:
Project Liaison - Kevin M. Thompson
Public & Government Affairs Advisor
(718) 404-0675
kevin.m.thompson@exxonmobil.com
38 Varick Street, Brooklyn, New York 11222
-------
For More Information
Online document repository:
Notice of Complete Application (pending):
• To be published in local newspaper
• To be provided in online document repository
• Contact Project Liaison to receive a copy by
email or mail
Project Liaison - Kevin M. Thompson
Public & Government Affairs Advisor
(718)404-0675
kevin.m.thompson@exxonmobil.com
38 Varick Street, Brooklyn, New York 11222
-------
nationalgrid
National Grid Newtown Creek
Purification System Operations Update
The system performed in line with expectations for a facility of this complexity during the first
year of operation. We addressed issues that arose. This is a demonstration project, and we
learn from it every day.
The Newtown Creek Renewable Energy Project helps address climate change and creates a
model for sustainability - it reduces GHG emissions today - by utilizing an existing waste
stream to produce a reliable source of renewable energy while diverting food waste from
landfills.
National Grid NTC Operations
By the Numbers
Year
Percent of Operational
Hours Online
2023
44%
2024 85%
Adjustments made in the first year:
• Vibration at the feed gas compressor that required repairs - accounting for 67% of total
outage time in year one.
Re-evaluated spare parts on hand for quicker response rates.
System tuning, adjustment, and calibration - which is common during the first year of
operation.
Increased transparency:
Closer coordination/collaboration with DEP.
Implemented real-time system status monitoring.
• Worked with DEP to create a public website showing system status.
Equivalent emission avoidance:
116,717 MMBtu of RNG was injected into the distribution system in year one, which has
reduced emissions by more than 30,400 MT of C02e. That is equivalent to removing
7,235 vehicles from the road for a year (Source EPA Greenhouse Gas Equivalencies
Calculator)
Rev: June 6, 2024
-------
nationalgrid
National Grid NTC 2023 Operations
April through December
.00%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
April May June July August September October November December
¦ Hours of Operation Online ¦ Hours of Operation Offline
National Grid NTC 2024 Operations
January through May
100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
¦ Hours of Operation Online ¦ Hours of Operation Offline
2023 Hours of Operation
2024 Hours of Operation
January
February
April
May
Rev: June 6, 2024
-------
From:
To:
Subject:
Date:
Attachments:
Lael Goodman
Ketu. Rupika
Meeker Avenue Plume Proposed Plan
Wednesday, June 26, 2024 9:13:07 PM
Meeker CAG Proposed Plan Comments.pdf
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
ii Rupika,
As a contributor to the CAG comments, North Brooklyn Neighbors would like to express our
support and reiterate the concerns put forward by the Meeker Avenue Plume CAG, attached
here.
Thanks,
Lael
(she/her)
Director of Environmental Programs
North Brooklyn Neighbors
240 Kent Avenue
Brooklyn, NY 11249
Currently working Mondays, Tuesdays, and Thursdays. Thanks for your patience.
718.384.2248 ext. Ill
-------
Meeker Avenue Plume CAG
Vapor Intrusion Proposed Plan Public Comments
OU2 Standards
1. The CAG requests that the EPA provide a proposal for how the agency plans to test buildings at
risk of vapor intrusion within the Investigation Area. The CAG is also concerned about the vast
number of properties where owners have not yet granted access and the lack of clarity from the
EPA in how realistic it would be for them to not only compel testing but address the issue in a
systematic way. Thus far, during the two heating seasons, the EPA has managed to test around
50 properties, far short of what should be done to provide adequate information and public
health protection in our community. While the CAG is and will continue to aid the EPA in
directing community members to get testing, the onus is on the EPA to protect our community
and thus far, the number of properties tested is not fulfilling that mission. We request
information to be made public about how many properties exist where the property owner has
refused testing.
a. This plan should be a proposal that has new strategies for outreach, including outreach
to non-residential properties, that has not yet been implemented by the EPA, as it has
become obvious that the current strategies are not getting results quickly enough to
protect community health.
2. We believe the Remedial Action Levels should be more stringent.
a. Residential RAL for TCE
• In particular, EPA Region 9 recommends that the TCE standard be 2 ug/m3 for
residential. The New York State Department of Health also recommends that
"TCE concentrations in the air not exceed 2 ug/m3." Further, Section 121(d) of
the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA) requires that on-site remedial actions attain or waive federal
environmental applicable or relevant and appropriate requirements (ARARs),
or more stringent state environmental ARARs, upon completion of the
remedial action. In this case, the state standard is more stringent, and we
would request that based on these two factors, the Remedial Action Level
should be 2 ug/m3 or below.
b. Commercial/Industrial RAL for TCE
• Both the 8-hour and 10-hour workday RAL for TCE are also below what the
EPA Region 9 has recommended. Because of the number of people who both
live and work in our neighborhood, and because of frequency with which
people work greater than an 8-hour workday here, we would request that
instead of using an 8-hour workday for calculations, the EPA instead use a 10-
hour workday and match if not exceed the stringency of the standards set in
EPA region 9. This would set the Commercial/Industrial RAL for TCE to be 7
ug/m3 rather than the proposed indoor air standards of 8.8 ug/m3.
c. Residential RAL for PCE
Meeker Ave Plume CAG Proposed Plan Public Comments 6/25/2024
1
-------
• The RALs for PCE seem to correspond not to a one in a million cancer risk, but
instead are pegged to non-cancer risk. Our community deserves to be granted
the utmost protection and we are concerned that the EPA allows a cancer risk
range of 1x10-4 and 1x10-6, but the RALs do not correspond to the most
stringent standard. Given the New York State Department of Health has
guidelines of 30 ug/m3 for PCE. we would request that ARARs be taken into
consideration and set a guideline of 30 ug/m3 or less.
d. Commercial/Industrial RAL for PCE
• We would again request that the RAL be calculated based on a 10-hour day
rather than an 8-hour workday for the same reasons as mentioned above.
3. At the May 30, 2024, presentation by the EPA, results of some of the well sampling were
presented. A select list of contaminants found in the groundwater was presented, many of which
are known to be harmful to human health. While the CAG applauds the investigation of PCE and
TCE in the area, given the profusion of other harmful contaminants, we are concerned that other
contaminants that may negatively affect our public health are not being properly considered.
When the EPA does indoor air sampling, does it test for other contaminants? If so, which ones? If
levels of these contaminants are found at harmful concentrations, what is done? We request that
the EPA take full advantage any time they have access to a property and ensure the inhabitants
are protected not just from PCE and TCE, but also from other potentially harmful compounds,
especially those that have been found to be present in the groundwater sampling.
4. While the proposed plan is an intermediate remedy and may not be subject to ARARs (according
to TASC Technical Advisor Brian Younkin) and the CAG believes that it is vital that they apply in
this case. The EPA has stated numerous times that the reason that it is addressing vapor
intrusion now is because it is an immediate health risk. As of yet, we have no timeline or plan for
an underlying cleanup or removal action. It is unknown for how long our community will exist
with only this proposed plan to protect our health, and because of all these unknowns and the
EPA's own indications that the health risks are immediate, we believe that the standards of
ARARs should apply. Additionally, the community has been very supportive of and even pushed
for the site to move from a state-level site to the National Priorities List. If this move means less
protective health standards than we had under our state cleanup, this goes against all the
reasons that the site was elevated to a national status.
5. The CAG believes that soil gas vapor testing should be implemented in addition to soil vapor
intrusion, since it can be done in the public right of way and would provide some data on how
likely a vapor intrusion risk is at a particular property, even if access to that property is denied.
This would provide additional information to help the EPA determine whether it is vital to
consider using additional measures to gain access to the property for testing. Depending on the
underlying properties of soil in different parts of the neighborhood, the well sampling might not
be a good proxy for soil gas vapor and potential vapor intrusion.
a. Without a larger data set of results from indoor air testing, we can't feel confident that a
plan based on such a small sample of properties is the best for our community. For
example, soil gas vapor testing could be used at residences where tenants have
Meeker Ave Plume CAG Proposed Plan Public Comments 6/25/2024
2
-------
requested testing, but the property owner has not granted access, should the EPA be
unwilling to use its administrative authority to force access.
6. The CAG also would ask that the EPA be willing to test apartments on upper floors in elevator
buildings and buildings with other vertical conduits. It has been found that elevators can
increase the movement of vapors throughout a building. The EPA has stated on numerous
occasions that testing every building within the investigation area would be an aspirational goal.
Since there is evidence that upper-level apartments in elevator buildings may have greater risk
of indoor air issues due to vapor intrusion, we see no reason why the EPA should turn away
willing participants of this type.
7. The CAG believes the EPA should do vapor intrusion sampling outside of the winter heating
season.
a. The EPA should identify test sites where indoor air is sampled during the winter
heating season and at other times as well, especially during times of heavy rainfall to
assess whether winter heating season testing is indeed the best method for determining
risk of vapor intrusion. Seasonal variability of factors such as weather and rainfall can
affect vapor intrusion. From a June 2.015 document of the EPA's Office of Solid Waste
and Emergency Response, "Because fluctuations in water table elevation can lead to
elevated vapor concentrations in the vadose zone, EPA also recommends that "near
source" soil gas sampling (and possibly a soil gas survey) be considered in different
seasons that coincide with groundwater fluctuations."
b. The CAG also believes that given that TCE exposure during the first few weeks of
pregnancy increases the risk of heart damage to a developing fetus, testing should be
done in homes at any season if there is a person of childbearing age living in the home.
The risk is greatest between weeks 2 and 8 of pregnancy, which is often before a person
may even know that they are pregnant. Thus, to reduce the risk of birth defects, it would
make sense to ensure safe living and working conditions for any person who may
become pregnant.
8. The CAG has questions about how long the results of vapor intrusion testing are valid. Given that
the condition of the foundation, for example, can change with construction projects,
earthquakes, etc, we are concerned that while initial testing may deem a location "safe," the
status may change in the future. We would like to see a schedule under which properties can be
retested or a list of changes that would make a property eligible to be retested. We have seen it
suggested that if soil gas vapor tests above a certain threshold, perhaps mitigation should be
suggested in locations even if the indoor air tests "safe" in the event of future changes to the
building.
9. The CAG is concerned that not all available information is being collected and analyzed. In
particular, the EPA should use all data and wells from the National Grid site to determine the
extent of the plume given that groundwater analysis presented at the May 30, 2024, CAG
meeting showed that contamination exists right up against the current boundary of the plume
and the National Grid property. We also believe that there should be better coordination with
Meeker Ave Plume CAG Proposed Plan Public Comments 6/25/2024
3
-------
the Newtown Creek site in order to gain further information about how the two sites affect one
another.
Meeker Ave Plume CAG Proposed Plan Public Comments 6/25/2024
4
-------
From:
To:
Cc:
Subject:
Date:
Maeve BT
Ketu. Rupika
Brennan. John F.: Veaa. Carlos
Re: Meeker Superfund Testing
Monday, April 29, 2024 10:40:49 AM
Caution: This email originated from outside EPA, please exercise additional caution when deciding
whether to open attachments or click on provided links.
li Rupika.
Hope you are well. I saw this article
recently: https://mai1.goog1e.eom/mai1/u/1/#search/riipika/KtbxLwgswrHnkxCxmBhCHGppFMvB.TcqpLV
and in this Gothamist article: https://gothamist.com/news/poisonous-vapors-mav-be-affecting-over-Tk-
buitdtngs-m-greenpomt-and-east-wtlltamsburg
Am I able to submit a public comment here'.' If so here it is below:
As mentioned previously one year ago. the fact that we have to get landlord permission to get our
apartment tested basically makes this testing program useless. As someone with health problems living
on the Meeker Superfund site who wanted to get our building tested. I was unable to do so because I
couldn't get landlord permission. This is an old building with many visible cracks in the facade and
ground floor where vapors could easily get through, plus a basement unit. For this program to work a
court order needs to be put in place immediately requiring testing, because when left with a choice, the
overwhelming majority of landlords will not choose to get the space tested. It is completely unrealistic to
think that they will comply voluntarily. Delays continue to jeopardize the health of the community who
actually lives in the superfund site- the renters.
Thanks.
Maeve
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APPENDIX V
RESPONSIVENESS SUMMARY
Attachment B- Proposed Plan
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ST*%>n
rJBLi
Superfund Proposed Plan
t PRO^
Meeker Avenue Plume Superfund Site
Brooklyn. Kings County. New York
Superfund Proposed Plan
April 2024
EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan describes the remedial alternatives
that the United States Environmental Protection
Agency (EPA) considered to address vapor intrusion
impacts at residential and non-residential properties at
the Meeker Avenue Plume Superfund site (Site) located
in Brooklyn, New York. This Proposed Plan also
identifies EPA's preferred remedial alternative and
provides the rationale for this preference.
The Site is being addressed under the Comprehensive
Environmental Response, Compensation, and Liability
Act (CERCLA, also known as the Superfund Law), as
amended. A broad, comprehensive remedial
investigation and feasibility study (RI/FS) for the Site is
currently ongoing, which is referred to as Operable Unit
1 (OU1) of the Site. The OU1 RI/FS includes sampling
at properties potentially impacted by subsurface vapors
caused by Site-related contamination that can migrate
under structures and up into an overlying structure
(called "vapor intrusion"). This Proposed Plan has a
narrower focus that is referred to as Operable Unit 2
(OU2) of the Site, which is to address mitigating the
effects of unacceptable levels of vapor intrusion at
residential and non-residential properties that are
identified at the Site.
EPA's preferred alternative for OU2 calls for the
installation of sub-slab depressurization systems at
residential and non-residential properties where
multiple lines of evidence indicate that subsurface
vapor intrusion resulting from Site-related
contamination is occurring at concentrations that
represent a threat or potential threat to human health, as
well as additional preventative measures, where
necessary, such as the sealing of cracks and gaps in the
lowest level of a structure. To use multiple lines of
evidence means that EPA will evaluate multiple pieces
of information and data to support a conclusion.
This Proposed Plan was developed by EPA, the lead
agency, in consultation with the New York State
Department of Environmental Conservation
(NYSDEC) and the New York State Department of
Health (NYSDOH), the support agencies. EPA is
issuing this Proposed Plan as part of its public
participation responsibilities under Section 117(a) of
MARK YOUR CALENDARS
Public Comment Period:
April 5, 2024 to May 10,2024
EPA will accept written comments on the Proposed
Plan during the public comment period. Written
comments should be addressed to:
Rupika Kclu
Remedial Project Manager
U.S. Environmental Protection Agency
290 Broadway. 18'1' Floor
New York. NY 10007
Email: kclu.rupika?/cpa.aov
Written comments must be postmarked no later than
May 10. 2024. To request an extension, send a request
in writing to Rupika Kclu bv 5:00 pm on Mav 10.
2024.
Public Meeting
April 16, 2024
6:00 to 8:00 pm
St. Stanislaus Kostka Church
607 Humboldt Street
Brooklyn, New York 11222
EPA will hold a public meeting to explain the Proposed
Plan. Oral and written comments will also be accepted
at the meeting.
In addition, documents from the administrative record
arc available online at:
https://www.epa. aov/supcrfund/mcckcr-avcniic-pliimc
701407
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CERCLA, as amended, and Section 300.430(f)(2) of
the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP).
Release of this Proposed Plan initiates a 30-day public
comment period. EPA, in consultation with NYSDEC
and NYSDOH, will select a final remedy for OU2 after
reviewing and considering all information submitted
during the public comment period. EPA, in consultation
with NYSDEC, may modify the preferred alternative or
select another alternative presented in this Proposed
Plan based on new information or public comments.
Therefore, the public is encouraged to review and
comment on all of the alternatives presented in this
Proposed Plan.
This Proposed Plan summarizes information that can be
found in greater detail in the focused feasibility study
(FFS) report prepared for OU2, which can be found in
the administrative record for this remedial decision.
The dates for the public comment period, the public
meeting described below, and the location of the
administrative record can be found in the "Mark Your
Calendars" text box on Page 1 and in the "For Further
Information" text box on Page 12. EPA and NYSDEC
encourage the public to review these documents to gain
a more comprehensive understanding of activities for
the Site.
COMMUNITY ROLE IN SELECTION PROCESS
This Proposed Plan is being issued to inform the public
of EPA's preferred alternative to address vapor
intrusion impacts at the Site and to solicit public
comments pertaining to all of the remedial alternatives
evaluated, including the preferred alternative. Changes
to the preferred alternative, or a change to another
alternative, may be made if public comments or
additional data indicate that such a change would result
in a more appropriate remedial action. The final
decision regarding a selected remedy will be made after
EPA has taken into consideration all public comments.
EPA is soliciting public comments on all of the
alternatives considered in the Proposed Plan because
EPA may select a remedy other than the preferred
alternative.
This Proposed Plan has been made available to the
public for a public comment period that concludes on
May 10, 2024.
2
A public meeting will be held during the public
comment period to present the conclusions of the FFS,
to elaborate further on the reasons for proposing the
preferred alternative, and to receive public comments.
The public meeting will include a presentation by EPA
of the preferred alternative and other cleanup options.
Comments received at the public meeting, as well as
written comments received during the public comment
period, will be documented in a Responsiveness
Summary section of a Record of Decision (ROD),
along with EPA's responses. A ROD is a document that
memorializes the selection of a remedy and the basis
for the selection.
SCOPE AND ROLE OF THE ACTION
As with many Superfund sites, the contamination at this
Site is complex, and the cleanup is being managed
through more than one operable unit.
As described above, OU1 currently is broader and more
comprehensive than the more focused OU2. A
comprehensive RI/FS for OU1 was initiated in 2023
and is ongoing. That RI/FS includes the investigation of
all media at the Site, including soil, soil gas,
groundwater, surface water, sediment, and air.
This Proposed Plan identifies an interim remedy for
OU2, which is to address unacceptable risks in indoor
air resulting from Site-related contamination. The
RI/FS for OU1 is still in its early stages. As such, the
OU2 alternatives are being considered interim while
EPA's overall conceptual site model of the Site is being
developed. Any selected remedy for OU2 will be
reviewed on an ongoing basis to determine if any
changes to the selected alternative are needed.
The ongoing performance of vapor intrusion sampling
to identify additional properties where the potential for
vapor intrusion of Site-related contamination poses
unacceptable risks will continue as part of OU 1 of the
Site. EPA's goal is to conduct vapor intrusion sampling
at as many properties as possible at the Site.
SITE DESCRIPTION
The Site is located in Brooklyn, Kings County, New
York and spans approximately 191 acres across several
city blocks in the Greenpoint and East Williamsburg
area of Brooklyn. The Brooklyn-Queens Expressway
(BQE) roughly bisects the Site in a west-southwest to
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east-northeast direction. The Site includes a mixture of
residential, commercial, and industrial uses. These land
use designations are not anticipated to change in the
future. The total population within the Greenpoint and
Williamsburg neighborhoods of Brooklyn where the
Site is located is approximately 160,000 people.
Figure 1 at the end of this document shows the Site and
the interim Study Area boundary, where Study Area is
defined as the area where the OU1 RI/FS activities are
currently focused. The interim Study Area boundary
will be refined as the OU 1 RI/FS continues and more
data are obtained.
SITE BACKGROUND
The Site is located in a region of historic petroleum
refining and storage operations that have occupied a
significant portion of the Greenpoint area since
approximately 1866. Currently, bulk oil storage
terminals exist north of the Site and include the former
British Petroleum Terminal (now Kinder Morgan) and
the ExxonMobil Brooklyn Terminal. The former
Paragon Oil facility was located along the northeastern
portion of the Site along Newtown Creek, north of
Bridgewater Street, between Meeker Avenue and
Apollo Street. The contamination associated with the
Site was discovered by NYSDEC during investigation
and remediation of an adjacent and overlapping
petroleum groundwater contamination area, which had
resulted from historical petroleum refining and storage
operations along the banks of Newtown Creek. During
several rounds of investigation, chlorinated volatile
organic compounds (CVOCs), including but not limited
to trichlorethylene (TCE) and tetrachlorethylene (PCE),
were found in subsurface soil and groundwater outside
the petroleum spill area. Upon discovery of the CVOC
contamination, NYSDEC initiated investigations in the
area to determine the extent and sources of CVOC
contamination, as well as the potential impacts of this
contamination on the community.
Since 2007, NYSDEC in conjunction with NYSDOH,
has conducted multiple investigations related to the
Site. These investigations have consisted of soil,
groundwater, soil gas, and soil vapor intrusion
sampling. NYSDEC completed nine separate Site
characterization investigations between 2007 and 2016
and ten soil vapor intrusion investigations between
2007 and 2023. In total, NYSDEC sampled more than
166 properties and installed 29 sub-slab
depressurization mitigation systems to address vapor
intrusion throughout the course of their investigations.
On March 17, 2022, the Site was added to EPA's
National Priorities List pursuant to CERCLA and
officially became a Superfund site. As mentioned above,
EPA is currently conducting the OU1 RI/FS for the Site.
Site Geology and Hydrogeology
Based on soil borings performed at and near the Site by
NYSDEC and other investigators, the Site is underlain
from the ground surface down by the Upper Glacial
aquifer, the Raritan Formation, and crystalline bedrock.
The primary hydrogeologic unit is the Upper Glacial
aquifer, which consists of a terminal moraine, a ground
moraine, and glacial outwash deposits, and it is
characterized by the United States Geological Survey
(USGS) as an unsorted and unstratified mixture of clay,
sand, gravel, and boulders. Textural units identified by
NYSDEC in the Upper Glacial aquifer at the Site
include fill material, silty sand, sandy silt, sand, and
localized clayey silt / silt. Based on slug test results
from several Meeker Avenue Plume Site monitoring
wells, the hydraulic conductivity of the Upper Glacial
aquifer ranges from 8.32 x 10"5 centimeters per second
(cm/s) to 2.91 x 10"2cm/s.
At and near the Site, the Upper Glacial aquifer is
underlain by the Raritan Formation unit at an
approximate depth of 100 to 140 feet below ground
surface. The Raritan Formation, which consists of clay,
silty clay, and clayey to silty fine sand, exhibits
hydraulic conductivity less than 10"6 cm/s and is
recognized as a confining unit. The water table surface
occurs in the Upper Glacial aquifer from approximately
10 to 60 feet below ground surface.
In general, natural groundwater flow in the aquifer is to
the east and northeast. However, the large, off-site
groundwater pump and treat system that has been
operated since the mid-1990s as part of an effort to
cleanup an overlapping petroleum groundwater
contamination area has produced localized cones of
depression.
The overall Site hydrogeology is being further explored
through the OU1 RI/FS process.
3
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WHAT IS NEEDED TO HAVE A COMPLETE
VAPOR INTRUSION PATHWAY?
In order for the vapor intrusion pathway to be
complete, there must be volatilization of Site-
related contaminants from contaminated
groundwater or other subsurface sources through
the vadose (or unsaturated) zone to the soil vapor
underneath a structure (i.e., sub-slab soil vapor).
These contaminants can then migrate through the
slab into indoor air. Contaminant vapors move from
an area of higher concentration to an area of lower
concentration. The vapor intrusion pathway is
complete when Site-related contaminants migrate
into indoor air where vapors may be inhaled.
SUMMARY OF ONGOING INVESTIGATIONS
Vapor Intrusion Description
The soil, soil gas, and groundwater at the Site are
contaminated with CVOCs. CVOCs are a subset of
volatile organic compounds (VOCs), which are
substances that typically evaporate at room
temperature. They can affect the indoor air of properties
located in close proximity to contaminated areas by
entering the indoor air of structures through small
cracks, pipes or other points of entry. Soil vapor
intrusion inside residential and commercial buildings is
a major concern at the Site. VOCs are also commonly
found in household products such as cleaning supplies,
building products like paints and air fresheners.
Therefore, sampling indoor air for the presence of Site-
related contamination is a complicated process that
involves sampling both the indoor air and the air
beneath the structure overtime. Common household
sources of VOCs also need to be removed during
testing so that the results can reliably reflect what may
be entering the structure from the contaminated
material beneath it, as opposed to from materials in the
building.
The soil vapor intrusion sampling being conducted by
EPA as part of the OU1 RI/FS is typically a three-day
process, which can generally be described as follows,
though slight modifications to this approach can be
made on an as-needed basis:
• Day 1: EPA inspects the property for any
potential sources of VOCs and temporarily
stores any that are found. EPA then installs a
sub-slab soil gas port, which involves drilling
an approximately quarter-sized hole through
the lowest level floor of a structure. Day 1
activities typically takes EPA between 1 and
1.5 hours to complete.
• Day 2: EPA returns to make sure the port is
functioning properly and, assuming it is, places
sampling devices throughout the lowest one or
two levels of the property (typically, basement
and first floor). These sampling devices need to
be left in place to collect air passively for 24
hours for residential properties and at least 8
hours for non-residential properties. Day 2
activities typically take EPA about 1 hour to
complete.
• Day 3: EPA returns to collect the air samplers,
which typically takes less than 1 hour to
complete.
Ideally, this sampling is conducted during the winter
heating season, which runs from mid-November
through March in the New York City area, because this
is when the greatest potential for subsurface vapor
intrusion is expected to occur.
