Stakeholders Forum on Vapor Intrusion

Transcription

1 Stakeholders Forum on Vapor Intrusion Mary Moore Lindon Park Neighborhood Association U.S. EPA Technical Assistance Grant Recipient Motorola 52 nd Street Superfund Site Phoenix, AZ Thank you for the opportunity to speak to you tonight. My name is Mary Moore and I am the Vice-President of the Lindon Park Neighborhood Association (LPNA), a neighborhood association that was formed in August 2001; just about the same time several residents from our area started attending Motorola 52 nd Street Superfund (M52) CAG meetings. By 2003 I had become a CAG member; and in 2004 our neighborhood association applied for and was awarded the U.S. EPA TAG for this Superfund site. 1

2 3 Operable Units (OU1, OU2 & OU3) and the Honeywell 34 th Street Facility Added to NPL in 1989 OU1 Interim Remedy approved in 1988 Boundaries: 52 nd Street to West 7 th Avenue to East Oak Street to North Buckeye Road to South M52 site is > 7 miles wide In 1983 TCE as high as 1,470,000 ppb and TCA as high as 731,000 ppb found in bedrock The M52 site is one of the larger and more complicated Superfund sites in the nation, which includes 3 Operable Units and the Honeywell 34 th Street Facility. At the Honeywell Facility we have a jet fuel plume commingled with the Superfund CVOCs. In our area the OU1 Interim Remedy began operation in Through 2005 an estimated total of 166 lbs of DNAPL and an estimated 17,265 lbs of CVOCs had been removed and 2.5 billion gallons of water pumped and treated. The OU2 Remedy began full operation on December 31, As of May 31, billion gallons of groundwater had been processed at OU2 and 7,926 lbs of CVOCs had been removed. OU3 is designated a study area and is still under investigation. 2

3 Our plume, at times, has been described as being dragon shaped. The Motorola and Honeywell facilities are shown on this map in red. Many of our recent TAG efforts have involved issues associated with the Honeywell jet fuel clean up. ADEQ, as the OU2 lead, determined it was appropriate to let Honeywell proceed with a UST clean up where ADEQ would not have authority over air emissions since the Corrective Action Plan was under UST and authority for the air emissions is delegated to the county. The result has Superfund CVOC air emissions being permitted under a Maricopa County Title V permit modification for a BSVE/Thermal Oxidation system. We fear this will set a nationwide Superfund precedent and may have many unintended consequences. We submitted written comments to Maricopa County on the Title V Permit modification and have filed a Petition to Object with EPA. The Title V Permit application or modification process does not disclose that the CVOCs being permitted are Superfund contaminants and are part of an active Superfund site clean up. 3

4 Several Major Concerns No Vapor Intrusion Investigation nearly five years after being proposed Unwillingness of ADEQ to support any soil sampling in SWPL before redevelopment Clean up of the DNAPL in fractured bedrock and potential for off-site migration Although the M52 site was added to the National Priorities List (NPL) in 1989, 19 years later we still don t have any vapor intrusion studies. In September 2003 the Work Plan for Soil Vapor Intrusion Risk Assessment for the area around OU1 was submitted. In September 2004, a Revised Work Plan was submitted. The process has been stalled for four and one-half years while the parties wait for the methodology to be finalized or for EPA and ADEQ to agree to the process for evaluating the pathway. The community feels this has taken too long and EPA should take the lead in getting the indoor air risk evaluation performed. 4

5 MOTOROLA 52 ND STREET SITE 5005 E. McDowell Rd. Approximately 90-acre campus ~75% of site to be redeveloped Lindon Park Neighborhood is continguous to OU1 along 50 th St. ON Semiconductor now owns the buildings and top one foot of soil Freescale is responsible for the Superfund remediation Brunson-Lee Elementary School is at 1350 N. 48 th Street Balsz Elementary School District Office is at 4825 E. Roosevelt St. The LPNA neighborhood borders OU1 to the west on 50 th Street. The Brunson-Lee Elementary School is on the other side of 48 th Street. ON Semiconductor, which is now the owner of the Motorola 52 nd Street property, is in the process of selling off approximately 70% to 75% of the site for redevelopment. The community feels that development at this site should not be allowed to progress without assessing the risk of indoor air vapor exposure. The developers are buying only the buildings and the top one foot of soil, which ON Semiconductor acquired from Motorola. However, the current proposed redevelopment involves tearing up the SWPL asphalt and building approximately a 90,000 SF 2-story warehouse/office building. This will require a substantial foundation and extensive soil disturbance. The developer is proposing to install a vapor barrier, but there are no mechanisms to require this to happen and it does not address any potential risks to workers or adjacent residents during the construction phase. 5

6 The OU1 site consists of 3 main areas of contamination: the Courtyard area to the north, the Acid Treatment Plant in the middle, and the Southwest Parking Lot to the south. The green area represents the site boundary, and the purple represents the basin fill (vadose zone). The previous aerial map showed that the areas to the west of OU1 are residential with a sensitive use (a K-3 elementary school and Head Start Preschool program) on 48 th Street within about 2 blocks of the site. 6

