[CPEO-BIF] Visiting Five Vapor Intrusion Brownfield Sites in New York State

[Lenny Siegel <lennysiegel@gmail.com>]

[To download this report as a formatted 6-page, 1.9 MB PDF file with 
photos, go to http://www.cpeo.org/pubs/NewYork5sites.pdf.]

Five Vapor Intrusion Sites in New York State
Lenny Siegel
August, 2007

New York state has perhaps the most advanced program, of any state or 
U.S. EPA region, for investigating and addressing the vapor intrusion 
pathway. The state is also in the midst of a debate over how best to 
promote the cleanup and productive reuse of brownfields properties. For 
these reasons, I visited five New York communities from July 31 to 
August 3, 2007, viewing contaminated properties and meeting with 
activists. The first four visits were upstate, and the fifth was on Long 
Island.

* Victor, near Rochester, where a plume of volatile organic compounds 
(VOCs) from apparent "midnight dumping" at an operating quarry has 
migrated under a residential neighborhood that gets its drinking water 
from private wells.

* Ithaca's South Hill neighborhood, where VOCs from the Morse Chain 
factory, now owned and operated by Emerson Electric, flow underneath 
homes. New York's Department of Environmental Conservation (DEC) is 
investigating possibly migration under an elementary school, and 
residents suspect a second source, a redeveloped property formerly 
occupied by NCR.

* Endicott, just west of Binghamton, where VOC contamination from IBM's 
original plant has impacted five hundred homes. This was my third visit 
to Endicott, and as before, I also met with activists from nearby Hillcrest.

* Cortland, north of Binghamton, where the Smith Corona plant in 
Cortlandville released VOCs under a residential neighborhood.

* Plainview-Old Bethpage, in Nassau County, where the local water 
district has been forced to conduct wellhead treatment to remove VOCs 
from water from the sole-source aquifer. The state has conducted some 
vapor testing on industrial properties, but the groundwater plumes are 
reportedly poorly characterized.

I gave public talks in the four upstate communities, with press coverage 
at the first three. The media blended my remarks with coverage of Sen. 
Clinton's recently introduced legislation designed to promote more 
protective standards for trichloroethylene (TCE), but at each of the 
four meetings I gave a primer on vapor intrusion, discussed the 
significance of the standards, and led discussions on site remediation.

I view my site visits as two-way learning exercises, and this was no 
exception. Below I summarize some of the more important lessons learned 
for both brownfields and vapor intrusion.

Reuse without Redevelopment

In Victor, two residents active in local government mentioned that new 
homes were being built, apparently over the contamination plume. Like 
most other communities in a similar situation, the town has no 
guidelines in place for determining whether and how to approve 
residential construction where vapor intrusion is likely.

Furthermore, at none of the sites I visited did the brownfields model 
drive the cleanup of the offending VOCs. By brownfields model, I mean 
that the funds generated by redevelopment pay (after the fact, usually) 
for cleanup.

Instead, I was struck that the source properties-except for the Victor 
Quarry-are now owned and operated by new entities, but the original 
buildings remain. Though the workforce is much smaller, Morse Chain is 
now Emerson Electric, which everyone seemed to agree is stuck, by reason 
of corporate acquisition, with the responsibility for cleaning up 
another business's mess. Huron Real Estate manages an industrial park on 
the old IBM Campus; IBM is just one of many tenants. Smith Corona's old 
typewriter plant in Cortlandville is now occupied by several firms. And 
current businesses in the Plainview Industrial Park are not the 
companies suspected of past pollution. Most of the official concern 
seems to be for the occupants of homes over the groundwater plumes 
migrating from these sites; I have not seen information on indoor air 
contamination within the industrial structures on site.

The only redevelopment site was Ithaca's South Hill Industrial Park, 
formerly NCR (National Cash Register), but thus far it is only suspected 
of contributing to the groundwater plumes. However, neighbors expect 
Emerson to shut down its remaining operations, opening the door to a 
major redevelopment in what appears to be a desirable location, between 
the attractive South Hill neighborhood and Ithaca College.

In general, these properties are brownfields, even though most are being 
reused without demolition and new construction. But the magnitude of the 
cleanup challenge, for most sites with migration volatile organic 
compounds, would make it difficult to fund cleanup as part of 
redevelopment. The responses in Endicott and Ithaca are being funded by 
the polluter or its corporate successor, and this may also be true in 
Cortland. Activity in Victor and Plainview is handicapped by the absence 
of a viable responsible party, though residents are not sure why the 
Victor quarry owners have not been held accountable for obvious releases 
on their property.