The results of the sampling are evaluated through
multiple lines of evidence to make recommendations on
next steps. The potential recommendations may include
(1) that the results clearly indicate that no action is
required; (2) that the results are not clear and additional
sampling is required; or (3) the results indicate that
contamination from the soil, groundwater, and/or soil
gas is entering or has the potential to enter the structure
above Remedial Action Levels (further defined below)
and, therefore, soil vapor mitigation in the structure is
required.
The purpose of OU2 is to evaluate alternatives for
addressing unacceptable risks associated with Site-
related soil vapor intrusion when mitigation is required.
Current Status of Investigation
There are currently well over 1,000 properties within
the preliminary Study Area for the Site that are at
potentially impacted by vapor intrusion of Site-related
contamination; the potential for vapor intrusion
depends on multiple factors, including the condition of
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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)(l)(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 groundwater, surface water, or air, or
acts as a source for direct exposure. Contaminated
groundwater generally is not considered a source
material; however, non-aqueous phase liquids 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. A decision
whether and how 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.
the building itself and the level of contamination
beneath and near a structure. As such, EPA's goal is to
conduct vapor intrusion sampling at as many properties
as possible within the Study Area. As part of this effort,
EPA has been seeking consent for access to conduct the
sampling while working closely with the community on
outreach efforts to help increase awareness about the
Site and encourage the public's overall willingness to
provide access.
EPA began soil vapor intrusion sampling activities at the
Site as part of OU1 in November 2022. As of December
2023, EPA has conducted vapor intrusion sampling and
fully evaluated the results at 18 residential structures,
11 public housing buildings, and one public school. Out
of these, EPA has determined that vapor mitigation is
not needed at this time at any of the properties it has
sampled, and that further monitoring should be
conducted at three of the residential properties. In
addition, in February and March 2024, EPA sampled 18
properties and will be evaluating the results, and will be
conducting additional sampling in the future. NYSDEC
did, however, identify 26 properties that they
determined required the installation of sub-slab
depressurization systems to mitigate risks from vapor
intrusion when they were conducting work prior to the
Site being designated as a Superfund site, and two that
required the sealing of cracks/gaps. As such, EPA fully
anticipates identifying additional properties that would
require vapor intrusion mitigation during the ongoing
OU1 RI/FS process.
EPA has recently completed an initial round of
groundwater sampling at the Site. This sampling effort
included surveying more than 370 existing groundwater
monitoring wells and sampling 344 of these for
CERCLA-related hazardous substances including
VOCs, semi-volatile organic compounds, 1,4-dioxane,
pesticides, polychlorinated biphenyls, metals, and per-
and polyfluoroalkyl substances. Once the analytical
results from the groundwater sampling are fully
available, the data will be used to refine the extent of
the preliminary Study Area, to determine the location of
additional wells that need to be installed to fill in data
gaps, and to help better determine areas where future
vapor intrusion sampling should be conducted.
PRINCIPAL THREATS
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. They include liquids and other
highly mobile materials (e.g., solvents) or materials
having high concentrations of toxic compounds. A
detailed explanation of principle threat wastes can be
found in the information box, "What is a Principal
Threat?" on this page.
This response action does not address source materials
constituting principal threat wastes because no such
materials are part of this operable unit. The interim
action that is being evaluated in this Proposed Plan
solely addresses vapor intrusion of contaminants into
structures from subsurface sources of contamination.
Soil vapor is neither a source material nor a principal
threat waste.
SUMMARY OF SITE RISKS
Human Health Risk Assessment
EPA conducted an expedited human health risk
evaluation of the soil vapor intrusion exposure pathway
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as part of the FFS for OU2 to estimate the risks
associated with exposure to Site-related contaminants
of potential concern (COPCs) in indoor air. The
evaluation utilized data obtained by both NYSDEC and
EPA.
The approach for the expedited risk evaluation
consisted of comparing sub-slab soil vapor and indoor
air concentrations against current, risk-based vapor
intrusion screening levels (VISLs). Two residential
properties previously assessed by NYSDEC, as well as
one residential property assessed by EPA, were chosen
for this evaluation. These properties were chosen
because, based on a review of the data, they are
representative of high-end exposure conditions.
Based on the results of the soil vapor intrusion
sampling thus far, the primary Site-related COPCs
associated with OU2 are currently PCE and TCE. As
the OU1 RI/FS is still ongoing, it is possible that
additional Site-related COPCs may be identified in the
future, but the expedited risk evaluation focused on
these two COPCs.
EPA recommends comparing the maximum detected
sub-slab and indoor air results to the appropriate EPA
VISLs for residential use based on a cancer risk of
lxlO"6 or hazard quotient (HQ) of 1 when evaluating
the VI pathway and determining potential risks. The
results of these comparisons are provided below.
TCE: The concentration of TCE in the sub-slab at the
residential properties that were evaluated ranged from
18 micrograms per meter cubed ((ig/m3) to 300 ug/m3,
and the concentration of TCE in the basement and/or
first floor indoor air ranged from 0.549 (ig/m3 to 12
(ig/m3. The noncancer hazards associated with these
concentrations ranged from an HQ <1 up to an HQ = 6,
which exceeds the goal of protection of an HQ = 1.
Cancer risks associated with exposure to TCE at the
residential properties evaluated were all below lxlO"4.
The HQ value and the significance of lxlO"4 are
described in the information box on the next page
entitled, "What is Human Health Risk and How is it
Calculated?"
PCE: The concentration of PCE in the sub-slab at the
residential properties that were evaluated ranged from
1,400 (ig/m3 to 4,200 (ig/m3, and the concentration of
PCE in the basement and/or first floor indoor air ranged
from 37 (ig/m3 to 170 (ig/m3. The noncancer hazards
associated with these concentrations ranged from an
6
WHAT IS 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 releases undercurrent- and
anticipated future-land uses. A four-step process is utilized for
assessing site-related human health risks for reasonable
maximum exposure scenarios.
Hazard h/eiilificalion: In this step, the chemicals of potential
concern (C( IPC's) 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 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" scenario that 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 and severity of
adverse effects 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
(>.£., changes in the effectiveness of the immune system).
Some chemicals are capable of causing both cancer and non-
cancer health hazards.
Risk ('liaraclerizalion: This step summarizes and combines
outputs ol'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 10"1 cancer risk means a
"one-in-ten-thousand excess cancer risk"; or one additional
cancer may be seen in a population of I (),()()() people as a
result 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"1 to 10"". corresponding to a
one-in-ten-thousand to a one-in-a-million excess cancer risk,
f or non-cancer health effects, a "hazard index" (1II) is
calculated. The key concept for a non-cancer III is that a
"threshold" (measured as an III of less than or equal to I)
exists below which non-cancer health hazards are not
expected to occur. The goal of protection is 10"" for cancer
risk and an III of I for a noncancer health hazard. Chemicals
that exceed a 10"1 cancer risk or an III of I are typically those
that will require remedial action at a site and are referred to as
chemicals of concern, or COCs. in the final remedial decision
document or Record of Decision.
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HQ <1 up to an HQ = 4, which exceeds the goal of
protection of an HQ = 1. Cancer risks associated with
exposure to PCE at the residential properties evaluated
were all below lxlO"4.
TCE and PCE are considered the contaminants of
concern (COCs) for OU2.
Ecological Risk Assessment
The first step in an ecological risk assessment is to
evaluate completed exposure pathways for ecological
receptors. For OU2, there are no completed ecological
exposure pathways, as the focus of this operable unit is
centered on vapor intrusion into buildings. As such, an
ecological risk assessment was not performed as part of
the OU2 evaluation process.
Conclusion
Based on the results of the expedited human health risk
evaluation, a remedial action is necessary to protect
public health, welfare, and the environment from actual
or threatened releases of hazardous substances.
It is EPA's judgment that the preferred alternative
summarized in this Proposed Plan is necessary to
protect public health or welfare or the environment
from actual or threatened releases of hazardous
substances into the environment.
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
(TBC) advisories, criteria, and guidance, and site-
specific risk-based levels, if applicable. The primary
objective of any remedial strategy is overall
protectiveness.
The following RAOs have been established for OU2 to
address soil vapor intrusion risks at the Site:
• Prevent exposure by current and future
occupants to Site-related PCE and TCE-
contaminated vapors within structures that
would result in a noncancer hazard index
greater than 1.
• Prevent the migration of contaminated
subsurface vapors into the indoor air of
structures from Site-related PCE and TCE in
soil and/or groundwater above remedial
action levels based on current and reasonably
anticipated future land use.
REMEDIAL ACTION LEVELS
To achieve the RAOs, EPA has identified the following
Remedial Action Levels (RALs)1 for TCE and PCE:
The RALs represent current EPA VISLs set at a target
HQ = 1, which falls midway between EPA's cancer
risk range of lxlO"6 to lxlO"4.
These RALs will be considered with other Site-specific
lines of evidence such as subsurface geology and
hydrogeology, the structural characteristics of each
building, and proximity to other impacted structures in
determining whether there is a need for remedial
action. The need for remedial action will also be
determined in consultation with NYSDEC and the New
York State Department of Health (NYSDOH),
including consideration of NYSDOH's Guidance for
Evaluating Soil Vapor Intrusion in New York State.
SUMMARY OF REMEDIAL ALTERNATIVES
Section 121(b)(1) of CERCLA, 42 U.S.C. § 9621(b)(1),
mandates that remedial actions must be protective of
human health and the environment, be cost-effective,
Residenlial
( ommeicial
Remedial
Induslnal Remedial
((K
Aclion 1
e\ els
Action l.e\els
(LIU 111 )
( LIL! Ill )
Indoor
Sub- slab
Indoor
Sub-
Air
Air
slab
TCE
2.1
70
8.8
290
PCE
42
1,400
180
5,800
1 Consistent with EPA's Technical Guide for Assessing and
Mitigating the Vapor Intrusion Pathway (OSWER 9200.2-
154, 2015), the RALs are developed assuming an attenuation
factor from sub-slab to indoor air of 33.
2 The commercial/industrial RALs assume an eight-hour
workday, which is protective of most non-residential settings
and can be adjusted as needed to account for property-specific
conditions.
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comply with ARARs, and utilize permanent solutions,
alternative treatment technologies, and resource
recovery alternatives to the maximum extent
practicable. Section 121(b)(1) of CERCLA also
establishes a preference for remedial actions that
employ, as a principal element, treatment to reduce
permanently and significantly the volume, toxicity, or
mobility of the hazardous substances, pollutants, and
contaminants at a site. Section 121(d) of CERCLA, 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 Section
121(d)(4) of CERCLA, 42 U.S.C. § 9621(d)(4).
upon several factors, including subsurface geology and
hydrogeology, the structural characteristics of the
building, and proximity to other impacted structures or
sources. Different impacted structures may therefore
require different vapor mitigation strategies based on
factors such as age of the building and construction
type, the depth to groundwater beneath a structure, etc.
For the purposes of the cost estimate, the mitigation
actions include sealing cracks and gaps in the slab,
installing a concrete slab or comparable membrane
system in instances where only a dirt floor is present,
and installing active sub-slab depressurization
mitigation systems for a projected number of 100
properties, which is approximately 10 percent of the
properties within the interim Study Area.
Descriptions of the remedial alternatives considered to
address vapor intrusion impacts resulting from Site-
related contamination are provided below. More detail
can be found in the FFS report prepared for OU2.
The construction time for each alternative does not
include the time required to design the remedy,
negotiate the performance of the remedy with any
potentially responsible parties, or procure necessary
contracts.
Alternative 1 - No Action
The NCP requires that a "No Action" alternative be
evaluated to establish a baseline for comparison with
other remedial alternatives. Under this alternative, no
action would be taken with regard to addressing vapor
intrusion at the Site.
Total Capital Cost: $0
Total O&M: $0
Total Cost: $0
Construction Time: 0 years
Alternative 2 - Vapor Intrusion Mitigation
Under this alternative, vapor intrusion mitigation would
be implemented at structures where EPA determines
that, based on multiple lines of evidence, vapor
intrusion of the COCs is occurring at concentrations
that exceed the RALs. The goal of vapor intrusion
mitigation would be to prevent contaminated soil
vapors from entering and/or accumulating in structures
at concentrations that represent a threat, or a potential
threat, to human health. The potential for vapor
intrusion to occur at a particular structure is dependent
The cost estimate reflects the estimated costs for
mitigation in the event that an estimated 100 structures
within the Study Area are found to require vapor
mitigation as a result of sampling and the other lines of
evidence described above. The cost estimate also takes
into consideration other factors including costs for
addressing basements and crawl spaces without any
existing concrete floor, as well as larger multi-unit
structures that would require more depressurization
points than smaller structures. The cost estimate also
reflects one year of estimated costs for operation and
maintenance (O&M) of sub-slab depressurization
mitigation systems to ensure the systems are operating
properly for the estimated 100 properties. The sampling
and mitigation is expected to occur on a rolling basis
over a period of five years. If it is determined that a
property requires a sub-slab depressurization system,
EPA will work with the owner to arrange for the
installation of the system. Construction can be
completed in as little as one day, and it can take up to
one week or longer for the installation of larger
commercial systems. The time required for the
construction is dependent on property owners providing
access.
The specific details and cost of the mitigation system
for any particular building would be determined during
remedial design.
Total Capital Cost:
Total O&M:
Total Cost:
Construction Time:
$1,124,000
$21,200
$1,145,200
5 years
-------
EVALUATION C RITERIA FOR SUPERFUND REMEDIAL
ALTERNATIVES
Overall Protectiveness of Human Health and the Environment
evaluates whether and how an alternative eliminates, reduces, or
controls threats to public health and the environment through
institutional controls, engineering controls, or treatment.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) evaluates whether the alternative meets
federal and state environmental statutes, regulations, and other
requirements that pertain to the site, or whether a waiver is justified.
Long-term Effectiveness and Permanence considers the ability of an
alternative to maintain protection of human health and the environment
over time.
Reduction of Toxicity, Mobility, or Volume of Contaminants
through Treatment evaluates an alternative's use of treatment to
reduce the harmful effects of principal contaminants, their ability to
move in the environment, and the amount of contamination present.
Short-term Effectiveness considers the length of time needed to
implement an alternative and the risks the alternative poses to workers,
the community, and the environment during implementation.
Implementability considers the technical and administrative
feasibility of implementing the alternative, including factors such as
the relative availability of goods and services.
Cost includes estimated capital and annual operations and maintenance
costs, as well as present worth cost. 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.
State/Support Agency Acceptance considers whether the State agrees
with the EPA's analyses and recommendations, as described in the
RI/FS and Proposed Plan.
Community Acceptance considers whether the local community
agrees with EPA's analyses and preferred alternative. Comments
received on the Proposed Plan are an important indicator of community
acceptance.
EVALUATION OF ALTERNATIVES
In evaluating the remedial alternatives, EPA considers
the following nine evaluation criteria set forth in the
NCP: overall protection of human health and the
environment; compliance with ARARs; long-term
effectiveness and permanence; reduction of toxicity,
mobility, or volume through treatment; short-term
effectiveness; implementability; cost; and state and
community acceptance. Refer to the table below for a
more detailed description of the evaluation criteria.
This section of the Proposed Plan summarizes the
evaluation of the relative performance of each
alternative against the nine criteria, noting how each
compare to the others under consideration. A detailed
analysis of alternatives can be found in the FFS.
Overall Protection of Human Health and the
Environment
A threshold requirement of CERCLA is that the
selected remedial action be protective of human health
and the environment. An alternative is protective if it
reduces current and potential future risk associated with
each exposure pathway at a site to acceptable levels.
Alternative 1 (No Action) would not meet the RAOs
and would not be protective of human health and the
environment since no action would be taken.
Alternative 2 (Vapor Intrusion Mitigation) would
control exposure to Site-related contaminants from
vapor intrusion into residential and non-residential
structures. Contaminated sub-slab vapor would be
prevented from entering and/or accumulating in
buildings at concentrations that represent a potential
threat to human health. Therefore, when implemented
at impacted buildings, Alternative 2 would be
protective of human health and the environment.
Compliance with Applicable or Relevant and
Appropriate Requirements
In accordance with the NCP (40 CFR §
300.430(f)(l)(ii)(c)(l)), interim actions such as this are
not required to comply with ARARs as long as the final
remedial action at the Site will attain them.
Consequently, no ARARs have been identified for this
interim action.
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.
Alternative 2 would be effective in the long term.
Previously installed vapor mitigation systems at other
structures in the area have demonstrated effectiveness
in addressing vapor intrusion concerns. Long-term
effectiveness of the vapor intrusion mitigation systems
would be provided by establishing and implementing
O&M procedures to ensure that the systems continue to
9
-------
mitigate the potential threat to human health posed by
vapor intrusion at impacted structures at the Site.
Reduction of Toxicity, Mobility, Volume of
Contamination through Treatment
Alternatives 1 and 2 would provide no reduction in
toxicity, mobility, or volume. However, under
Alternative 2, Site-related contaminants in vapor form
would be prevented from entering into buildings at
concentrations that represent a potential threat to human
health.
Short-Term Effectiveness
Alternative 1 does not involve any active construction
activities that could present a risk to workers or the
public.
Implementation of Alternative 2 would not be expected
to result in short-term risks to the community, the
workers installing the vapor intrusion mitigation
systems, or the environment in general. Any potential
threats to the workers from inhaling hazardous
substances in vapor form during system installation
would be minimized with the implementation of
appropriate health and safety measures.
As for short term impacts, no time is required for
construction of Alternative 1. Under Alternative 2, the
installation of sub-slab depressurization systems can be
completed in as little as one day and it can take up to
one week for the installation of larger commercial
systems. While, for planning purposes, it is estimated
that Alternative 2 may take up to five years to install
the estimated 100 systems to address vapor intrusion
concerns within the Study Area, this would not,
however, be a continuous five years of effort. Rather,
the installations would happen as the need is
determined through the ongoing OU1 RI/FS process.
Implementability
Alternative 1 does not involve the application of any
technology, therefore, there are no issues relating to
feasibility of implementation.
Alternative 2 is considered to be readily implementable.
The installation of vapor mitigation systems under
Alternative 2 would use readily available services and
equipment. Such systems have already been installed at
other buildings in the area and have shown to be
reliable and effective in addressing vapor intrusion and
mitigating exposures.
Cost
There is no cost associated with Alternative 1 because
no activities are implemented.
The estimated cost of Alternative 2 was developed as a
range of costs because the total number of residential
versus non-residential buildings that require vapor
mitigation is not currently known. In addition, the
actual costs could vary depending on the particular
building and would be determined during design. The
estimated total cost includes capital costs and O&M
costs for one year to ensure the system is operating
properly. After one year, O&M of the vapor mitigation
system is turned over to the State.
Note that Alternative 2 provides for the potentiality of
designing, installing, and maintaining vapor mitigation
systems, but it does not address the electricity costs to
operate the vapor mitigation system. The operating
costs for these systems are minimal, similar to costs to
operate radon mitigation systems, and they would be
the responsibility of the property owner.
The estimated total cost for Alternative 2 is $1,145,200.
State Acceptance
NYSDEC concurs with EPA's preferred alternative.
Community Acceptance
Community acceptance of the preferred alternative will
be evaluated after the public comment period ends and
will be described in the Responsiveness Summary
section of the ROD. Based on public comment, the
preferred alternative could be modified from the
version presented in this Proposed Plan.
PREFERRED REMEDY AND BASIS FOR
PREFERENCE
Based upon an evaluation of the remedial alternatives,
EPA, with the concurrence of NYSDEC, proposes
Alternative 2, Vapor Intrusion Mitigation. Vapor
intrusion mitigation would be implemented at
residential and non-residential structures at the Site
where multiple lines of evidence indicate that vapor
10
-------
intrusion is occurring at concentrations that represent a
threat or a potential threat to human health.
The potential for vapor intrusion to occur at a particular
structure is dependent upon several factors, including
subsurface geology and hydrogeology, the structural
characteristics of each building, and proximity to other
impacted structures or sources. Different impacted
structures may therefore require different vapor
mitigation strategies based on factors such as the age of
the building and construction type, the depth to
groundwater beneath a structure, etc. As such, the
preferred alternative has the following key components,
some or all of which may be used at any particular
property: the installation of sub-slab mitigation
systems; engineering measures such as the sealing of
cracks and gaps in the lowest level slab of a structure;
the installation of a concrete slab or comparable
membrane system in instances where only a dirt floor is
present; and one year of O&M. This alternative has the
estimated total cost of $1,145,200.
Basis for the Remedy Preference
Alternative 2 (Vapor Intrusion Mitigation) is the
preferred alternative because it meets the threshold
criteria to protect human health and the environment by
preventing contaminants of concern from entering
indoor air at levels that pose an unacceptable risk. The
exact number of residential properties to be remediated
will be determined upon completion of additional vapor
intrusion sampling during the ongoing OU1 RI/FS.
Based upon the information currently available, EPA
believes the preferred alternative meets the threshold
criteria and provides the best balance of tradeoffs
compared to the other alternative with respect to the
balancing and modifying criteria set forth in the NCP.
The preferred alternative is considered protective of
human health and the environment in the short-term
until a final remedy is implemented for the Site.
Although this interim action is not intended to address
fully the statutory mandates, the preferred alternative, if
implemented, would satisfy the statutory requirements
of Section 121(b) of CERCLA, namely being (1)
protective of human health and the environment and (2)
cost effective. EPA expects the final remedy for the site
will fully satisfy the statutory requirements. The
preferred alternative would be readily implementable
using technologies proven to be effective at this Site, as
well as similar sites. The short-term effects of the
preferred alternative include potential impacts to
workers, but these could be mitigated using appropriate
health and safety measures.
The preferred alternative does not satisfy the preference
for treatment because vapor intrusion mitigation
systems do not treat the subsurface vapor source, and
treatment of groundwater and/or soil gas is outside the
scope of this interim action. The environmental benefits
of the preferred alternative may be enhanced by
consideration, during the design, of technologies and
practices that are sustainable in accordance with both
the EPA Region 2's Clean and Green Energy Policy
and NYSDEC's Green Remediation Policy3. This
would include consideration of green remediation
technologies and practices.
With respect to the two modifying criteria of the
comparative analysis, which are state acceptance and
community acceptance, NYSDEC concurs with the
preferred alternative and community acceptance will be
evaluated upon the close of the public comment period.
COMMUNITY PARTICIPATION
EPA provides information regarding the cleanup of the
Site to the public through meetings and announcements
published in the local newspaper. EPA and NYSDEC
encourage the public to gain a more comprehensive
understanding of the Site and the Superfund activities
that are being conducted there. The interim remedy for
the Site will be selected after reviewing and considering
all information submitted during a 30-day public
comment period.
The dates for the public comment period, the date,
location, and time of the public meeting, and the
locations of the Administrative Record files are
provided on the front page of this Proposed Plan.
3 See http://www.epa.gov/greenercleanups/epa-region-2- http://www.dec.ny.gov/docs/remediation_hudson_pdf/der31.
cleanand-green-policy and pdf
11
-------
FOR FURTHER INFORMATION
The administrative record file, which contains copies
of the Proposed Plan and supporting documentation, is
available at the following locations:
EPA Region 2 Supert'und Records Center
290 Broadway. 18lh Floor
New York. New York 10007-1866
(212) 637-4308
Hours: Monday-Friday - 9 A.M. to 5 P.M.
Brooklyn
Grccnpoint Public Library
107 Norman Avenue
Brooklyn. New York 11222
Hours:
Monday. Wednesday. Friday - 10 A.M. To 6 P.M.
Tuesday - 1 P.M. to 8 P.M.
Thursday - 10 A.M. to 8 P.M.
Saturday - 10 A.M. to 5 P.M.
Sunday ~ Closed
In addition, the administrative record file is available
on-line at:
hllDs://\Yww.CDa.uov/suDcrfund/mcckcr-a venue-plume
12
-------
Figure 1 - Site Location Map
Norman Avenue.
*N5sauA«nu|
'Avenue,
>rt Avenue.
Richardson^
gi^oit Street.
Withers
"jackson
Meeker Avenue Plume
Superfund Site
Preliminary Study Area
Figure 1
1,200
Feet
Site Location Map
Meeker Avenue Plume
Superfund Site
Preliminary Study Area
Brooklyn, Kings County, NY
A=COM
-------
APPENDIX V
RESPONSIVENESS SUMMARY
Attachment C- Public Notice
-------
-nrcr me ncia snouia move soon, as entry namers arcn t
wcrty prohibitive.
"If you look at the descriptions for AJ. job postings,
many of the roles arc still very exploratory, alluding to
wilding or testing new products." ZipRecruiter chief
xonomist Julia Pollak told CNBC in December "A lot
companies still don'I seem to know how best to har-
ness these tools in their businesses and are still hiring
Deople who can help them figure it out and decide if
ihcy should make a long-term investment in A.!, talent."1
Keep Hustling
In this era of personal life arid wellness prioritiza-
:ion, employees need more than a paycheck. Last year, a
majority of Americans earning six-figure salaries lived
aavchcck-to-paychecL Plenty of potentially lucrative
side hustles are available for the currently employed
iecking supplemental income. Such activities include
leveraging existing assets, like hosting on Airbnb. rent-
ing out tools or equipment and loaning vehicles.
Alternatively, such gigs could require labor appli-
ration, whether delivering food, cleaning houses, or
mowing lawns. Have a strategy when kick-starling
itdc hustles and ensure their sustainability as profitable,
king-term undertakings.
