INTERACTION
MEDIA GROUNDWATER
DIRECT EXPOSURE PATHWAY
RECEPTOR
z
INGESTION BY RESIDENTS WHO USE PRIVATE WELLS FOR POTABLE WATER SUPPLY INHALATION OF VOLATILES STRIPPED FROM THE DRINKING WATER DURING IN-HOME USES SUCH AS BATHING AND COOKING
--- DERMAL CONTACT WITH CONTAMINATED GROUNDWATER FROM RESIDENTS PRIVATE WELLS
o
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Z
o
ft: o
00
SOIL
INGESTION OF CONTAMINATED SOIL BY ONSITE WORKERS
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DERMAL CONTACT WITH CONTAMINATED SOIL BY ONSITE WORKERS
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INHALATION BY ONSITE WORKERS OF VOLATILES IN SOIL GAS RELEASED TO THE ATMOSPHERE
RQURE 2-5 EXPOSURE PATHWAY AND RECBTOR SUMMARY
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PHOENIX GOODYEAR AIRPORT ROD
INORGANIC COMPOUNDS
This group of compounds includes metals. Some of the inorganic compounds detected at the PGA site, such as chromium, are much more toxic than others.
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Chromium has been identified in some water samples taken from the site in both the trivalent and hexavalent states. Chromium compounds in the trivalent (+3) state are of a low order of toxicity. In the hexavalent (+6) state, chromium compounds are irritants and corrosive and can enter the body by ingestion, inhalation, and through the skin (Sittig, 1981). Hexavalent chromium may cause liver and kidney damage, internal bleeding, and respiratory disorders (U.S. EPA, 1985b). Hexavalent chromium has been designated by the CAG as a human carcinogen (Group A) via the inhalation route (U.S. EPA, 1989).
RISK ^
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Risk is a function of both exposure and toxicity. At present, the exposure to contaminated groundwater is limited,
and the population and environment are not in any immediate danger. However, future use of contaminated groundwater will result in increased risks as shown in Table 2-3.
The risk associated with exposures to contaminated groundwater through drinking water ingestion, particularly for future use scenarios, is an estimated excess lifetime cancer risk. The overall future residential risk resulting from groundwater exposure could be as much as 4 x 10"3 to 9 x 10"4 based on the maximum-reported and average concentrations of carcinogens detected in groundwater at the site. For the northern portion of the site, the estimated excess lifetime cancer risk could go as high as 1 x 10"1 (one excess lifetime cancer occurrence per 10 people exposed over the course of a 70-year lifetime) based on the maximum reported TCE concentration in groundwater at the UniDynamics facility. For the southern portion of the site, the estimated excess lifetime cancer risk as a result of groundwater ingestion could go as high as 1 x 10"4 (one excess lifetime cancer occurrence per 10,000 people exposed over the course of a 70-year lifetime) based on the maximum reported TCE concentration in
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groundwater. Also for the southern portion of the site, the 1
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Table 2-3
SUMMARY OF EXPOSURE ROUTES AND RISKS
Medium Groundwater
Exposure Setting Residential--Current and
Exposure Risk
Results o For the Goodyear municipal wells (COG #1, 2, 3, and 6) there is an estimated excess lifetime cancer risk of 2 x 10"" based on the maximum trichloroethylene concentration for these wells. There is no identified ingestion risk due to noncarcinogens. o For the private domestic wells PLUMB, SHAWVER, and DOMEST3, the risk due to trichloroethylene contamination of these wells can only be expressed qualitatively because fewer than three samples were collected from each well. A carcinogenic health risk may be present; however, the exact nature of the risk cannot be identified. There is no identified ingestion risk due to noncarcinogens from these wells.
