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Morse Chain / Emerson Power Transmission Site

100-year-old factory site has received the most attention as a source of toxins found on South Hill

Early  -  20th Cent.  -  2001-2003  -  2004  -  2005  -  2006  -  2007  -  2008  -  2009  -  2010 -  2011

Centennial festivities for the plant were modest, the best days of this facility are clearly behind it. Borg Warner, the firm that owned the plant for over half the century, moved its automotive operations to a more modern facility by the Tompkins Regional Airport in the early 1980s and sold the remaining operations to Emerson in 1983. The number of employees has been dropping, and it was announced in 2007 that the headquarters and higher-level and sales employees would be moved out. Still, the plant and its owners have made contributions to our community beyond the wages paid to employees. In the summer of 2009, it was announced that the entire facility would be shut down by the end of September 2010. This schedule stretched to the end of 2010, but the once-busy plant now is idle and abandoned.

Photo by Regina Deschere




Remaining machinery and tools were auctioned off and taken away early in the year 2011. After reports of open doors and lack of appropriate security, damaged doors were repaired and facility guards began taking a strict attitude toward all who came near the plant grounds. Even neighbors walking dogs were threatened with arrest.

Any signs of interest in buying the site have been kept secret. Groups have expressed public interest in discussing what could be done on this large parcel of land, but seemingly everything hinges on the willingness of a buyer to accept the challenges of remediation, even if most costs are paid by the current owners. The downhill section of the site (with most of the buildings) is in the City of Ithaca. The larger uphill section is in the Town of Ithaca. How those jurisdictions will coordinate their efforts to allow new uses for the site, remains to be seen.

Karen Cahill, Project Manager from the Syracuse DEC office, e-mailed this report in early June 2011, regarding the Fire Water Reservoir (FWR) and other cleanup/encapsulation plans:
*        FWR pre-design report submission to NYSDEC.  End of June 2011
*        FWR remedial action work (as warranted based on pre-design investigations).  September 2011
*        Former 507 Degreaser pre-design report submission to NYSDEC * End of June 2011; Pilot Test  August 2011; Remedy Fall 2011
*        Cap installation outside former 507 Degreaser Area.  Fall 2011  
*        Final remedial action report submission for all 3 efforts.  Early 2012 


The FWR "Pre-Design" Report, dated June 30, 2011, has been released. It describes the decommissioning of the infamous FWR, and includes pictures of the removal of the liner, installation of test points, and excavation in and around the FWR. While the FWR is empty and the levels of TCE are lower immediately around the FWR, the levels in the downgradient groundwater test wells are still very high. There are also problems with oil and petroleum products seeping - the DPE system is not designed to handle these.
The full report is here. The full report is over 16MB.  Smaller files with report sections are available as well:
Text Figures  Tables Site Photographs  Waste Maintenance  Boring Logs and Well Diagrams  Geophysical Survey  

Progress Report #4 for the onsite "Dual Phase Extraction" system was released on August 9, 2011, covering the operations during July-December 2010. The short summary of the report is this:

During the reporting period, approximately 4.1 pounds (lbs) of volatile organic compounds (VOCs) were removed from the aqueous phase, and approximately 296.2 lbs of VOCs were removed from the vapor phase (Tables 3 and 4). Since the start of the IRM system, approximately 774.6 lbs of VOCs have been removed by the DPE system.

The full report is here and is over 6 MB.  Smaller files with report sections are available as well:
Text  Figures  Tables Lab Reports  Data Usability Summary  Monitoring Well Purge Logs

OFFSITE - "Operable Unit 3" (OU3) - Neighborhoods down hill from the EPT Site

As described in the 2010 section below, The Record of Decision for OU3 was released in October 2010. It contains none of the extra steps or follow-up testing requested by the affected neighbors. The only testing to be performed will be testing of the exhaust at the top of the 25-foot venting stack to be placed at the Turner Place end of the 300-foot replacement section of sewer on East Spencer Street - shown in blue in this diagram:

East Spencer St Sewer and Stack

Karen Cahill's early-June 2001 update:
* OU No. 3 Remedy: Emerson anticipates starting the remedy implementation beginning mid July 2011, pending NYSDEC review and approval of 90% design and the permitting process.

The detail diagrams of the Sewer and Vent system are here. There are homes along the section of sewer being replaced which had very high test results. We hope that the excavation of the current sewer and installation of the venting system will, in fact, reduce the toxic vapors intruding in these homes. We sincerely doubt that homes further up the hill will be positively affected by the sewer replacement. That the mitigation systems in all the Phase I - Phase V neighborhoods are slated to remain indefinitely suggests strongly that little progress is expected. That the DEC accepted a plan which calls for NO testing other than at the exhaust from the vent stack is incomprehensible and a slap in the faces of all of us who listened to DEC's explanations of how new and untested all this effort was and remains. "We've never done anything like it before, but we will declare it a success (our final step) before the plans have even been reviewed." A more honest answer might have been, "We've spun our wheels here for so long, we simply HAVE to move on."

WSP (Emerson’s Consultants) Release “90 PERCENT DESIGN” Document for Sewer Work

Dated July 12, 2011, WSP released the “90 PERCENT DESIGN” Remedial Design Report for “Operable Unit No. 3” (The South Hill neighborhood below the Emerson site.)  It is a collection of many documents:

The full document is here.
The text sections are here.
Figures 1-3 are here.
The “Design Drawings” are here.
The Construction Quality Assurance Project plan is here.
The Health and Safety Plan is here.
The Community Air Monitoring Plan (CAMP), revised July 15, is here.

The document spells out the various steps to be taken to excavate about 300 feet of existing sewer from the bottom of Turner Place (Manhole No. 9) down East Spencer Street to Manhole No. 17.  The sewer would be replaced with a new sewer,  surrounded by “highly permeable granular material”, into which a perforated pipe would be installed, with a single exhaust stack located near the NYSEG gas installation, to release the vapors from the sewer bedding.

The stack would be approximately 25 feet in height, with a wind turbine on the top. Neighbors are concerned that the vent stack is at the height of many of their homes’ windows.  That the vapors from the vent stack would be any higher or lower in concentration than the exhaust from the existing mitigation system stacks is not clear, but there would be testing of the stack exhaust on a regular basis until the overall levels are known.