Ample opportunities pepper the present U.S. labor
market Employers in fast-growing industries, namely
ech. finance, and healthcare organizations, are desper-
ate for solid staff.
Whether pursuing side hustles, online entreprcneur-
ihip. or entering a new field this year could be a de-
cisive opportunity for millions of Americans to pursue
lew career aspirations
Ct£5 OF OR&ANCATlOh FILED WITH
SECRETARY Of STATE Of NEW YORK
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SMALL MAIL A COPY OF ANY PRO
CESS AGAINST THE LLC SERVED
UPON HM.4CH 6 ZENBUSiNESS INC
41 STATE STREET, SUITE 1S2 ALBAV*
NY, 12207 PUBfOSL«CHAHACTER OF
LLC. ANY LAWFUL PURPOSE
PROMOTt YOUR EVENT,
REACH A MILLION
PAGEVIEWS.
len Hopewell will help,
eagSeurbaimedia
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41 STATE STREET, SUITE 112 ALBANY.
NY. 12207 PURPOSE-CHARACTER OF
LLC ANY LAWFUL PUWOSE.
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&EPA
United Stales
Environmental Protection
Agency
EPA INVITES PUBLIC COMMENT ON THE PROPOSED CLEANUP PLAN
FOR THE MEEKER AVENUE PLUME SUPERFUND SITE IN BROOKLYN, NEW YORK
The Ui Lnvronrnental Protection Agency I EPA) is aaiung the pubbc for input on rts proposed cleanup
plan to address the potential vapors that may be entering into rcsderfflal and ooirmemai buildings ait
the Meeker Avenue Pkjme Superfund site wi Brooklyn, Mew Yari.
The EPA is accepting comments from the public on; the proposed cleanup ptan iot this site from Friday
April 05,2024 to Ft id ay May 10,2024 The EPA will con side: comments submitted during the comment
period before making a final d cos ion The public w encouraged to review the p&an, attend the public
meeting, and comment on the proposed cleanup alternative. Comments may be emailed to
ftefurupito&epagov ar mailed to Ruptka Ketu, US EPA. 290 Broadway, 1 Sh Floor. New York. MY 10007-
1866 no later than May 10th, 2024.
The EPA will hold an m-person pubfec meeting to discuss the proposed cleanup dan on Aprd 16th. 2024
at 6.00 pm at St Stanislaus Kostka Lower Church. GD.r Hurnbof.dt St, Brooklyn, NY. For more information,
please contact tPA's Community Involvement Coordinator. Anna Drabefc at dfobek.arma&epa.gov or visit
httpE/Zmimupa qm/superfiFK&'metter-Gvcnue-phone.
We make memories over food. We tell stories over a good meal.
But sometimes the meal is a story. And sometimes, ifs so much more.
Restaurants are a family's LEGACY, a chefs PASSION, a business owner's PRIDE.
Let Us Tell the World Your Food Story
if you own a restaurant in Brooklyn and would like to find out more, please contact:
Jen Hopewell:
jdh@eagleurbanmedia.com
Fnd&y. April 5, 2024 ¦ SECOND DEPARTMENT iBrooklyiVDally Eagle • tg
-------
The "Public Place" site off the Gowanus Canal as it looked like in 2019.
Community Board 6 wanted all of
Gowanus Green to be affordable.
Based on the latest literature from the
developers that describes the planned
development as being "100 % afford-
able." it looks like the board won that
point.
Gowanus Green has been in the works
since 2008, as evidenced by a city docu-
ment. issued that November, called
Eagle Site cfiy.Q by Low Craghan
"Gowanus Green Draft Scope of work for
an Environmental Impact Statement."
The Gowanus neighborhood it-
self is surrounded by Carroll Gar-
dens, Boerum Hill and Park Slope, and
is within walking distance of Down-
town Brooklyn. At one time much of
Gowanus was an industrial area, but
residential development has increased
in the recent past since plans to clean up
the Gowanus Canal were announced.
PROMOTE YOUR EVENT, REACH MILLION PAGEVIEWS.
Jen Hopewell will help,
$h@mgieurbonmedia. com
United States
Environmental Protection
M % Agency
EPA INVITES PUBLIC COMMENT ON THE PROPOSED CLEANUP PLAN
FOR THE MEEKER AVENUE PLUME SUPERFUND SITE IN B ROOKLYN, NEW YORK
The U.S Environments* Protection Agency CEPAf ts asking the public for input on its proposed cleanup
plan to address (he potential vapors that may be enlcrsng into residentlai and canvnercial buildings at
the Meeker Avenue Plume Superfund site in Brooklyn, New York. The EPA has extended the public
comment penofl and ts accept ng comments f?txn the public on the proposed cleanup plan for this site
until Tuesday, June 25,2024. The EPA will consider comments submitted dunng the comment
period before making a final deci sion. The public es encouraged to renew the plan and comment on the
proposed cleanup alternative Comments may be emailed to ketu.tupAafepa.go* a mailed to fiupika
Ketu, US EPA. 290 Broadway, 18th Floor, New Vorit. NY 10007-1866 no later thin June 25th, 2024.
The Gowanus Canal borders Gowanus Green on one end and defines the
neighborhood for many people. ea^i*r,ic photo b» Bet Abruucu
Friday, April 19. 2024 ¦ Brooklyn Daily Eagle • 3
-------
Srednia cena benzyny
(ceny benzyny REGULAR izmiana w dolarach od ub. tygodnia)
USA
3,630
4
+ 0.063
Nowy Jork
3,442
~
+ 0.041
Barylka ropy
85,64
0
- 0.95
Stacje benzynowe
(przykfadowe ceny w roinych miastach New Jersey)
Bronx - B&G Services
3,19s
1243 E. Tremont Ave.
Staten Island - Mobil
3,2 39
1774 Victory Blvd.
Brooklyn - BP
3,2 99
765 Pennsylvania Ave.
Manhattan - Shell
3,69s
1599 Lexington Ave.
Ceny z dnia: 11IV 2024 r., godz. 4 pm
PRZEGLAD TYGODNIA
Trudno powiedziec czy do rozejmu w ogole doj-
dzie, gdyz Izrael przeprowadzil atak, w ktorym
zgingli trzej synowie lidera Hamasu, Ismaila Ha-
nijji, na stale rezyduj^cego w Katarze. Bracia
Hazem, Ameer i Mohammed Hanijja zgingli po
tym, jak samochod, ktorym jechali, zostal
zbombardowany w poblizu obozu dla uchodzcow
w Strefie Gazy.
~Wedlug prezydenta Ukrainy Wolodymyra Ze-
lenskiego, byly prezydent USA Donald Tramp
wyrazil ch?c odwiedzenia Ukrainy, ale nie wie,
kiedy bfdzie mogl przybyc. Ukraina znajduje si?
w najgorszym kryzysie od czasu rosy jskiej inwazji
w lutym 2022 roku: silom zbrojnym konczy si?
amunicja, a obrona powietrzna nie jest juz w sta-
nie odpierac rosyjskich atakow. S4 tez problemy
z rekrutacj^ nowych zolnierzy do ukrainskiej ar-
mii. Tymczasem Moskwa intensyfikuje naloty
bombowe na ukrainskie miasta, mowi si? o nowej
duzej ofensywie na Charkow. Prawdopodobnie
jest to jeden z powodow, dla ktorych Zelenski
skontaktowal si? z Donaldem Trumpem, republi-
kanskim kandydatem na prezydenta. To on blo-
kuje pakiet pomocowy. "Sam do niego nie dzwo-
nilem. Zaprosilismy go na Ukraine zarowno pub-
licznie, jak i niepublicznie" - powiedzial Zelenski.
Zaproszenie Trumpa do Kijowa moze miec tez
zwi^zek z "tajnym planem" Donalda Trumpa na
zakonczenie wojny na Ukrainie. Wedlug "Wa-
shington Post", plan Donalda Trumpa polega na
wywarciu presji na Kijow, by oddac Rosji Don-
bas i Krym. Wedlug bylego prezydenta Stanow
Zjednoczonych, mieszkancy tej cz?sci Ukrainy
nie mieliby nic przeciwko zyciu pod rz^dami
Federacji Rosyjskiej.
~Prezydent USA Joe Biden powiedzial, ze rozwa-
za wniosek Australii o zaprzestanie scigania zalo-
zyciela Wikileaks, Juliana Assange'a, co trwa juz
od dekady. Australia od lat wzywa USA o wyco-
fanie oskarzenia przeciwko Assange'owi, oby-
watelowi Australii, ktory przebywa obecnie w
brytyjskim areszcie i walczy przed miejscowym
wymiarem sprawiedliwosci o uniknigcie ekstra-
dycji do USA. Assange'owi postawiono formalnie
w USA 17 zarzutow o szpiegostwo i jeden zarzut
niewlasciwego uzycia komputera w zwi^zku z
publikacj^ na jego stronie internetowej zbioru
tajnych dokumentow prawie 15 lat temu. Amery-
kanscy prokuratorzy utrzymuj^, ze 52-letni As-
sange zachgcal i pomagal oficerowi wywiadu
wojskowego USA, w celu wykradzenia tresci de-
pesz dyplomatycznych i dokumentow amerykan-
skich sil zbrojnych, ktore nastgpnie byly publiko-
wane na portalu WikiLeaks.
~Minister spraw zagranicznych Rosji Siergiej
tawrow odbyl dwudniow^ wizyt? w Pekinie,
gdzie spotkal si? ze swoim chinskim odpowiedni-
kiem Wang Yi. Jak zapewnia tawrow: "Wi?zi
migdzy Rosj^ a Chinami osi^gngly bezpreceden-
sowy poziom dzifki przywodcom tych krajow".
Szef MSZ Rosji podkreslil, ze "Rosja i Chiny b?-
d^ nadal wspolpracowac w walce z terroryzmem
w ramach stale zaciesniaj^cych si? relacji".
~Do biblioteki w Fort Collins, w stanie Kolorado,
zwrocono powiesc, ktor^ czytelnik powinien byl
oddac najpozniej 13 lutego 1919 roku. Ksi^zka
- powiesc historyczna "Ivenhoe" Waltera Scotta
- zawgdrowala z wypozyczalni w Kolorado az do
Kansas, gdzie zostala ostatnio odnaleziona w rze-
czach po zmarlej starszej pani. Gdyby biblioteka
nadal pobierala oplaty za przetrzymane ksi^zki
(wynosily one 2 centy za kazdy dzien) czytelnik
winny spoznieniu o ponad 38 tysigcy dni musial-
by zaplacic okolo 760 dolarow. Gdyby jednak
stawki uwzglfdnialy wplyw inflacji, kara powin-
na przekroczyc 14 tysigcy dolarow. W 1919 roku
bilet do kina kosztowal 15 centow, nowy samo-
chod marki Chevrolet - 525 dolarow, a przeciftny
dochod amerykanskiego gospodarstwa domowe-
go wynosil niespelna 3,3 tysi^ca dolarow rocz-
nie. Na szczgscie biblioteka zrezygnowala przed
czterema laty z wyci^gania powaznych konsek-
wencji finansowych wobec spoznialskich czy-
telnikow (w tym wypadku przetrzymanie wy-
nioslo 105 lat).
~S^d stanowy w Michigan skazal Jamesa i Jenni-
fer Crumbley'ow na kar? 10-15 lat wigzienia za
nieumyslne spowodowanie smierci w zwi^zku z
zabiciem przez ich 15-letniego syna Ethana czte-
rech szkolnych kolegow w 2021 roku. Oglaszaj^c
wyrok, prowadz^ca proces s?dzia Cheryl Mat-
thews oznajmila, ze wysoki wymiar kary w
pierwszym procesie tego typu w Stanach Zjedno-
czonych ma sluzyc jako czynnik odstraszaj^cy
dla innych rodzicow, ignoruj^cych problemy
psychiczne swoich dzieci. Sg dzia Matthews zazna-
czyla, ze rodzice otrzymali wiele sygnalow alar-
mowych dotycz^cych ich syna, lecz zadne z
rodzicow odpowiednio nie zareagowalo.
~W niedziel?, 7 kwietnia 2024 roku, pokrywa
silnika samolotu Boeing 737-800 linii lotniczych
Southwest Airlines odpadla podczas startu z
lotniska w Denver. Maszyna zawrocila i bez-
piecznie wyl^dowala na lotnisku, nikt nie ucier-
pial. Federalna Administracja Lotnictwa (FAA)
wszczgla sledztwo. Samolot ze 135 pasazerami i
szescioma czlonkami zalogi na pokladzie mial
leciec do Houston. Maszyna zostala wyproduko-
wana w 2015 roku. To kolejny incydent samo-
lotow Boeinga w ostatnich miesi^cach. Wczesniej
informowano o licznych awariach modeli rodzi-
ny 737-MAX. W dniu 5 stycznia 2024 roku, w
nowym samolocie Boeing 737-MAX 9 linii
Alaska Airlines, podczas lotu odpadly drzwi
ewakuacyjne.
~Na miesi^c wigzienia oraz trzy miesi^ce aresztu
domowego skazano mieszkank? Florydy, Aimee
Harris, za to, ze w 2020 roku ukradla pamiftnik
corki prezydenta Bidena, Ashley. Harris sprzedala
pami?tnik corki prezydenta za kilkadziesi^t tysig-
cy dolarow, organizacji Project Veritas, specjali-
zuj^cej si? w zbieraniu kompromituj^cych mate-
rialow na amerykanskich politykow, urz?dnikow
i dzialaczy, zwi^zanych z demokratami. W s^dzie
stwierdzono, ze Harris najpierw probowala sprze-
dac pamigtnik komitetowi wyborczemu Donalda
Trumpa w 2020 roku, ale bezskutecznie.
~Nie zyje polska lekarka z Long Island w No-
wym Jorku. Doktor Monika Woroniecka zgi-
n?la w wypadku na drodze stanowej 12E w
Watertown. 58-latka wypadla z ci^gniftej przez
samochod przyczepy kempingowej na oczach
swojej corki i jej chlopaka. Rodzina byla w dro-
dze na kemping, z ktorego razem mieli obser-
wowac poniedzialkowe zacmienie Slonca.
Monika Woroniecka znajdowala si? w przycze-
pie Airstream, ci^gnigtej przez Dodge'a Rama,
prowadzonego przez jej m?za, kiedy nagly po-
dmuch wiatru spowodowal otwarcie drzwi
przyczepy. Motocyklisci, ktorzy jechali za nimi,
stwierdzili, ze widzieli otwarte drzwi na boku
przyczepy oraz r?k? Moniki Woronieckiej, si?-
gaj^c^ klamki. ci%g dalszy na str. 4
United States
Environmental Protection
Vkil Mm Agency
EPA ZAPRASZA MIESZKANCOW DO ZGtASZANIA UWAG NA TEMAT
PROPONOWANEGO PLANU OCZYSZCZANIA DOTYCZ/^CEGO OBSZARU
ZANIECZYSZCZEN MEEKER AVENUE PLUME, OBJfTEGO PROGRAMEM
SUPERFUND, W DZIELNICY BROOKLYN, W NOWYM JORKU
Amerykanska Agencja Ochrony Srodowiska (Environmental Protection Agency, EPA) zwraca
si§ do mieszkancow o wyrazenie opinii na temat proponowanego przez niq planu
oczyszczania dolyczqcego potencjalnych oparow, ktore mogq przedostawac si§ do budynkow
mieszkalnych i komercyjnych, znajdujqcych si§ na obszarze zanieczyszczen Meeker Avenue
Plume, obj^lym programem Superfund, w dzielnicy Brooklyn w Nowym Jorku.
EPA przyjmuje uwagi mieszkancow na temat proponowanego planu oczyszczania tego
obszaru od piqlku, 5 kwietnia 2024 r. do wtorku, 11 czerwca 2024 r. Przed podj^ciem
ostatecznej aecyzji EPA uwzgl^dni uwagi zgtoszone w wyznaczonym okresie. Zach^camy
mieszkancow do zapoznania si§ z planem, wzi^cia udziatu w spotkaniu publicznym i
zgtaszania uwag na temat proponowanej opcji oczyszczania. Uwagi mozna wystac emailem
na adres ketu.rupika@epa.gov\\h pocztq do Rupika Ketu, US EPA, 290 Broadway, 18th Floor,
New York, NY 10007-1866, najpozniej do 10 maja 2024 r.
W dniu 16 kwietnia 2024 r. o godzinie 6pm EPA zorganizuje stacjonarne spotkanie publiczne
w celu omowienia proponowanego planu oczyszczania. Spotkanie odb^dzie si§ w dolnym
Kosciele sw. Stanistawa Kostki przy 607 Humboldt Street, Brooklyn, NY. W celu uzyskania
bardziej szczegotowych informacji nalezy skontaktowac si§ z Annq Drabek, koordynatorem
EPA ds. zaangazowania spotecznosci, pod adresem dmbek.anna@epa.gov lub wejsc na
strong https://www.epa.gov/superfund/meeker-avenue-plume.
-------
Ok United States
Environmental Protection
^^¦¦¦1 M m Agency
EPA ZAPRASZA MIESZKANCOW DO ZGtASZANIA UWAG NA TEMAT
PROPONOWANEGO PLANU OCZYSZCZANIA DOTYCZ/^CEGO OBSZARU
ZANIECZYSZCZEN MEEKER AVENUE PLUME, OBJfTEGO PROGRAMEM
SUPERFUND, W DZIELNICY BROOKLYN, W NOWYM JORKU
Amerykariska Agencja Ochrony Srodowiska (Environmental Protection Agency, EPA)
zwraca si§ do mieszkancow o wyrazenie opinii na temat proponowanego przez niq
planu oczyszczania dolyczqcego potencjalnych oparow, ktore mogq przedostawac
si? do budynkow mieszkalnych i komercyjnych, znajdujqcych si§ na obszarze
zanieczyszczen Meeker Avenue Plume, objglym programem Superfund, w dzielnicy
Brooklyn, w Nowym Jorku.
EPA przedtuzyta okres zgtaszania uwag i przyjmuje uwagi mieszkancow na
femat proponowanego planu oczyszczania lego obszaru do wtorku, 25 czerwca
2024 r. Przed podjgciem ostatecznej decyzji EPA uwzglgdni uwagi zgloszone w
wyznaczonym okresie. Zachgcamy mieszkancow do zapoznania si? z planem i do
zgtaszania uwag na temat proponowanej opcji oczyszczania. Uwagi mozna wysteic
emailem na adres ketu.rupika@epa.gov lub pocztq do Rupika Ketu, US EPA, 290
Broadway, 18th Floor, New York, NY 10007-1866, najpozniej do 25 czerwca 2024 r.
~zatrudnimy osob§ do dyspozy-
torni, konieczna znajomosc ksi§-
gowosci, prowadzenia biura, lo-
gistyki i obslugi zleceri w branzy trans-
portowej, praca na caty etat (z domu),
wymagany biegly j^zyk angielski i dob-
ra organizacja pracy, stale wynagrodze-
nie plus bonusy. Tel.: (347) 225-7078
~looking for a seamstress with experience
to work on wedding dress alterations
in Manhattan. Call: (212) 764-1701
~zatrudni^ stolarza, z bardzo dobrym dos-
wiadczeniem, do produkcji i instalacji
mebli na zamowienie, dobre wynagro-
dzenie, praca na czek rozliczeniowy.
Tel.: (718) 344-0535
~pracownia artystyczna zatrudni uzdol-
iiionq manualnie osob§ do renowacji an-
tykow, doswiadczenie nie wymagane,
mozliwosc przyuczenia, stala praca na
pelny etat w West Palm Beach, FL.
Tel.: (786) 498-4406
~restauracja Texas Chicken w NYC za-
trudni pracownika na pelny etat, oferu-
jemy ubezpieczenie zdrowotne, okuli-
styczne i dentystyczne, $15-$21/godz.
Tel.: (347) 780-3009 Sam lub Elijah,
po angielsku
~szukam osob z samochodem, ktore mo-
gq, za niewielkq oplatq, przewiezc 9
lipca artystow gdanskiego choru Non
Serio z lotniska LaGuardia do Our La-
dy of Mount Carmel Shrine i odwiezc
na lotnisko JFK 14 lipca. Tel.: (718)
314-4028
~firma zajnmjqca si§ instalacji szafek
kuchennych potrzebuje fachowcow i
pomocnikow, praca w NY, dobre zarobki.
Tel.: (201) 953-2175 Michal
~potrzebny doswiadczony mechanik sa-
mochodowy do pracy w Hollis, praca
na caly etat lub pol etatu. Tel.: (718)
207-2816 po angielsku
~potrzebna opiekunka i asystentka do
59-letniego pana na wozku inwalidzkim,
pomoc przy codziennych czynnosciach
i pracach domowych, przenoszenie z
wozka, wymagany j^zyk angielski i
szczepionka przeciwko covid, praca w
Battery Park City, 3 catodobowe dyzury
tygodniowo, $900-$1200. Przeslij CV
na email: JosephGWayne@gmail.com
lub SMS: (929) 280-2938 po angielsku
~assistant/caregiver wanted for a 59-year-
-old disabled, professional man who
uses a wheelchair, help with daily living
activities, housekeeping, exercise and
wheelchair transferring, must speak
English and be vaccinated for Covid-19,
work in a high-rise condominium in
Battery Park City, 3 shifts lasting 24
hours, $900-1200 per week. Email
resume: JosephGWayne@gmail.com
or text: (929) 280-2938
~firma transportowa Alcatraz w Saint
Louis, Missouri, poszukuje osoby do
pracy w dyspozytorni (dispatcher), z
doswiadczeniem lub bez, odpowiedniq
osob§ przyuczymy i pomozemy z prze-
prowadzkq i znalezieniem mieszkania.
Tel.: (314) 892-7200 lub (314) 435-3611
~potrzebny slusarz do firmy Lockman,
Inc. w Richmond Hill, wymagane dos-
wiadczenie i prawo jazdy, $20-$30/godz.
Email: ken@lockmansystems.com lub
tel.: (718) 849-7556, po angielsku
~polski sklep na Staten Island zatrudni
osob§ do pracy na caly lub pol etatu, dos-
wiadczenie mile widziane, wystarczy
minimalny j^zyk angielski, wynagrodze-
nie w zaleznosci od doswiadczenia. SMS:
(917) 991-4441 lub email: jn72@aol.com
~potrzebna dziewczyna do pracy jako
ekspedientka w popularnej cukierni
na Greenpoincie, praca na weekendy.
SMS: (718) 877-1357
~Lockman, Inc. in Richmond Hill is
looking for a full-time locksmith, com-
mercial experience and driver's license
required, $20-$30/h. Email: ken@lock-
mansystems.com or call: (718) 849-7556
~potrzebna opiekunka do pracy w La'-
Dorch Home Care do opieki, towarzy-
stwa i prac domowych, wymagane
pozwolenie na prac§ i certyfikat HHA
lub PC A. Tel.: (929) 679-0201
~La'Dorch Home Care seeks a certified
home health aide to assist in daily living
and personal care services in patients'
homes, must be authorized to work
and have an HHA or PCA certificate.
Call: (929) 679-0201
~Techvalens zatrudni osob§ do wprowa-
dzania danych, wymagana dokladnosc
i znajomosc obslugi komputera i pro-
gramow Microsoft Office. Email:
mohit.techvalensoftware@tuta.io po
angielsku
~Techvalens is looking to hire a data
entry clerk, must be able to accurately
review and input data and use Micro-
soft Office suite and internet. Email:
mohit.techvalensoftware@tuta.io
Jezeli szukasz pracy w NJ, przej-
rzyj ponizszg ofert§. Wi^cej po-
dobnych ofert znajdziesz w wy-
daniu "abecadla" z New Jersey.
Oferty pracy z New Jersey
~zatrudni^ stylistic^ fryzur oraz asystent-
ka do salonu w Butler, NJ, praca na
caly lub pol etatu, przyuczymy odpo-
wiedni^ osob§. Tel.: (973) 271-7002
~potrzebna opiekunka do starszej osoby
w Haworth, NJ, praca z zamieszkaniem,
od 9am w poniedzialki do 9am w soboty,
j^zyk angielski nie wymagany. Tel.:
(201) 387-7154
~szukam pracownika do instalacji base-
now, okolice Linden, NJ. Tel.: (908)
296-8242
~potrzebna kobieta do sprzqtania w due-
cie, praca na zast^pstwo, od 1 maja do
25 maja, bardzo dobre zarobki. Tel.:
(201) 704-3167 Malgorzata
~potrzebny pomocnik oraz murarz do
pracy na budowie, dobre zarobki. Tel.:
(201) 655-2127
~poszukuje niani do pomocy przy 11-mie-
si^cznym dziecku, praca w moim domu
na 2 dni w tygodniu od 8:30am do 5:30pm,
$16/godz. Email: eternity88i@yahoo.com
~firma zajnmjqca si§ instalacji mebli
poszukuje pomocnika do pracy na tere-
nie NJ, mila atmosfera, dobre wyna-
grodzenie dla odpowiedniej osoby.
Tel.: (201) 598-2468
Poszukiwanie pracy
|=v^=| ~poszukuje pracy jako towarzysz-
| R ) ka lub opiekunka do starszej
osoby. Tel.: (347) 546-7855
~odpowiedzialna, opiekuncza i
pracowita Polka szuka pracy jako
opiekunka do starszej osoby lub jako
gospodyni, ma bardzo dobre referencje.