Ingestion Potential Uses
Inhalation
o The risk from inhalation of volatiles released from the groundwater in the course of in-home uses such as cooking, bathing, etc., cannot be quantified. However, it should be recognized that this exposure could contribute to the overall risk from the use of contaminated groundwater.
o The estimated excess lifetime cancer risk from ingestion of ground water from the Unidynamics' monitoring wells presents the most significant risk values for the site that could be as much as 1 x 10^ based on the maximum concentration of trichloroethylene. There is no identified ingestion risk due to noncarcinogens from these wells.
o The GAC monitoring wells follow with estimated excess lifetime
Residential--Potential Use Only
Ingestion
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I
cancer risks that could be as high as 2 x 10"5 for carbon tetrachloride, 3 x 10"5 for chloroform, and 5 x 10"5 for trichloroethylene, all based on the maximum concentration of each constituent from the three wells. The daily intake of chromium in groundwater exceeded the AIC, RfD, and/or AIS value for ingestion exposures based on concentrations in 16GMW-1 and 16GMW-3. For other non carcinogens evaluated, there does not appear to be an ingestion risk based on the limited available data.
o For the EPA monitoring wells for which enough data exist to quanUse
tify estimated risks, there is an estimated excess lifetime cancer
risk that could be as high as 1 x 10"4 for trichloroethylene, based on its maximum concentration, due to exposure through ingestion of groundwater. The daily intake of chromium in groundwater exceeded the AIC, RfD, and/or AIS value for ingestion exposures based on con centrations in 16EMW-3. For other noncarcinogens evaluated there does not appear to be an ingestion risk based on the limited avail able data.
o For EPA Phase II monitoring wells, groundwater data are limited to two or three sampling rounds; therefore, risks were described qualitatively. All of these wells exhibited lead concentrations that
exceeded the current or proposed MCL.
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Table 2-3 (continued) Medium Groundwater (cont'd) Exposure Setting Exposure Risk Results Other wells in the area that presented an estimated excess lifetime cancer risk due to trichloroethyletie include the following: GAG GAG PLA PLA #3: 3 X #4: IX #2: IX #3: 1 x iQ based 10 based 10 based 10"** based on on on on the the the the maximum maximum maximum maximum concentration concentration concentration concentration
There was also an estimated excess lifetime cancer risk that could be as much as 6 x 10 for COG #5 (fire control well) due to the maximum concentration of arsenic. There is no identified Ingestion risk due to noncarcinogens from these wells. The risk from inhalation of volatiles released from the groundwater in the course of in-home uses such as cooking, bathing, etc., cannot be quantified. However, it should be recognized that this exposure could contribute to the overall risk from the use of contaminated* groundwater.
Air
K)
Occupational--Current and Potential Uses
Inhalation
I
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Based on inhalation of volatiles emitted from the onsite soil and an 8-hour exposure period, the estimated excess lifetime cancer risk for all compounds with a cancer potency factor for inhalation exposures considered could be as much as 1 x 10"^ to 2 x 10"^. There is no known inhalation risk as a result of Inhalation exposure to the noncarcinogens considered in the evaluation.
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I I I I I I I I I I I I I I I I I I I
daily intake of chromium in groundwater exceeded the acceptable intake-chronic, the reference dose, and/or the acceptable intake-subchronic values for ingestion exposures, assuming chromium is in the hexavalent species.
The Arizona Department o£ Water Resources (ADWR) used a groundwater model to predict the effect on TCE concentrations based on a number of scenarios under the no action alternative. These scenarios, or base cases, are:
o
Base Case 1--Continued agricultural pumpage at 1985 levels in addition to full implementation of City of Goodyear proposed wells. Section 16 Operable Unit not incorporated.
o
Base Case 2--Pumpage and recharge assumed to remain constant at 1985 rates over modeling run. Section 16 Operable Unit incorporated.
Base Case 3--Phase in City of Goodyear's projected production wells per the City of Goodyear's Water Master Plan. Phase out agricultural pumpage and recharge. Section 16 Operable Unit incorporated.
o
Trichloroethylene (TCE) concentrations were estimated for areas adjacent to selected municipal wells using the ADWR model. Table 2-4 presents the estimated TCE concentrations and the associated excess lifetime cancer risks as a result ' of ingestion of groundwater with the respective TCE concentration.
The estimated excess lifetime cancer risk as a result of TCE exposure through ingestion given the assumptions defined above could be as much as 3 x 10"6 for the highest estimated concentration. This particular evaluation does not consider the effect of exposure to other contaminants detected in groundwater at the PGA site and therefore may underestimate the total risk. This assessment also only considers exposures through ingestion; however, additional exposures may be anticipated through inhalation of volatiles as a result of in-home uses of groundwater and exposures through dermal contact with the contaminated groundwater.
