1 1 united states environmental … 1 united states environmental protection agency region 6 2 3...
TRANSCRIPT
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1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 6
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3 EAGLE PICHER CAREFREE BATTERIES SUPERFUND SITE
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8 PUBLIC MEETING
June 26, 2014
9 6:15 p.m.
Socorro City Hall
10 111 School of Mines Road
Socorro, New Mexico
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17 REPORTED BY: Mary Abernathy Seal, RDR, CRR, NM CCR 69
Bean & Associates, Inc.
18 Professional Court Reporting Service
201 Third Street, Northwest, Suite 1630
19 Albuquerque, New Mexico 87102
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21 (724L) MAS
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1 A P P E A R A N C E S
2 Mr. Sai Appaji, Remedial Project Manager, U.S. EPA
3 Mr. Jason T. McKinney, Community Involvement
Coordinator, U.S. EPA
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Mr. Sabino Rivera, State Project Manager, New Mexico
5 Environment Department
6 Ms. Phyllis Bustamante, Superfund Oversight Section,
New Mexico Environment Department
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Ms. Paula Schuh, Daniel B. Stephens & Associates
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Ms. Kelly Isaacson, Daniel B. Stephens & Associates
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Mr. Jason Raucci, Daniel B. Stephens & Associates
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Mr. Jay Santillanes, City of Socorro
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Ms. Gina Dello Russo, citizen
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1 MR. McKINNEY: My name is Jason McKinney.
2 I'm the coordinator with EPA for Eagle Picher. This
3 is Sai Appaji. He's the project manager.
4 Go ahead.
5 MR. APPAJI: Good evening. My name is Sai
6 Appaji and I'm the remedial project manager for the
7 Eagle Picher Superfund site. The purpose of our
8 meeting today is to discuss the proposed plan for
9 cleanup of the contamination at the Eagle Picher
10 site. Myself and Sabino Rivera, from the New Mexico
11 Environment Department, will be explaining the site
12 contamination and what we are going to be doing to
13 address the contamination at the site.
14 In my presentation I'm going to be
15 covering the following. I'll talk about the
16 background and history of the site, the
17 contamination present, and the risk assessment that
18 EPA conducted at the site. We'll talk about the
19 remedial alternatives that were evaluated and EPA's
20 preferred alternative for cleanup, and also the next
21 steps we are going to be taking at the site.
22 This slide shows the map that you already
23 have seen over there. The site itself is
24 approximately 55 acres. The red dotted line is the
25 extent of the site, is divided into two parts, two
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1 tracts. On the east is the large tract where the
2 former manufacturing building is located, and some
3 of the other industrial activities that occurred
4 were on that part of the site. And on the western
5 half of the site, there are some old historical
6 facilities. Next slide.
7 Again, this is another map that you have
8 seen over there. That shows the location of the
9 private wells that are on top of the plume. It also
10 shows the extent of the groundwater plume. As you
11 can see, it's fairly large. It's almost 9,000 feet
12 in length and extends all the way from just south of
13 the Eagle Picher site into the New Mexico Tech golf
14 course, and it's approximately 2,000 feet wide at
15 its widest point.
16 The site has a long history. Back in the
17 '30s, the U.S. Government used this site as a
18 Civilian Conservation Corps barracks, then
19 transferred to the New Mexico State, which used it
20 as a tuberculosis sanitarium from the mid-'30s to
21 the mid-'50s.
22 The City of Socorro sold the property to
23 the Eagle Picher company in 1964, and Eagle Picher,
24 from 1964 to 1976, operated a printed circuit board
25 manufacturing facility. Again, in between, there
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1 was jewelry manufacturing that was going on at this
2 facility, and then Eagle Picher again came back, and
3 this time they were manufacturing lead acid
4 batteries, and they operated until about the late
5 1990s.
6 Since then, the company went through
7 bankruptcy and the EPA and the State did an
8 investigation due to the groundwater contamination
9 at the site. So the site was listed on the National
10 Priorities List, or NPL, we call it, as a Superfund
11 site in 2007.
12 Now, what's the problem at the site? We
13 find contamination in various media. You know, we
14 look at contamination in soil, groundwater, and some
15 debris onsite. For example, in the groundwater we
16 find chlorinated solvents commonly used for
17 degreasing operations in industrial factories, such
18 as perchloroethene, or PERC, and daughter products
19 or byproducts of perc such as trichloroethylene,
20 TCE, PCE, and 1,1 dichloroethene, DCE. And we also
21 found some small amounts of 1,4 dioxane which is a
22 solids stabilizer used at industrial facilities.
23 The soil has some contamination from metals such as
24 lead, chromium, and cadmium. Next slide.
25 So like I mentioned, we also found
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1 construction debris scattered throughout the site,
2 primarily from the asbestos-containing building
3 materials from the manufacturing plant and some of
4 the other old facilities. And also some of these
5 old structures contained lead-based paint in the
6 doors and window frames.
7 Now, what's the risk from all this
8 contamination? So when EPA investigates a site for
9 contamination, we also, once we collect the data,
10 will look at the risk to humans and also the
11 environment. So we do a human health risk
12 assessment and an ecological risk assessment. So
13 EPA will look at and collect data from the different
14 media, like the soil, groundwater, and the debris.
15 As for soil, EPA found lead contamination
16 in some areas that exceeded the EPA's screening
17 level for industrial sites. The screening level for
18 lead is 800 parts per million. What does screening
19 level mean? It means that EPA can consider taking
20 action, you know, above that level.
21 Now, EPA also did some blood-level
22 modeling to see if there's any risk to humans from
23 exposure to lead, but there was no risk from
24 exposure to lead through blood.