Tel.: (347) 664-0186 Anna
-------
4/11/24, 3:36 PM
Subscribe Past Issues
Greenpoint This Week
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6REENP0INTERS
Offerings from Bagel Joint, making their Smorgasburg debut this Saturday.
Image courtesy of Brooklyn Flea.
Greenpoint This Week:
Good afternoon, Greenpointers.
How about that earthquake, huh? With Monday's big solar eclipse it feels like a
harbinger of something; should we be looking for Godzilla?
Or it could mean we're in for an exciting weekend. In any case, check out our
roundup of things to do here.
This week's news was mostly food-related. Smorgasburg is back! A few
Williamsburg spots made the New York Times' top 100 best restaurants
(Greenpoint got snubbed).
Two new bars to look out for—Animal and Bar Madonna.
https://mailchi.mp/greeripointers/greenpoirit-this-week-3-29-2850737
-------
4/11/24, 3:36 PM
Greenpoint This Week
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and restaurant opening in the revamped Domino Sugar Factory. As always, we
have a Community Cookbook recipe.
The line at Radio Bakery snakes down the block on the weekends, so
neighbors decided to make some money from it. Appliance rental service Green
Gooding just launched a delivery service.
Is there any point in sharing an April Fools' Day article? Well, here it is. The
venue Dead Letter No. 9 has reopened with new programming.
A legitimately affordable resident building, 35 Commercial Street, opened in
Greenpoint.
oEPA
United States
Environmental Protection
Agency
EPA INVITES PUBLIC COMMENT ON THE PROPOSED CLEANUP PLAN
FOR THE MEEKER AVENUE PLUME SUPERFUND SITE IN BROOKLYN,
NEW YORK
The U.S. Environmental Protection Agency (EPA) is asking the public for input
on its proposed cleanup plan to address the potential vapors that may be
entering into residential and commercial buildings at the Meeker Avenue Plume
Superfund site in Brooklyn, New York.
The EPA is accepting comments from the public on the proposed cleanup plan
for this site from Friday April 05, 2024 to Friday May 10, 2024. The EPA will
consider comments submitted during the comment period before making a final
decision. The public is encouraged to review the plan, attend the public
meeting, and comment on the proposed cleanup alternative. Comments may
be emailed to ketu.rupika@epa.gov or mailed to Rupika Ketu, US EPA, 290
Broadway, 18 th Floor, New York, NY 10007-1866 no later than May 10th,
2024.
The EPA will hold an in-person public meeting to discuss the proposed cleanup
plan on April 16th, 2024 at 6:00 p.m. at St. Stanislaus Kostka Lower Church,
https://mailchi.mp/greenpointers/greenpoint-this-week-3-29-2850737
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4/11/24, 3:36 PM
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Greenpoint This Week
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For more information, please cont mmunity Involvement
Coordinator, Anna Drabek at
drabek.anna@epa.gov or visit https://www.epa.gov/superfund/meeker-avenue-
plume.
In and around North Brooklyn
Greenpoint's trendiest new brand? The fashion club at St. Stanislaus Kostka
Catholic, Academy.
j can't find a parking spot, tak e from the 94th precinct, and create
your own.
JJ's Southern Vecian gets a feature in Hell Gate,
https://mailchi.mp/greenpointers/greenpoint-this-week-3-29-2850737
3/3
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5/8/24, 10:19AM
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Greenpoint This Week
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6REENP0INTERS
A spread from Sereneco, who just got a new executive chef.
Greenpoint This Week:
Good afternoon, Greenpointers.
Welcome to the weekend!
And what a weekend it should be. 4/20, Record Store Day, and Earth Day
celebrations all abound. Check out our weekend roundup for some specific
ideas (like this Peter Pop art show).
Good Williamsburg news: A Williamsburg duo has a new film set to make its
debut (and it was filmed in Greenpoint!). Bad Williamsburg news: North
Brooklyn Neighbors found high levels of lead in certain parts of McCarren Park.
https://mailchi.mp/greenpointers/greenpoirit-this-week-4-12-2850745
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5/8/24, 10:19 AM Greenpoint This Week
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restaurant, likely by next week.
Bathhouse has submitted plans to remove the Hecla Iron Works water tower,
A sad story this week— a driver in South Williamsburg hit and killed a ten-vear-
OiigirL Our hearts go out to the families affected.
United States
Environmental Protection
Agency
EPA IN\ - .BUC COMMENT ON ¦ 1 •'
FOR THE I ' •• ;, ; UME SUPERFU < IN BROOKLYN,
NEW YORK
T "onmental Protection Agen is asking the public for input
on its proposed cleanup plan to address the potential vapors that may be
entering into residential and commercial buildings at the Meeker Avenue Plume
Superfund site in Brooklyn, New York,
T as extended the public comment period and is accepting comments
from the public on the proposed cleanup plan for this site un sclay, June
will consider" comments submitted during the comment
period before making a final decision. The public is encouraged to
review the plan and comment on the proposed cleanup alternative. Comments
may be emailed to ketu.rupika@epa.gov or ma .pika Kc .
290 Broadway, 1 tor, New York, NY 10007-1866 no later than June 25th,
2024.
https://mailchi.mp/greenpointers/greenpoint-this-week-4-12-2850745
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5/8/24, 10:19AM
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Greenpoint This Week
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(
GREENPOINT OPEN STUDI
jUHt
%
CALLING ALL LOCAL ARTISTS!
Artist sign-ups for Greenpoint Open Studios 2024 are now live!
deadline to sign up is May 2C - s year's event is happening on
Saturday June 1st & Sunday June 2nd,
Since 2016, GOS has offered local artists with the unique opportunity to
showcase their work and connect directly to the public. This weekend long
celebration builds and celebrates the creative c - nity - „< jenpoint.
If you have any kind of creative work to show, whether it is in painting,
performance art, digital art, book designs, or even handcrafted items like
jewelry and shoes, you should participate as long as you hs pace in the
neighborhood of Greenpoint,
https://mailchi.mp/greenpointers/greenpoint-this-week-4-12-2850745
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5/8/24, 10:19AM
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Greenpoint This Week
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City Council Member Lincoln Restler went on NY1 's Inside City Hall to talk
about bills regulating lobbying efforts.
The Williamsburg location of Veselka is getting closer to opening.
More on Greenpointers.com
© ©
-------
7/29/24, 8:45 AM
EPA przyjmuje uwagi mieszkancow - Nowy Dziennik
nowy dziennik
** POLISH WEEKLY
SZUKAJ
Jestesmy z Poloni^ od 1971 r.
Nowy Dziennik Wiadomosci Nowyjork EPA przyjmuje uwagi mieszkancow
WIADOMOSCI NOWYJORK POLONIA
EPA przyjmuje uwagi mieszkancow
05.04,2024
Lubi§ to!
A EPA
United States
Environmental Protection
Agency
Wcena informacja
EPA ZAPRAS2A MiESZKAKlCbW DO ZGLASZANIA UWAG NA TEMAT
PROPONOWANEGO PLANU OCZYSZCZANIA DOTYCZ^CEGO OBSZARU
ZANIECZYSZCZEKl MEEKER AVENUE PLUME OBJ^TEGO PROGRAMEM SUPERFUND
W DZIELNICY BROOKLYN W NOWYMJORKU
https://dziennik.com/epa-przyjmuje-uwagi-mieszkancow/
1/7
-------
7/29/24, 8:45 AM EPA przyjmuje uwagi mieszkancow - Nowy Dziennik
Amerykariska Agencja Ochrony Srodowiska (Environmental Protection Agency, EPA)
zwraca siq do mieszkancow o wyrazenie opinii na tern at proponowanego przez nig
planu oczyszczania dotyczqcego potencjalnych o pa row, ktore mogq przedostawac siq
do budynkow mieszkalnych i komercyjnych, znajduj^cych siq na obszarze
zanieczyszczen Meeker Avenue Plume obj^tym programem Superfund, w dzielnicy
Brooklyn w Nowym Jorku.
EPA przyjmuje uwagi mieszkancow na temat proponowanego planu oczyszczania tego
obszaru od piqtku 5 kwietnia 2024 r. do piqtku 10 maja 2024 r. Przed podj^ciem
ostatecznej decyzji EPA uwzgl^dni uwagi zgtoszone w wyznaczonym okresie.
Zach^camy mieszkancow do zapoznania siq z planem, wzi^cia udziatu w spotkaniu
publicznym i zgtaszania uwag na temat proponowanej opcji oczyszczania. Uwagi
mozna wystac e-mailem na ad res ketu.rupika@epa.gov lub pocztq do Rupika Ketu, US
EPA, 290 Broadway, 18th Floor, New York, NY 10007-1866, najpozniej do 10 maja
2024 r.
W dniu 16 kwietnia 2024 r. o godzinie 18:00 EPA zorganizuje stacjonarne spotkanie
publiczne w celu omowienia proponowanego planu oczyszczania. Spotkanie odb^dzie
siq w Dolnym Kosciele sw. Stanistawa Kostki, przy 607 Humboldt St, Brooklyn, NY. W
celu uzyskania bardziej szczegotowych informacji nalezy skontaktowac siq z Annq
Drabek, koordynatorem EPA ds. zaangazowania spotecznosci, pod adresem
drabek.anna@epa.gov lub wejsc na strong https://www.epa.gov/superfund/meeker-
avenue-plume
i i , to,
Dodaj komentarz
Musisz siQ zaloaowac. a by moc dodac komentarz.
Nowy Jork
Polonia
Brooklyn
meeker ave
PODOBNE ARTYKUtY
https://dziennik.com/epa-przyjmuje-uwagi-mieszkancow/
2/7
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"NY'I " U ODPAliCJU ATAKU IHANU NA IZRALL.
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APPENDIX V
RESPONSIVENESS SUMMARY
Attachment D- Public Meeting Transcript
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
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Transcript of Video File:
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
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April 16, 2024
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Video Runtime: 1 Hour 14 Minutes 22 Seconds
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(Beginning of Video Recording.)
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MS. KETU: Be careful.
4
3
MS. DRABEK: Thank you.
All right. Hello. Welcome, everyone. Thank
5 you so much for coming out. This is the Meeker Avenue
6 Plume Superfund Site proposed plan public meeting. As
7 you know, we released a proposed plan for addressing
8 contamination at the site earlier this month. And now
9 is the chance for us to kind of explain it in depth and
10 then to answer any questions, take any comments you may
11 have. So I will just go over a few points, and then
12 we'll go ahead and begin.
13 So hopefully, when you walked in, you saw a
14 sign-in sheet. If you didn't sign it, I'm going to
15 pass it around. Please just put your name and e-mail.
16 And then if you're not yet on our e-mail list, I'll
17 make sure you're added so you can receive regular
18 updates. We do also have a glossary of terms that
19 we'll be using throughout the meeting at the table in
20 the back. I'll kind of walk around and wave them
21 around in case anyone would like one and doesn't have.
22 We have headsets for (foreign language
23 spoken) we have headsets for translation. Just wanted
24 to make sure folks are aware of that. This meeting is
25 being recorded. We have a videographer who will then
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1 transcribe everything that we say, and then that
2 transcription will be part of the formal -- the final
3 plan, the record of decision in a few months. So just
4 wanted to make sure folks are aware of that. We'll
5 have a presentation and then questions and answers and
6 comments. All of those will be in the official record
7 as well. And then bathrooms are in the back. On the
8 left-hand side, there's a little sign for anyone who
9 may need.
10 I think that is it. I'd like to introduce
11 the EPA team that's here. So I'm Anna Drabek. I'm the
12 community involvement coordinator for the site. Should
13 have said that maybe in the beginning. The two project
14 managers are here, Rupika Ketu, who will be giving the
15 presentation, and John Brennan. Then Stephanie Vaughn,
16 the site supervisor, is with us. We have Andrea
17 Leshak, the site attorney, and then Carlos Vega, who's
18 our press officer. So any members of the press, please
19 approach Carlos if you have any questions. I think
20 that's it. All right.
21 MS. KETU: Thanks, Anna.
22 Hi, everyone. I'm Rupika. I'm one of the
23 project managers for the site. And today, I'm going to
24 be going over the proposed plan. I'll start off with,
25 you know, just some -- purpose of the meeting, why
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1 we're here today. I'll give a brief history of the
2 site and a site description. I'll go through what
3 vapor intrusion is. I'll go through the Superfund
4 process. And then I'll give an overview of the vapor
5 intrusion proposed plan itself. And then we'll have
6 plenty of time for questions and comments at the end.
7 Can you-all hear me all right? This is good? Okay.
8 Great.
9 So we're really here today to talk about our
10 proposed plan for addressing site-related vapor
11 intrusion in commercial and residential properties. As
12 some of you are aware, I've -- I see a lot of familiar
13 faces. You know, we're conducting a site-wide remedial
14 investigation at the site, and we're expedited vapor --
15 we're expediting vapor intrusion sampling in
16 residential and commercial properties. So this
17 proposed plan is really so that we can mitigate any
18 site-related vapor intrusion risks at these properties
19 while we continue our site-wide investigation. So
20 they're going to both move in parallel. And it's just
21 an interim measure to mitigate any immediate risk to
22 those living and working in this area.
23 And then down the line, once we complete our
24 remedial investigation, we will be developing and
25 evaluating cleanup methods for the entire site as well.
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1 So just a brief description about the site. The Meeker
2 Avenue Plume Superfund site is located in the
3 Greenpoint and East Williamsburg area of Brooklyn, New
4 York. And then on the right over there, we have our
5 preliminary study area. And you can see that it's next
6 to Newtown Creek and -- and bisected by the BQE. So in
7 this area, the soil, soil gas, and groundwater are
8 contaminated with chlorinated volatile organic
9 compounds. I know that's a mouthful.
10 So CVOCs for short. And at the site, in the
11 groundwater in particular and -- and vapor intrusion --
12 for vapor intrusion, trichloroethylene and
13 tetrachloroethylene are the main contaminants of
14 concern for vapor intrusion. Sorry. And so these
15 CVOCs are volatile organic compounds. They are a
16 subset of them that are substances that typically
17 evaporate at room temperature, and they can affect the
18 indoor air of properties that are located over an area
19 that's contaminated with these compounds. And you can
2 0 find chlorinated volatile organic compounds in common
21 household items such as cleaners, air fresheners and in
22 building supplies, like paints.
23 And so you know, we're investigating the full
24 nature and extent of this contamination throughout the
25 site. But, you know, today we're focusing on vapor
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1 intrusion because it is a health concern.
2 Tetrachloroethylene and trichloroethylene have both
3 cancer and non-cancer effects, so we're -- we're
4 looking to mitigate any risk from those at the site.
5 So just a brief history about the site. Around 2005,
6 2006, the New York State Department of Environmental
7 Conservation was investigating --or sorry, cleaning up
8 the Greenpoint oil spill. And they discovered these
9 chlorinated volatile organic compounds in the
10 groundwater as well, and that led to a series of
11 investigations in the area between 2007 and 2022 where
12 they tested the indoor air of over 160 properties and
13 installed over 25 mitigation systems.
14 And then in March of 2 022, EPA added the site
15 to the Superfund National Priorities List, and that
16 initiated our remedial investigation and feasibility
17 study process for the site. And I'll talk a little bit
18 more about that in a few slides. And so since November
19 of 2022, we've been conducting groundwater sampling
20 throughout the site and vapor intrusion investigations.
21 And then on April 5th, we released our proposed plan
22 for addressing vapor intrusion at the site. And I just
23 wanted to quickly show this map of other federal
24 Superfund sites and state-led sites in the area. So
25 down here you have Gowanus in pink. Oh, can you guys
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1 still hear me? Okay. And then the pink dash line --
2 Sorry.
3 Up here, that's the Meeker Avenue Plume
4 Superfund site. In yellow is the Greenpoint oil spill.
5 And then in pink up top, you have the Newtown Creek
6 Superfund Site. And then around here, you also have
7 the Wolff-Alport Superfund site that some of you might
8 be familiar with. So I just want to take a moment to
9 briefly explain what vapor intrusion is in case, you
10 know, you're new, and you haven't heard us talk about
11 this before. So I've mentioned that at, you know, the
12 groundwater in this area is also contaminated with
13 these chlorinated volatile organic compounds. So in
14 the past, at some point, these chlorinated volatile
15 organic compounds entered the groundwater through
16 unintentional or intentional releases.
17 But because these compounds are volatile,
18 they don't like to stay in a liquid state. So what
19 they do is they move up through the soil, and they
20 contaminate the air between soil particles, which is
21 called soil vapor. So then you have this contaminated
22 soil vapor resulting from the groundwater that can then
23 build up beneath the foundation of buildings. And so
24 you have this contaminated soil vapor built up beneath
25 the buildings, and it can enter into the buildings
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1 through either breaks in the utility lines or cracks in
2 the foundation of the building. And that process
3 itself is called vapor intrusion. And luckily, that
4 can be mitigated by using a sub-slab depressurization
5 system.
6 And so the sub-slab depressurization system
7 is similar to a radon system. And it's basically a fan
8 that draws out vapor from beneath the structure and
9 redirects it out of the building, above the roof line
10 so that those living or working in the building are not
11 breathing those vapors in. VI sampling, or Vapor
12 Intrusion sampling, is typically conducted in the
13 winter heating seasons because that's when vapor
14 intrusion is most likely to occur. That's because
15 windows and doors are typically shut and HVAC systems
16 are running, so it can perpetuate the ventilation of
17 contaminated soil vapors indoors. And it's typically -
18 - soil vapor intrusion sampling is typically conducted
19 on the basement and first floor because that's where
20 you're most likely to find impacts.
21 And the way we do it is a three-day process.
22 So on the first day, EPA arrives at the property at a
23 pre-scheduled time, and we inspect the -- the property
24 to make sure there aren't any background sources, such
25 as cleaning products and paints, that might affect the
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1 sampling results. And we take those. We box them up
2 and put them somewhere else so that they're, you know,
3 not in the way. And then what we do is we install a
4 small sub-slab soil gas port, which is the size of a
5 quarter, very small, through like the lowest level, so
6 typically, a basement floor. And this is used to
7 sample the vapors from beneath the building. So on the
8 first day we install the port. You typically only need
9 one per home.
10 And then it's -- it's cemented through the
11 slab or the floor of the building or property, but the
12 port can be removed once the soil vapor sampling is
13 complete. And then we restore the floor to its
14 preexisting conditions. And this takes like usually
15 between an hour and an hour and a half. On the second
16 day, we come back. We make sure that the port is
17 functioning properly. We do a helium leak test to make
18 sure that -- that it works. And then we connect a
19 sampling canister that looks like this to the port so
20 that it can collect a sample from beneath the building,
21 the soil vapor. And then we place these sampling
22 canisters throughout the basement and first floor as
23 well. They're just freestanding. And these all stay
24 in place for a period of about 24 hours.
25 And this takes, you know, an hour to hour and
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1 a half. Sometimes it's faster. And then on the third
2 day, we just come back, and we pick up all the sampling
3 canisters. And we deliver them to the lab for
4 analysis, and it typically takes at least 90 days to
5 get results back. And once we do, then we notify the
6 property owner and the tenant of the results. So just
7 an update on our vapor intrusion sampling efforts.
8 We've been working very hard to try and get access to
9 as many properties as we can in the area. Anna has
10 been very good about going door to door. She has gone
11 down every single street. We've also done mass
12 mailings and social media outreach, so we're trying
13 various methods.
14 We're working with the CAG also, Community
15 Advisory Group in case you guys aren't familiar with
16 the CAG, to -- to do additional outreach. So they've
17 been helping us out as well. And so with those
18 efforts, in the winter heating season of 2022 and 2023,
19 we were able to test 13 residential properties, one
2 0 public school, and the Cooper Park Houses complex,
21 which is made up of 11 public housing buildings. And
22 then this past winter heating season between November
23 and March of 2024, we were able to test 23 properties.
24 Out of these, we've determined that 15
25 residential properties, Cooper Park Houses, and the
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1 public school require no further action. Three
2 properties require some additional sampling. And then
3 we're still evaluating data from the 18 remaining
4 properties that were sampled in 2024. And we're going
5 to continue to conduct our vapor intrusion sampling
6 throughout the next few heating seasons as time goes
7 on. So I just want to go through the Superfund process
8 real quick. I think some of you are familiar with
9 this, but in case you're not, I wanted to explain, kind
10 of, where the proposed plan falls in our process.
11 So in 1980, Congress established the
12 Comprehensive Environmental Response and Liability Act
13 -- sorry, Environmental Response, Compensation, and
14 Liability Act, CERCLA for short and informally known as
15 Superfund. And so then this allows EPA to clean up
16 contaminated sites, hold parties responsible for the
17 contamination, or reimburse EPA or the government for
18 costs for, like, EPA-led cleanups. And so the
19 Superfund process has several major phases, and it
20 starts with the discovery of the contamination. And
21 that's when EPA goes out and does some investigations,
22 some preliminary work to see if the site meets
23 Superfund criteria to actually become a Superfund site.
24 Once we decide that, yes, it should be a
25 Superfund site, we list it on the National Priorities
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1 List. And then that allows us to conduct our remedial
2 investigation and feasibility study. So during the
3 remedial investigation, we do a lot of sampling to
4 determine, like, what the contaminants are, their
5 concentrations, how they move around, where they're
6 present. And then we also conduct human health risk
7 assessments and ecological risk assessments. And that
8 allows us to then come up with different ways or -- or
9 evaluate different cleanup methods for the site. And
10 so once we do that -- and that's called a feasibility
11 study, when we evaluate the different cleanup methods.
12 Once we do that, we then put our preferred --
13 EPA's preferred cleanup method in a proposed plan. And
14 so that's what we're here to talk about today. And so
15 the proposed plan is then open for public comment and
16 review. And once we receive all the comments, we take
17 a look at them. We respond to each one. And then
18 based on that feedback, we then formalize the cleanup
19 plan for the site in something called a record of
20 decision. And so once that's issued, then that allows
21 us to actually implement the cleanup. And then it goes
22 through a -- a couple steps of actually designing the
23 cleanup. It's called remedial design. And then
24 remedial action is the actual implementation of the
25 cleanup.
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1 And then after the cleanup method has been
2 implemented, then we just periodically check to make
3 sure that it's working. So for this site specifically,
4 for vapor intrusion -- sorry. I just need to flip my
5 page. In general, our cleanup objectives are to
6 prevent exposure to people in -- in commercial or
7 residential buildings from -- from these site-related
8 contaminated vapors. And like I said,
9 tetrachloroethylene and trichloroethylene are the main
10 contaminants of concern for vapor intrusion at the
11 site. So they're abbreviated as PCE and TCE. And then
12 we also want to prevent the migration of these
13 contaminated vapors indoors.
14 And so then this is the language that's from
15 the proposed plan. So you can take a look at that, but
16 I just wanted to explain it in -- in simpler terms.
17 And then these are the cleanup levels that we've
18 identified for residential and commercial properties.
19 The residential levels have been calculated to be
20 protective of the most sensitive populations, including
21 elderly folks, pregnant women, and young children. And
22 it's calculated over a period of 24 hours per day, 350
23 days a year for 20 plus years. And then the commercial
24 levels assume an eight-hour workday, which is
25 protective of most non-residential settings.
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1 So as part of the vapor intrusion proposed
2 plan, we evaluated two cleanup alternatives. One would
3 -- the first one was no action. Under no action, we
4 would not take any action at the site. We're legally
5 required to evaluate no action, to establish a baseline
6 to compare with other alternatives. So that's why
7 that's there. And then the second alternative that we
8 evaluated was vapor intrusion mitigation, which is: If
9 we find an issue in the -- in the property or in your
10 home, we would mitigate it by either installing a sub-
11 slab depressurization system or sealing any cracks or
12 gaps in the foundation if that can do it too.
13 And the way that we evaluate the alternatives
14 is through nine criteria. And so the first two
15 criteria there, the threshold criteria, are -- are --
16 are really important because any cleanup action that we
17 select must comply with these two. So it must comply
18 with the appropriate laws and regulations and then be
19 protective of human health and the environment. And
20 then we also look at five balancing criteria, and that
21 includes how effective the -- the cleanup method will
22 be in the short term and long term, the cost, is it
23 implementable? And so I just want to emphasize though
24 that cost is just one of the balancing criteria, and --
25 and these are all weighted equally.
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1 And then the last two are two modifying
2 criteria, which are community acceptance and state
3 acceptance. And that's part of the reason why we're
4 here today. These we take into consideration after the
5 proposed plan is issued, after we receive all the
6 public comments, and then the State has already let us
7 know that they concur with us on this action. So in
8 the proposed plan that we released on April 5th, we
9 identified Alternative 2 as our proposed alternative.
10 So in the event that we find any site-related vapor
11 intrusion issues in a property, we would install a sub-
12 slab depressurization system where necessary or use a
13 preventative measure, such as sealing cracks and gaps
14 in the foundation or the --or the basement of a
15 building.
16 And like I mentioned, the sub-slab
17 depressurization system, sorry, involves connecting a
18 blower, like small electric fan, to at least one
19 suction pit that's dug into the foundation of the
2 0 building. And it vents the vapors outdoors above the
21 roof line so that the vapors are not going inside. And
22 so our proposed plan reflects the cost for mitigating
23 an estimated 100 properties within the Meeker Avenue
24 study area with ongoing maintenance. And then the plan
25 also estimates that indoor air sampling and mitigation
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1 will just be conducted on an ongoing basis as needed
2 for at least five years.