7 EXPLANATION OF HYDROSTATIGRAPHIC UNITS (HSUs) A Salt River Gravel Deposits: Rounded gravel, cobbles, and boulders in a sandy matrix with minor silt and clay. B Upper Basin Fill Deposits: Interbedded fine and coarse grained unconsolidated sediments. - Fine grained beds are typically sandy silt with clay. - Course grained beds are sand with rounded pebbles, gravel, cobbles, and lesser amounts of silt and clay. D Lower Basin Fill Deposits: Predominantly fine-grained unconsolidated sediments with coarse grained interbeds. - Fine grained beds are typically sandy silt with clay. - Coarse grained beds are sand with rounded pebbles. C Bedrock: Fractured, tilted, and faulted mid-tertiary sedimentary and volcanic rocks and pre-cambrian metamorphic and igneous rocks. The geology under OU1 is made up of basin fill deposits and fractured bedrock. The DNAPL (dense non-aqueous phase liquid) consists of a plume of TCE and TCA. Free product has been detected in OU1 in the bedrock. The main sources for this contamination were a leaking TCA underground storage tank (UST) and a drywell. It was estimated approximately 93,000 gallons of TCE was disposed of in this drywell. The vertical extent of this contamination has not been determined. 7

8 MOTOROLA 52 ND STREET SUPERFUND SITE PHOENIX, ARIZONA SEPTEMBER 2006 TCE CONCENTRATION CONTOURS HYDROSTRATIGRAPHIC SUBUNIT B This slide shows that TCE hot spots of > 500 ppb still exist in OU1 and OU2 in the groundwater. Over the last few years the groundwater levels at the OU2 site have fluctuated several feet or more with the potential for transfer of VOCs from the groundwater to the soil. The community believes that vapor intrusion risk assessments should be conducted in both the OU1 and OU2 areas. 8

9 M o t o r o l a These are pictures of Motorola, the OU1 treatment system and another aerial showing the neighborhood and the Motorola facility. The community feels that when the Fourth Five Year Review comes out it should contain the results from the OU1 vapor intrusion risk assessment, and we strongly encourage EPA to work toward that result. 9

10 Excerpts from Interviews Nadia Hollan, EPA Project Manager the evaluation of the vapor intrusion pathway is an issue and needs to be completed. Karen O Regan, City of Phoenix, Director of Environmental Programs vapor intrusion is a top issue for the City, along with OU3 and the declining water levels. Interviews included in the Third Five Year Review have expressed many of the same concerns that the community has about vapor intrusion risks. In regards to vapor intrusion, Karen O Regan, Director of Environmental Programs for the City of Phoenix, commented that, there aren t any standards and the guidance is controversial and she would appreciate some appropriate guidance on how to handle this issue. 10

11 Excerpts from Interviews Donn Stoltzfus, Environmental Program Specialist, City of Phoenix he would like to see more investment in the removal of DNAPL at OU1. Martha Brietenbach, M52 CAG Member expressed concern over the soil contamination... the sludge in the bedrock is still contaminated and... an outstanding issue. She strongly recommended a more aggressive approach to cleaning up the contamination. Additional community concerns also expressed by interviewees included DNAPL quantification and remediation, clean up of the bedrock contamination and disappointment that there isn t a faster approach to cleaning up the Superfund site. 11

12 Table 3 Actions taken since the Last Five-Year Review for OU1 Issues from Previous Review No confirmatory soil sampling was performed after the shut down of the SVE system within the SWPL area. Recommendations/Follow-up Actions Confirmatory soil samples should be collected in the areas impacted by the SVE system at the SWPL area. Prior to conducting any work, Freescale should submit a work plan to ADEQ. Party Responsible: Freescale Milestone Date: 3/29/2002 Action Taken and Outcome: A No Further Action was issued by ADEQ on November 15, Date of Action: 11/15/2002 The community does not understand ADEQ s reluctance to support our requests for soil gas sampling in the Southwest Parking Lot. We believe there exists enough uncertainty that some further investigation is warranted especially before redevelopment is allowed to proceed. Perhaps there is some confusion due to the inaccuracy of statements about the closeout of the SVE in the SWPL that were included in the Third Five Year Review both in Table 3 and on page 29 in section 5.3 Results of Implemented Actions where it states that, ADEQ determined that soil cleanup in the SWPL Area was complete and issued a No Further Action letter in November

13 Please note that this determination does not provide Motorola a letter of completion under the Soil Rule nor a No Further Action under WQARF The actual November 15, 2002 letter states that due it being uneconomical to continue to operate the SVE system in the SWPL area it meets one of the two closeout requirements under the 1989 Consent Order and there is no further obligation to operate the SVE system. However, the letter very clearly states that this is NOT a No Further Action determination as was requested by Motorola. The community has asked what else might be done? It seems the logical next step would be soil gas sampling in the SWPL area before the asphalt is removed for construction and the foundation dug out. The community needs EPA and ADEQ to investigate the potential for risk in the immediate and adjacent areas since no standards for new construction under these circumstances exist. I hope a little of our frustration is evident tonight. We need action from EPA and the other regulatory bodies on our OU1 vapor intrusion risk assessment and our repeated requests for soil gas sampling in the SWPL area. We cannot afford to be patient any longer. 13

14 Contact Info: Mary Moore Lindon Park Neighborhood Association 1430 N. Fifth St. Phoenix, AZ (mobile) (fax) Motorola 52nd Street Superfund Site Phoenix, AZ Here is my contact information if anyone is interested in following up with us. Please feel free to call me on my mobile or me. Thank you. 14