25 As far as groundwater, EPA looked at the
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1 cancer risk, excess cancer risk, and noncancer risk.
2 When EPA evaluated the groundwater data, we found
3 that the excess cancer risk from the contamination,
4 the groundwater, is within the EPA risk range. I'll
5 talk a little bit about that in the next slide. But
6 one more thing. So the noncancer risk, you know,
7 there are three wells where we found the risk is
8 elevated. But all the residents -- the good thing
9 is that they all have access to safe municipal water
10 supply.
11 So how does EPA evaluate risk? You know,
12 like I said, we look at both excess cancer risk and
13 noncancer risk. So what does excess cancer risk
14 mean? It means the risk above and beyond what
15 people would be normally exposed to from different
16 sources. And it's all expressed as a probability of
17 someone getting cancer from exposure to contaminants
18 at the site. And it's expressed as a probability
19 like 1 in 10,000, or 1 in a million. So that's how
20 the excess cancer risk is expressed.
21 What's noncancer risk? Some examples
22 include rashes, eye irritation, breathing
23 difficulties, organ damage, et cetera. And usually
24 noncancer risk is expressed in terms of a hazard
25 quotient or a number. So if a hazard quotient is
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1 greater than 1, that means it is a possibility of
2 someone being affected by risks from noncancer.
3 We also look at another pathway for human
4 exposure, which is vapor intrusion. So vapor
5 intrusion is when we have contaminants such as the
6 solvents that are highly volatile, and they can get
7 in from the groundwater into the soil. And if there
8 are homes above the groundwater plume, it could
9 enter into homes and people could be exposed to the
10 vapors that are breathed in the home.
11 When we looked at vapor intrusions, it was
12 done through modeling. The excess cancer risk was
13 within the risk range, so there was no risk to any
14 humans or people on the plume. However, there was
15 some -- noncancer risk was elevated based on data
16 from four wells. But we also understand that the
17 risk predicted by this model is slightly -- it
18 overpredicts, so what we intend to do is conduct
19 some additional evaluation to make sure that there
20 is no risk from vapor intrusion.
21 We also conducted an ecological risk
22 assessment, which means looking at risk to any
23 animals or plants onsite. Based on the data
24 collected, there is very low risk throughout the
25 site for any hypothetical animals or plants. There
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1 were no sensitive receptors, which means there were
2 no animals that were sensitive or found onsite.
3 What kind of scenarios do we look at? We
4 look at, you know, what's the current exposure
5 scenarios? You know, are there people living there,
6 or is it an industrial facility, people are working
7 there? Or people who live there? So we look at
8 both current and future risk.
9 And then we look at the different
10 pathways, how people might be exposed. You know, we
11 look at the pathway through ingestion, inhalation of
12 groundwater, including all uses of household, inside
13 a house, such as showering, bathing, cooking, dish
14 washing, and -- cooking would be consumption.
15 Dermal contact with groundwater. We also look at
16 ingestion of fruits and vegetables grown using
17 groundwater, you know, that they use for growing the
18 fruits and vegetables in the yards. And also
19 inhalation of volatile chemicals migrating from
20 groundwater into the homes. Next slide.
21 So what are our goals at the site? So
22 what we want to do is prevent exposure. Obviously,
23 we want to prevent any exposure to people, so with
24 regard to that, for soil, we want to prevent
25 exposure to lead from soils above safe level, we
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1 want to prevent any migration of contaminants from
2 the soil contaminating the groundwater.
3 Construction debris. We want to prevent
4 exposure to asbestos.
5 Groundwater, we want to prevent exposure
6 to contaminants that are above a safe level. We
7 want to restore the groundwater.
8 So that's our ultimate objective, is to
9 clean up the groundwater to safe drinking water
10 levels, and we want to prevent the plume from
11 migrating further. As we have seen, the plume is
12 fairly long and has been moving along. You know, we
13 want to stop the plume from migrating any more.
14 This is kind of a sequence -- this is a
15 continuation of the different scenarios I was
16 talking about. We look at, you know, the future
17 site and we also look at intermittent visitors, such
18 as trespassers who come onsite, what is the risk to
19 any intermittent trespassers. So similar to the
20 current and future residential or industrial
21 scenario, we also look at the different exposure
22 pathways for the trespassers. Next slide.
23 For the next few slides, Sabino will help
24 explain the groundwater contamination of the site.
25 MR. RIVERA: This is a 3-D rendering of a
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1 geological cross-section of the site. To the north,
2 A, that would be the approximate location of the
3 Eagle Picher facility, and to the south, A-prime
4 would be just north of the New Mexico Tech golf
5 course.
6 The aquifer is broken down into three
7 aquifer zones, the shallow water-bearing zone. I
8 wished I had a laser pointer I could use to point it
9 out to you.
10 And then there's the intermediate water
11 bearing zone, right around 4,550 feet mean sea
12 level. And then there's the deep water-bearing
13 zone.
14 As Sai mentioned before, the plume is
15 approximately 9,000 feet long, and 2,000 feet wide.
16 There's two hot spots, and I'm not sure if you can
17 see Ellis East, right towards the beginning of the
18 orange. It almost looks like a shark, a well. Just
19 above that's one of the hot spots, that's a
20 residential well. And just south of that is OMW-7.
21 That's another hot spot.
22 Next slide, please. This is the shallow
23 and intermediate water-bearing zones, and you'll see
24 the two hot spots broken up, just to the north, is
25 the Ellis residential well, and to the south is the
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1 OMW-7. And a groundwater sampling was done in July,
2 October, November, and December of 2013. Next
3 slide.