3 I just want to touch on how we determine the
4 need for vapor intrusion. So obviously, like, we
5 conduct sampling, and we look at those results. But
6 then we also look at other pieces of information to
7 help us make a conclusion or draw a conclusion. And
8 that could include, like, looking at the subsurface
9 geological and hydro-geological conditions around a
10 building or structure; the -- the characteristics of
11 each property, like what -- what are the conditions of
12 the foundation of the building itself, is it intact, is
13 it not; and proximity to other impacted structures. So
14 --so looking at these lines of evidence and -- and the
15 sampling results, we then may determine that no further
16 action is needed, or we might need to do some
17 additional sampling to get confirmation.
18 Or we would determine that a sub-slab
19 depressurization system is needed to mitigate the
20 indoor air impacts that we find. So we are accepting
21 public comments on this plan until June 25th, 2024, and
22 you can either mail me comments or e-mail them to me.
23 I'm going to leave this up here for a minute so you
24 guys can, you know, take note of my e-mail address and
25 my mailing address. And then any questions that are
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1 asked today, any comments today, those will also be
2 recorded and answered formally as well. At the end of
3 the public comment period, we -- we make sure that we
4 respond to each question and -- which you'll be able to
5 view too. And then our proposed plan is available on
6 our website.
7 And let me know once you guys are good. I
8 see a couple more cameras. Okay. I'm going to go to
9 the next slide. If anyone wants me to stay on this
10 slide, just let me know. So yeah. So like I said,
11 once the comment period ends, we'll review and respond
12 to the public comments. What happened? Oh, okay. And
13 then we will prepare a record of decision, which is the
14 final decision document that will formalize our
15 preferred cleanup method based on all the input that we
16 receive. And the -- the record of decision will
17 include responses to comments received through June
18 25th. Okay. And now we're ready for questions.
19 MS. DRABEK: I came up here too early. Okay.
20 All right. So now, we're at the question-and-answer
21 portion of the evening. So please, if anyone has
22 questions or would just like to give a formal comment,
23 please let me know. I'll come over with the
24 microphone. Like I said at the beginning of the
25 meeting, the meeting is recorded, so any questions or
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1 comments will be transcribed and will be part of the
2 formal record. And then we do ask to -- if -- when you
3 speak, to please give your name or at least your
4 affiliation with the site, whether a resident, a
5 business owner, community member, et cetera. So all
6 right. Any questions or thoughts?
7 Yes.
8 UNIDENTIFIED SPEAKER: Yeah. Could you just
9 identify what the source is of the pollution?
10 MS. DRABEK: Sorry. Can I ask you to repeat
11 that into the microphone?
12 UNIDENTIFIED SPEAKER: Can you just answer
13 it?
14 MS. DRABEK: No?
15 UNIDENTIFIED SPEAKER: Do you know the source
16 of the pollution?
17 MS. DRABEK: Do we know the source of the
18 pollution?
19 MR. BRENNAN: Yes. The State has located at
20 least six different source areas that have been
21 identified. There's also at least 10 to 20 additional
22 probable sources that EPA will have to investigate.
23 UNIDENTIFIED SPEAKER: Can you say anything
24 about them?
25 MR. BRENNAN: Do we have that as a -- a spare
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1 slide, the -- the location of those?
2 UNIDENTIFIED SPEAKER: Dry cleaning, the
3 commercial --
4 MR. BRENNAN: One was dry cleaning. One was
5 a drum reconditioner. There's, you know, two active
6 facilities that are just under the BQE.
7 MS. KETU: Yeah. I can --
8 MR. BRENNAN: You have that one?
9 MS. KETU: I forgot [inaudible 00:23:03].
10 No, I don't have it [inaudible 00:23:04]. Sorry.
11 MR. BRENNAN: That's all right.
12 MS. VAUGHN: Yeah. I -- and -- and I just
13 want to stress that we're -- we're still the -- like
14 Rupika mentioned, we're -- we're addressing the site
15 sort of in two parallel tracks. So the investigation
16 of source areas is ongoing, and so we may find
17 additional source areas. Some of the source areas
18 we're looking at now may end up not being source areas,
19 so it's -- it's -- it's a question we're still working
2 0 on. And sorry.
21 While I have the mic, can I make -- add one
22 thing to Rupika's presentation? When we're making
23 determinations on whether mitigation is needed at a
24 property or what next steps are needed, there's one
25 more thing that we take into account. And that is
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1 consultation with the State Department of Environmental
2 Conservation and Department of Health. So I just
3 wanted to add that.
4 MS. DRABEK: Any other questions? Yes.
5 MS. VICHNEVSKY: Hello. My name is Natalie
6 Vichnevsky. I'm a resident in the area and also work
7 for a local nonprofit called Evergreen. That's an
8 industrial economic development organization that works
9 with the industrial manufacturing community in the
10 area.
11 I was curious if you-all could explain a
12 little bit more about the remedial action levels and if
13 -- the reason that they're different between
14 residential and commercial, if that's just the math
15 because of the different hours that people tend to
16 spend in one place or the other, and if it effectually
17 is the same level of protection.
18 MR. BRENNAN: That's right. It has to do
19 with the exposure time. So exposure time at home would
20 be different than exposure time in a -- a commercial
21 building when you would expect to probably work eight
22 hours a day as opposed to home when you could be home
23 for 24 hours a day. Some of the other things that, you
24 know, fall into that, we wouldn't expect there to be a
25 baby at a commercial facility. Although, you know,
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1 residential numbers typically include elderly that --
2 you -- you know, the most -- what's the word I'm
3 looking for, most sensitive populations.
4 MS. VICHNEVSKY: So then actually, there's
5 more TCE or PCE or what -- the intrusion kind of
6 allowed in a space that's commercial because people
7 might spend less time there?
8 MR. BRENNAN: That's correct.
9 MS. VICHNEVSKY: Okay. Okay. And I have one
10 -- well, I'll just ask one more question. I have more
11 questions. But the 100 -- the -- the 100 buildings,
12 like the -- why -- why is 100 the number that is being
13 targeted?
14 MS. KETU: Yeah. That -- that's fine. I can
15 start.
16 That's just based on how many properties
17 we've gotten access to so far. So it's just an
18 estimate. We're not tied to it, right, by any means.
19 MS. VAUGHN: Yeah. I was just going to -- so
2 0 -- so we need to -- when we put out a proposed plan, we
21 need to have some cost estimate associated with it. So
22 we estimated the 100 based on sort of best professional
23 judgment. If it's significantly more, it doesn't mean
24 that we won't address those properties. There is --
25 within -- within a Superfund decision, the -- the costs
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1 can end up being greater than 50 percent or less than
2 30 percent than is estimated in the record of decision.
3 But even if it's outside that range, we can then modify
4 the decision. So it's -- it's not -- it doesn't limit
5 us.
6 MS. VICHNEVSKY: Okay. Good. Yeah. Because
7 I know the -- with the DEC, right, they did like 160
8 tests and did 25. I didn't know if it was, like, a
9 similar proportion or something, but --
10 MR. BRENNAN: No.
11 MS. VICHNEVSKY: It doesn't have anything to
12 do with --
13 MS. VAUGHN: We -- we -- we sort of looked at
14 proportion, but it -- yeah.
15 MS. VICHNEVSKY: Okay. Thank you.
16 MS. DRABEK: Thanks. All right.
17 MR. CHESLER: Hi. My name is Steve Chesler.
18 I'm chair of the Environmental Protection Committee at
19 Brooklyn Community Board 1. My question about the
20 qualification for -- you know, the threshold
21 qualification to have remedy implemented, so, you know,
22 property tests -- you know, it's a, you know, negative
23 result. But in terms of what -- what proximity means
24 in terms of -- there's, you know, property nearby that
25 tests positive or offsite, say, in the street or in the
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1 sidewalk.
2 And if there are details, you know, in the
3 documentation that can be reviewed to take a deeper
4 dive -- but I'm wondering if you could just add some
5 more to that now.
6 MR. BRENNAN: There's nothing, as far as I
7 recall, in the document about a proximity from -- from
8 one home to another. Every home was looked at on an
9 individual basis from one to the other, so there's not
10 a -- a proximity distance in there. Well, if we had an
11 issue here three homes over, you know, we have to do
12 something. There's nothing in there about that.
13 Everything is looked at on an individual basis.
14 MR. CHESLER: And -- but what about, say,
15 testing done offsite in the street or in the sidewalk
16 and -- example, go -- backing up, there's a negative
17 result in the property, but in the street or in the
18 sidewalk, you know, the -- in the -- testing the wells,
19 there is a, you know, positive result.
20 So what is, you know, the threshold
21 determined for that?
22 MR. BRENNAN: I can do it -- yeah.
23 If we were to find something in the
24 groundwater or -- you know, the State has at least a
25 few hundred soil gas wells that are in sidewalks like
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1 you're mentioning or whatnot. And that might be a good
2 reason for us to try to get access to some of those
3 properties around in that vicinity. But you know, is
4 there a number in there for that? No. Not
5 necessarily. Like, a distance or something like that?
6 No.
7 MR. CHESLER: And just quickly, just in terms
8 of just the sampling area, in terms of, you know,
9 approximately how many residential properties are
10 within the -- the border right now?
11 MR. BRENNAN: Nine hundred.
12 MR. CHESLER: Okay.
13 MR. BRENNAN: Yeah. It doesn't mean
14 residential. It's about 900 properties. Yeah.
15 BENNETT: Thanks.
16 Hello. I'm Bennett (phonetic). I'm a
17 resident a couple blocks away. My question is about if
18 similar sites exist in the city or elsewhere and if
19 there's similar data that you've seen and if the
20 depressurization system has been deployed elsewhere and
21 how it's -- what the results have been.
22 MR. BRENNAN: Sure. The -- the sub-slab
23 depressurization system, it's a proven technology,
24 number one. Number two, it's the same technology that
25 the State used when they did sampling before the EPA's
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1 arrival. The State was involved from 2007. It's still
2 to today, and they've installed, I think the number is,
3 26 mitigation systems. It's the same technology that
4 the State used.
5 BENNETT: Are there other neighborhoods that
6 have similar -- are there other -- other neighborhoods
7 that have similar contaminants that have showed up with
8 similar numbers? I mean, I -- you know, I imagine
9 there are similar businesses around here than there are
10 in other parts of the city, so I'm -- I guess I'm
11 curious why this neighborhood and if -- if similar data
12 has been seen elsewhere.
13 MR. BRENNAN: I -- I can't speak specifically
14 to this neighborhood, but I mean, EPA has used this
15 technology on other sites if that's what you're asking.
16 BENNETT: I guess I'm asking on the sample
17 data specifically.
18 MS. KETU: Yeah. So we're investigating this
19 area based on what the State found during their
20 investigations between like 2007 and 2022. So we're
21 building off that. We're not investigating outside of
22 this area right now because we have no, you know,
23 reason to believe that we should. So, like, I think
24 you mean like other parts of Brooklyn or in Manhattan,
25 right? Yeah. No. We haven't done any sampling there.
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1 LAUREN: Hi. I'm Lauren. I live and work in
2 the area. I don't know if this is the point in your
3 timeline where you can share this information.
4 But based on the testing that you've done so
5 far, does your testing area remain the same, or has it
6 expanded or contracted based on what you've been
7 finding so far?
8 MR. BRENNAN: At this time, it remains the
9 same.
10 LAUREN: Okay.
11 MS. SPIROFF: Hi. I'm a resident, Deborah
12 Spiroff. My question is more about a -- there's
13 several sites in this area, and there's some -- there
14 appears to be some overlap. Is there currently or will
15 there be more of an oversight body that coordinates the
16 various sites? Because as more data comes in and you
17 evaluate the boundaries, they -- they can often shift.
18 And is there a coordinating body entity, one, and if
19 so, who is that?
20 And there appears to be responsible parties
21 that have been determined. And they -- one of which
22 is, I believe, to my knowledge, is New York State, and
23 is that -- as well as other entities. And that -- if
24 that goes -- you have potentially a conflict of cost
25 and the remediation costs and the people determining
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1 that. Is that -- how is that being looked at, and is
2 that being looked at?
3 MS. VAUGHN: So --
4 MS. SPIROFF: I know that's a long,
5 convoluted, multiple layered --
6 MS. VAUGHN: I -- I can try to address at
7 least some of your questions.
8 MS. SPIROFF: Okay.
9 MS. VAUGHN: So -- so first off, I'm a
10 supervisor of this site as well as Newtown Creek, so
11 the two sites do share a border. So we definitely look
12 at the sites together and share information. And --
13 and in fact, some of the groundwater sampling we did
14 recently, you know, we -- we sort of coordinated across
15 the two sites. And Rupika works on both sites as well,
16 so there is that -- you know, that -- that shared
17 knowledge. And we also work in the same office as the
18 project managers for the other sites that Rupika
19 mentioned, like the Wolff-Alport and Gowanus. So we
20 coordinate with them as well.
21 In terms of responsible parties, we have not
22 yet named any responsible parties for the Meeker Avenue
23 Plume site. That is a process that we're working on,
24 and it's -- it takes a little while. The State is not
25 a responsible party for this site, and so -- so the
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1 State is considered our partner agency. They -- they
2 gave us the -- the site. You know, they referred it to
3 us after they had been investigating it for a number of
4 years. If a common PRP is found between, let's say,
5 Meeker and Newtown Creek, then, you know, that's
6 something we'll have to figure out. But we're not
7 there yet.
8 I don't know if -- Andrea, if there's
9 anything you want to add.
10 She's the site attorney.
11 MS. LESHAK: No. Stephanie covered it.
12 Under EPA guidance, our policy is enforcement first.
13 So we do try to identify potentially responsible
14 parties. As Stephanie mentioned, that process is
15 ongoing, so we don't have any real update to share at
16 this time.
17 MS. SPIROFF: Thank you.
18 MR. ELKINS: Hi. My name is Willis Elkins.
19 I work for the Newtown Creek Alliance. So I have a
20 question -- a couple questions. First is about -- back
21 to get to the -- the threshold levels and to the
22 gentleman's question. I understand if EPA hasn't done
23 sampling at the site, but I believe DEC has done
24 sampling at other similar sites around the city. So
25 the -- the question is about -- you just sort of gave
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1 us the numbers, and maybe it'd be helpful to go back to
2 that slide, of what EPA has determined as an acceptable
3 amount of TCE and PCE. So I just feel like it would be
4 helpful to understand how EPA arrived at these numbers,
5 give some context of other sites. Maybe DEC can chime
6 in.
7 And then I would also add a comment that I do
8 think, to Natalie's point, that the commercial actions
9 -- I appreciate being very conservative with the
10 residential areas and assuming people would spend 24
11 hours. I don't know anybody who spends 24 hours, seven
12 days a week, inside their house, but it's good to be
13 protective. However, I know a lot more people that
14 spend more than 40 hours in their workplace. So that's
15 a comment that I think that, you know, four to one
16 ratio of the protectiveness is -- is unacceptable,
17 especially given the vast amount of commercial
18 industrial properties that are in the zone. So that's
19 a comment.
20 But the first question is about how we
21 arrived at these numbers, and then I have a couple more
22 questions.
23 MR. BRENNAN: Thank you, Willis. Our -- our
24 risk assessor unfortunately is not here tonight, but as
25 we said, we're documenting all of that -- you know, all
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1 those questions. So we can certainly have her reply to
2 that in one of the comments when -- when they come out
3 in the written. That -- that's a -- there's a lot of -
4 - you know, a lot of questions within questions you
5 asked there about that. So I think maybe best to let
6 her answer that, which we could do in writing.
7 MR. ELKINS: Okay. And I don't -- I don't
8 know if --
9 MS. VAUGHN: Can I add one other thing?
10 MR. BRENNAN: Yeah. Sure.
11 MS. VAUGHN: And -- and I -- I just want to
12 stress that -- that these numbers are one line of
13 evidence, for lack of a better term. We do look at
14 each property sort of holistically -- not sort of. We
15 look at each property holistically and make a
16 determination on a property by property basis. So if -
17 - you know, I -- I guess what I'm trying to say is
18 these numbers aren't bright lines necessarily.
19 MR. ELKINS: Would -- right. Would -- I
2 0 mean, so I don't know --to the gentleman's question
21 about comparable data and numbers, would -- I don't
22 know if DEC is willing to share anything about other
23 sites and sort of thresholds for other DEC-led
24 cleanups, et cetera.
25 MS. DUDEK: I -- I can speak in general --
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1 generalities. I'm Heide Dudek. I'm the section chief
2 for the Meeker Avenue Plume. I'm also the section
3 chief for the Newtown Creek, when you asked about
4 coordination. So the State and EPA are in constant
5 communication with both of the sites in the surrounding
6 area. DEC actually relies on our sister agency, who's
7 represented here today by our -- our project manager
8 for the Meeker Avenue Plume.
9 But DOH has their own soil vapor matrix, and
10 they are the ones that will make the determination on a
11 DEC site. Yes. There are many places within New York
12 City and New York State that do have soil vapor plumes,
13 and they have been mitigated with this radon-type
14 system. It's well documented, and it's a standard
15 remedial action. So I can't answer anything else like
16 that if --
17 Shaun?
18 MR. SURANI: Yeah. There are some -- some
19 difference -- slight differences in numbers criteria
20 that -- that the State has used in the past and -- and
21 I have used to, you know, recommend actions to mitigate
22 properties. As far as the indoor air, they're pretty
23 close for the TCE and the PCE to what New York State
24 was. You know, our --we don't necessarily draw that
25 distinction between commercial and residential, but you
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1 know, like I said, we each have our own -- two
2 different agencies, we all have our, you know,
3 criteria. And as Stephanie had mentioned before, they
4 -- you know, EPA will -- will work with us, you know,
5 to make those determinations.
6 MR. ELKINS: Yeah. So I mean, just if I'm
7 hearing that correctly, the State has numbers that are
8 different than these and that there's not a major
9 distinction between commercial and residential? So
10 maybe it'd be very helpful to share, like, more details
11 about that.
12 MR. SURANI: Yeah. I -- our numbers -- in --
13 in the past -- the decisions that we've done in the
14 past, we have our own, like, decision matrices, and we
15 have used those in the past to make recommendations
16 based on the numbers, you know. And having made that
17 distinction between commercial or residential, for
18 instance, you know, we've recommended to mitigate a
19 property, you know, a commercial space where TCE in the
20 indoor air was above two, you know, in that range, not
21 above eight. So, you know, but each -- each individual
22 property is different, and we -- we look into --to all
23 of that to make our recommendations and including how
24 that space is used, how often folks are there. So
25 there is a lot that goes into it other than -- than
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1 just these numbers.
2 MS. DUDEK: And that --
3 MR. SURANI: And we -- we are committed to
4 working, you know, as closely as we can with -- with
5 the EPA to -- to -- to -- to make sure that our --
6 their decisions, you know, would line up with ours.
7 MS. DUDEK: And -- and I would fully concur
8 with that, that the -- and that's what I mean by each
9 property will be evaluated individually. So if there
10 were a commercial space, let's say, where people are
11 spending significant amounts of time and there were,
12 you know, the -- and -- and the numbers fell below
13 these, but the -- you know, we felt it was warranted,
14 we -- we -- we could install a mitigation system. And
15 the decision document will be written up in such a way
16 to give us that flexibility.
17 Yeah. Okay.
18 UNIDENTIFIED SPEAKER: Yeah. If -- if it's
19 okay, I wanted to do a different topic, which is the --
2 0 the number of buildings and how many people you have
21 brought into this process. You may have debriefed on
22 that at the beginning of your speech, so I don't --
23 please don't repeat it if you did. But you said
24 there's 900 properties of concern, commercial and
25 residential. And I think you also said that you've
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1 determined that Cooper Park Houses is not in need of
2 remediation.
3 So could you tell us more about how many
4 properties you got into, how many owners or resident
5 occupants on the first floor, to your knowledge, are
6 aware of this problem? I just went one day out on the
7 street with the organizing outreach team, and it was
8 extremely difficult to get into properties with
9 absentee landlords. And it's -- a lot of the buildings
10 are occupied by hardworking people who aren't home at
11 normal hours.
12 So I -- I just wondered, do you -- how -- how
13 well do you feel you've penetrated the population that
14 could be impacted? Tell us about that if you -- it
15 seems like maybe you feel good about it. Tell us.
16 MR. BRENNAN: Sure. Do you have the -- not
17 that number necessarily. The -- the map of the -- the
18 outline?
19 MS. KETU: Oh, I --
2 0 MR. BRENNAN: That's not the first slide or -
21
22 MS. KETU: Oh, yeah.
23 MR. BRENNAN: That one. Right. So it -- my
24 estimate inside that blue area was that there's about
25 900 properties. And -- and I did that for another
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1 reason. We're trying to take a look at different
2 sections of that outlined area just to see -- or you
3 know, we've seen higher concentrations in certain areas
4 than others. The State, before EPA's involvement,
5 sampled north of about 160. EPA, since our
6 involvement, which the site was listed in March of
7 2022, we sampled 23 properties through last December.
8 And -- and that data has been shared with those
9 property owners. We sampled another 18 just this
10 February and March.
11 UNIDENTIFIED SPEAKER: Are those different?
12 That's 38 different properties from the original 160?
13 MR. BRENNAN: That's right. That's right.
14 One of those 18 properties we had sampled a prior time,
15 so it was only 17 new properties. We -- we asked them
16 to come back a second time and -- and sample it at a
17 different winter heating season. So that -- that's the
18 numbers that we have. As far as outreach, that has
19 been a struggle, and that has been something that we
2 0 have worked extremely hard on, both through mailings,
21 through door to door, just trying to get information
22 out through word of mouth, through our social media.
23 That -- that has been a -- a tremendous
24 challenge. And I know you said that, you know, it's
25 tough to get people during the day when they're at
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1 work. We had, you know, similar circumstances when we
2 went around at night after work. People not wanting us
3 to bother them at -- at dinner time. Or you know,
4 Rupika and I went around one night. And they're like,
5 it's dark; what are you knocking on my door for? So it
6 has definitely been one of our main priorities, but I
7 mean, it has been a challenge. Did you have another
8 question in there? I know you --
9 UNIDENTIFIED SPEAKER: Well, I just -- how do
10 you feel -- I'm sorry. How do you -- how do you feel?
11 So it's less than 200 properties out of 900, and -- and
12 I kind of connect to that Cooper Park Houses. How many
13 ground floor units did you get into?
14 MR. BRENNAN: Oh, okay.
15 UNIDENTIFIED SPEAKER: How many residents did
16 you converse with? You know, just -- I -- I guess,
17 kind of the history of our community, I'd like to be
18 sold a little more --
19 MR. BRENNAN: Sure.
2 0 UNIDENTIFIED SPEAKER: -- that the people
21 have had a chance to ask for remediation if they need
22 it.
23 MS. VAUGHN: There's one other point, I
24 think.
25 MR. BRENNAN: Okay. Sure.
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1 MS. VAUGHN: Okay. I just -- I -- I'll let
2 John answer that, but one other point that maybe we
3 should make is that our outreach and access efforts are
4 ongoing. So by making --by making this decision, we
5 have the ability -- it will give us the ability to
6 mitigate any problems we find, but we plan to keep
7 going for years to come, to -- to try to access as many
8 of those properties as we can. I don't know if that
9 gets to your concern.
10 UNIDENTIFIED SPEAKER: That's good to hear.
11 MR. BRENNAN: As far as Cooper Park Houses,
12 we got inside of all 11 buildings when we did the
13 sampling last year. There are no residences on the
14 ground floor in any of those buildings. However, we
15 were able to sample in, you know, the -- the manager's
16 office, the lunch area. You name it, we were inside of
17 every single building. Every building, it -- it's kind
18 of unique. Every building is a little bit different.
19 It's a different size, and it has got a different
2 0 purpose.
21 It's kind of like their own city, if you
22 will. So we got inside of all 11, and we were able to
23 get not only sub-slab soil gas, but indoor air, outdoor
24 air. And in many cases, the center -- you can't really
25 see it here, but the center of the buildings actually
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1 have vented areas. It's just the way the building was
2 constructed. We got in there as well. So that was
3 very successful. And none of those needed mitigation.
4 MR. SURANI: I just wanted to -- to also
5 clarify that, just to echo what they -- the EPA has
6 noted, you know, in the State's investigations to date,
7 the -- that has also been our biggest hurdle, is -- is
8 obtaining access to buildings. I think prior to the
9 State or the site going to -- to -- to the EPA, I think
10 it was what, maybe the 2021 to 2022 heating season, you
11 know, DEC, the State sent out letters to, I think,
12 every property within the area of interest. You know,
13 there were -- there -- there's difficulties in -- in --
14 in outreach, but letters were mailed to, you know,
15 close to 1,000 properties. And, you know, the response
16 rate was low. So that -- that's something --
17 UNIDENTIFIED SPEAKER: Sixty.
18 MR. SURANI: What?
19 UNIDENTIFIED SPEAKER: Sixty.
2 0 MR. SURANI: About 60. So, you know, roughly
21 a six percent response rate. So that is something the
22 State has -- has struggled with to date and does seem
23 to be kind of the biggest hurdle for -- for the site.