It is distressing that the “remedial action” doesn’t include any testing to see if the new sewer actually reduces (remediates) the toxin vapors which are present in the East Spencer Street area.  The “Remedial Objectives” for this project are to address the three pathways identified for the potential migration of vapors from the sewer lines, including:

“(1) along the sanitary sewer lines;
 (2) along the residential sanitary sewer laterals; and
 (3) within the vertical and horizontal planes of porosity (fractured bedrock) surrounding the sewer lines.”  (page 1)

Without in-home air testing, and testing of the sub-slab vapors under the affected homes, there is no way of knowing that any of these remedial objectives will have been met.


As reported online in the Ithaca Times, July 27, the Ithaca City Board of Public Works received a petition from East Spencer Street neighbors asking the City to delay granting of an easement required by EPT to proceed with the sewer work. They heard pleas from neighbors about the quality of the air, asking for tests to confirm that the sewer "remedy" would not make things worse. Tellingly, one of the WSP consultants remarked that the emissions from this proposed PASSIVE stack would be "nothing" compared to the emissions for the many existing ACTIVE vent stacks which are part of the 59 mitigation systems already in place in the lower South Hill neighborhoods. (The vent stacks were tested in 2008, with distressing, but seemingly "legal" results.)  

The BPW passed a resolution adding a testing stipulation to the Easement agreement. A similar resolution was passed soon thereafter by the City Administration Committee - Ithaca Times report here. On Monday, August 1, the City Community Advisory Group met and discussed this issue as well, making changes to the proposed stipulation and agreeing to finalize wording to be submitted to the Common Council for their meeting August 3. The Council spent over an hour discussing the matter but decided to table the matter, to get more information from the DEC. (Ithaca Times report here, Ithaca Journal report here.)




The Morse facility on South Hill expanded through its first seven decades, with the most significant and lasting development in power transmission equipment for industrial and automotive applications: drive chains, timing chains, sprockets, gears and combinations in various housings for front-wheel and four-wheel drive systems. The plant layout and functions are suggested by the "Sanborn" map shown below - a 1929 map updated to the early 1960's.

Activities included metal stamping, punching, grinding, milling, heat-treating, oil-quenching, parts washing and product assembly. Other operations started in the 1960's and 1970's included copper and cadmium plating, and wire drawing. Many of these processes require the use of "cutting oils" which must be removed from the pieces after the process. The removal steps involved a variety of solvents including mineral spirits, Freon, 1,1,1-trichloroethane, TCE, and tetrachloroethane. While TCE use was discontinued in 1977 or 1978, peak usage was reported to be about 1200 gallons per week.

"Sanborn" map of Morse Chain Site, early 1960's- for a printable version, click here


Environment awareness and concerns about carcinogenic effects of the various lubricants and solvents were not as developed in the mid-20th century as they are today. However, the Morse facility, like many other industrial and military sites across the country, became the focus of attention as neighbors reported odors, and strange colors and oil slicks in water running downhill from the plant.

Some of the problems found are documented in correspondence between Morse employees and local and State health officials. Many of these documents have been collected by Walter Hang of Toxics Targeting, Inc.

Cutting oils used in processing the metal parts were found everywhere - coating the finished parts and dripping off the pieces of scrap and shavings which were hauled in bins from the plant to recycling centers. PCBs were found in this oil, and as our knowledge of the problems with PCBs grew, so did concern about the oil runoff from the plant.

The use of chlorinated solvents as degreasing agents (to remove the oil from the metal) increased in an attempt to limit the spread of the PCB-laden oil. However, as it was learned that some of the active agents in these solvents themselves presented problems, efforts were made to reduce their use.

The volumes of metal, cutting oils, solvents, and water that moved through the plant site are large. The amounts of metal scrap and the oil it was treated with are the subject of ongoing discussions between Morse staff and County Health officials, and the solvents used and the water taken in and discharged by the plant are detailed in the 1981 application Morse filed for a discharge permit.

Water Flow Schematic, submitted by Morse Chain as part of State pollution Discharge Elimination System (SPDES) Permit Application, Sept. 30, 1981

Map submitted as part of SPDES Permit Application, showing location of Outfall Discharges. A "Google Earth" view of these locations may be viewed here. The locations are:
- uphill from the top of South Cayuga Street,
- below West Spencer Street, near the intersection of Wood and South Geneva Streets.

In 1987, TCE was found in oil that had been taken from the surface of the large fire reservoir on the plant site. Further tests disclosed the TCE was present in the reservoir water as well.

According to the "Record of Decision" issued by NYSDEC in December, 1994, these steps were taken over the next years:

February 1987: EPT notified NYSDEC of the discovery of TCE in oil skimmed off the surface of an underground fire reservoir. At this time, EPT hired Radian Corporation to prepare a preliminary environmental assessment to address TCE contamination in the fire reservoir and to investigate whether TCE had impacted groundwater.

As part of this work, the reservoir was emptied and cleaned using high pressure water and five monitoring wells were installed. Samples were collected of the groundwater from those wells, soil, surface water and sediment from Six Mile Creek, and seeps. This sampling showed local groundwater was contaminated and that the fire reservoir was likely a source.. The study also detected petroleum hydrocarbons in soil taken from the railroad ditch.

July 1987: The site was added to the New York State Registry of Inactive Hazardous Waste Disposal Sites.

July 1988: EPT signed a consent order with the NYSDEC for a remedial investigation/feasibility study (RI/FS) and remedial program at the site.

February 1990: Radian Corporation submitted the RI. This information was used to evaluate interim remedial measure (IRM) alternatives and to complete the Feasibility Study (FS).

May 1991: EPT entered into a consent order for an IRM.

August 1991: EPT finished construction of a groundwater extraction and treatment system (henceforth referred to as "pump and treat system") to operate as an IRM prior to completion of the FS.

May 1991: NYSDOH collected air samples from homes near the Morse site. Based on these samples, the NYSDOH requested and EPT agreed to install vadose zone monitoring wells to assess the potential for impacts adjacent to the site.

August 1992: The Fire Reservoir was rehabilitated and put back into service. Cracks in the concrete were patched and a liner was installed.

February 1994: EPT completed a pilot test using the Xerox Two-Phase Vacuum Extraction system, which was initiated in October 1993. Pilot test objectives included: evaluating system effectiveness for removing VOCs from the soil, dewatered bedrock, and groundwater; comparing system performance to the pump and treat system; and evaluating the benefit of supplementing or replacing the pump and treat system with two-phase vacuum extraction for remediation.

The pilot test results showed that the two-phase vacuum extraction system outperforms the pump and treat system. The two-phase vacuum extraction system removes greater quantities of groundwater, has higher VOC removal rates, and has a greater zone of influence.

June 1994: Four vadose monitoring wells were installed and will be sampled on two occasions. This investigation will be completed concurrently with the monitoring program for the remedy selected by the PRAP. Should the need for further remediation or other mitigation be identified it will be evaluated as a component of the operation and maintenance program for the site.