4 This is the deep water-bearing zone, and
5 the length of the deep zone is 4,550 feet long.
6 Jason, can you help me explain why the
7 deep zone is smaller?
8 MR. RAUCCI: Yes. Sure. Because based on
9 some soil samples collected during drilling and
10 based on -- we had to analyze them. We had some
11 soil samples collected and analyzed for hydraulic
12 conductivity in our soil lab, and we also did
13 lithologic logging of all deep wells that were
14 drilled. And that deeper zone is slightly
15 finer-grained, slightly less, slightly -- it's less
16 well sorted, there's a little bit more fine material
17 in there, which makes it less permeable. It's not
18 tremendously less permeable, but it is less
19 permeable.
20 And so the plume has traveled not quite as
21 far in the deep zone. And we could see that because
22 we have a deep well right in the path of it. Right
23 at the southern extension of that blob there is a
24 deep zone well that is clean. So the length of it
25 is very well-constrained. It really cannot be any
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1 longer than what is shown on that map there. It
2 could actually be shorter than that. That is sort
3 of the maximum extent that is shown on the map.
4 MS. DELLO RUSSO: And this is 200 feet?
5 MR. RIVERA: 200. Jason, can you go back
6 to the -- right there.
7 MR. RAUCCI: You see right there, there's
8 a layer -- I wish I could throw something at it, but
9 there's a layer in the center that is somewhat --
10 I'll just use my finger. How does that sound?
11 MR. McKINNEY: Use that cone right there.
12 That's an extension.
13 MR. RAUCCI: Right there. There's this
14 layer here that is somewhat finer-grained and
15 somewhat less permeable. So the plume just doesn't
16 travel as quickly through it as it does the other
17 subsurface materials.
18 MR. RIVERA: So the shallow aquifer zone
19 right on that hump that you see out there by OMW-1
20 Lopez, the groundwater is around 20 feet, and up in
21 the higher part, the north part, it's around 100
22 feet. Next slide.
23 MR. APPAJI: So now we know -- we look at
24 where the contamination is, the problems, and now
25 we're looking at solutions. How do we deal with
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1 these contaminations? So we do what's called a
2 feasibility study where we look at various
3 alternatives for cleanup for various media.
4 With the Superfund process, we are
5 required to evaluate different alternatives for each
6 media, and one of the alternatives would be what's
7 called a no-action alternative, which is a baseline
8 comparison alternative. It's a requirement like if
9 we didn't do anything, what would be the
10 consequences? So you'll see that no-action
11 alternative for each media.
12 So for soil, you know, we look at three
13 alternatives, S1, S2, and S3. So S1 is the no
14 action.
15 S2 would be consolidate and cap in place.
16 So what that means is, you know, we would excavate
17 all the soil that's contaminated from the site and
18 we would put it in a repository onsite with a cover
19 on it, or a cap, and we would maintain the cap for
20 the long-term.
21 And alternative S3 would be excavation and
22 offsite disposal, which means we would excavate all
23 the contaminated material and then take it offsite
24 for disposal to an approved facility, so that there
25 would be no more contamination onsite left.
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1 Next, for the construction debris, CD1 is
2 no action. And the second alternative would be to
3 remove the contaminants from the buildings and also
4 debris scattered onsite. We would remove all the
5 asbestos and the lead-based paint that's on the
6 ground and also that's exposed in these buildings
7 and we would remove them and dispose offsite.
8 Next slide. For groundwater, we have a
9 number of alternatives, almost seven alternatives.
10 For alternative 1, again, no action. Alternative 2
11 is called a monitored natural attenuation. So
12 what's monitored natural attenuation? It's a
13 natural process by which contaminants in the
14 groundwater are degraded. For example, the bugs in
15 the groundwater and soil consume the contaminants,
16 the solvents, so over a period of time they
17 eventually break down into nontoxic compounds.
18 Initially we had considered the monitored
19 natural attenuation approach for the site, but later
20 we rejected it because the time frame required for
21 this process to occur is significant. So when we
22 look at alternatives, you know, we want to make sure
23 that the cleanup will happen in a reasonable amount
24 of time. And with this type of approach, the time
25 frames involved are fairly long, so that's why we
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1 rejected that.
2 Alternative 3 involves MNA, monitored
3 natural attenuation, with some institutional
4 controls, or ICs. So what are institutional
5 controls? They are nothing but administrative
6 controls. For example, the State Engineer might
7 issue a temporary moratorium, you know, for people
8 not to drill any wells where the groundwater is
9 contaminated in the plume area. Or it could be in
10 the form of a health advisory, advising people not
11 to consume water.
12 The next alternative, GW4, is called ERD,
13 which is enhanced reductive dechlorination, in
14 combination with MNA. And I'm going to talk about
15 that in the next two slides.
16 So the next alternative is pump and treat,
17 with a combination of enhanced reductive
18 dechlorination, monitored natural attenuation, and
19 institutional controls.
20 The sixth alternative is focused pump and
21 treat with hydraulic containment, MNA, and
22 institutional controls.
23 And the seventh alternative is GW6A, the
24 phased focused -- the same as the sixth one, but it
25 will be implementing the remedy in a phased manner.
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1 Next slide.
2 So this map shows the soil and
3 construction debris contamination locations. The
4 red circles you see are where the lead contamination
5 is in the soils. So approximately 1,000 cubic yards
6 of soil contamination is present onsite. And the
7 pink outlined areas are where the construction
8 debris, containing asbestos and the lead paint, is
9 in those areas. Next slide.