24 UNIDENTIFIED SPEAKER: May I ask a follow-up
25 question? This may be legalese, but if a landlord --
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1 if the landlord received a letter like that and it
2 comes to light some time later that they did not avail
3 themselves of this investigation and the potential
4 remediation, can the tenants sue in the future? Like,
5 if their kids grow up and they're sick, something like
6 that?
7 MS. LESHAK: Thank you for your question. So
8 that question is outside the purview of what the EPA
9 can answer because we cannot provide legal advice, so
10 you could feel free to contact an attorney. I will
11 clarify that EPA has authority under the Superfund Law
12 to access properties for sampling and response actions.
13 So while we are seeking consent from owners and tenants
14 to sample, our policy advises us that if access is not
15 forthcoming, we are able to require access through
16 administrative or judicial means. But of course, we
17 want to cooperate with the community, and that's why
18 we've made our outreach efforts thus far to try to
19 cooperate and obtain access consensually.
2 0 MS. BACH: Hi, there, I'm Paloma Bach
21 (phonetic). I'm a community member, and I also work in
22 the community. One thing that was of note when we went
23 back a couple slides ago that we tested -- you-all
24 tested about 20 buildings in 2022 to 2023 and 20
25 buildings the year after that.
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1 But my concern mainly, especially with the
2 active sites that were -- are still being investigated
3 is what's the likelihood of going back to some of these
4 buildings and retesting based off the fact that we're
5 not really sure how widespread the contamination is and
6 -- and how -- how many sites are currently active?
7 MR. BRENNAN: That's a good question. EPA
8 hasn't seen the need to go back to any of the homes
9 that were previously sampled by the State as yet. You
10 know, if we have data that indicates that that's the
11 case, then of course we'll go and -- and try to get
12 access to those properties and -- and to retest them.
13 But we haven't seen the need to do that yet. There are
14 some properties, based on our data, that we -- you
15 know, we have asked to go back to and sample a second
16 time. The State had to do similar things. So in those
17 cases, then yes. Then we -- we go back another time to
18 make sure. You know, if -- if we saw some data -- I'll
19 give you a perfectly good example.
20 Last year, we had tested a -- a building, and
21 there was nothing in the first floor space. There was
22 two units. There was, you know, nothing in the
23 basement, but we did find it in the sub-slab soil gas.
24 So we said, we want to go back out and test again to
25 see if there's any changes. Make sure, even though no
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1 one is living in the basement, it's just a storage
2 area, make sure that there's nothing coming in there.
3 There's people living in the first floor spaces; make
4 sure there's -- you know, they're not getting any type
5 of exposure. And that was -- that was the one house we
6 did again, I -- I -- I mentioned it a few minutes
7 earlier, just this past February and March, but we
8 don't have the data back yet.
9 MS. BACH: Okay. So just to confirm, even if
10 there -- the first time around testing there was
11 nothing found, even if buildings may be at risk, you
12 are not required to go in and test again?
13 MR. BRENNAN: I -- I wouldn't use the word
14 required. I mean, if -- if I had a homeowner call me
15 and said, hey, you know -- I'll give you a perfect,
16 good example. We had the house tested 10 years ago,
17 and since that time, A, B, and C happened. Well, there
18 might be a reason for us to go back. You know, maybe
19 they, you know, had a big crack form in the floor.
2 0 Maybe they did a big remodel that might have changed
21 some of the structure of the building. There's plenty
22 of reasons to go back. So, you know, we take phone
23 calls from -- from everyone and try to go through that
24 with them. It's not just no. We did -- you know, no.
25 Sorry. You've already been sampled.
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1
MS. BACH: Okay. Thank you.
2
MR. BRENNAN: Sure.
3
MS. GOODMAN: Hi. I'm Lael Goodman. I'm
4 with North Brooklyn Neighbors and also part of the
5 Meeker CAG. I guess you were talking about the
6 differences in the thresholds for residential and
7 commercial. And just to go back to that, I mean, I
8 know we talked about the number of hours, but there was
9 also something said about, like, the vulnerability of
10 the populations. You were saying that for residential,
11 you considered, you know, the most -- most vulnerable
12 people.
13 And I was just wondering if in the commercial
14 properties, you are also using the most vulnerable
15 populations of just, you know -- there are, like,
16 pregnant women and people who are elderly who do work
17 in those spaces, so I guess that's a comment and a
18 question.
19 MR. BRENNAN: No. That -- that's a real --
20 that's a really good question, and I -- I have a good
21 example. We -- we tested a home last December, and I,
22 you know -- I won't go into details about where it was.
23 But the gentleman uses it as his business on -- on the
24 first floor, but he lives on the second floor. So when
25 we sampled that property, you know, we didn't use
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1 commercial. We didn't use the commercial numbers
2 because he could be down there all the time, on the
3 weekends, at night. Plus, he lives upstairs. It's
4 not, you know, like your traditional, you know,
5 environment. So in that particular instance, we
6 compared, you know, his numbers to residential numbers.
7 So, you know, when we evaluate properties, of course
8 those things are taken into consideration.
9 MS. GOODMAN: I guess -- I guess I would just
10 argue that sometimes the current workers aren't
11 necessarily the future workers or people may become
12 pregnant or things like that. So that's one comment.
13 My other question was about the venting. I know you
14 said it goes to the roof line of the property.
15 I know there's very varied roof lines here
16 and would want to make sure that -- I don't know, is
17 there a radius of you do it as high as the neighboring
18 house within three houses? Or how do you make sure
19 that that venting doesn't affect nearby properties?
2 0 MR. BRENNAN: Yes. I mean, we would want to
21 get it above the highest roof line. If -- if your
22 neighboring property was higher, we wouldn't want there
23 to be any reintroduction into him because he happened
24 to have a window there. Of course.
25 MS. GOODMAN: So it would go as high as the
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1 neighboring property or if there was one, like, you
2 know, two properties away -- or I guess how do you kind
3 of -- what the criteria is there?
4 MR. BRENNAN: I'll -- I'll double check that.
5 I'll double check that, and we can get that information
6 to you if there's a distance.
7 MS. GOODMAN: Okay. Thanks.
8 KYLE: Hi. My name is Kyle. I'm a resident
9 in the area. I had a question on access to information
10 and the process around that in terms of whether
11 sampling is being completed in your building from a
12 renter's perspective and whether there's a process to
13 ask for access to that information or confirmation,
14 whether sampling has been completed or not, or if you
15 could talk about the process.
16 MR. BRENNAN: Sure. Typically, what we'll
17 do, you know, aside from our typical outreach, we get
18 phone calls from property owners or tenants fairly
19 regularly. And, you know, what we need to do is we
2 0 need to get permission from the property owner. The
21 way EPA has handled their sampling is that we get
22 permission from the -- from the property owner. Of
23 course, the property owner would get that data. If we
24 get into the tenant space, let's say the tenant has the
25 first floor space or the basement space and they allow
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1 us access to come in and -- and to sample their --
2 their indoor air, then that data would get shared with
3 that tenant as well because they gave us access to
4 their space.
5 KYLE: Understood. I guess in terms of
6 whether sampling has been completed or not, outside of
7 whether they actually require access to your specific
8 unit, is there a process for requesting that
9 information, or is it limited to, you know, your
10 relationship or the contract with your actual property
11 owner?
12 MR. BRENNAN: Yes. We haven't shared that
13 information, you know, with anyone or -- the State has
14 been the same way. We've been trying to come up with a
15 way to get people a -- a better sense on, you know,
16 generally speaking, where homes have been tested, you
17 know, what we call a -- a cluster map. It's something
18 we'll probably be sharing with everyone at our next CAG
19 meeting in May, which is May 30th. But we've been
2 0 trying to get an -- you know, give people an idea
21 about, you know, if I live in this part of the
22 community, has there been a lot of testing in the -- in
23 my part of the community? Has there been a lot of
24 systems installed in my part of the community?
25 It won't -- it's not specific enough. It's
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1 not street level, but, you know, give you an idea that
2 if you live on -- and I'm just going to make up a name,
3 on Sutton, right, that, you know, within a certain
4 block of area, has there been a lot of testing? And if
5 -- you know, if there has been, you know, how many
6 people have -- have needed systems? But it's not going
7 to get specific to if you wanted to know what your
8 neighbor was or something like that because that's --
9 that falls under the, you know -- the -- the privacy of
10 that person. We're trying to balance not only the
11 privacy of the people that have been sampled, but the
12 communities, you know, want to know, and EPA's need to
13 --to share -- their responsibility, I should say, to
14 share that data.
15 KYLE: Thank you.
16 MR. SURANI: To clarify a little bit on
17 what's done in New York State, in New York State -- and
18 we've worked -- we've dealt with this in the past. New
19 York State, what's -- has what it's called a tenant
20 notification law. So for vapor intrusion results, if a
21 -- if a result -- if an indoor air result is above New
22 York State's air guideline values, which are 2
23 micrograms per cubic meter for TCE and 30 micrograms
24 per cubic meter for PCE -- if the results -- indoor air
25 results are above those numbers, in the past, when --
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1 when we would send results letters out, we would
2 include that information as well.
3 And if -- if -- if the -- the indoor air
4 numbers are above those, they would be required by law
5 to -- to share that with tenants. If they're below
6 that, they are not required to -- by law to -- to -- to
7 --to share that. But that would be, you know,
8 something that would have to be worked out between the
9 tenant and the landlord, you know. You could always
10 request it, but they're not necessarily required to.
11 But in letters that we have sent out in the past, we
12 always do encourage owners to share their results with
13 all occupants and all tenants.
14 UNIDENTIFIED SPEAKER: Do you publish --
15 MS. DRABEK: Do we publish --
16 UNIDENTIFIED SPEAKER: The -- the letters
17 with --
18 MS. DRABEK: -- the letters --
19 UNIDENTIFIED SPEAKER: -- (crosstalk)
2 0 property where the numbers can come in at [inaudible
21 00:58:41]?
22 MS. DUDEK: No. We have the same privacy
23 policy. We provide the -- the data to the owner of the
24 property. And under New York State law, that the
25 landlord is required to -- if there is a mitigation
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1 needed, to notify the tenants. They're not -- he's not
2 or they're not required to do it if there's no
3 mitigation needed, but those are private. We don't
4 share people's private data.
5 UNIDENTIFIED SPEAKER: So if the landlord
6 doesn't tell the tenant, the tenant has no way of
7 knowing?
8 MS. DUDEK: If it -- if the building needs
9 mitigation, they're required by law to tell the
10 tenants. If it does not, they aren't. They would --
11 UNIDENTIFIED SPEAKER: If they don't?
12 MS. DUDEK: If they don't, then you -- the
13 best thing to do is to -- if you have a question, is to
14 reach out to EPA. If they -- if it's your building,
15 they can let you, you know -- they can discuss with
16 you, and they can work with your landlord to try to get
17 them -- if they're not sharing the data that they
18 should. And it's the same thing if DEC has done it.
19 But again, we all are -- are, you know, bound by
2 0 privacy laws in what we can and can't do.
21 UNIDENTIFIED SPEAKER: I know that, John, you
22 said before to Willis's question with kind of figuring
23 out the sort of calculus behind getting the actual
24 numbers that you would share that in writing.
25 But could you-all talk just briefly a little
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1 bit more about the risk characterization in terms of,
2 like, just explaining to folks, like, what, you know --
3 what we're even talking about in terms of what the
4 danger is, like, the, you know, one in 10,000, you know
5 -- just understanding broadly what the health risks
6 are.
7 MS. KETU: Yeah. So I can speak to some of
8 the cancer and non-cancer health effects of both TCE
9 and PCE. So cancer effects from the exposure to TCE
10 and PCE can include liver and kidney tumors. And then
11 non-cancer effects for TCE include developmental and
12 immune system effects. And non-cancer effects for PCE
13 exposure include nervous system and ocular effects. As
14 far as explaining, I think, like -- I think you're
15 talking about, like, the hazard index and the way risk
16 is actually calculated. It would be best if we let our
17 risk assessor do that. Yeah.
18 UNIDENTIFIED SPEAKER: -- (crosstalk) in the
19 same bucket.
2 0 MS. KETU: Yeah. Yeah.
21 MS. GOODMAN: -- comment about that. Just a
22 comment about that. Sometimes those documents can be,
23 like, really hard to understand. So I guess I'm just
24 hoping that when that does -- is sent around, that it
25 is in easy-to-understand terms.
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1 MS. KETU: Yeah. So we'll include a response
2 to, you know, your question and Willis's question in
3 our responsiveness summary which you will all be able
4 to view, and we'll make sure that it's, you know,
5 explained in a way that's easily understandable.
6 Because I -- I understand. It can be confusing.
7 MS. DUDEK: John has a good one with, like,
8 the marbles in a pool [inaudible 01:01:43]. Stuff like
9 that would help.
10 MR. BRENNAN: Okay.
11 MR. ELKINS: Hi. Willis again. So the -- I
12 guess I'm having a hard time sort of understanding what
13 -- what is actually being proposed because it sounds
14 like you're already, like, doing all this stuff. And
15 so, you know, if there's a record decision that you
16 want people to comment on, what is actually happening
17 here --
18 UNIDENTIFIED SPEAKER: Yeah.
19 MR. ELKINS: -- that -- then that's different
20 from being happening aside from like -- honestly, the
21 only thing -- I mean, it's great that it sounds like
22 you're working on identifying more responsible parties,
23 doing more testing, expanding the potential range. But
24 honestly, it's like the State has already -- was
25 already doing installing vapor mitigation systems.
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1 That's what you're doing. The thresholds seem less
2 protective than the State's.
3 Is there actually steps towards any real
4 remediation of the contamination as opposed to just
5 getting it out of people's houses, the vapors?
6 MS. VAUGHN: So yeah. You -- you picked up
7 on exactly what's -- what's happening here. So -- so
8 as I mentioned before, there are the two parallel
9 tracks going on with this site. The way Superfund is
10 set up, we cannot take a remedial action, including a
11 mitigative action like installing a -- a mitigation
12 system, without some sort of record of decision
13 allowing us to do that. So this proposed plan is
14 really very straightforward.
15 It -- it -- it gives us the ability to take
16 action if we find a problem in a -- in a -- in a
17 residence or a -- or a property. This is not cleaning
18 up the site. This is an interim measure that will
19 protect people's health who are being impacted by the
2 0 contamination. In the long term and, you know, as you
21 know, the -- the process can take a long time, we are
22 investigating the groundwater. And we'll do it -- be
23 doing all the investigations and seeing what kind of
24 cleanup actions we can take to -- to come up with a
25 more permanent solution. But we're not there yet.
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1 MR. ELKINS: So -- and sorry if I missed
2 this. So just to clarify, EPA hasn't installed any
3 mitigation systems yet; the DEC has. So this is a way
4 for EPA to start doing that as an agency?
5 MS. VAUGHN: Correct.
6 MR. ELKINS: Okay.
7 MS. VAUGHN: So the site is now under, you
8 know, Superfund federal authority, so we need to be
9 able to install them. If in the meantime -- just --
10 just for the record, if last year we had found a
11 problem that required mitigation before this decision
12 was signed or if we find one if this gets delayed, we -
13 - we can use our removal program to -- to install a
14 system. But that's not a long-term solution.
15 MR. ELKINS: So then a follow-up is a sort of
16 -- what -- is there a timeline on -- probably your
17 favorite question from us. Is there a timeline about,
18 you know, the -- the next steps in the actual real
19 remediation?
2 0 MS. VAUGHN: So it'll be long. We -- we --
21 at the May -- correct me if I'm wrong, but at the May
22 30th CAG meeting, we do intend to share some results --
23 or at least preliminary results of the initial
24 groundwater sampling we completed. That will give us
25 an idea of where we need to install additional wells,
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1 and it'll help us flesh out the rest of the
2 investigation. We're -- I mean, it will take years to
3 --to get to a -- this meeting for the rest of the site
4 unless we determine that some sort of early action is
5 needed. I -- I don't have a solid timeline at this
6 point. We're too early in the process.
7 MS. VICHNEVSKY: Can I ask one more thing? I
8 know that Lauren asked this earlier about the boundary,
9 but is that -- at -- and I know that we will talk more
10 in detail about this at the CAG meeting on May 30th.
11 But when, John, you said that there's no
12 change, does that mean that there's no change as of
13 what you can share right now or as in like right now,
14 in time, there is no change?
15 MR. BRENNAN: Either today or the next time
16 we meet on May 30th, the outline will be the same.
17 MS. VICHNEVSKY: Okay. Thank you.
18 MR. BRENNAN: Sure.
19 MS. VICHNEVSKY: And then I had one more
20 quick question. The rolling basis of five -- in the
21 five-year period, does that have -- like, why -- what,
22 you know -- where did that come from?
23 MS. KETU: Yeah. So like Stephanie
24 mentioned, just for cost estimate purposes --
25 MS. VICHNEVSKY: Okay.
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1 MS. KETU: We have to do some kind of
2 estimation. So we just said, for at least five years,
3 you know, we're going to be doing the sampling. But
4 that's not, like, set in stone or anything.
5 MS. VICHNEVSKY: Okay. Thank you.
6 MS. GOODMAN: Hi. Another comment, I guess I
7 would say I very much appreciate you saying you look at
8 things, like, on an individual basis. And that's great
9 for people who, like, know and trust you. But I would
10 also say that, like, that's not always the case. And
11 so while it is great that sometimes you go to the
12 residential levels if you think, you know, a commercial
13 building warrants that, I think there is something to
14 having it kind of a little bit more formal. So I just
15 want to make sure that that is recognized, that, you
16 know, it's all well and good to -- to -- to trust you
17 guys. But like I said, that's not always the case.
18 MS. VAUGHN: Yeah. No. We -- we appreciate
19 that. But just -- just to clarify, we could make the -
20 - the -- the case-specific determination to be more
21 conservative, to be more protective. But we do not
22 have the flexibility to be less protective. So we
23 wouldn't look at a property and be like, eh, this one
24 doesn't really need mitigation. You know, it's -- it
25 would be in the more conservative direction.
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1 UNIDENTIFIED SPEAKER: Hello. The November
2 to March period for testing, I get that in warmer
3 weather, people keep their windows open. But if we're
4 -- is it possible to test, say, a basement where
5 there's not much air flow even during warmer weather
6 just to kind of get ahead of it, or are we strictly
7 staying within these months?
8 MR. BRENNAN: If -- if we, you know --
9 obviously, EPA prefers to do the sampling in the winter
10 heating season. If we had reasoning to do it outside
11 of the winter heating season, I mean, yes. We could do
12 it. We would have to go do it again back in the winter
13 heating season though anyway, unless we found such
14 egregiously high levels down there that, you know, we
15 had the answer we needed in a sense. If it came back
16 below, we would still have to do it in the winter
17 heating season.
18 UNIDENTIFIED SPEAKER: What -- so to -- I've
19 one more to -- I'm going to piggyback on his question,
2 0 but then I have one other question. So I know that,
21 John, you've explained in the past that for the winter
22 heating season, there's also -- I think there's only
23 like one lab that you-all work with and --or that
24 processes things and that it takes, you know -- there's
25 only so much that you would even be able to do in a
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1 certain period of time.
2 Are there any limitations, like that kind of
3 thing, to the amount of testing that could be done?
4 MR. BRENNAN: I -- I mean, are there
5 limitations on the high end? I -- I -- I don't know.
6 I mean, I -- I had to -- I had to book it very far in
7 advance, and I booked a high number. I mean, we didn't
8 --we didn't get to the number that I booked to. What
9 you're referring to is that, you know, in the winter
10 heating season, everyone does this kind of work. So
11 it's -- it's a challenge to get lab space.
12 UNIDENTIFIED SPEAKER: Yeah.
13 MR. BRENNAN: However, you know, we -- we --
14 we -- because we're planning this that far in advance,
15 we're able to get that lab space. I think we booked
16 for -- I think it was 24 for, you know, February and --
17 and March, and we got 18. Next season, because I got
18 18, I'll make sure I'm going to probably book for more,
19 I mean, depending on what type of response we're
2 0 getting at the end of the year. But we have to get it
21 that far in advance to guarantee that we don't have the
22 issue of not getting lab access.
23 UNIDENTIFIED SPEAKER: And then the -- as we
24 discussed that the values are a little bit less
25 protective as compared to DEC'S numbers, what -- I know
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1 that it depends on the math.
2 But does that have to do with -- like, is
3 there a cost factor? Does cost factor into that at all
4 or - -
5 MR. BRENNAN: As far as into the -- the vapor
6 intrusion screening levels we used, there's no cost
7 factor in that.
8 UNIDENTIFIED SPEAKER: Okay.
9 MR. BRENNAN: No.
10 UNIDENTIFIED SPEAKER: Thanks.
11 UNIDENTIFIED SPEAKER: Thanks. In regarding
12 -- you know, assuming the, you know -- the ROD is
13 approved, who will do -- do -- if a property requires
14 the remedy, who physically does the installation? Does
15 EPA do it directly, or do they have a contractor? Or
16 can, you know, the property owner actually do it
17 themselves under the guidance of the agency?
18 MR. BRENNAN: EPA has been doing the work.
19 What we've been doing -- all the work we've been doing
20 is through the United States Army Corps of Engineers.
21 That's just the way we have this set up. So the Army
22 Corps and their contractor staff have been doing it all
23 for us. It would probably be the same for, you know,
24 the mitigation systems if we needed to install any.
25 UNIDENTIFIED SPEAKER: Hi. There were only
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1 two remedies looked at. I'm assuming that's because
2 there's not really another option. Or are there other
3 options that exist or other technologies?
4 MR. BRENNAN: This is a proven technology
5 that has been used in this neighborhood. And so that's
6 why we evaluated that. You know, one of the other
7 technologies -- and I -- I think Rupika might have
8 mentioned it is. And it -- a few -- the State did it a
9 few times. It's just to seal the basement floor and
10 sample again. Let's say the basement floor has so many
11 cracks in it that it's not hard to figure out why it's
12 getting in that house. You could, you know, either put
13 a membrane down, or you could seal the floor and then
14 sample it again. And then, you know, you wouldn't need
15 a -- a, you know, sub-slab depressurization system. So
16 that's certainly another option. Sometimes you need to
17 do both.
18 MS. VAUGHN: So and -- and that -- just -- I
19 -- the -- the alternative we developed includes the
20 sealing of cracks --
21 UNIDENTIFIED SPEAKER: Yeah.
22 MS. VAUGHN: -- and -- as needed, so --
23 UNIDENTIFIED SPEAKER: But it's just -- this
24 is -- this is what --
25 MS. VAUGHN: But just put it all together. I
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1
2 UNIDENTIFIED SPEAKER: -- basically anyone --
3 everyone does --
4 MS. VAUGHN: Yes.
5 UNIDENTIFIED SPEAKER: -- when there's vapor
6 intrusion in people's homes or --
7 MS. VAUGHN: As far as I know, I don't think
8 there's another solution that's as effective or --
9 UNIDENTIFIED SPEAKER: Great.
10 MS. VAUGHN: Yeah.
11 MR. SURANI: There's things that we view that
12 --at sites, you know, throughout New York State where,
13 for whatever various reasons, the SSDS install, you
14 know, wasn't feasible. And, you know, it is possible,
15 if there's indoor air impact in the building, to
16 install, like, standalone carbon filtration units. But
17 they're not as effective as an SSDS to, you know --
18 kind of clearing the air. They are, you know --
19 there's maintenance associated with it, regular carpet
2 0 change outs.
21 They are, you know, not as effective, and you
22 know, they can be loud and cumbersome. You know, I --
23 I got a building, you know, in the Bronx that's, you
24 know, got -- got issues going on, and they got, you
25 know, these massive 6-foot-high, you know, units
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1 throughout the building. And it is cumbersome and
2 costly to keep those running and -- and -- and maintain
3 them and you know -- whereas it's, you know, not as --
4 as effective as an SSDS solution.
5 UNIDENTIFIED SPEAKER: Thanks.
6 MS. DRABEK: Any other questions, thoughts,
7 comments?
8 JOHN: Thanks for doing this, guys.
9 Appreciate it.
10 MS. DRABEK: Yeah. Thank you-all so much for
11 coming.
12 MR. BRENNAN: Thank you, everyone, for
13 coming.
14 MS. DRABEK: We'll be in touch about the next
15 steps when we release the final plan.
16 JOHN: Yeah.
17 MS. VAUGHN: Thanks, everyone.
18 (End of Video Recording.)
19
20
21
22
23
24
25
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1
CERTIFICATE
Page 61
2
3
I, Doug Yarborough, do hereby
certify
4
that I was
authorized to and transcribed
the
5
foregoing
recorded proceedings, and that
the
6
transcript
is a true record, to the best
of my
7
ability.