The Morse facility on South Hill seemingly escaped significant environmental notice during the first few years of the 21st Century. The April 1, 2003 NYS DEC listing of Hazardous Waste sites considered the plant site to be "Inactive", having reclassified it to an official status of "4" - "Properly closed - requires continued management". The document's Assessment of Environmental Problems stated "A plume of volatile organics emanating from a concrete tank (referred to as the fire water reservoir)  is a threat to the surrounding environment. The low volume pump & treat system currently in use is helping to lower the groundwater containment levels." The report also stated "The remedy (operation of the two phase extraction system) is performing properly and is effective."


The groundwater extraction system continued to be used, and results were monitored and readings from one well (MW-3-31, located East of the top of South Cayuga Street, between the Fire Reservoir and the NYSEG Substation) are summarized in this February 2004 report prepared by Radian. The readings vary wildly from season to season and year to year: for TCE, summer readings (in micrograms per Liter) were:
  1996: 6900     1997: 1100    1998: 82,000    1999: 260    2000: 43,000    2001: 78,000   2002: 28,000    2003: 21,000
These readings are all relative to a NYS Target Cleanup Objective of 5 micrograms per Liter.
Within 2003, the last year reported, the results varied significantly as well:
  March: 20,000     June: 21,000     August: 5800    November: 28,000
After over a dozen years of groundwater extraction, levels were still very high and showing little sign of abating.

In May of 2004, Walter Hang, President of Toxics Targeting, Inc. held a Press Conference below the Morse Plant discussing the first of two letters he would send to Emerson and to the NYSDEC, referencing many historic documents and maps his firm had collected and prepared. The attention Mr. Hang's actions drew helped to spur a variety of actions, many of which are continuing. The extensive documentation he attached identified many issues which still have not been addressed by the responsible parties and State agencies.

In response to the concerns Mr. Hang raised, a group of South Hill residents signed a letter dated May 25, 2004, to the heads of the NYS DEC, US EPA, NYS DOH, and to the Mayor of Ithaca, requesting that the agencies report to the public on their responses to his points and that they press for actions for mitigation, research into how far the toxins have spread and the need for health studies.

On June 15, 2004 Emerson issued this "Public Notice" to S. Cayuga Street and Spencer Street Residents describing 8-hour canister tests to begin on June 16 with the installation of monitoring points to sample vadose zone gas.  They concede "We are working closely with the state to remedy a situation that was present when Emerson purchased Morse Chain in 1983.", but contend "these response actions are adequate and in compliance with the NYSDEC Record of Decision."

The first reply received by the South Hill residents was a letter (dated June 16, 2004) from Assemblywoman Barbara Lifton indicating the she and her staff had taken the initiative to contact the various parties and would try to organize a meeting with the public.

During the first part of 2004, Emerson engaged Environmental Strategies Consultants LLC to perform vadose zone tests on and near the EPT facility. Their proposal for this plan was dated January 16, 2004 and approved by the NYS DEC on May 13, 2004. The samples were taken on June 17, 2004, and this report of the results, from ESC's Scott Haitz to Carl Cuipylo of NYSDEC, is dated July 7, 2004. Roughly half the samples taken showed TCE well above the relevant standards.

The Public Meeting was scheduled for August 4, 2004. On August 2, both NYS DEC and NYS DOH churned out their replies to the May 25 letter from South Hill residents. It took 10 weeks, but we had both replies and a Public Meeting.

The DEC letter, from Mary Jane Peachey, Regional Engineer, discussed the agency's response to the EPT situation, including the development and distribution of a "Public Information Session" announcement, acknowledged the consideration and ongoing review of the site classification for possible revision (back) to class 2, based on the "new data" being presented, reported that homes within a certain area would be tested for indoor air quality, and that NYS DEC would work with NYS DOH to determine if mitigation systems would be required.

The DOH letter, from Gary A. Litwin, Director of the DOH Bureau of Environmental Exposure Investigation, reviewed the site history: in the late 1980's and early 1990's investigations showed that on-site groundwater was contaminated with volatile organic compounds. These were attributed to the fire reservoir and seemed to decrease significantly as the plume flowed away from the source, and that these levels had decreased "significantly" since groundwater treatment began in 1991. He also discussed the testing of 10 houses in the lower South Hill area, and reported that "soil vapor intrusion" of various site-related contaminants was found at some of the homes, but that "health effects were not expected at the levels found." [One of the sites had an indoor TCE level of 46 ug/cm^3!]  Mr. Litwin went on to explain how some tests required by the 1994 Record of Decision were never (successfully) performed, but that EPT had installed new vapor wells on South Cayuga and South Geneva Streets, and results from these well tests "indicate the need for additional soil gas monitoring and indoor air sampling of nearby residences."

Mr. Litwin goes on to state: "We do not plan to conduct any health studies specific to this site. The data collected to date do not indicate that people in the area are being exposed to chemicals from the site at levels that would be a health concern. In the absence of significant exposure, adverse health effects are not anticipated." His letter has a four-page NYS DOH "Frequently Asked Questions" document on "Soil Vapor Intrusion" attached.

Emerson Power Transmission (EPT) also prepared a Notice for the "Public Information Session", with a two-page "Fact Sheet" relaying their view of the site history and recent "soil gas" investigations. They will prepare a work plan involving indoor and sub-slab air testing, and the installation and monitoring of additional groundwater monitoring wells. These tests should combine to determine what additional "investigation activities" may be necessary." "Since indoor air sampling results may vary from season to season, it may be necessary to sample some of the structures on more than one occasion."

The Public Meeting was fragmented both in terms of time and location- there were two sessions: one at the hotel in the afternoon and another at the hotel in the evening. An "alternate" meeting with various State officials was also held in the (Borg Warner Room of the) Public Library in the afternoon. Emerson released their plan to test 32 homes very close to the plant. Homeowners in other neighborhoods were not pleased, but held out hope that the State agencies reviewing the plans would force expansion of the area. The Ithaca Journal report on the meetings is here.


On August 31, 2004 DEC Engineering Geologist Carl Cuipylo sent this 3-page letter (with 16 pages of attachments) to Scott Haitz (ESC Project Director), responding to August 2, 2004 Indoor Air Assessment Work Plan..  Mr. Cuipylo criticizes the detection limits used in the June 2004 testing as being too high and requests that ALL the volatile organic compounds (VOCs) detected in test be included in the reports to provide information about the interference that other compounds may be causing.  He states that the locations to be sampled need to be expanded, and that comprehensive testing of the ambient air and subslab (or subsurface in the absence of a slab) test most be performed.  The attachments include the NYS DOH "Indoor Air Sampling & Analysis Guidance" (08/01/01),  "Indoor Air Quality Questionnaire and Building Inventory" forms, "Substructure Soil Gas Sampling" instructions, and the NYS DEC "Guidance for the Development of Data Usability Summary Reports".