10 So these two maps show the conceptual
11 layout of the remedy for the groundwater. So the
12 red lines that you see, there are lateral red lines
13 called the bio barriers. They are nothing but a
14 series of injection wells that are located 25 feet
15 apart along the transects. So what you do is inject
16 carbon substrate, such as vegetable oil or some
17 other proprietary substrate, to treat the
18 groundwater. So as you inject the oil, like
19 vegetable oil, over a period of time and the
20 groundwater moves through the oil, the oil works
21 with the contaminants, breaks it down, and it acts
22 as a source for the bacteria in the groundwater to
23 break down the contaminants. So with this approach,
24 you would have to reinject every so often, like
25 every two years or so, we would have to come back
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1 and reinject over a period of like 20, 30 years.
2 This is the map showing the conceptual
3 layout of the pump-and-treat remedy in combination
4 with some in situ bioremediation. The red box that
5 you see is an area where you would have groundwater
6 extraction wells. We would extract the groundwater
7 and then treat it ex situ, which means we would
8 treat the groundwater first, and then we would
9 dispose of the treated water. So through different
10 ways, we could dispose of that to the city sanitary
11 sewer, or we could even dispose of it to the city
12 water treatment system, or it could even be used for
13 irrigation. So that is something that has not been
14 decided yet. But the water that will be treated
15 will be clean enough for consumption.
16 These two maps show the last, the sixth
17 and the seventh alternatives for groundwater remedy.
18 The one on the left is GW6. It's called the focused
19 pump and treat with hydraulic containment. So in
20 this alternative, we won't have the in situ
21 bioremediation like in the previous one. This would
22 be only pump and treat, so we would have a number of
23 extraction wells. And also there would be two
24 extraction wells at the leading edge of the plume,
25 right down here, to pull the plume back.
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1 The one on the right, the last groundwater
2 alternative, like I said, is the same, except what
3 we would do in this case, we would install these two
4 extraction wells at the leading edge of the plume.
5 After we implement the remedy, we put the three
6 extraction wells in the center of the plume, and the
7 reason is that we want to see how the plume behaves
8 and based on that, you know, if we don't need to
9 install those wells in the leading edge, we may not.
10 Or if it is, we may implement it as it is required.
11 So this is a table showing the approximate
12 cost for the remedies. For the soil remedy, it
13 ranges from the no action, zero, to $1.6 million for
14 the excavation and disposal.
15 For the construction debris, it's fairly
16 small compared to the other remedies. It's
17 $120,000. For groundwater, you know, we have all
18 the way from zero to $16.5 million.
19 So what's the preferred solution? When
20 EPA selects a preferred alternative, we compare all
21 the alternatives based on a number of criteria. We
22 use like nine criteria to compare and see which one
23 is the best solution. So based on that, what we
24 found here was for soil, excavation and offsite
25 disposal is the best alternative. The reason being,
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1 you know, we will achieve our goals, it will meet
2 all the requirements for cleanup, and there's going
3 to be no long-term maintenance required, once you
4 remove and dispose of it offsite, and the risk is
5 eliminated for anyone onsite.
6 For the construction debris, the same
7 thing. Remove all the asbestos-containing materials
8 from the buildings and dispose of it. This will
9 meet our goals. It will meet all the regulations.
10 There won't be any long-term maintenance required,
11 and the risk will be eliminated.
12 And for groundwater, we prefer the last
13 alternative, seventh alternative, which is the
14 phased pump-and-treat approach. This will achieve
15 all of our goals in a reasonable time frame. It
16 will meet EPA's preference for treatment. Whenever
17 we clean up groundwater, we always want to treat the
18 groundwater first rather than just contain, so it
19 does meet our preference for treatment. It will
20 meet all the regulatory requirements, and the
21 capital cost is fairly low, compared to some of the
22 in situ bioremediation alternatives.
23 And I also mentioned at the beginning that
24 we found some small amounts of 1,4 dioxane. So we
25 have a separate treatment for this. 1,4 dioxane is
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1 called an emerging contaminant because it's still
2 fairly new. EPA does not have a limit or a maximum
3 contaminant level, a standard. EPA does not have a
4 standard, unlike the other contaminants. We have a
5 standard for them. So what we have for 1,4 dioxane
6 is what's called an EPA health advisory. And based
7 on the contamination concentrations we have found,
8 they are well below the EPA health advisory levels.
9 But EPA, when we do the cleanup, we go to
10 even more conservative cleanup levels, which means
11 we want to clean up to a level that's really low,
12 like at 6.7 parts per billion is what we are
13 planning to clean this up, if we have cleanup. And
14 this is based on the EPA risk levels. Although EPA
15 we say is 100 parts, 200 parts per billion, it's
16 still within that advisory level, but the cleanup
17 goals are much, much lower than the health advisory
18 levels.
19 So for 1,4 dioxane, the treatment has to
20 be different. The pump and treat and the other
21 alternatives that we have will not clean it up, so
22 we have to have a different treatment system, and
23 this would be through a process called advanced
24 oxidation process. However, we don't anticipate
25 implementing this remedy at this time, because of
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1 the levels we have seen. However, we want to do
2 some additional investigation and if things change,
3 you know, if there is more 1,4 dioxane that we find
4 that we have not already found, then we may
5 incorporate that remedy later. So the cost for this
6 is about $975,000.
7 So this is an illustration of the EPA
8 Superfund process. We start off with preliminary
9 assessment, site investigation. Right at the bottom
10 of the screen you see PA/SI, so this is the point
11 when initially we come across sites where there's
12 contamination, and that point is called a
13 preliminary assessment/site investigation.