For the southern portion of the site, the inhalation risk to onsite workers as a result of volatile emissions from soil could be as much as 1 x 10"4 to 2 x 10's (8-hour exposure) based on all volatile compounds detected with a cancer
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Table 2-4
--
ESTIMATED EXCESS LIFETIME CANCER RISK DUE TO TCE EXPOSURE BASED ON IMPLEMENTING THE NO ACTION ALTERNATIVE3
Estimated Well ID COS School District COG 2 COG 3 COG 8 COG 11 COG PW 1 COG PW 2 COG PW 3 COG PW 4 COG PW 5 COG PW 6 COG PW 7
Base Case 1 TCE Cone. (Jls/1)
Excess Cancer Riskb
_c
<3 x 10-7 ._ 7 <3 x 103 X 10-6 ._.
Lifetime
Base Case 2
TCE Cone.
(tte/1)
0 <1 0 <1 40 . __ --_ __ __ __ __ --
Base Case 3 TCE Cone. (Ug/1) Cancer Risk"
<3 x 10-7 ,-7 <3 x 10
Estimated Excess Lifetime
Cancer Riskb
Estimated Excess Lifetime
0 <1 0
,-7 <3 x 10 11 0 ,-7 <3 x 10 3 x <3 <3 <3 <3 6 <3
x 10 x 10 x IO x 10"; x 1' 0° x 10"'
1 x
<1.0 1.7
<1.0 <1.0 3.4
<1.0
<3 5 <3 <3 1 <3
X X X X
X
X
10-7 10-7 10-7 10-7 10-6 10-7
1.9
Based on the level of TCE (|lg/l remaining in groundwater adjacent to selected municipal wells. Based on the following assumptions: LA.WI = 0.029 1/kg/day.
-- = Data not available.
2 Ifday intake; 70 kg bodyweightj 70-year exposure duration;
potency factor for inhalation. Likewise, based on air samples collected in upwind areas, the inhalation risk to onsite workers could be as much as 2 x 10"s based on an 8hour daily exposure over the course of a work lifetime.
More information on health effects associated with contaminants found at the PGA site can be found in Appendix R of the PGA RI/FS Report.
CLEANUP LEVELS AND APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
As part of the final remedy, EPA is setting cleanup levels for the soils and groundwater at the PGA site. Cleanup levels are set by considering the statutory factors set forth in CERCLA Section 121. In particular, determining cleanup levels requires compliance with CERCLA Section 121(d). This requires, at a minimum, that the remedial action "attain a degree of cleanup...which assures protection of human health and the environment...." CERCLA Section 121(d)(l). Moreover, cleanup standards must comply with
standards under Federal environmental laws and more stringent, promulgated standards under State laws which are "legally applicable...(or are) relevant and appropriate
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under the circumstances...." CERCLA Section 121(d)(2). Applicable or relevant and appropriate requirements (ARARs) may be waived at the discretion of EPA if criteria set forth in CERCLA Section 121(d)(4) are met. For this remedial action, it is appropriate to set cleanup levels for soils and groundwater. For groundwater, EPA performed independent analyses of appropriate cleanup level for Subunit A and Subunit B/C because of different, sitespecific, groundwater quality concerns.
Soils
EPA has identified no chemical-specific ARARs defining cleanup levels for soils at either the northern or southern portions of the site. EPA is setting its cleanup level for soils based on the need to protect human health and the environment from the contamination of groundwater (both Subunits A and B/C) which would result without a cleanup of soils.
EPA's soil cleanup standard for volatile organic compounds is to remove those contaminants from the soil until EPA is convinced the levels remaining will not cause or contribute to the contamination of groundwater in levels in excess of the cleanup standards for groundwater discussed below. The volume of contaminants to remain in the soil will be determined using a decision-tree that was developed by the PGA Committee members. This decision-tree will be used in the implementation of the remedial action.
For chromium and other metal contamination in the sludge pits on the southern portion of the PGA site, EPA will set final cleanup levels through an administrative order to Goodyear Tire and Rubber Company. This order will require Goodyear to remove metals to level sufficient to ensure that the soils will not be a source of contamination to the groundwater in excess of the cleanup standards for groundwater discussed below.
Groundwater
For both Subunits A and B/C of the PGA site, EPA is establishing cleanup levels as set forth in Table 2-5. These cleanup levels are to be met throughout the aquifer.