On September 20, 2004, the Ithaca Department of Public Works released this Report by Tom West, Assistant City Engineer, to South Hill Residents on subsurface soil investigations performed August 11, 2004, showing that samples from the Cayuga Street embankment, soil, and water all reflected compounds below cleanup standards.  Among the chemicals found were Tetrachloroethene, Toluene, and Chloroform.

This letter, dated November 20, 2004, from Carl Cuipylo (DEC) to Scott Haitz (ESC) reviews the July 28, 2004 Supplemental Off Site Investigation Work Plan.  He specifies inspection and repair of several suspect wells, and requests certain new wells into the "unconsolidated overburden", as well as tests of the seep behind 123 South Hill Terrace, the seep at 514 South Cayuga Street, the cistern at the upper end of South Cayuga, and of the artesian well behind 212 Wood Street.  He refers to "the persistent elevated concentrations of contaminants remaining in the on site groundwater and those found in the off site vadose zone and nearby residences."

That letter drew this November 12 response from Derek Chase (EPT) agreeing to most of the DEC points, but refusing to investigate the artesian well as it is "beyond the study area".

On November 24, James Burke (DEC) sent this letter, accepting the response by EPT to their review and indicating that DEC will test the artesian well and sample some wells of particular concern.

The Ithaca Journal carried this article on December 14, detailing the discovery of rusted 55-gallon drums which had contained methyl chloroform on the wooded hillside below the south end of the EPT plant, not far from the Morris Heights home of the resident who reported the drums. A DEC engineer reviewing the site said the barrels appeared to have been there for "quite some time, tens of years". Apparently, the "due diligence" steps that Emerson performed in reviewing the property they purchased weren't entirely diligent. One wonders why there have been no soil vapor tests performed on the properties in Morris Heights.



On February 25, 2005 this Letter from the DEC "Site Control Section" was sent to EPT, with notification of the plant site's reclassification from 4 to 2 (Significant Hazard to Environment).

This Letter from James Burke (DEC) to Derek Chase (EPT), dated February 28, 2005, calls for expansion of the indoor air study area to include areas west of Spencer Street, including "the area bordered by Albany, Wood, Plain and Elmira Roads."  A second letter, dated the same day, calls for more comprehensive reporting of monitoring well data, including all analytic sampling from 1995-present.

These DEC-prepared slides for the March 3, 2005 public meeting reviewed late 2004 and early 2005 activities. Phase I and II results show need for Phase III.  Site reclassified from 4 to 2 "based on indoor air results".

This March 11, 2005 Letter from ESC to DEC details plans for testing the VOC emissions related to the operation of a sub-slab depressurization system at 126 South Hill Terrace", to "evaluate the potential affect on ambient air quality".

Letter from Derek Chase (EPT) to James Burke (DEC), dated March 30, 2005, details the results of the additional Ground Water test wells tested on Feb. 25, claiming that these results (as well as the prior air sample results) show that "there is no technical basis for expanding the current study area at this time."

Letter from James Burke (DEC) to Scott Haitz (ESC), dated April 5, requests changes in the proposed Preliminary Onsite Remedial Investigation Work Plan.  More detail is desired, especially involving those places to be tested and their relation to areas identified in prior studies.  ESC is instructed to use a lower detection limit for TCE (0.25 ug/m^3 rather than the 0.82 ug/m^3 used in Phase I and II.  Mr. Burke also comments, "The statement that the 2-phase system is 'containing' VOCs cannot be confirmed presently due to the lack of a historical offsite monitoring network".

April 12, 2005 Letter from James Burke (DEC) to Brian Silfer (ESC) about the DEC and EPA review of the "Drum Recovery / Soil Sampling Report"; asks that this report be incorporated in the "onsite investigation" EPT has proposed for other purposes.

On May 4, 2005, Ithaca's Common Council passed a resolution calling for full disclosure (by Emerson and Borg Warner) of all toxic substances known to have been used in the plant, and of all spills of such substances. For the text of the Resolution, see pages 26 and 27 of the Council Minutes. The Ithaca Journal article on the meeting is here.

Letter (May 11, 2005) from Scott Haitz (ESC) to James Burke (DEC) reports the Feb. 2005 sampling results for offsite GW monitoring wells around the EPT facility, which found no significant levels of any chemicals of concern.  Retests in April 2005  and additional wells tested then also showed no significant concentrations of any chemicals of concern.  EPT proposes more wells at the uphill end of South Cayuga Street and also proposes to conduct an electrical resistivity (ER) imaging geophysical survey with dipole arrays of electrodes spaced 3 meters apart.

Letter (June 2, 2005) from James Burke (DEC) to Derek Chase (EPT) regarding the March 2005 proposals for Aquifer Testing and GW Evaluation of the Remediation area.  Mr. Burke acknowledges that there will be some value to the proposed pump tests, but feels it will be necessary to review all site data to properly understand the effectiveness of any proposed changes to the recovery system.  He states, "A major issue is the lack of any one time assessment of all possible data collection points.  The Department has put together a snapshot of the site based on data from different time frames and although the Department can achieve a reasonable picture of site conditions, it is uncertain how accurate this picture is or how conditions change over time with relationship to one another.  This site lacks comprehensive periodic monitoring.  Although several of the wells in the immediate area of the extraction wells have been monitored regularly, there is no periodic monitoring over the entire site and affected off site areas from which to evaluate trends over time."  He also rebukes EPT for considering the fire reservoir to be the sole source for the on site groundwater contamination.

Letter (June 21, 2005) from James Burke (DEC) to Derek Chase (EPT) regarding the Electrical Resistivity (ER) tests EPT has proposed.  DEC wants more test points on the plant site itself.  Mr. Burke also reminds EPT that previously-requested detail for monitoring wells on and off the site property still has not been received.

Letter (also June 21, 2005) from James Burke (DEC) to Derek Chase (EPT) regarding the expansion of the air test study area.  Mr. Burke states, "Through negotiation and counter-proposals, agreement has been reached in regard to the resampling of specific homes, an expansion into additional homes, and a vapor point installation/sampling project west of Geneva Street."  As for EPT's contention that no further home tests are needed west of Spencer St., he says, "That monitoring wells in the western neighborhood showed no detectable levels of site-related VOCs cannot be used as definitive proof that vapor intrusion is not an issue.  It is one piece of evidence."