14 Once that's complete, you know, if the
15 site qualifies to be a Superfund site, that's when
16 it gets to the NPL listing process. And then once
17 it's listed, we do the remedial investigation and
18 feasibility study. That's what we've just completed
19 at the site.
20 And then the next milestone is called the
21 ROD, or the record of decision. So the record of
22 decision would be the basis for taking action at the
23 site. So what we decide, based on this proposed
24 plan, we would select the remedy, and that remedy
25 will be in the record of decision. So EPA will use
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1 that as the basis for all ongoing cleanup at the
2 site.
3 So once the record of decision is signed,
4 you know, we get into the phase called remedial
5 design and remedial action. So we first design the
6 remedy and then actually construct the remedy. So
7 that will be the construction completion.
8 And then there's construction completion,
9 then we go to a year-long operation in the
10 functional stage where we will make sure that it's
11 operating as it was designed. And then once we
12 achieve the cleanup goals, which in this case, you
13 know, is going to be a long-term, you know, we think
14 it's going to be close to 30 years, so that's when
15 the site will be deleted off the NPL, and then the
16 site can be reused for any other purpose. I mean,
17 even now the site can be used for -- once the
18 surface contamination is all removed, the site can
19 be used for whatever the City intends, as long as
20 they don't use the groundwater, since that will be
21 still undergoing the remediation. But they can
22 reuse the site for any purpose.
23 So what are the next steps in the process?
24 We opened the proposed plan on June 12 for public
25 comments, so we will be accepting public comments
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1 until July 11. People can send comments and also
2 any comments you have today, we can take those
3 comments. And once we receive all the comments, you
4 know, we will use those comments and consult with
5 the State and then select the remedy. So if we get
6 some adverse comments regarding the remedy, then we
7 might propose a different remedy.
8 We plan to issue a record of decision by
9 the end of September of this year, and then the
10 remedial design phase is planned to start sometime
11 in December of this year.
12 Once the design is complete, the remedial
13 action is planned for sometime in 2016. And we
14 anticipate completing construction by September
15 2017.
16 Thank you. So if you have any
17 questions...
18 MS. DELLO RUSSO: So with the soil
19 remediation process, you expect to get 100 percent
20 of all the contaminants out.
21 MR. APPAJI: Yes.
22 MS. DELLO RUSSO: Give me an idea. I know
23 the site has been manipulated in terms of topography
24 and that. What are the soil depths that you're
25 dealing with? Since things have been moved around,
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1 what will be the depth that you'll actually be
2 cleaning or --
3 MR. APPAJI: The soil contamination?
4 MR. RAUCCI: Well, what we did when we did
5 the soil investigation was, we had surficial soil
6 sampling and then we did surficial soil
7 investigation, which is zero to one foot, but we
8 also did subsurface down to five feet at a smaller
9 number of locations, and we found everywhere, except
10 right at the entrance to the building, everywhere
11 else the soil contamination was limited to the first
12 foot.
13 So obviously, we didn't turn the whole
14 site upside down, but we tried to pick locations
15 that seemed likely that had been modified during
16 floods, whether soil deposited or moved or places
17 where things had been dumped, we tried to find
18 locations where it would be likely to find some
19 surface contamination. And with one exception,
20 everything was quite shallow.
21 MR. APPAJI: I should also point out that
22 there's been a lot of investigation that has gone on
23 at this site for a really long time. And the State
24 did some soil sampling in some residential yards
25 years back, so they did not find any soil
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1 contamination in the soils in the yards, so it was
2 all contained within the site.
3 MS. DELLO RUSSO: As to the time frame
4 thing, you're working with the City in terms of what
5 to use the groundwater for?
6 MR. APPAJI: Yes.
7 MS. DELLO RUSSO: I'm sure on other
8 Superfund sites, one of the options for using
9 groundwater was to stabilize the site in terms of
10 restoring native grasses, or kind of at least
11 leaving the footprint of Eagle Picher kind of in
12 better condition than it is now? Is that something
13 that EPA considers would be part of their costs, or
14 would they cost-share with the City on that? Do you
15 know? It may be too early for you to say one way or
16 another, but at least a portion -- I realize it's
17 not a lot of groundwater, but a portion to put onto
18 the site to establish native plants that help
19 stabilize the soil?
20 MR. APPAJI: If the remedy requires any
21 type of, you know, erosion control, then it would be
22 planting and using the water. But otherwise, you
23 know, you wouldn't be using the groundwater for
24 irrigation onsite to develop the property.
25 MS. DELLO RUSSO: The same with like
006678
27
1 changing topography, so that the site is left in a
2 more natural condition than how it is now? Is that
3 something that is usually done by EPA or is that not
4 part of it?
5 MR. APPAJI: If we were to excavate the
6 soils, we would excavate the soils if it was
7 contaminated soils, but we wouldn't do anything to
8 further improve the site conditions. So we would
9 only address the contamination present unless the
10 remedy requires soil to be -- surface soil to be
11 regraded. If it does not, then we won't be doing
12 anything like that.
13 MS. DELLO RUSSO: It's useful for me to
14 understand what the City might be left with in terms
15 of what happens next to the site after you're done
16 with your work.
17 MR. APPAJI: Okay.
18 MR. RIVERA: And we consulted with the
19 City as far as what they foresaw the end use to be,
20 and industrial use was what -- at most they saw it
21 would be used for.
22 MR. APPAJI: One of the things that we do
23 at Superfund sites is what is called reuse planning.