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Table 2-5
LEGALLY APPLICABLE STATE AND FEDERAL REQUIREMENTS AND OTHER CRITERIA FOR GROUNDWATER
(Concentrations ±n pig/1)
Compound
Legally Applicable SDWA MCL 7 100
Other Criteria
ADEQ
AWQC--_Drinking Water Only Cancer 10'" Risk Toxicity
0.033 0.19 15,000 2.8
Action Level Water
Proposed MCL
5 200
Cleanup Level 7 1 100
340 5 1 5 1 170 440 1.46 50 1,000 0.0039 10 50 50 2 15.4 10 50 5,000
1.1-Dichloroethylene
1.2-Dichloropropane Chloroform Toluene Trichlo roe thylene
1 1 3
340 5 1 5 1 170 440
5 5
TrIchlo ro fluoromethane
Carbon Tetrachloride
Methylene Chloride Methyl Ethyl Ketone
Xylenes Antimony Arsenic Barium Beryllium
1.46 50 1,000 10 50 50 2 10 50 10 50 50 10 15.4 10 50 5,000
170 0.0025 0.0039
10,000 5,000 5,000 5 100 5 50
to
Cadmium Chromium
Lead Mercury Nickel
I
to
K)
Selenium
Silver Zinc Notes:
ADEQ = Arizona Department of Environmental Quality. AWQC = Ambient Water Quality Criteria; adjusted for consumption of AWQC (10"6) = The Ambient Water Quality Criteria resulting in a 10"6 excess
drinking water only; fish ingestion component removed (U.S. EPA, 1986), lifetime cancer risk (U.S. EPA, 1986).
MCL = Maximum Contaminant Level. MCLG Maximum Contaminant Level Goal. SDWA Safe Drinking Water Act, 40 CFR 141, November 15, 1985,
Source:
U.S. EPA, 1987. IRIS Database. ad Proposed MCLs - Federal Register, May 22, 1989.
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I I I I I I I I I I I I I I I I I I I
Subunit B/C
Subunit B/C is a potential source o£ drinking water, and therefore it is relevant and appropriate to use maximum contaminant levels (MCLs) set pursuant to the Safe Drinking Water Act as cleanup levels for contaminants covered by MCLs. This approach is consistent with Arizona law (discussed in more detail below) which establishes the MCLs are to be used as aquifer water quality standards as part of the process for defining aquifer cleanup levels. Health-
based levels are designed as cleanup levels where they are more stringent than MCLs or where no MCL exists for a contaminant .
Subunit A
Subunit A is not a potential source of drinking water as defined by the Safe Drinking Water Act and EPA's Groundwater Protection Strategy because of its elevated levels of total dissolved solids and nitrates. Because of this, the Safe Drinking Water Act is not a basis for cleanup levels in Subunit A. EPA's determination of cleanup levels in Subunit A is based on the statutory requirement that cleanup levels protect human health and the environment, RCRA corrective action requirements, and Arizona cleanup standards. Each of these criteria result in the cleanup levels in Table 2-5 applying in Subunit A. As discussed below, further analysis, at least possibly, could result in some modification to EPA's determination of cleanup levels based on the above three criteria. In such event, in setting cleanup levels, EPA would also consider the statutory preference for treatment remedies which permanently and significantly reduce the volume, toxicity, or mobility of contaminants.
Protection of Subunit B/C
The cleanup levels in Table 2-5 for Subunit A are necessary to prevent the migration of contaminants to Subunit B/C at levels in excess of health-based levels and ARARs. UniDynamics, Inc., has contended that higher cleanup levels could be set for Subunit A while still protecting Subunit B/C. However, UniDynamics has not, to date, established a basis for any levels other than those set forth in Table 2-5. Should EPA determine that other levels are appropriate to protect Subunit B/C, EPA would consider revising the cleanup levels in the ROD. However, such a revision would have to be consistent with EPA's ARARs determinations discussed below.