Letter (also June 21, 2005) from James Burke (DEC) to Derek Chase (EPT) regarding the May 11th proposal for tests in and around the R&D ("Service") Building at the top of Turner Place.  He states that the proposed tests "will not sufficiently define or evaluate groundwater quality downgradient from the R & D Building" .  He requests that GW levels be included in data for all sampling events, and that the "seep" north of the building be analyzed and included in the R&D report.

A Public Meeting was held June 22, 2005 to discuss the results from the first Phase II indoor air tests and to announce the expansion of the test area for Phase III, adding homes north of Hillview Place along both sides of Turner Place, both sides of South Hill Terrace, and on the "uphill" portion of the 100-block of East Spencer Street.

During the summer of 2005, It was announced that Emerson would hire consultants to study the "Electrical Resistivity" of the areas below the plant, to try to identify various features under the surface.

In an "Onsite Assessment", released on December 13, 2005 (links to document and components of it below), ESC reviews various maps and previous environmental reports to try to piece together the history of operations in the various buildings.  "The solvent TCE, was reportedly used to clean metal parts and scrap metal in conveyor type vapor degreasers located on the ground floor of the main plant building (Building 4 - 507 Degreasing Department).  Only one of three areas requiring "oily soil remediation" was treated to a point that it met applicable standards.  SVOCs and PCBs were found in the soil remaining after various corroded drums ("discovered" in Dec. 2004) and other pieces of scrap were removed.  Activities once performed in various sections of the plant (mostly no longer used) include solvent degreasing and recovery, copper and cadmium plating.  One degreasing using was the "source of an unknown amount of solvent released to the sanitary sewer system", though its exact location is unknown.  Oil leaking from scrap was captured in scrap loading area but there were discharges which were detected in the South Cayuga St. sewer and in the outcrops along West Spencer Street. There was a "Cyanide Room Drainage Trench", and acid pickling tanks.  There were coal piles and four "below grade oil quench pits" which are no longer in service, though a fifth quench oil pit is still in use.  Various underground storage tanks are no longer in use and have been closed in accordance with NYSDEC regulations.  Many of the aboveground storage tanks still remain in service, but ten tanks, including a 100,000-gallon fuel oil tank, have been removed.  Potential migration of chemicals from offsite sources (including Therm, NCR/Axiohm, and various other spill sites) is also reported.  Test samples in the Axiohm disposal area show high levels of TCE, cis-1,2-DCE, vinyl chloride, SVOCs and metals.  21 specific "Areas of Concern" throughout the EPT site are detailed, as are the sewer lines down Turner Place and South Cayuga Street, and "seven potential migration pathways" identified on old maps.  ESC states that their August 2005 tests suggest that the R&D building (built on top of a former City Reservoir) is no longer an Area of Concern.
You may view or download:
The full document (12.5 MB)
Report Text
Figures (including map of Areas of Concern)
Environmental Database Report (The names of databases reviewed)
EDR Radius Map - Findings (Details on spills and incidents)
Government Records Searched
GEOCHECK Physical Settings Source Records
Sanborn Map Report
EDR Historical Topographical Maps




Slides from EPT presentation at the Jan. 25, 2006 Public Meeting.  Overviews were presented on the various investigations performed during 2005, including R&D air and slab tests, GW tests, the Geophysical Survey, the Onsite Assessment results, and the expansion of the Study area for the Phase IV testing: homes on lower Turner Place, Pleasant Street, and East Spencer St.

Description of plan to investigate soil surrounding the two sanitary sewer lines running down Turner Place from the EPT site - one called the 1878 Line and the other called the 1979 Line.  There would be 24 borings just to the west of each of the lines, spaced about 100 feet apart, with soil samples analyzed in the field for VOCs using a photo ionization detector and then shipped to a lab for further analysis.

Letter from ESC to DEC reporting the results of Nov. 18, 2005 vadose zone tests performed along the "NCR sewer" line which runs downhill on the east side of the plant site.  The highest values found were for TCE with a reading of 477 ug/m^3 at the downhill end, near where the line runs to South Aurora Street, and 536 ug/m^3 at the uphill end where it enters the EPT site.

On March 3, 2006, ESC released a report of results from their testing of the former "R&D Building" on the EPT site, at the top of Turner Place. In tests performed in September 2005 and in test performed in January 2006, TCE and PCE were found in all tests in all locations. The Indoor air tests would justify installation of a mitigation system under the 0.8 ug/cm^3 TCE threshold now being used by EPT. The report includes maps of the sampled locations, and detailed results of the tests.

On March 6-8, EPT first announces that it is sending letters to South Hill Residents, informing them that EPT has voluntarily lowered the threshold for the Indoor Air test level of TCE needed to qualify for a mitigation system. They will now offer systems to any home where any Indoor Air test has found a TCE level of 0.8 micrograms per cubic meter.  On March 10, they sent out offers of mitigation systems to those homeowners newly-eligible under the revised threshold.

On May 10, EPT sends letters to those homeowners to whom mitigation systems have been offered, offering to help pay for the electricity used by the ventilation fans used by those systems. The payments will be made monthly, in the form of checks for $12.00 payable to NYSEG.

On May 19, ESC released a notice to Turner Place Residents stating the their proposed work plan to investigate the Turner Place sanitary sewer lines has been approved. The work will involve drilling soil borings in the public rights of way to test whether historic releases of site related compounds have occurred from these sewer lines. The work was performed during the week of June 5, 2006.

Round 4 Test Results - from James E. Burke, NYS DEC - May 25, 2006

"[I]n response to your email of 5/19/06:

The Phase IV samples were taken from residential structures during the approximate time period of February 20 to April 19, 2006. EPT typically will receive results from the lab within one month of sampling. The results are then validated, which can take another 2 to 3 weeks. Once EPT receives the validated results, they will review them internally and then send to the State for review. Our review should normally be completed within 2 to 3 weeks of receipt of validated test data from EPT. Draft homeowner letters are then prepared by EPT and sent to the State for review and comment. Once final agreement is reached on the content of the letters for a residence, they are then sent to the homeowners. The entire process can take upwards of 3 months from the time of sample collection to the time the letter is sent to the homeowner. The draft bill requires that the homeowners receive results from the Responsible Party (RP) within thirty (30) days of receipt of validated results by the RP. The State will work with EPT and all other RPs to meet this goal.