24 So we talk to the stakeholders of the site to see
25 what end use the site might have, you know. If the
006679
28
1 City or other stakeholders are looking to do
2 something else on the site, the EPA would try to
3 partner with the different agencies or bring people
4 together so that that can happen, and that would be
5 taken into consideration when we build a remedy. So
6 that's why we actually had a conversation with the
7 City this last year to find out what the City was
8 planning.
9 So the City, you know, didn't really have
10 any specific plans other than future industrial
11 site. They didn't have any immediate plans. So
12 there was no pressing or any, I guess, demand for
13 the land there. So that's why there was no study
14 done with regard to that.
15 MS. DELLO RUSSO: So not to put you on the
16 spot, Jay, but is the City planning to have like
17 some kind of a forum where people can throw out
18 ideas about what might happen on the site? Because
19 it is kind of the first thing you see when you come
20 into the Socorro valley, and I know past proposals
21 for things to do on the site have met with some
22 opposition by the public. So I was just wondering
23 if the City was planning to have like a forum where
24 neighbors like myself could have some input into
25 what happened next.
006680
29
1 MR. SANTILLANES: Personally I don't think
2 so, unless there's something imminent, something is
3 proposed, because at this point we're not really
4 sure what's going to be done there. We talked about
5 the construction debris. Does that include the
6 building? Does that, you know, I mean --
7 MR. APPAJI: No, it's just construction
8 debris that's scattered. Actually removed asbestos
9 that's exposed. In the Superfund, we are limited in
10 our authority to take action for asbestos, because
11 of the situation, you know, there is a release -- we
12 call it a release, because it's in poor condition,
13 the building materials, so that's why we are taking
14 action.
15 So normally asbestos is something that
16 other agencies actually deal with, so we don't take
17 action. And the only reason is because there's a
18 potential for future release and there is some
19 release already. But as far as actually demolishing
20 the building, we don't have the authority to do
21 that, unless, you know, there is some imminent
22 danger to people, you know, going onsite. At that
23 point it might take action. So we won't do anything
24 with the building itself.
25 MR. SANTILLANES: So until now we really
006681
30
1 didn't know what was happening. Until the site is
2 totally remediated, we will look at that, we
3 probably will demo the building because the building
4 has been pretty much determined to be in poor
5 condition. Eventually we'll demo the building and
6 then the site will probably be available for -- I
7 mean, it is city property that's in a fairly
8 accessible area, so probably we're looking at
9 economic development, some form of that.
10 And prior to that being put in place --
11 because there's nothing in the works for it, but
12 prior to that being put in place, I'm sure there
13 will be some comment period. It depends what
14 time -- if it's an office building, I don't think
15 people will care too much. You know, there are
16 state police offices there. And so it all depends,
17 and we have no plans for it. You know, economic
18 development hasn't been a big push around here
19 because there's not really a work force and that
20 type of thing. There's a whole lot of things that
21 go into play with putting stuff like that together.
22 So in short, we don't have any plans for
23 it, but I would assume there would be some kind
24 of --
25 MS. DELLO RUSSO: Will the public be
006682
31
1 involved?
2 MR. SANTILLANES: Yes, a public meeting or
3 something, when something became imminent, or at
4 least was introduced.
5 MS. DELLO RUSSO: Proposed. Okay, thanks,
6 Jay.
7 Monitoring requirements over time?
8 MR. APPAJI: Yes. So as part of that,
9 monitoring requirements, we will be having a number
10 of monitoring wells around the plume. We will be
11 collecting data. During the design phase we'll be
12 determining how often we have to monitor the wells.
13 But we'll definitely be monitoring the groundwater
14 area.
15 MS. DELLO RUSSO: The plume starts below
16 the flood control there. Do you assume that the
17 plume, you know, actually starts on the site and
18 goes underneath there? Will there be like a time
19 period then where you feel like you have collected
20 everything here, but the lag time for anything that
21 is in the groundwater but coming down -- is that
22 factored in, kind of?
23 MR. APPAJI: Yeah. The groundwater
24 extraction? The system will be designed to pull the
25 entire contaminated plume. So whatever is coming
006683
32
1 upgrade will be pulled, so there won't be any
2 residue of contamination left.
3 MS. DELLO RUSSO: So it's like a cone of
4 depression in the groundwater that pulls things to
5 where you're focusing it, and pumping it out.
6 MR. APPAJI: Right.
7 MS. DELLO RUSSO: Where was the 1,4
8 dioxane found?
9 MR. APPAJI: It was found in three wells.
10 Actually we found it so far in three wells. I don't
11 recall exactly. Ellis East is one I remember.
12 MR. RIVERA: OMW-6.
13 MR. RAUCCI: Is it Ellis East or Ellis
14 West?
15 MR. RIVERA: It was the Ellis West.
16 MS. DELLO RUSSO: And so is that kind of
17 an isolated area or is it --
18 MR. APPAJI: It appears to be, based on
19 the sampling we've done, you know. So 1,4 dioxane
20 was not sampled earlier so we came to know about it
21 only later. So we've done two rounds of sampling,
22 but not very extensive sampling, so what we plan to
23 do in the next couple of months is collect more data
24 from more wells to completely understand the extent
25 of the 1,4 dioxane in the groundwater.
006684
33
1 MS. DELLO RUSSO: And do you expect --
2 kind of a soils or, I guess, chemistry question for
3 you. Do you expect, since there's tighter soils in
4 some of these concentrated -- or where you showed
5 that map of the groundwater, the cross-section of
6 the groundwater, do you expect the soil to have -- I
7 don't know these chemicals at all -- but is there
8 some attraction to tighter soils or do clay lenses,
9 you know, make it harder for you to extract the
10 chemicals out of them, or is there any of that kind
11 of chemistry going on?