8
9
10
11
Dated this 30th of April, 2024
•
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: 00:23:03..action
1980 11:11
22 : 8
900 24:14
0
25th 16:21
17 : 18
33 : 24
00:23:03
2
34 : 25
19 : 9
2 15 : 9
26 25:3
36:11
00:23:04
46:22
A
19 : 10
3
20 13:23
00:58:41
47 : 21
01:01:43
50 : 8
18 : 21
39 : 24
200 36:11
2005 6:5
30 22:2
46 : 23
30th 45:19
52 : 22
53:10,16
61 : 11
abbreviated
13 : 11
ability 3 7:5
51 : 15 61:7
absentee
1
2006 6:6
34 : 9
1 22:19
2007 6:11
25:1,20
350 13:22
acceptable
29 : 2
1,000 38:15
2021 38:10
38 35:12
acceptance
10 18:21
15:2,3
2022 6:11,
41 : 16
14, 19
4
accepting
10,000 49:4
10 : 18
40 29:14
16 : 20
100 15:23
21:11,12,
25:20 35:7
access 10:8
21:17 24:2
38:10
39 : 24
2023 10:18
39 : 24
2024 10:23
11:4 16:21
61 : 11
5
22
11 10:21
37:12,22
13 10:19
50 22:1
5th 6:21
15 : 8
37:3,7
38 : 8
39 : 12,14,
15, 19
40 : 12
15 10:24
6
44 : 9,13
160 6:12
22:7 35:5,
23 10:23
35 : 7
6 - foot-high
59 : 25
45:1,3,7
56 : 22
12
17 35:15
24 9:24
13 : 22
60 38:20
account
19 : 25
18 11:3
20 : 23
9
Act 11:12,
35:9,14
29:10,11
14
56:17,18
56 : 16
25 6:13
90 10:4
action 11:1
12 : 24
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Meeting Index: actions..Avenue
14:3,4,5,
16 15:7
16 : 16
20 : 12
31 : 15
51:10,11,
16 53:4
actions 2 9:8
31:21
39 : 12
51 : 24
active 19:5
40:2,6
actual 12:24
45 : 10
48 : 23
52 : 18
add 19:21
20:3 23 :4
28:9 29:7
30:9
added 6:14
additional
10:16 11:2
16 : 17
18 : 21
19 : 17
52 : 25
address
16:24,25
21:24 27:6
addressing
4:10 6:22
19 : 14
administrative
39:16
advance
56:7,14,21
advice 3 9:9
advises
39 : 14
Advisory
10 : 15
affect 5:17
8:25 43 : 19
affiliation
18:4
agencies
32 : 2
agency 2 8:1
31:6 52:4
57 : 17
ahead 55:6
air 5:18,21
6:12 7:20
15 : 25
16 : 20
31:22
32 : 20
37 : 23,24
45 : 2
46:21,22,
24 47:3
55 : 5
59:15,18
Alliance
28:19
allowed 21:6
allowing
51 : 13
alternative
14:7 15 : 9
58 : 19
alternatives
14 :2,6,13
amount 2 9:3,
17 56:3
amounts
33 : 11
analysis
10:4
Andrea 2 8:8
Anna 10:9
appears
26 : 14,20
approved
57 : 13
approximately
24 : 9
April 6:21
15:8 61:11
area 4:22
5:3,5,7,18
6:11,24
7:12 10:9
15 : 24
20:6,10
24 : 8
25 : 19,22
26:2,5,13
31:6 34 : 24
35:2 37:16
38 : 12 41:2
44:9 46:4
areas 18:20
19:16,17,
18 29:10
35:3 38:1
argue 43:10
Army 5 7:2 0,
21
arrival 2 5:1
arrived
29:4,21
arrives 8:22
assessments
12 : 7
assessor
29 : 24
49 : 17
assume 13:24
assuming
29 : 10
57 : 12 58:1
attorney
28 : 10
39:10
authority
39 : 11 52:8
authorized
61:4
avail 3 9:2
Avenue 5 : 2
7:3 15 :23
27 : 22
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: aware..building
31:2,8
14 : 5
blocks 24:17
26:8 29:23
aware 4:12
basement
blower 15:18
30:10
34 : 6
8:19 9:6,
22 15:14
blue 34:24
34 : 16,20,
23 35:13
B
40:23 41:1
Board 2 2:19
3 6:14,19,
44:25 55:4
25 37:11
body 2 6:15,
baby 2 0:25
58:9,10
18
40:7 41:13
42:2,19
Bach 3 9:20
basically
book 5 6:6,
43 : 20
41:9 42:1
8:7 59:2
18
44 :4,16
back 9:16
basis 16:1
booked 5 6:7,
45 : 12
10:2,5
23:9,13
8, 15
50 : 10
28:20 29:1
30:16
border 24:10
53 : 15,18
3 5:16
53 : 20 54:8
27 : 11
55:8 56:4,
39 : 23
beginning
13 57:5,9,
40:3,8,15,
bother 3 6:3
18 58:4
17 : 24
17, 24
33 : 22
bound 4 8:19
60 : 12
41:8,18,22
briefly 7 : 9
42:7
beneath
boundaries
55:12,15
7 :23,24
26 : 17
48 : 25
background
8:8 9:7,20
boundary
bright 3 0:18
8 : 24
Bennett
53 : 8
broadly 4 9:5
backing
24:15,16
25:5,16
box 9 : 1
Bronx 5 9:23
23 : 16
BQE 5 : 6
Brooklyn 5 : 3
balance
big 41:19,
20
19 : 6
22 : 19
46 : 10
breaks 8 : 1
25 : 24 42:4
balancing
14:20,24
biggest
38 : 7,23
breathing
8 : 11
brought
33 : 21
based 12:18
bisected 5 : 6
BRENNAN
bucket 4 9:19
17 : 15
bit 6:17
18 : 19,25
build 7:23
21 : 16,22
20 : 12
19:4,8,11
25 : 19
37 : 18
20:18 21:8
building
2 6:4,6
46:16 49:1
22 : 10
5:22 8:2,
32 : 16
54 : 14
23 : 6,22
9,10 9:7,
40 : 4,14
56 : 24
24:11,13,
11, 20
15 : 15,20
baseline
block 4 6:4
22 25:13
16:10,12
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: buildings.xollect
20:21
48 : 23
61 : 1
city 24:18
25 : 21
call 41:14
certify 61:3
25 : 10
37:17,18
38:1 40:20
45 : 17
cetera 18:5
28 : 24
31 : 12
41 : 21
called 7:21
30 : 24
37:21
44 : 11
48:8,14
54 : 13
8:3 12 : 10,
19,23 20:7
46:19
chair 2 2:18
challenge
35 : 24 36:7
clarify 3 8:5
39 : 11
46 : 16 52:2
59:15,23
calls 41:23
56 : 11
54 : 19
60 : 1
44 : 18
chance 3 6:21
clean 11:15
buildings
cameras 17:8
7:23,25
change
cleaners
10:21 13 : 7
cancer 6 : 3
53:12,14
5 : 21
21 : 11
49:8,9
59 : 20
cleaning 6 : 7
33:20 34:9
canister
changed
8:25 19:2,
37:12,14,
9:19
41 : 20
4 51:17
25 38:8
canisters
characteristic
cleanup 4:25
39:24,25
9:22 10:3
s 16:10
12 : 9,11,
40:4 41:11
carbon 5 9:16
characterizati
13,18,21,
built 7:24
carpet 5 9:19
on 4 9:1
23 , 25
business
18:5 42 : 23
case 7 : 9
10:15 11:9
check 13:2
44 :4,5
13:1,5,17
14:2,16,21
17 : 15
businesses
40 : 11
Chesler
51 : 24
25 : 9
54:10,17
22 : 17
cleanups
case-specific
23:14
11 : 18
C
54 : 20
24:7,12
30 : 24
CAG 10:14,
cases 3 7:24
chief 31:1,3
clearing
16 42:5
40 : 17
children
59 : 18
45 : 18
cemented
13 : 21
close 31:23
52 : 22
9 :10
chime 2 9:5
38 : 15
53 : 10
center
chlorinated
closely 33:4
calculated
37:24,25
5:8,20 6:9
13:19,22
cluster
49 : 16
CERCLA 11:14
7:13,14
45 : 17
calculus
CERTIFICATE
circumstances
collect 9:20
3 6:1
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: comment..contamination
comment
community
40 : 1
consent
12 : 15
10:14 15:2
conclusion
39 : 13
17:3,11,22
18:5 20:9
16 : 7
Conservation
29:7,15,19
22 : 19
concur 15:7
6:7 20:2
42 : 17
36 : 17
43 : 12
39:17,21,
33 : 7
conservative
49:21,22
22 45:22,
conditions
29 : 9
50:16 54:6
23, 24
9:14 16:9,
54 : 21,25
comments 4 : 6
comparable
11
consideration
12:16 15 : 6
30:21
conduct 11:5
15:4 43:8
16:21,22
compare 14:6
12:1,6
considered
17:1,12,17
16 : 5
28:1 42:11
18:1 30:2
compared
60 : 7
43 : 6 56:25
conducted
constant
8:12,18
31:4
commercial
Compensation
16 : 1
constructed
4:11,16
11 : 13
conducting
38:2
13:6,18,23
complete
4 : 13 6:19
19:3
4:23 9:13
consultation
20:14,20,
confirm 41:9
20 : 1
completed
2 5 21:6
44:11,14
confirmation
contact
29:8,17
45:6 52 : 24
16 : 17
39:10
31:25
44 : 13
contaminants
32:9,17,19
complex
33:10,24
10:20
conflict
5:13 12 :4
26 : 24
13:10 25:7
42:7,13
comply 14:17
43:1 54:12
confusing
contaminate
compounds
50 : 6
7 : 20
committed
5:9,15,19,
33 : 3
20 6:9
Congress
contaminated
Committee
7:13,15,17
11 : 11
5:8,19
connect 9:18
36 : 12
7:12,21,24
22 : 18
common 5:20
Comprehens ive
11 : 12
8:17 11:16
13:8,13
28:4
concentrations
connecting
contamination
5 : 24
communication
12 :5 35:3
15 : 17
31 : 5
concern 5:14
consensually
11 : 17,20
communities
6:1 13 : 10
39:19
40:5 51:4,
46 : 12
33:24 37:9
20
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: context..decision
context 2 9:5
correctly
crosstalk
day 8:22
continue
32 : 7
47 : 19
9:8,16
4:19 11:5
cost 14:22,
49 : 18
10:2 13:22
contract
45 : 10
24 15:22
cubic 4 6:23 ,
20 :22,23
21:21
24
34:6 35:25
contracted
26 : 6
26 : 24
cumbersome
days 10:4
53 : 24
59:22 60:1
13 : 23
57:3,6
29 : 12
contractor
costly 6 0:2
curious
20 : 11
dealt 46:18
57:15,22
costs 11:18
25 : 11
Deborah
converse
36 : 16
21:25
26:25
current
43 : 10
26 : 11
debriefed
convoluted
27 : 5
couple 12:22
17:8 24:17
CVOCS 5:10,
15
33 : 21
DEC 22:7
Cooper
28:20
28:23 29:5
10 : 20,25
29:21
D
30 : 22
34:1 36:12
39 : 23
31:6,11
37 : 11
covered
danger 4 9:4
38 : 11
cooperate
28 : 11
dark 3 6:5
48 : 18 52 :3
39:17,19
crack 41:19
dash 7 : 1
DEC 1 s 5 6:25
coordinate
27 : 20
cracks 8 : 1
data 11:3
DEC-LED
14 : 11
24 : 19
30 : 23
coordinated
15 : 13
25:11,17
December
27 : 14
58 : 11,20
26 : 16
35:7 42:21
coordinates
Creek 5 : 6
30:21 35:8
decide 11:24
26 : 15
7:5 27:10
40 : 10,14,
28:5,19
18 41:8
decision
coordinating
31:3
44:23 45:2
12 : 20
26 : 18
46 : 14
17:13,14,
coordination
criteria
47:23
16 21:25
31:4
11 : 23
48:4,17
22:2,4
Corps 5 7:2 0,
14:14,15,
32 : 14
20,24 15:2
date 3 8:6,
33 : 15 37:4
22
31:19 32:3
22
50 : 15
correct 21:8
44 : 3
Dated 61:11
51 : 12
52 : 5,21
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: decisions..easy-to-understand
52 : 11
decisions
32 : 13 33:6
deeper 23:3
delayed
52 : 12
deliver 10:3
Department
6:6 20:1,2
depending
56 : 19
depends 5 7:1
deployed
24 : 20
depressurizati
on 8:4,6
14 : 11
15:12,17
16 : 19
24:20,23
58 : 15
description
4:2 5:1
design 12:23
designing
12 : 22
detail 53:10
details 23:2
32 : 10
42 : 22
determination
30:16
31:10
54 : 20
determinations
19 : 23 32:5
determine
12:4 16:3,
15,18 53 :4
determined
10 : 24
23 : 21
26:21 29:2
34 : 1
determining
26:25
developed
58 : 19
developing
4 : 24
development
20 : 8
developmental
49 : 11
difference
31:19
differences
31:19 42:6
difficult
34 : 8
difficulties
38 : 13
dinner 3 6:3
direction
54 : 25
directly
57 : 15
discovered
6 : 8
discovery
11 : 20
discuss
48 : 15
discussed
56 : 24
distance
23:10 24 : 5
44 : 6
distinction
31:25
32:9,17
dive 23:4
document
17 : 14 23:7
33 : 15
documentation
23 : 3
documented
31 : 14
documenting
29:25
documents
49:22
DOH 31:9
door 10:10
35:21 36:5
doors 8:15
double 44:4,
5
Doug 61:3
DRABEK 17:19
18 : 10,14,
17 20:4
22 : 16
47 : 15,18
60 : 6,10,14
draw 16:7
31 : 24
draws 8 : 8
drum 19:5
dry 19:2,4
Dudek 3 0:25
31:1 33:2,
7 47:22
48 : 8,12
50 : 7
dug 15:19
e-mail
16 :22,24
earlier 41:7
53 : 8
early 17:19
53:4,6
easily 5 0:5
East 5 : 3
easy-to-
understand
49 : 25
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Meeting Index: echo..exposure
echo 3 8:5
ecological
12 : 7
economic
20 : 8
effective
14 : 21
59:8,17,21
60:4
effects 6 : 3
49:8,9,11,
12, 13
effectually
20 : 16
efforts
10:7,18
37:3 39:18
egregiously
55 : 14
eight-hour
13 : 24
elderly
13 : 21 21:1
42 : 16
electric
15 : 18
Elkins 2 8:18
30:7,19
32 : 6
50 : 11,19
52:1,6,15
emphasize
14 : 23
encourage
47 : 12
end 4 : 6
17:2 19:18
22:1 56:5,
20 60:18
ends 17:11
enforcement
28 : 12
Engineers
57 : 20
enter 7:25
entered 7:15
entire 4:25
entities
26 : 23
entity 26:18
environment
14 : 19 43 : 5
Environmental
6:6 11:12,
13 20:1
22 : 18
EPA 6:14
8:22
11:15,17,
21 18:22
25 : 14
28:12,22
29:2,4
31:4 32:4
33:5 35:5
38:5,9
39:8,11
40:7 44:21
48 : 14
52 :2,4
55 : 9
57 : 15,18
EPA's 12:13
24 :25 35:4
46 : 12
EPA-LED
11 : 18
equally
14 : 25
establish
14 : 5
established
11 : 11
estimate
21 : 18,21
34 : 24
53 : 24
estimated
15 : 23
21:22 22:2
estimates
15 : 25
estimation
54 : 2
evaluate
12:9,11
14:5,13
26:17 43 : 7
evaluated
14 :2, 8
33:9 58:6
evaluating
4:25 11 :3
evaporate
5 : 17
evening
17 : 21
event 15:10
Evergreen
20 : 7
evidence
16 : 14
30 : 13
exist 24:18
58:3
expanded
26 : 6
expanding
50 : 23
expect
20 : 21,24
expedited
4 : 14
expediting
4 : 15
explain 7 : 9
11:9 13:16
20 : 11
explained
50:5 55:21
explaining
49 : 2,14
exposure
13 : 6
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Meeting
MEETING
Index: extent..gas
20:19,20
41:5 49:9,
13
extent 5:24
extremely
34:8 35:20
faces 4 : 13
facilities
19 : 6
facility
20:25
fact 2 7:13
40:4
factor 57:3,
7
fairly 44:18
fall 20:24
falls 11:10
46 : 9
familiar
4:12 7:8
10:15 11:8
fan 8 : 7
15 : 18
faster 10:1
favorite
52 : 17
feasibility
6:16 12:2,
10
feasible
59 : 14
February
35:10 41:7
56 : 16
federal 6:23
52 : 8
feedback
12 : 18
feel 29:3
34:13,15
36:10
39:10
fell 33:12
felt 33:13
figure 2 8:6
58 : 11
figuring
48:22
filtration
59 : 16
final 17:14
60 : 15
find 5:20
8:20 14 : 9
15 : 10
16 : 20
19 : 16
23 : 23 37:6
40 : 23
51 : 16
52 : 12
finding 2 6:7
fine 21:14
five-year
53 : 21
flesh 53 : 1
flexibility
33 : 16
54 : 22
flip 13:4
floor 8:19
9 : 6, 11,13 ,
22 34:5
36 : 13
37 : 14
40:21
41:3,19
42 : 24
44 : 25
58:9,10,13
flow 55:5
focusing
5 : 25
folks 13:21
32:24 49:2
follow-up
38 : 24
52 : 15
foregoing
61 : 5
forgot 19:9
form 41:19
formal 17:22
18:2 54 : 14
formalize
12 : 18
17 : 14
formally
17 : 2
forthcoming
39 : 15
found 2 5:19
28:4 41:11
52 : 10
55 : 13
foundation
7:23 8:2
14 : 12
15:14,19
16 : 12
free 3 9:10
freestanding
9 : 23
fresheners
5 : 21
full 5:23
fully 33:7
functioning
9 : 17
future 3 9:4
43 : 11
gaps 14:12
15 : 13
gas 5:7 9:4
23 : 25
37 : 23
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Meeting Index: gave..holistically
40 : 23
43:9,25
45:5 49:23
20:2 49:5,
gave 2 8:2,
44:7 49:21
50 : 12 54:6
8 51:19
25 45:3
54 : 6
guidance
hear 4 : 7
general 13:5
government
28 : 12
7:1 37:10
30:25
11 : 17
57 : 17
heard 7:10
generalities
Gowanus 6:25
guideline
hearing 3 2:7
31 : 1
27:19
46 : 22
heating 8:13
generally
great 4 : 8
guys 6:25
10 : 18,22
45 : 16
50:21
10 : 15
11:6 35:17
gentleman
42 : 23
54:8,11
16:24 17:7
38:10
59 : 9
54 : 17 60:8
55:10,11,
greater 22:1
13,17,22
gentleman1s
H
56:10
Greenpoint
28 : 22
30:20
5:3 6:8
half 9:15
Heide 31:1
geological
7:4
10 : 1
helium 9:17
16 : 9
ground 3 6:13
handled
helpful
give 4:1,4
37 : 14
44 : 21
29:1,4
17:22 18:3
groundwater
happened
32 : 10
29:5 33:16
5:7,11
17 : 12
helping
37:5 40:19
6:10,19
41 : 17
10 : 17
41 : 15
7:12,15,22
43 : 23
hey 41:15
23 : 24
4 5:20 46:1
happening
high 43:17,
52 : 24
27:13
50 : 16,20
51 : 22
25 55:14
good 4 : 7
52 : 24
51:7
56:5,7
10:10 17:7
Group 10:15
hard 10:8
22:6 24:1
35 : 20
higher 3 5:3
29 : 12
grow 3 9:5
49 : 23
43 : 22
34 : 15
guarantee
50 : 12
highest
37:10
56 : 21
58 : 11
43 : 21
40:7,19
history 4 : 1
41:16
guess 25:10,
hardworking
42:20 50:7
16 30:17
34 : 10
6:5 36:17
54 : 16
36 : 16
hazard 4 9:15
hold 11:16
42:5,17
holistically
30 : 14,15
Goodman 4 2:3
43 : 9 44 : 2
health 6 : 1
12 : 6 14 : 19
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: home..install
home 9 : 9
14 : 10
20:19,22
23 : 8 34:10
42 : 21
homeowner
41 : 14
homes 23:11
40:8 45:16
59 : 6
honestly
50 : 20,24
hoping 4 9:24
hour 9:15,
25
hours 9:24
13 : 22
20:15,22,
23 29:11,
14 34:11
42 : 8
house 2 9:12
41:5,16
43 : 18
58 : 12
household
5 : 21
houses
10 : 20,25
34:1 36:12
37 : 11
43:18 51:5
housing
10 : 21
human 12:6
14 : 19
hundred
23 : 25
24 : 11
hurdle 3 8:7,
23
HVAC 8:15
hydro-
geological
16 : 9
I
idea 45:20
46:1 52:25
identified
13 : 18 15 : 9
18 : 21
identify
18:9 28:13
identifying
50:22
imagine 2 5:8
immune 4 9:12
impact 5 9:15
impacted
16 : 13
34 : 14
51 : 19
impacts 8:20
16 : 20
implement
12 : 21
imp1ementab1e
14 : 23
implementation
12 : 24
implemented
13 : 2 22:21
important
14 : 16
inaudible
19:9,10
47:20 50:8
include 16:8
17:17 21:1
47 : 2
49:10,11,
13 50:1
includes
14 : 21
58 : 19
including
13 : 20
32 : 23
51 : 10
index 4 9:15
individual
23:9,13
32:21 54:8
individual ly
33 : 9
indoor 5:18
6:12 15:25
16 : 20
31:22
32 : 20
37 : 23 45:2
46:21,24
47:3 59:15
indoors 8:17
13 : 13
industrial
20:8,9
29 : 18
informally
11 : 14
information
16:6 26:3
27 : 12
35 : 21
44:5,9,13
45:9,13
47 : 2
initial
52 : 23
initiated
6 : 16
input 17:15
inside 15:21
29 : 12
34 : 24
37 : 12,16,
22
inspect 8:23
install 9:3,
8 15:11
33 : 14
52:9,13,25
57 : 24
59 : 13,16
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC
Meeting
MEETING
Index: installation„led
installation
57 : 14
installed
6:13 25:2
45:24 52:2
installing
14 : 10
50 : 25
51 : 11
instance
32:18 43:5
intact 16:12
intend 52:22
intentional
7 : 16
interest
38 : 12
interim 4:21
51 : 18
intrusion
4:3,5,11,
15, 18
5:11,12,14
6:1,20,22
7:9 8:3,
12,14,18
10:7 11:5
13:4,10
14:1,8
15:11 16:4
21:5 46:20
57:6 59:6
investigate
18 : 22
investigated
40 : 2
investigating
5:23 6:7
25:18,21
28:3 51:22
investigation
4:14,19,24
6:16 12 :2,
3 19:15
39:3 53 :2
investigations
6:11,20
11 : 21
25:20 38:6
51 : 23
involved
25 : 1
involvement
35:4,6
involves
15 : 17
issue 14 : 9
23 : 11
56 : 22
issued 12:20
15 : 5
issues 15:11
59 : 24
items 5:21
John 3 7:2
48:21 50:7
53 : 11
55 : 21
60:8,16
judgment
21 : 23
judicial
39:16
June 16:21
17 : 17
K
KETU 19:7,9
21 : 14
25 : 18
34 : 19,22
49:7,20
50:1 53:23
54 : 1
kidney 4 9:10
kids 3 9:5
kind 11:9
21 : 5
36 : 12,17
37:17,21
38 : 23 44:2
48 : 22
51 : 23
54:1,14
55:6 56:2,
10 59:18
knocking
36 : 5
knowing 4 8:7
knowledge
26 : 22
27 : 17 34:5
Kyle 44:8
45:5 46:15
lab 10:3
55 : 23
56:11,15,
22
lack 3 0:13
Lael 42:3
landlord
38:25 39:1
47:9,25
48:5,16
landlords
34 : 9
language
13 : 14
Lauren 2 6:1,
10 53 : 8
law 3 9:11
46 : 20
47 :4,6,24
48 : 9
laws 14:18
48 : 20
layered 2 7:5
leak 9:17
leave 16:23
led 6:10
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC
Meeting
MEETING
Index: legaL.math
legal 3 9:9
legalese
38:25
liquid 7:18
list 6:15
11:25 12:1
legally 14:4 listed 35:6
LESHAK 2 8:11
39:7
letter 3 9:1
letters
38 : 11,14
47:1,11,
16,18
level 9 : 5
20:17 46:1
levels
13:17,19,
24 20:12
28 : 21
54 : 12
55 : 14 57:6
Liability
11:12,14
light 3 9:2
likelihood
40:3
limit 2 2:4
limitations
56 :2,5
limited 45:9
lines 8 : 1
16 : 14
30:18
43 : 15
live 2 6:1
45:21 46:2
liver 4 9:10
lives 42:24
43 :3
living 4:22
8:10 41:1,
3
local 2 0:7
located 5:2,
18 18:19
location
19 : 1
long 14:22
27 : 4
51:20,21
52 : 20
long-term
52 : 14
looked 2 2:13
23:8,13
27:1,2
58 : 1
lot 4:12
12:3 29:13