This Phase has been slightly delayed due to discussions between the State and EPT on the content of the Phase 4 homeowner letters. Please note these discussions are focused solely on the wording and content of the letters. It should not be speculated that the delay in sending the letters is related to the nature of the Phase 4 results. There is currently a conference call being scheduled in the next 1-2 business days with EPT and the State to resolve issues.

The current work at the site includes the Turner Place sewer investigation; preparation of final geophysical investigation and well aquifer pump test reports; preparation of the final Onsite Assessment Work Plan by EPT; and subsequent proposed modifications to the onsite treatment system by EPT to improve capture of groundwater contaminants.

Please call me at 315-426-7550 with any questions, or email at jeburke@gw.dec.state.ny.us . Thank you."

The first copies of Round 4 Test Results were received June 8, and have been added to the SHIP Database. Our ability to understand and explain what's going on around us is greatly improved by the collection and organization of the results for all the properties in the neighborhood. Please consider sharing your results. If you'd like to contribute results you have received, please contact us.

We have received reports of an even higher subslab TCE reading among the houses tested for the first time. This was true for the 2nd, and 3rd rounds of testing as well: the further down the hill they test, the higher the sub-slab readings found. Please continue to monitor the SHIP Database for the latest results and updated maps.

June - July 2006 ESC Documents Available in Library Archive

Cover Letters and a few of the attachments of a flurry of correspondence from James P. Bulman of Environmental Strategies Consulting LLC (ESC - the consulting firm retained by Emerson to assist in handling the investigation into the site toxins) to James E. Burke of NYSDEC have arrived at the Tompkins County Public Library Archive. We have copied portions of them, and they are available here as Adobe PDF documents. (Many of the letters contain responses to NYSDEC requests - those NYSDEC documents do NOT appear to be available in the archives.)

- June 16, 2006 letter Re: Semi-Annual Progress Report - Response to NYSDEC Comments
This document discusses a May 8, 2006 NYSDEC letter providing comments on the Semi-annual Report for July 2005 - January 2006. NYSDEC had recommended adding 9 new and 4 additional wells to the list of extraction and monitoring wells "routinely" sampled and reported semiannually. The sampling events were scheduled for December 2005 (to be included in the July 2006 Semiannual Report) and again in July 2006. We have yet to find any of these reports in the Library Archive.

NYSDEC also commented on the "elevated levels of VOCs significantly above State Standards", which "persist in many of the on-site wells, including:
- Extraction Wells 1, 2, and 3
- Monitoring Wells 2, 3-31, 3-100, 3-150."

That these levels remain so high after so many years of operation of the VOC removal system suggests that the system simply isn't doing the job that was intended and expected. Many of the current documents address attempts to improve extraction levels, and to learn more about the continuing movement of the toxins through the many pathways.

- June 16, 2006 letter Re: May 8, 2006 NYSDEC Correspondence - Response to NYSDEC Comments March 10, 2006 Proposed Supplemental Geophysical Survey
This document discusses a May 8, 2006 NYSDEC letter providing comments on the proposed supplemental geophysical survey work plan for the EPT site (a document apparently dated March 10, 2006.) NYSDEC asserts that there may be more zones than the eight areas identified by ESC as likely "water bearing zones" which are also "hydraulically conductive." There is discussion of the resistivity measurement techniques which will be needed to produce three-dimensional models of the "major conductive zones, which exhibited resistivity signatures and shapes consistent with potential water-bearing fractures on site (7A, 2A, and 12A/2D) and offsite (6F, 10A, 9C, 11B, and 11E), [which] will be further evaluated using closely spaced ER survey lines oriented in a grid around the area where each major conductive zone was identified."

ESC also states that "following the completion of the supplemental geophysical survey, Emerson will develop a work plan, which will include 1 to 3 exploratory bedrock borings to confirm the supplemental ER image results." "The fracture-like anomalies will be the focus of the confirmation borings."

These discussions require some knowledge of the results of the Electrical Resistivity Studies (ERS) performed during the summer of 2005. Some of the relevant documents are these:

The October 19, 2005 Report from Forrest Environmental Services, Inc., which discusses (in 9 pages of text) the ERS results, and specifies (on the last page) the many "conductive anomalies" which were identified, and suggests that these may be saturated fractures.

The October 31, 2005 Results from Environmental Strategies Consulting are best put into context by the map on page 2 (Figure 2) which shows the location of the various test lines, and then shows the colorful (but seemingly inscrutable) results generated by the tests along each line. (This is a big file and will download slowly, but the results can help with understanding the discussions in the ESC report of the same date, listed next.)

The October 31, 2005 Report  from Environmental Strategies Consulting attempts to explain the results of the ERS tests and to draw conclusions. The Summary (on the last page) states:

"The geophysical survey results indicate that five major conductive zones are located along the northeast and southwest portion of the EPT site. No major conductive zones were identified in the immediate vicinity of the current remediation area downgradient of the fire water reservoir, which was identified in 1987 as the source of the TCE release.
The results of the geophysical survey also demonstrate that groundwater migration at EPT is controlled by the orientation of bedrock structures, including bedding plane fractures and vertical joint sets. Groundwater flow through the bedrock, as indicated by the conductive anomalies, is confined to relatively well-defined, discrete water-bearing zones that correspond to the secondary porosity of the rock. In the area directly downgradient of the remediation area where affected groundwater is found in wells that are not near any significant water-bearing anomaly, the flow is likely controlled by the amount of horizontal bedding plane fractures and, thus, the terms stress relief, transition, and lithologically controlled zones ( i.e., "B", "C", and "D" zones ) are useful for discussing the distribution of affected groundwater. However, it is clear from the geophysical results that the partings alone are not controlling the migration of groundwater over other portions of the site and a horizontally zoned conceptual model cannot be used to generalize the hydrogeologic framework of the site."

- June 16, 2006 letter Re: May 8, 2006, Correspondence NYSDEC March 20, 2006, Geophysical Survey - Response to NYSDEC Comments
This document discusses a May 8, 2006 NYSDEC letter providing comments on the ERS geophysical survey investigation report dated October 31, 2005. The critical nature of correct siting of the exploratory borings is discussed, as is the need for correlation with existing well data. NYSDEC Comment 3 (presumably in the May 8, 2006 correspondence) is quoted:

"the Department is keenly interested in the interconnectedness of the features identified to date, and the preferential migration pathways beneath and around the Emerson Power Transmission Facility. We intend to do a thorough review of upcoming Environmental Strategies submissions. A knowledge of what information upon which a given conclusion is based will expedite the review process as well as the decisions made regarding remediation of impacts on the surrounding community."