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1
RCRA Corrective Action RCRA's corrective action requirements are relevant and appropriate to setting the cleanup levels for Subunit A. Pursuant to RCRA and its implementing regulations, corrective action requires compliance with MCLs established pursuant to RCRA at the boundary of the unit. Where RCRA MCLs are not available, EPA applies Safe Drinking Water Act MCLs and health-based limits as the alternate concentration limit (ACL) for contaminants covered by those MCLs and health-based limits. In an appropriate case, EPA can allow different ACLs to apply if EPA determines that the hazardous constituent will not pose a substantial present or potential hazard to human health or the environment as long as the ACL is not exceeded. As applied to this case, EPA is setting the levels in Table 2-5 as the ACLs for Subunit A. The point of compliance for these ACLs is the boundary of the locations into which the contaminants were released; e.g., the boundaries of the disposal pits, extending vertically through Subunit A. These ACLs apply unless EPA determines that the substantive requirements for different ACLs are satisfied. These substantive requirements are set forth at 40 CFR Section 264.94(b),(c). · · j| <· ||
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Arizona Law
Arizona law establishes a comprehensive scheme for classifying and protecting aquifers. Portions of this scheme are relevant and appropriate in defining the cleanup levels for Subunit A. Under Arizona law, Subunit A is classified for drinking water protected use, and is subject to aquifer water quality standards. These standards include MCLs established pursuant to the Safe Drinking Water Act. Arizona law also establishes statutory and regulatory requirements governing the selection of cleanup remedies for contaminated aquifers. EPA believes that the Arizona groundwater classification scheme, as applied through the Arizona statutory and regulatory criteria for selection of cleanup remedies, is relevant and appropriate to the setting of cleanup levels. As applied here, Subunit A is protected for drinking water uses because it is part of a definable aquifer and has not received an aquifer exemption. Therefore, Safe Drinking Water Act MCLs are water quality standards for Subunit A. Pursuant to Arizona law, cleanups must achieve the maximum protection of drinking water (i.e., compliance with aquifer
1
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water quality standards) consistent with the other requirements for selection of remedial actions.
EPA interprets this requirement here to require the cleanup of Subunit A to achieve MCLs unless that is not costeffective; not reasonable and necessary to prevent, minimize, or mitigate danger to public health or welfare or to the environment; or inconsistent with other relevant aspects
of Arizona water law. In this case, EPA determines that complying with MCLs is cost-effective, is reasonable and necessary to prevent, minimize, or mitigate danger to public
health, welfare, and the environment, and can be achieved consistent with relevant Arizona water law. Therefore, MCLs are ARARs for Subunit A throughout the subunit, unless Subunit A qualifies for an aquifer exemption, or EPA has reason to alter its determination as to whether achieving such levels is cost-effective, reasonable and necessary, or achievable consistent with Arizona water law.
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3.
ENFORCEMENT HISTORY
PHOENIX-GOODYEAR AIRPORT AND FORMER GAG FACILITY
The responsible parties identified for the PGA site are: o Goodyear Tire and Rubber Company for activities at the former Goodyear Aerospace Corporation facility. The facility has been sold to the Loral Corporation, who has not been named a responsible party.
o
United States Department of Defense, on behalf of the United States Navy who operated the Litchfield Naval Air Base. The Litchfield Naval Air Base was sold to the City of Phoenix in 1968 and is now the Phoenix-Goodyear Municipal Airport.
UniDynamics Phoenix Incorporated for activities at its facility.
o
The remedial actions for the south half of the site, the Phoenix-Goodyear Airport and former GAG facility, will be the responsibility of the Goodyear Tire and Rubber Company and the Department of Defense. Goodyear Tire and Rubber has been participating in the RI/FS since 1984. Its efforts have been concentrated on determining the extent of soil contamination at the former GAG facility and the extent of groundwater contamination underneath the facility and the airport. A history of EPA enforcement actions toward Goodyear Tire and Rubber includes: o July 23, 1982--RCRA Section 3007/CERCLA Section 104 request for information issued to Goodyear Tire and Rubber
o
o
March 27, 1984--General notice letter sent to Goodyear Tire and Rubber from EPA
March 27, 1984--RCRA Section 3013/CERCLA Section 106 Administrative Order on Consent issued to Goodyear Tire and Rubber
December 20, 1984--Violation of the Clean Water Act issued to Goodyear Tire and Rubber from EPA
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January 14, 1986--Violation of the Clean Water Act issued to Goodyear Tire and Rubber from EPA
Order on Consent signed by Goodyear Tire and Rubber and EPA
April 22, 1987--CERCLA Section 106 Administrative Order for the implementation of the Section 16 groundwater remedial action--The order was prepared during negotiation of the Consent Decree for the remedial action but was not issued.