12 MR. RAUCCI: Luckily, luckily, the aquifer
13 here is mostly a big sand box. And there's very
14 little organic matter in the aquifer, and that would
15 be the real problem. The organic chemical can
16 absorb onto clays also. There is clay, but it's a
17 very, very minor component of the aquifer. And so
18 yeah, we don't see that there's much potential for
19 these chemicals to adsorb into the soil itself and
20 be left behind residually. Basically it's a bag of
21 marbles and the water flows through it, which is
22 great. That's the good news.
23 MR. APPAJI: That's a good question,
24 because we do find in sites where these
25 contaminations are getting to the clay and it's very
006685
34
1 difficult, first of all, to determine where they
2 are, and then to begin to treat. It takes a very
3 long time, and then many times the remedies don't
4 work. But like this, you know, this site we don't
5 have a problem.
6 MS. DELLO RUSSO: I asked you earlier. Is
7 this considered basically Rio Grande aquifer or
8 soil?
9 MR. RAUCCI: That's a geology question.
10 MS. DELLO RUSSO: I'm switching.
11 MR. RAUCCI: The surficial soils are
12 probably locally derived from the mountains here.
13 But the underlying aquifer soils are Rio Grande
14 sand, yeah, or axial river sand. It's interpreted
15 to say it's the Rio Grande, but just looking at the
16 soil there, it's derived from a large
17 through-flowing river system. So they're quite
18 different in character. You wouldn't have to be a
19 geologist to have a handful of one and a handful of
20 the other and they're quite different.
21 MS. DELLO RUSSO: Yeah. Okay. I think
22 that's all my questions. Thank you for this. I'm
23 glad it's getting attention. Having lived in
24 Escondido now for almost 30 years, it's certainly
25 been a concern for people in Escondido, which
006686
35
1 obviously is not in the direction of the plume, but
2 still pretty near.
3 MR. APPAJI: Thanks for coming and all
4 your questions.
5 MR. SANTILLANES: I do have a couple of
6 questions. On the phased focused pumping that
7 you're looking at doing, you have some dollar
8 figures and stuff, but do you have an estimated flow
9 rate that's required, and a time period for the --
10 MS. ISAACSON: I'm Kelly Isaacson from
11 Daniel B. Stephens. So for the phased pump and
12 treat, the flow rate --
13 MR. SANTILLANES: I'm sorry to interrupt.
14 I'll add a little bit to it. Will the two
15 contaminants be treated through the same process or
16 they will be two different processes?
17 MS. ISAACSON: Okay. So just to clarify
18 your question, two contaminants, do you mean the PCE
19 and TCE, or PCE and the 1,4 dioxane?
20 MR. SANTILLANES: The 1,4.
21 MS. ISAACSON: Okay. The PCE and TCE can
22 get removed by the same process, either air
23 stripping or granulated activated carbon. Those are
24 pretty standard and you know, relatively simple.
25 The 1,4 dioxane is much more difficult to remove
006687
36
1 from the water, so we'll have to do an advanced
2 oxidation process.
3 MR. SANTILLANES: Through the same
4 pumping?
5 MS. ISAACSON: What we would do, yes, we
6 would install the same extraction wells, just
7 basically run all that water through an air
8 stripper, and then we just run it through an AOP
9 skid so it goes boom, boom, and out to wherever it
10 ends up going. But they would be in the same
11 facility and for the most part would all be part of
12 the same deal, just be another step.
13 MR. RAUCCI: What is the advanced
14 oxidation process?
15 MS. ISAACSON: Essentially what it is is,
16 you generate ozone and inject it, and ozone is a
17 very powerful oxidant, and it will get most
18 everything out. So we'll run it through -- the
19 PCE -- or the PCE and TCE we'll treat with
20 air-stripping first, because you can get them out
21 much cheaper by air-stripping, and then we'd just be
22 targeting that 1,4 dioxane through the AOP. It's
23 the kind of thing, in general, you plug-and-play
24 and, you know, it just does its thing and you give
25 it what it needs. But it's much more expensive to
006688
37
1 operate than an air-stripper or gas and probably has
2 a little bit higher maintenance requirements and
3 more high maintenance.
4 MR. RAUCCI: Is that UV you use to make
5 the ozone?
6 MS. ISAACSON: Depends on the vendor.
7 MS. SCHUH: And the rates.
8 MS. ISAACSON: The rates. Back to the
9 rates question. So for focused phased pump and
10 treat, we're looking at, I believe -- and I'll
11 double-check, but I believe the flow rate for that
12 is 350 gallons a minute. Alternative 5 was 420
13 gallons a minute, but the focused one is on the
14 order of 350 gallons a minute.
15 MR. SANTILLANES: And the length of time
16 required, estimated to --
17 MS. ISAACSON: We are looking at on the
18 order of 30 years to --
19 MR. SANTILLANES: Continuous.
20 MS. ISAACSON: -- yes, to bring in the
21 entire plume, or what we're trying to get at, you
22 know, to bring that all into the well. So to answer
23 your earlier question, that time frame considers not
24 only the treatment of it but also trying to bring as
25 of the plume in as possible. "In" is not a good
006689
38
1 word.
2 MR. SANTILLANES: So 350 gallons a
3 minute --
4 MS. ISAACSON: Pretty much all the time.
5 When we do calculations like that, we make
6 assumptions about the number of hours that equipment
7 runs because nothing ever runs full-time. So we'll
8 make some assumptions about downtime for maintenance
9 events or if something goes wrong and you need to
10 fix it, those kinds of things.
11 (A discussion was held off the record.)