- June 22, 2006 letter Re: Aquifer Testing Summary and Design Modification Status
This document summarizes the "aquifer testing" performed by ESC at the EPT facility in February 2006. The test scheme, seemingly under discussion since the previous summer, involved pumping quantities of water from various spots on the plant site and measuring the degree to which water levels changed in the different Monitoring Wells. Different technical methods were used to analyze the drawdown data for the highly-fractured upper portion of the "B" zone bedrock (where the flow is assumed to be mainly through the fractures, acting as if "porous media") and for the less fractured bedrock where the flow is the results of primary and secondary porosity, resembling non-porous media. Maps of the wells and a diagram of the geologic cross-section through which the test wells run are also provided.

- July 3, 2006 letter Re: Response to Comments - May 8, 2006, Correspondence regarding Onsite Assessment Report (December 13, 2005)
This letter was accompanied by a table listing the products that are currently or have been used at the facility. The table is considered "business confidential" and was not released to the public. Their general description of such products is:

"The primary materials used by EPT are steel, cast iron, and plastic. Other materials used by EPT include coolants, detergents, aluminum oxide, paints and thinners, ammonia, tumble media, nitrogen, carbon dioxide, oxygen, helium, kerosene, diesel fuel, and cutting, quench, and punch oils. Natural gas is used to heat the facility. Propane is used to fuel forklift trucks, and diesel fuel is used to fuel the facility's tractor."

Reference is made to the industrial chemical use inventory that was part of the 1981 SPDES permit application, but Emerson claims that it does not have a complete list of chemicals used by the former Borg Warner facility. There are also references to an outdoor drum storage area and to a "perennial stream" originating near Ithaca College and extending through the EPT site. ESC disputes the need for further remediation for petroleum hydrocarbons.

NYSDEC "Comment 7" is quoted:

"The location of onsite facility storm, sanitary, process and utility lines, as well as sumps, discharge structures, etc. should be investigated as potential pathways for pollutants."

Building #24 (the former NCR building) is now considered an "Area of Concern" (AOC) based on the indoor air tests performed in December 2005.

NYSDEC "Comment 16 " is quoted:

"Please detail conceptually how the seven potential migration pathways will be further investigated."

Seven pathways is more than we'd been led to believe existed. ESC says the investigations will include soil vapor sampling, soil sampling, and groundwater sampling.

Finally, NYSDEC "Comment 17" is quoted:

"EPT has submitted two letter reports, dated, 2/13/06 and 4/25/06, detailing indoor air testing at the EPT facility. The results from those tests indicated that VOCs are present in the facility subslab and indoor air at elevated levels for most locations sampled.  The results from all subslab samples taken during both testing events requires that these locations be considered as AOCs that will require further investigation as potential source areas of contamination. It is noted that several of these sites do correspond to previously identified AOCs. THE NYSDOH is currently reviewing the indoor air quality and subslab results from these sampling events, and comments on this will be provided under separate cover."


Environmental Strategies Consulting LLC has been calling residents to request permission to access their property for additional rounds of Electrical Resistivity testing, involving more probes spaced more closely, to try to get a more detailed study of the geological features of the area, including the various fractures through which contaminants could travel. There will be transect lines along South Hill Terrace, Hillview Place and East Spencer Street as well as in yards downhill from homes on the Western side of of the 500-block of Turner Place, with work scheduled for the last week of July 2006. A sample letter from ESC is here.

Emerson Power Transmission has issued a "Site Update" dated July 19, 2006, and received by mail from ESC on July 22. The single-page document addresses:
- Phase IV Indoor Air Testing - 26 homes were tested, 2 have been offered mitigation. Results will be submitted to NYSDEC and NYSDOH in August 2006. [That this round of tests found a home with the highest subslab TCE test reading yet encountered is NOT mentioned.]
- Turner Place Sewer Investigation - "22 soil borings were installed along the two sanitary sewer lines and 25 soil samples were collected for laboratory analysis. Results to be submitted to DEC and DOH in "early August 2006."

-Supplemental Geophysical Survey - to begin during the week of July 24, performed along public "rights-of-ways" and on "selected residential properties" to "further characterize the subsurface geology and ground water flow pathways", for a report to DEC in October 2006.
- Remediation System Modification - additional extraction wells and new treatment equipment to modify the existing groundwater remediation system at the fire reservoir site. To be finished in the fall, with a report submitted to DEC in November 2006.

The final sentence of the update states "All documents relating to the ongoing investigation in Ithaca may be reviewed, as they become available, at the Tompkins County Public Library, 101 East Green Street, Ithaca, New York." ESC and EPT have (to their credit) made some letters available recently - see below - but recent documents from DEC and DOH have not been made available at the archive.

Dated July 28, 2006, the Report and associated map detail the results of soil tests performed along Turner Place June 6-8, 2006. Some of the samples are listed for depths as shallow as "0.5 - 2 Ft." and others are as deep as "6 - 8 Ft." There are many chemicals sampled and we see the same wide variations in test values that we've seen in the house air tests. The highest TCE levels are at the intersection of Columbia Street with Turner Place. This correlates with some of the higher sub-slab TCE readings in the homes above and below the west side of the intersection.

This intersection is also the spot where the overloading of the storm sewer system has been most evident. During heavy rains, the manhole cover near the intersection levitates with water that the sewer cannot contain. The ongoing Aurora Street sewer project is supposed to remedy this, by connecting a 24" diameter sewer line to the Town of Ithaca line which comes down Aurora Street. This new line will start at the intersection of Columbia and Aurora and run down to the Wastewater Treatment facility behind Aldi's. The existing 14" diameter line will continue to serve the "local" neighborhood needs. With the high TCE readings noted in the "NCR Sewer line" running from the EPT plant property to South Aurora Street, one can only wonder how much TCE has been carried through these sewer lines, and where it has settled.

City of Ithaca Common Council Resolution- August 2, 2006

The City of Ithaca Common Council unanimously approved a "RESOLUTION IN SUPPORT OF BLANKET MITIGATION AND EXPANDED HOME TESTING IN ALL NEIGHBORHOODS AFFECTED BY CHEMICALS FROM THE EMERSON POWER TRANSMISSION SITE". The Resolution calls for NYSDEC and NYSDOH to push the "responsible parties" to provide blanket mitigation of affected neighborhoods and to provide wider areas of testing at all times of the year. Council Members Maria Coles, Mary Tomlan, and Shane Seger were instrumental in moving this resolution through the process and we thank them for their help and hope that the statement will have positive effects.