« _ ]· TM
1987--Sidebar agreement between Goodyear Tire and Rubber Company and the Department of Defense for the Section 16 groundwater remedial action--This agreement was a result of the alternative dispute resolution (ADR) process, and apportioned the financial contributions of the two responsible parties.
o 1988--CERCLA Consent Decree between U.S. EPA and Goodyear Tire and Rubber Company for the Section 16 groundwater remedial action
II
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Between 1945 and 1968, the U.S. Navy operated the Litchfield Park Naval Air facility adjacent to the GAG facility. The Navy had sold the Naval Air facility to the City of Phoenix in 1968 for use as a municipal airport. The U.S. Corps of Engineers was assigned in May 1985 to represent the Department of Defense on the Phoenix-Goodyear Airport Interagency Committee, which was established by EPA to involve state and local agencies as well as responsible parties in CERCLA actions at the site.
UNIDYNAMICS PHOENIX. INC.
ft ft
11 ft
A history of EPA enforcement actions toward UniDynamics Phoenix, Inc., includes:
o 1986--RCRA Section 3013/CERCLA Section 106 Administrative Order on Consent was issued to UniDynamics Phoenix, Inc., from EPA (Docket No. 86-02).
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o
July 30, 1987--A Supplemental Order was issued to UniDynamics Phoenix, Inc., from EPA under RCRA
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Section 3013 for installation of additional monitoring wells and collection of soil samples (Docket No. 86-02). February 6, 1989--An Order was issued to UniDynamics Phoenix, Inc., from EPA under CERCLA Section 106, for submission of an RI/FS report (Docket No. 89-04).
May 5, 1989--Finding of violation of the terms of Order 89-04 was issued February 6, 1989. UniDynamics resubmitted the required deliverables to correct the deficiencies which caused the finding of violation.
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4.
COMMUNITY RELATIONS HISTORY
The following is a list of community relations activities conducted by the U.S. EPA at the PGA Superfund site (formerly the Litchfield Airport Area site):
o
EPA conducted interviews with Goodyear and , Avondale residents and State and local officials in 1984 to improve EPA's understanding of community concerns. These interviews provided the basis for the Phoenix-Litchfield Airport Area Community Relations Plan .released in October 1984.
o
EPA established information repositories at the Avondale Public Library, Phoenix Public Library, and the Arizona Department of Health Services. EPA updated repositories periodically with factsheets and other relevant documents.
EPA established a computerized mailing list with over 200 addresses of interested individuals.
o
o
EPA contributed PGA-related information to Groundwater Quality Update, a newsletter that provides information about groundwater quality to interested parties, prepared and distributed by the Arizona Department of Health Services. EPA distributed a factsheet in July 1984 which provided an overview of the Superfund process, gave a brief description of the PGA site contamination, and described proposed remedial investigation/feasibility study (RI/FS) activities. EPA held a community meeting on August 1, 1984, to provide an overview of the Superfund process and information on past site activities and outline future RI/FS activities. EPA distributed an "Update on Site Activities" factsheet in February 1985 which described ongoing RI/FS activities including water level measurement and water quality sampling, soil boring and sampling, well installation, and computer modeling. EPA released the "Water and Soil Sample Results" factsheet in June 1985which reported the results
o
o
o
o
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of the soil and water sampling, and discussed how this information would be used in the second phase of the RI/FS.
o EPA held a community meeting on February 19, 1986, to report the Remedial Investigation ( I Phase I R ) results, and to discuss the additional information needed to complete the RI and the plan for obtaining this information during the upcoming RI Phase II activities.
o
EPA sent out a factsheet in January 1987 which provided groundwater sampling results and discussed the Operable Unit Feasibility Study (OUFS). EPA distributed a factsheet in May 1987 announcing the release of the OUFS and the beginning of a public comment period for the study, as well as announcing a community meeting on June 4, 1987.
EPA held a public comment period from June 2, 1987, to July 2, 1987, on the draft OUFS and prepared a responsiveness summary to address the comments received.