30:3,4
32:25 34:9
45:22,23
46:4
loud 5 9:22
low 3 8:16
lowest 9 : 5
luckily 8 : 3
lunch 3 7:16
M
made 10:21
32 : 16
39:18
mail 16:22
mailed 3 8:14
mailing
16 : 25
mailings
10 : 12
35 : 20
main 5:13
13 : 9 36:6
maintain
60 : 2
maintenance
15 : 24
59 : 19
major 11:19
32 : 8
make 8:24
9:16,17
13 : 2 16:7
17:3 19:21
30 : 15
31:10
32 : 5,15,23
33 :5 37:3
40 : 18,25
41:2,3
43:16,18
46:2 50:4
54:15,19
56 : 18
making 19:22
37:4
manager 31:7
manager1s
37 : 15
managers
27 : 18
Manhattan
25 : 24
manufacturing
20 : 9
map 6:23
34 : 17
45 : 17
marbles 5 0:8
March 6:14
10 : 23
35:6,10
41:7 55:2
56 : 17
mass 10:11
massive
59 : 25
math 2 0:14
57 : 1
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: matrices..nervous
matrices
41:6 51:8
mitigation
nature 5:24
32 : 14
53 : 24 58:8
6:13 14 : 8
nearby 2 2:24
matrix 31:9
mentioning
15 : 25
43 : 19
means 21:18
24 : 1
19:23 25:3
33 : 14 38:3
necessarily
22 : 23
meter 4 6: 23 ,
47 : 25
24 : 5 30:18
39:16
24
48:3,9
31 : 24
meantime
method 12:13
50 : 25
34 : 17
52 : 9
13 : 1 14 : 21
51 : 11
43 : 11
measure 4:21
17 : 15
52:3,11
47 : 10
15 : 13
methods 4:25
54 : 24
needed 16:1,
51 : 18
10 : 13
57 : 24
16,19
media 10:12
12:9,11
mitigative
51 : 11
19 : 23,24
38:3 46:6
35 : 22
mic 19:21
48:1,3
Meeker 5 : 1
micrograms
modify 2 2:3
53 : 5 55 : 15
7:3 15:23
46 : 23
modifying
57 : 24
LT
OC
CN
CN
CN
O
CN
microphone
15 : 1
58 : 22
31:2,8
17 : 24
moment 7 : 8
negative
42 : 5
18 : 11
months 55:7
22 : 22
meet 53:16
migration
23 : 16
mouth 3 5:22
meeting
13 : 12
neighbor
17:25
minute 16:23
mouthful 5 : 9
46 : 8
45 : 19
52 : 22
minutes 41:6
move 4:20
7:19 12 : 5
neighborhood
25 : 11,14
53:3,10
missed 52:1
multiple
58 : 5
meets 11:22
mitigate
27 : 5
neighborhoods
member 18:5
4:17,21
25:5,6
39:21
6:4 14 : 10
N
neighboring
16 : 19
membrane
31:21
named 2 7:22
43 : 17,22
58 : 13
32:18 37:6
Natalie 2 0:5
44 : 1
mentioned
mitigated
Neighbors
7:11 15:16
Natalie1s
8:4 31:13
29:8
42:4
19 : 14
nervous
49 : 13
27 : 19
mitigating
National
28 : 14 32:3
15 : 22
6:15 11:25
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC
Meeting
MEETING
Index: Newtown..part
Newtown 5 : 6
7:5 27:10
28:5,19
31:3
night 3 6:2,4
43 : 3
non-cancer
6:3 49:8,
11, 12
non-
residential
13 : 25
nonprofit
20 : 7
normal 3 4:11
north 3 5:5
42 : 4
note 16:24
39:22
noted 3 8:6
notification
46 : 20
notify 10:5
48 : 1
November
6:18 10:22
55 : 1
number 21:12
24:4,24
25:2 28:3
33 : 20
34:17 42:8
56:7,8
numbers 21:1
25:8 29:1,
4,21
30 : 12,18,
21 31:19
32:7,12,16
33:1,12
35 : 18
43 : 1,6
46:25
47:4,20
48 : 24
56 : 25
objectives
13 : 5
obtain 3 9:19
obtaining
38 : 8
occupants
34:5 47:13
occupied
34 : 10
occur 8:14
ocular 4 9:13
office 2 7:17
37 : 16
offsite
22 : 25
23 : 15
oil 6:8 7:4
ongoing
15:24 16:1
19 : 16
28 : 15 37:4
open 12:15
55 :3
opposed
20:22 51:4
option 58:2,
16
options 58:3
organic 5:8,
15,20 6:9
7:13,15
organization
20 : 8
organizing
34 : 7
original
35 : 12
outdoor
37 : 23
outdoors
15 : 20
outline
34 : 18
53 : 16
outlined
35 : 2
outreach
10 : 12,16
34:7 35:18
37:3 38:14
39:18
44 : 17
outs 5 9:20
overlap
26 : 14
oversight
26 : 15
overview 4 : 4
owner 10:6
18 : 5
44 : 20,22,
23 45:11
47 : 23
57 : 16
owners 3 4:4
35:9 39:13
44 : 18
47 : 12
paints 5:22
8 : 25
Paloma 3 9:20
parallel
4:20 19:15
51 : 8
Park 10:20,
25 34 : 1
36 : 12
37 : 11
part 14 : 1
15:3 18:1
42 : 4
45 : 21,23,
24
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: particles..pre-scheduled
particles
41:3
phases 11:19
41 : 21
7 : 20
42 : 12,16
phone 41:22
Plume 5 : 2
parties
43 : 11
44 : 18
7:3 27 :23
11 : 16
26 : 20
27 : 21,22
28 : 14
45:15,20
46:6,11
50:16 54:9
55 :3
phonetic
24 : 16
39:21
31:2,8
plumes 31:12
point 7:14
50 : 22
people1s
physically
26:2 29:8
48:4 51:5,
57 : 14
36:23 37:2
partner 2 8:1
53 : 6
19 5 9:6
pick 10:2
parts 25:10,
24
percent
picked 51:6
policy 2 8:12
22:1,2
39 : 14
party 27:25
38:21
pieces 16:6
47 : 23
past 7:14
10 : 22
perfect
41 : 15
piggyback
55 : 19
pollution
18:9,16,18
31:20
32:13,14,
perfectly
pink 6:25
7:1,5
pool 5 0:8
15 41:7
40:19
population
46:18,25
period 9:24
pit 15:19
34 : 13
47 : 11
13 : 22
place 9:21,
populations
55 : 21
17:3,11
24 20:16
13 :20 21:3
PCE 13:11
53:21 55 : 2
places 31:11
42:10,15
21:5 29:3
56 : 1
plan 4:5,
port 9:4,8,
31 : 23
periodically
10,17 6:21
12,16,19
46 : 24
13 : 2
11 : 10
portion
49 : 9,10,12
permanent
12:13,15,
17 : 21
penetrated
51 : 25
19 13:15
positive
34 : 13
permission
14:2 15:5,
8,22,24
22 : 25
people 13:6
44 : 20,22
16:21 17:5
23 : 19
20:15 21:6
perpetuate
21:20 37:6
potential
26 : 25
8 :16
51 : 13
39:3 50:23
29:10,13
60 : 15
33:10,20
person 4 6:10
potentially
34 : 10
perspective
planning
26 : 24
35 : 25
44 : 12
56 : 14
28 : 13
36:2,20
plenty 4 : 6
pre-scheduled
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: preexisting..proven
8 : 23
preexisting
9 : 14
preferred
12:12,13
17 : 15
prefers 55 : 9
pregnant
13 : 21
42 : 16
43 : 12
preliminary
5:5 11:22
52 : 23
prepare
17 : 13
present 12:6
presentation
19 : 22
pretty 31:22
prevent
13:6,12
preventative
15 : 13
previously
40 : 9
prior 3 5:14
38 : 8
priorities
6:15 11:25
36 : 6
privacy
46:9,11
47:22
48:20
private
48:3,4
probable
18 : 22
problem 34:6
51 : 16
52 : 11
problems
37 : 6
proceedings
61 : 5
process 4 : 4
6:17 8:2,
21 11:7,
10,19
27 : 23
28 : 14
33 : 21
44:10,12,
15 45:8
51:21 53 : 6
processes
55 : 24
products
8:25
professional
21:22
program
52 : 13
project
27:18 31:7
properly
9 : 17
properties
4:11,16,18
5:18 6:12
10:9,19,
23 , 25
11:2,4
13 : 18
15 : 23
21 : 16,24
24:3,9,14
29 : 18
31:22
33 : 24
34:4,8,25
35:7,12,
14, 15
36:11 37:8
38 : 15
39 : 12
40:12,14
42 : 14
43:7,19
44 : 2
property
8 :22,23
9:11 10:6
14:9 15:11
16 : 11
19 : 24
22:22,24
23 : 17
30 : 14,15,
16 32:19,
22 33:9
35:9 38:12
42 : 25
43 : 14,22
44 : 1,18,
20,22,23
45 : 10
47:20,24
51 : 17
54 : 23
57 : 13,16
proportion
22 : 9,14
proposed
4:5,10,17
6:21 11:10
12:13,15
13:15 14 : 1
15:5,8,9,
22 17:5
21 : 20
50 : 13
51 : 13
protect
51 : 19
protection
20 : 17
22 : 18
protective
13 : 20,25
14 : 19
29:13 51:2
54 : 21,22
56 : 25
protectiveness
29 : 16
proven 24:23
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Meeting Index: provide..reimburse
58:4
provide 3 9:9
47 : 23
proximity
16 : 13
22 : 23
23:7,10
PRP 28:4
public
10 : 20,21
11:1 12:15
15:6 16:21
17:3,12
publish
47 : 14,15
purpose
37:20
purposes
53 : 24
purview 3 9:8
put 9 : 2
12 : 12
21 : 20
58:12,25
Q
qualification
22 : 20,21
quarter 9 : 5
question
17:4 19:19
21 : 10
22 : 19
24 : 17
26 : 12
2 8:20,22,
25 29:20
30:20 36:8
38:25
39:7,8
40 : 7
42 : 18,20
43 : 13 44 : 9
48 : 13,22
50:2 52:17
53 : 20
55:19,20
question-and-
answer 17:20
questions
4:6 16:25
17:18,22,
25 18:6
20:4 21:11
27:7 28:20
29:22
30:1,4
60 : 6
quick 11:8
53 : 20
quickly 6:23
24 : 7
R
radius 43:17
radon 8 : 7
radon-type
31 : 13
range 2 2:3
32 : 20
50 : 23
rate 3 8:16,
21
ratio 2 9:16
reach 4 8:14
ready 17:18
real 11:8
28 : 15
42:19 51:3
52 : 18
reason 15:3
20 : 13 24 : 2
25 : 23 35:1
41 : 18
reasoning
55 : 10
reasons
41 : 22
59 : 13
recall 23:7
receive
12:16 15 : 5
17 : 16
received
17:17 39:1
recently
27 : 14
recognized
54 : 15
recommend
31:21
recommendation
s 32:15,23
recommended
32 : 18
reconditioner
19 : 5
record 12:19
17 : 13,16
18:2 22:2
50 : 15
51 : 12
52 : 10 61:6
recorded
17:2,25
61 : 5
Recording
60 : 18
redirects
8 : 9
referred
28 : 2
referring
56 : 9
reflects
15 : 22
regular
59 : 19
regularly
44 : 19
regulations
14 : 18
reimburse
11 : 17
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Meeting Index: reintroduction..roof
reintroduction
52 : 13
residential
restore 9 : 13
43 : 23
removed 9:12
4:11,16
result 22:23
relationship
45 : 10
renter1s
44 : 12
10 : 19,25
13:7,18,19
20:14 21:1
23:17,19
46 : 21
release
repeat 18:10
24:9,14
resulting
60 : 15
33 : 23
29:10
7 : 22
released
reply 3 0:1
31:25
results 9 : 1
32:9,17
6:21 15:8
10:5,6
represented
33 : 25
16-5,15
releases
31 : 7
—I— f —I—
7 : 16
42:6,10
24 : 21
request
43:6 54:12
46 :20,24,
relies 31:6
47:10
residents
25 47 : 1,12
remain 2 6:5
requesting
36 : 15
52:22,23
remaining
45 : 8
respond
retest 4 0:12
11:3
require
12 : 17
retesting
remains 2 6:8
11:1,2
17:4,11
40:4
remedial
39:15 45:7
response
review 12:16
4:13,24
required
11:12,13
17 : 11
6:16 12:1,
14 : 5
38 : 15,21
reviewed
3,23,24
41:12,14
39:12 50:1
23 : 3
20 : 12
47:4,6,10,
56 : 19
31 : 15
51 : 10
25 48:2,9
52 : 11
responses
17 : 17
risk 4:21
6:4 12:6,7
29 : 24
remediation
requires
responsibility
41 : 11
26:25 34:2
57 : 13
46 : 13
49 : 1,15,17
36:21 39:4
residence
51 : 17
51:4 52:19
responsible
risks 4:18
11 : 16
49 : 5
remedies
58 : 1
residences
26 : 20
ROD 57:12
37 : 13
27 : 21,22,
remedy 2 2:21
57 : 14
resident
25 28:13
50 : 22
rolling
53 : 20
18:4 20:6
remodel
24 : 17
responsiveness
roof 8 : 9
41 : 20
26:11 34:4
50:3
15 : 21
44 : 8
43:14,15,
removal
rest 53:1, 3
21
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: room..site
room 5:17
27 : 13
send 4 7:1
shut 8:15
roughly
28:23,24
sense 45:15
sick 3 9:5
38:20
37 : 13
39 : 12
55 : 15
sidewalk
running 8:16
44:11,14,
sensitive
23:1,15,18
60 : 2
21 45:6
13 :20 21:3
sidewalks
Rupika 19:14
52:24 54:3
series 6:10
23 : 25
27 : 15,18
55 : 9
set 51:10
signed 52:12
36:4 58:7
school 10:20
54:4 57:21
11 : 1
significant
Rupika1s
settings
33 : 11
19 : 22
screening
13 : 25
significantly
5 V I G
Q
share 2 6:3
21 : 23
D
seal 58:9,
27:11,12
similar 8 : 7
sample 9:7,
13
28 : 15
22 : 9
20 25:16
sealing
30:22
24:18,19
35 : 16
14 : 11
32 : 10
25:6,7,8,
37 : 15
15 : 13
46 : 13,14
9,11 28:24
39 : 14
58 : 20
47:5,7,12
36:1 40:16
40 : 15 45:1
48:4,24
58:10,14
season
52 : 22
simpler
10:18,22
53 : 13
13 : 16
sampled 11:4
35 : 17
single 10:11
35:5,7,9,
38:10
shared 27:16
14 40:9
55:10,11,
35:8 45:2,
37:17
41 : 25
13,17,22
12
sister 31:6
42 : 25
56:10,17
sharing
site 4:2,
46 : 11
seasons 8:13
45 : 18
14,25 5:1,
sampling
11 : 6
48 : 17
2,10,25
4:15 6:19
section
Shaun 31:17
6:4,5,14,
00
\—1
CM
\—1
\—1
\—1
00
17,20,22
31:1,2
shift 2 6:17
7:4,6,7
9:1,12,19,
21 10:2,7
sections
short 5:10
11:22,23,
11 :2,5
35 : 2
11 : 14
25 12:9,19
12:3 15:25
seeking
14 : 22
13:3,11
16:5,15,17
39 : 13
show 6:23
14 : 4 18:4
24:8,25
19 : 14
25 : 25
select 14:17
showed 2 5:7
27 : 10,23,
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Meeting Index: site-related..state
25 28:2,
small 9:4,5
sources 8:24
45 : 16
10, 23
15 : 18
18 : 22
specific
31:11 35:6
social 10:12
space 21:6
45:7,25
38 : 9,23
35:22
32 : 19,24
46 : 7
51:9,18
soil 5 : 7
7:19,20,
33:10
specifically
13 : 3
52:7 53 :3
40:21
site-related
21,22,24
44:24,25
25 : 13,17
4:10,18
13:7 15:10
8:17,18
9:4,12,21
45:4
56:11,15
speech 33:22
site-wide
23 : 25
spaces 41:3
spend 2 0:16
4:13,19
31 : 9,12
42 : 17
21:7
sites 6:24
37 : 23
spare 18:25
29:10,14
11 : 16
40 : 23
speak 18:3
spending
sold 3 6:18
33 : 11
24 : 18
25 : 13
25 : 15
solid 53:5
30:25 49:7
spends 2 9:11
26 : 13,16
spill 6 : 8
7:4
27:11,12,
solution
SPEAKER
15, 18
51 : 25
18:8,12,
28 : 24 29:5
52 : 14 59:8
15,23 19:2
Spiroff
30:23 31:5
60:4
33 : 18
26 : 11,12
40:2,6
sort 19:15
35 : 11
27:4,8
59 : 12
21:22
36 : 9,15,20
28 : 17
Sixty 3 8:17,
22 : 13
37:10
38-17,19,
SSDS 59:13,
19
27:14
• —L. / f _1_ _•/ f
17 60:4
28:25
24 47:14,
staff 57:22
size 9 : 4
30:14,23
16,19
37:19
48 : 23
48:5,11,21
standalone
slab 9:11
50 : 12
49 : 18
59 : 16
14 : 11
51 : 12
50 : 18
standard
15 : 12
52:15 53 :4
55 : 1,18
56 : 12,23
31 : 14
slide 17:9,
sounds
57:8,10,
start 21:15
10 19:1
50 : 13,21
11,25
52 : 4
29:2 34:20
source 18:9,
58 : 21,23
starts 11:20
slides 6:18
15,17,20
59:2,5,9
60 : 5
state 6 : 6
39 : 23
19:16,17,
18
7:18 15:2,
slight 31:19
speaking
6 18:19
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Meeting Index: State's..TCE
20:1 23:24
straightforwar
subset 5:16
6,7 14:11
24:25
d 51:14
substances
15:12,17
25:1,4,19
street 10:11
5 : 16
16 : 19
26 : 22
22 : 25
24 : 20,23
27:24 28:1
23:15,17
subsurface
31 : 14
31:4,12,
34:7 46:1
16 : 8
33 : 14
20,23 32:7
stress 19:13
successful
49:12,13
35:4 38:9,
51 : 12
38:3
3 0:12
11,22
suction
52 : 14
40:9,16
strictly
15 : 19
58 : 15
45:13
55 : 6
systems 6:13
sue 3 9:4
46:17,19
structure
8 : 15 25:3
47 : 24
8:8 16:10
summary 5 0:3
45 : 24 46:6
50 : 24 58:8
59 : 12
41:21
structures
Superfund
4:3 5:2
50 :25 52 :3
57 : 24
State 1s 3 8:6
16 : 13
6:15,24
46:22 51:2
7:4,6,7
T
struggle
35:19
state-led
11:7,15,
6 : 24
19,23,25
takes 9:14,
struggled
21 : 25
2 5 10:4
States 57:20
38:22
39:11 51:9
27 : 24
stay 7:18
study 5 : 5
52 : 8
55 : 24
9:23 17:9
6:17 12 :2,
supervisor
talk 4 : 9
staying 55:7
11 15:24
27 : 10
6:17 7:10
stuff 5 0:8,
12 : 14
Stephanie
supplies
44 : 15
28:11,14
14
5:22
4 8:25 53:9
32:3 53:23
sub- 14:10
SURANI 31:18
talked 42:8
15 : 11
steps 12:22
32 : 12 33:3
19:24 51:3
sub-slab
38:4,18,20
talking 4 2:5
52 : 18
8:4,6 9:4
46 : 16
49 :3,15
60 : 15
15 : 16
59 : 11
targeted
Steve 22:17
16 : 18
surrounding
21 : 13
stone 54:4
24 : 22
31 : 5
TCE 13:11
storage 41:1
37 : 23
40 : 23
Sutton 4 6:3
21:5 29:3
31 : 23
58 : 15
system 8:5,
32 : 19
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Meeting Index: team..unacceptable
46 : 23
49:8,9,11
team 34:7
technologies
58 :3, 7
technology
24:23,24
25:3,15
58:4
temperature
5 : 17
tenant 10:6
44:24 45:3
46:19 47:9
48 : 6
tenants
39 :4,13
44 : 18
47:5,13
48:1,10
tend 2 0:15
term 14:22
30 : 13
51 : 20
terms 13:16
22:23,24
24:7,8
27 : 21
44:10 45:5
49:1,3,25
test 9:17
10:19,23
40:24
41:12 55:4
tested 6:12
39 : 23,24
40:20
41 : 16
42 : 21
45 : 16
testing
23:15,18
26:4,5
41:10
45:22 46:4
50:23 55:2
56:3
tests 22:8,
22,25
tetrachloroeth
ylene 5:13
6:2 13 : 9
thing 19:22,
25 30:9
39:22
48 : 13,18
50:21 53:7
56:3
things 2 0:23
40
43
54
59
16
8, 12
8 55:24
11
thoughts
18:6 60:6
three-day
8:21
threshold
14 : 15
22 : 20
23 : 20
28 : 21
thresholds
30 : 23 42:6
51 : 1
tied 21:18
time 4 : 6
8:23 11:6
20:19,20
21:7 26:8
28 : 16
33 : 11
35 : 14,16
36:3 39:2
40 : 16,17
41:10,17
43 : 2 50 : 12
51 : 21
53:14,15
56 : 1
timeline
26:3
52 : 16,17
53 : 5
times 58:9
today 4:1,9
5:25 12 : 14
15:4 17:1
25:2 31:7
53 : 15
tonight
29 : 24
top 7 : 5
topic 33:19
touch 16:3
60 : 14
tough 3 5:25
tracks 19:15
51 : 9
traditional
43 : 4
transcribed
18:1 61:4
transcript
61 : 6
tremendous
35 : 23
trichloroethyl
ene 5:12
6:2 13 : 9
true 61:6
trust 54:9,
16
tumors 4 9:10
type 41:4
56 : 19
typical
44 : 17
typically
5:16 8:12,
15,17,18
9:6,8 10:4
21:1 44 : 16
U
unacceptable
29 : 16
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MEEKER AVENUE PLUME SUPERFUND SITE PUBLIC MEETING
Meeting Index: understand..widespread
understand
40:22
vast 2 9:17
vulnerability
ISJ
00
ISJ
ISJ
ISJ
59:16,25
VAUGHN 19:12
42 : 9
49 : 23 50:6
update 10:7
21 : 19
vulnerable
understandable
28 : 15
22 : 13
42 : 11,14
50 : 5
upstairs
27:3,6,9
unders tanding
43 :3
30:9,11
W
49:5 50:12
utility 8 : 1
36:23 37:1
51:6 52 : 5,
wanted 6:23
Understood
7,20 54 : 18
11:9 13:16
45 : 5
V
58:18,22,
20:3 33:19
UNIDENTIFIED
25 59:4,7,
38:4 46:7
18:8,12,
values 4 6:22
10 60:17
56 : 24
wanting 3 6:2
15,23 19:2
vented 3 8:1
warmer 55:2,
33 : 18
vapor 4:3,4,
35 : 11
10,14,15,
ventilation
5
36 : 9,15,20
18 5:11,
8 : 16
warranted
37:10
12,14,25
venting
33 : 13
38:17,19,
6:20,22
43 : 13,19
warrants
24 47:14,
7:9,21,22,
vents 15:20
54 : 13
16,19
24 8:3,8,
48:5,11,21
11,13,18
VI 8:11
ways 12:8
49 : 18
9 :12,21
Vichnevsky
weather
50 : 18
10:7 11:5
20:5,6
55 :3,5
55:1,18
13:4,10
21:4,9
website 17:6
56:12,23
14:1,8
22:6,11,15
57:8,10,
15:10 16:4
53:7,17,
week 2 9:12
11,25
31:9,12
19,25 54 : 5
weekends
58:21,23
46:20
vicinity
43 : 3
50:25 57:5
59:2,5,9
60:5
59 : 5
24 :3
weighted
Video 60:18
14 : 25
vapors 8:11,
unintentional
wells 23:18,
view 17:5
7:16
17 9:7
50:4 59:11
25 52:25
unique 3 7:18
13:8,13
15:20,21
volatile
whatnot 24:1
unit 45:8
51 : 5
5:8,15,20
widespread
United 57:20
varied 43:15
6:9 7:13,
40 : 5
units 3 6:13
14 , 17
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Meeting Index: Williamsburg..zone
Williamsburg
48 : 16
56 : 20
5:3
Willis 2 8:18
55 : 23
56 : 10
years 13:23
16:2 28:4
29 : 23
57:18,19
37:7 41:16
50 : 11
workday
53 : 2 54 : 2
Willis 1s
13 : 24
yellow 7 : 4
48:22 50:2
worked 3 5:20
York 5 : 4
window 43:24
46:18 47:8
6:6 26:22
windows 8:15
workers
31 : 11,12,
55 :3
43:10,11
23 46:17,
winter 8:13
10:18,22
35 : 17
working 4:22
8:10 10:8,
14 13:3
19,22
47 : 24
59 : 12
55 : 9,11,
19:19
you-all 4 : 7
12,16,21
27:23 33:4
20 : 11
56 : 9
50:22
39 : 23
Wolff-alport
7:7 27:19
workplace
29 : 14
48 : 25
55 : 23
60 : 10
women 13:21
42 : 16
works 9:18
20:8 27:15
young 13:21
wondered
writing 3 0:6
Z
34 : 12
48 : 24
wondering
23:4 42:13
written 3 0:3
33 : 15
zone 2 9:18
word 21:2
wrong 52:21
35 : 22
41 : 13
Y
work 11:22
Yarborough
20:6,21
61:3
26:1 27:17
28:19 32:4
36:1,2
39:21
42 : 16
year 13:23
37 : 13
39:25
40:20
52 : 10
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