12 MR. SANTILLANES: So that's what you need
13 for the City and the -- because how do you handle
14 the State Engineer?
15 MS. ISAACSON: That is really a good
16 question.
17 MR. SANTILLANES: The City and State have
18 water rights, but the need for water is maybe not
19 that critical.
20 MS. ISAACSON: I don't have a definitive
21 answer for you. That is always an issue in a
22 situation like this. It depends on the sites on how
23 you work that issue out. So that will be something
24 that is the kind of thing that will get addressed in
25 the remedial design, for certain, obviously, because
006690
39
1 we're going to have to figure out what we're going
2 to do.
3 MS. BUSTAMANTE: Some possibilities that
4 have been done at other sites where you can get
5 return credit for extracting water is to reinject so
6 that you have clean water. So you reinject it into
7 the aquifer. So that's considered return credits
8 for your extraction. So I don't know how much those
9 possibilities exist at this point, but they're
10 always options.
11 MR. SANTILLANES: Sure.
12 MS. DELLO RUSSO: So there will be this
13 cone. Are you expecting the cone to influence or
14 affect the city wells that are somewhat near where
15 you'll be pumping? That is quite a pumping rate.
16 MS. ISAACSON: It is quite a pumping rate.
17 We have done groundwater modeling. That's how we
18 came up with the 350 gallons a minute. It looked at
19 particle tracking for the aquifer to figure out what
20 we need to use to bring the plume to our treatment.
21 I do not know, off the top of my head, what the
22 impacts were to the nearby production wells.
23 MS. SCHUH: But they were considered --
24 MR. RAUCCI: They are minimal.
25 MS. SCHUH: -- and that's part of our
006691
40
1 modeling.
2 MR. SANTILLANES: We can probably verify
3 that just with the water we pump.
4 MR. RAUCCI: That 350 is cumulative.
5 That's important to know it's cumulative. I forget
6 the number of wells.
7 MS. ISAACSON: In this alternative there
8 are three wells that --
9 MS. SCHUH: Initially.
10 MS. ISAACSON: Yes, three wells initially.
11 MS. DELLA RUSSO: There will be three
12 wells initially?
13 MR. RAUCCI: And then more phased in over
14 time.
15 MS. DELLO RUSSO: If needed or as needed.
16 MR. RAUCCI: But that 350 is cumulative,
17 so there won't be a single well pumping 350. It
18 will be spread out over quite a large area.
19 MS. SCHUH: Which will minimize the impact
20 to any one location.
21 MS. DELLO RUSSO: So going back to the
22 very next cross-section, if your wells are deep
23 enough to capture the bottom of that contamination
24 and you just did like a slope of what you're going
25 to try and pull in, is that how you figure that it
006692
41
1 wouldn't affect the city, because the city was
2 outside of that slope?
3 MS. SCHUH: Yes.
4 MS. DELLO RUSSO: Very good information.
5 MR. APPAJI: Anything else? Anybody else?
6 Well, thank you. Thank you so much for
7 coming. I appreciate all your questions and your
8 interest and comments. So if you have any other
9 concerns or comments, you're welcome to submit them
10 to my e-mail. We have the fact sheet here which has
11 all our information. So you can submit them or if
12 you know anybody else who would like to submit
13 comments, please ask them to submit. Like I said,
14 you'll have until July 11 we'll be taking comments,
15 and after that, we will be looking at all the
16 comments and we will respond to these comments in
17 the record of decision as part of the responsiveness
18 summary.
19 MS. DELLO RUSSO: Are you in contact with
20 the landowners that are certainly directly affected
21 by the project outside of this just public
22 information? Do you have like contact information
23 for them?
24 MR. APPAJI: Yes, the State folks. They
25 have been --
006693
42
1 MR. RIVERA: We do.
2 MR. APPAJI: They have access to many of
3 these properties to actually go and frequently take
4 collect samples. So through them, I think Sabino
5 has been in contact with many of the landowners.
6 MS. DELLO RUSSO: And the site for your
7 facilities has been decided on?
8 MS. SCHUH: That will be decided in the
9 design. But we did take into consideration where
10 the public or the city property is in terms of where
11 we put our treatment center initially. So we tried
12 to get some information based on that preliminarily.
13 But it will have to be finalized.
14 MS. BUSTAMANTE: Thanks, EPA.
15 MR. APPAJI: Thank you.
16 MR. McKINNEY: I have left extra copies
17 here of all the fact sheets and the community
18 involvement plan. I also have some at the library,
19 a lot at the library, so if any of your friends need
20 one --
21 MS. DELLO RUSSO: The library is a great
22 place to put it. There are two libraries, a tech
23 library and the public.
24 MR. McKINNEY: Public, right down here.
25 MR. RIVERA: And the findings of the
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43
1 initial investigation, those copies will be
2 available at the library also, those two reports.
3 (The public meeting concluded at 7:20
4 p.m.)
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006695
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1 STATE OF NEW MEXICO ss
2 COUNTY OF BERNAL ILLO
3
4 REPORTER'S CERTIFICATE
5 I, MARY ABERNATHY SEAL, New Mexico
6 Certified Shorthand Reporter, DO HEREBY CERTIFY that
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8 prior to t he ta k ing of this deposition, and that I
9 did report in stenographic shorthand the proceedings
10 set forth herein, and the foregoing is a true and
11 correct transcr i ption of proceedings .
1 2 I FURTHER CERTIFY that I am neither
13 employed by no r related to any of the parties or
14 attorneys in this case, and that I have no interest
15 whatsoever in the final disposition of this case in
16 any court .
17
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20 ( 7 2 4 L) MAS
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