EPA announced the public comment period on the draft OUFS and the public meeting with a public notice placed in Goodyear's weekly newspaper Westsider which ran on Thursday, May 28, 1987, and Thursday, June 4, 1987.
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o
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o
EPA distributed a factsheet in October 1987, describing the treatment system proposed for the Section 16 OU. EPA distributed a factsheet in December 1 8 9 8 updating the public on site-related activities. The factsheet included the terms of the agreement finalized with Goodyear Tire and Rubber, the Department of Defense, and EPA concerning cleanup activities for the Section 16 OU.
EPA distributed a factsheet in May 1989 announcing the release of the Feasibility Study and preferred remedy for public comment.
o
o
o
EPA held a public meeting on June 21, 1989, to solicit public input on the RI/FS and preferred remedy.
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o
EPA held a public comment period on the RI/FS report from June 7 to July 7, 1989. A response summary to address the comments received is included as Appendix B of this ROD.
In addition, EPA will continue to conduct ongoing community relations activities at the PGA site throughout the duration
of the remedial action.
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5.
ALTERNATIVES EVALUATION
A range of remedial action alternatives were evaluated for the volatile organic compound (VOC)-contaminated vadose zone and groundwater in Subunit B/C and Subunit A outside of Section 16 in the northern portion of the site. Alternatives were evaluated based on their ability to meet the remedial response objectives.
PHOENIX-GOODYEAR AIRPORT AND THE FORMER GAG FACILITY
The soil and vadose zone investigations identified two problem areas:
o
I I I I I I 1 I I I I I
VOC-contaminated soils on the Phoenix-Goodyear Airport and former Goodyear Aerospace Corporation (GAG) facility Contaminated soils associated with the former chromium sludge beds
o
Chromium-contaminated soils were not considered in this evaluation since Goodyear Tire and Rubber will perform the remedial action for the chromium-contaminated soil under an Administrative Order on Consent.
A wide range of technologies was identified for VOCcontaminated soil. The remedial response objectives for contaminated soil are to:
o
o
Protect public health and the environment from exposure to VOC-contaminated soil
Prevent migration of VOCs that would result in concentrations in the groundwater exceeding the requirements of the Section 16 Record of Decision and the requirements of this sitewide Record of Decision
The areas of groundwater contamination have been identified as the following:
o
Subunit A plume of TCE and 1,1-dichloroethylene (1,1-DCE). This problem is being addressed in an expedited fashion as the Section 16 Operable Unit, The Operable Unit remedy is consistent with and
5-1
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1
part of the final remedy proposed in this Record of Decision. o Subunit B/C near the former GAG facility and the airport with TCE above ARARs. This includes some City of Goodyear wells. II II *
. _ _ . _ _ _ _ _ . . _ _ _ _ _ _ _ ____ _.__r___ . . _ _ _ _ _ _ _ . _ _ _ . . _ _ . duction wells. One well in particular, the
Phillips well, has exhibited TCE concentrations above ARARs. || p
For groundwater, the technologies were screened on_their ability to satisfy the media-specific remedial response objectives:
ik ||
o
o o
Protect public health and the environment from exposure to contaminated groundwater
Eliminate further migration of contaminated groundwater Restore the quality of the Subunit B/C aquifer with respect to contaminant levels that can be attributed to industrial activities
II
II TM II II
II
||
SOILS
Listing of Alternatives
The soil alternatives for remedial action are:
Excavation and treatment
I
_| II
o
Placement of a RCRA-type multilayer clay and membrane cap and/or an asphaltic concrete cap over contaminated soils
o o
In-place treatment by soil vapor extraction No action
II
._ ness in meeting the remedial response objectives. A range of action levels, determined through analyzing the applicable and relevant or appropriate requirements, was also evaluated for three areas delineated by the level of soil contamination. These target areas are depicted in Figures 5-1 through 5-3. ,
II ||
·· ||
I
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I I I I I I I I f
I
I I I I I I I I I
RDD63605.'R'A MAY" 1989
200
400 FEET
FIGURE 5-1 TARGET AREA 1 FOR SOILS REMEDIAL ACTION AT PHOENIX GOODYEAR AIRPORT AND FORMER GAC FACILITIES
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PHOENIX GOODYEAR AIRPORT ROD
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