Viewing the New York sites along with others I have visited, including 
those in my own community, vapor intrusion is a major obstacle to 
redevelopment. In many cases, it is feasible, and it takes only a small 
percentage of construction costs to design mitigation into new 
structures, particularly for industrial or commercial use.

But rarely will construction budgets cover complete source removal of 
volatile organic compounds or a complete response-including 
investigation, mitigation, and remediation-over migrating plumes. Thus, 
redevelopment may uncover vapor intrusion risks, but either designating 
responsible parties or allocating government funds will be necessary to 
get the entire job done.

Vapor Intrusion Lessons

There was a thirst, in all of the communities I visited, for a better 
understanding of vapor intrusion and how it is measured. Even community 
members with many public meetings under their belts seemed unfamiliar 
with the attenuation factor, "alpha" in the Johnson-Ettinger Model. 
Activists with engineering backgrounds were pleased to learn how to 
convert Ug/m3 (micrograms per cubic meter) to ppbv (parts per billion by 
volume), and vice versa. People were also confused by the roles and 
responsibilities of the various environmental agencies. I've attended 
numerous technical conferences on vapor intrusion, but usually I'm the 
only community member present. There's a need for workshops on the 
subject, targeted at the impacted public.

Not surprisingly, the people I met with showed great interest in the 
sampling results from their own homes. They wanted to understand why 
some rooms register more TCE or PCE vapors than others. They told me 
that scientists from the New York Department of Environmental 
Conservation are conducting a study to help understand that variability, 
but that study the relies on Summa canisters-vacuum vessels that collect 
samples for off-site analysis.

Over the phone in Victor, Hopewell Junction (New York) activist Debra 
Hall explained how U.S. EPA surveyed her home with the Trace Atmospheric 
Gas Analyzer (TAGA) a  real-time measuring instrument. I retold Debra's 
anecdotes at my other sessions. In every community, participants like 
the idea of sitting in a van, watching samples register on a computer 
screen, as a technician in their homes pointed the end of a long plastic 
tube at likely pathways and potential alternative sources.

On their own, a number of residents with subslab depressurization 
systems in place expressed concern that long-term monitoring was 
insufficient. In fact, some were unhappy that some homes were given "all 
clear" ratings based upon just one or two sampling events.

Like homeowners anywhere vapor intrusion is reported, residents were 
concerned about property sales and values as well as the health effects 
of vapor intrusion. We shared some anecdotes, but it appears there have 
been no systematic surveys of the economic impact of the discovery or 
mitigation of vapor intrusion.

Finally, residents expressed concern about the protectiveness of action 
levels, the indoor air concentrations requiring that mitigation or 
remediation be initiated or enhanced. Though they showed interest in the 
background to the federal legislation, just introduced by Sen. Clinton 
and other Senators, in each town I explained the matrices establish by 
the New York Department of Health to determine where action is required. 
As I wrote last October 
(http://www.cpeo.org/lists/brownfields/2006/msg00424.html), the 
difficult-to-comprehend table has two advantages. First, it allows for 
the mitigation of potential vapor intrusion and second, it discourages 
mitigation where it appears that the vapor source is not in the subsurface.

I asserted that the matrix for TCE essentially provided as much 
protection as the single-number, 1 Ug/m3 action level used by numerous 
jurisdictions. One activist, from Hillcrest, New York, tactfully 
challenged me. He pointed out that box 7 in the TCE matrix only required 
monitoring. That's where indoor TCE levels are between 1 and 5 Ug/m3 
while subslab concentrations are between 5 and 50 Ug/m3. I had stated 
that the 5 to 50 range suggested that the indoor contamination was 
likely from a source other than the subsurface. In those cases, subslab 
depressurization would do no good.

But the activist had a point: Where such subslab readings (between 5 and 
50 Ug/m3) occur in an area where nearby residences register above 50 
Ug/m3, that is a sign that whatever is showing up indoors is intruding 
from below. He, like community members at other locations, argued in 
essence for the "blanket" approach-a strategy used sometimes by 
regulators in New York and elsewhere. Under this approach, if a home is 
located between other structures requiring mitigation, it is also 
mitigated even if it falls into box 7 of the matrix, or if no sampling 
is done in that particular building. He made a good case: To fail to 
take action, based upon subslab measurements, at homes nested among 
others where it is required, is arbitrary and unprotective.


I have long argued that experts should listen to the people most 
affected by site contamination-that even where they lack the scientific 
background, they too are experts in their own right. In this instance, I 
was the "expert" who needed to hear from an impacted resident.


--


Lenny Siegel
Director, Center for Public Environmental Oversight
c/o PSC, 278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org


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