Dated September 1, 2006, this Report details the findings of the tests performed in 26 neighborhood homes, including 15 homes not previously sampled. Based on the results and the NYSDOH decision matrix, 3 homes were designated "No further action", 21 homes will "require further monitoring" and two homes have been offered mitigation systems.   Details are provided for test results for all Phase IV tests, as are questionnaires and household inventory forms.

Report from "WSP Environmental Strategies LLC" (the new name for Environmental Strategies Consulting LLC) detailing the extraction well tests conducted January to June 2006, during which period the average system uptime was 80%.  The system removed 170,558 gallons of groundwater, including a half-pound of VOCs from the aqueous phase and approximately 31 pounds of VOCs from the vapor phase.  This brings the estimated total of VOCs removed by the system to approximately 350 pounds since the start of system operation. TCE levels ranged from 38 to 32,000 ug/L, cis-1,2-DCE from 15 to 8,100 ug/L, trans-1,2-DCE 89 to 92 ug/L, vinyl chloride 4.6 to 1,200 ug/L and methylene chloride 48 to 640 ug/L.  The report states "Since September 2004, when ESC Engineering began managing the 2-PHASE ™ extraction system, the concentrations of VOCs in these wells have exhibited no consistent trend."

Results of "Packer testing and sampling" performed onsite August 14 - 23, 2006.  The tests hoped to explore the nature of open horizontal bedding plane fractures present in extraction wells EW-1 and EW-3 at approximately 52 feet below the top of each well.  "The packer testing results indicate that the bedding fracture identified at 52 feet is a transport pathway for groundwater below the current remediation.  The results suggest that the horizontal bedding plane fracture has been intersected by a vertical conduit (joint set), which allows affected groundwater to migrate downward to the bedding fracture plane... the upper C-zone and B-zone wells are not in direct hydraulic connection with the deeper extraction wells."

Letter and Map from WSP describing the properties they intend to test as part of Phase V.  (The letter refers to "Table 1" which is not part of this copy.) They will test 18 properties that were sampled once during Phase IV.  Two properties have been offered mitigation but have not accepted the offer and will be tested again.  One home (Property 97b) will be sampled for the first time, as will the Ithaca City Court building and the Ithaca Police Department headquarters.  [Subsequent discussions supposedly added the Police garages to the list - they are located across from the IPD main building, below the "creek side" row of homes along the 100-block of East Spencer St.]

Reservoir Work Plan submitted by WSP. "The additional subsurface information gained from this investigation is necessary to complete the design upgrades to the remediation system at the site.  The proposed scope of work involves installing and sampling six open boreholes in areas hydraulically upgradient, cross-gradient, and downgradient of the fire reservoir and three shallow B-zone wells immediately surrounding the reservoir."

Supplemental Geophysical Survey - A 225-page report prepared by WSP, with all manner of theory and discussions of the additional Electrical Resistivity tests, with results displayed with various colorful graphs.  Fields notes and tables of points along the various lines are included, as are notes of anomalies found.  Unfortunately, there is no discussion about what all this might mean in terms of changes to be made in testing or remediation efforts.



Phase V Indoor Air Tests for Ithaca Police Department, City Court

The results from the Phase V tests performed in January and February 2007 are finally being released and received. Among those reports are results for the Ithaca Police Department and City Court Building, and the Garage/Sheds across the street. Site related toxins were found in both sites, with the highest levels in the sheds, which are located between the "creek side" of the 100-block of East Spencer Street and Six Mile Creek. These results complete tests along one path from the plant site to the creek, with high levels of TCE found up and down the path. That these toxins have moved roughly 1500 feet down the hill shows just how wide an area of South Hill the plumes involve. Expansion of the testing area is needed to find the "perimeter" of the plume, but significant actions to stem the toxins at the source (the plant site) are the more critical need.

Ambient Air Tests show more and more TCE

The "Outside" Ambient Air tests performed as a "background" reference for the ongoing indoor air tests are showing more and more TCE in the air we breathe. As these tables show, finding detectable levels of TCE in the "Outside" air was the exception in the results from Rounds I, II, and III, which were performed before most of the mitigation stacks were installed in our neighborhood. However, the results from Rounds IV and V show that detects are now the rule, not the exception. Given the number of stacks now exhausting TCE into our air, this is not entirely a surprise, but it IS distressing to think that we've moved the TCE from being largely trapped underneath our homes out into the air that's around us and streams into our homes. Is this really "mitigation"??

The Areas of Concern listed in the Onsite Assessment of the EPT site dated December 13, 2005, are finally getting some attention as Walter Hang, President of Toxics Targeting, Inc., has posted this letter to DEC Commissioner Grannis.  Maps of the Areas of Concern at the EPT plant site are in PDF versions here: Map 1  Maps 2-3.  That neither the NYS Department of Health nor the NYSDEC have organized any public meetings to discuss the many serious problems described in the Assessment is an "Area of Concern" in itself. Mr. Hang's News Release is discussed in the April 26, 2007 Ithaca Journal. Thank you, Walter, for sounding the alarm again.

The May 1, 2007 Ithaca Journal carries a trio of stories (as well as download links for many source documents) discussing the history of problems at the Wallace Steel site. The huge quantities of metal scrap (from Morse Chain, NCR, Ithaca Gun and Smith Corona) which passed through the Wallace site were generally coated with oil, some of which leaked off during transit and during storage and handling at the dump site. Reports of leaks of oil into and onto the water are cited. (Unfortunately, this article is no longer online.)

Ithaca Mayor Carolyn Peterson asks DEC for EPT Cleanup of Contamination Source

On May 23, 2007, Ithaca Mayor Carolyn Peterson sent this letter to DEC Commissioner Grannis, regarding the EPT site and stated, "This serious and ongoing affront to the health and safety of our community must receive the fullest extent cleanup as is possible. I understand there are a number of mitigation possibilities that can improve the indoor air quality of the affected homes. Mitigation should be installed forthwith; enough testing has been done. Secondly, source cleanup is essential through removal of the contamination. Thirdly, an immediate and thorough investigation of the former Wallace Junk Yard should be conducted immediately." Mayor Peterson also offers her office as a source of help for any public outreach the DEC cares to make. Thank you, Mayor Peterson!


DEC pressures EPT for Unified Remediation Plan; Expanded Area for Home Testing

49 Properties added to Study Area, including some large rental units

DEC-Proposed Phase VI Area (yellow shading):

The detailed response from the DEC to EPT's May 3, 2007 Supplemental Remedial Investigation Work Plan is a 12- page document. The first 5 pages are a May 31, 2007 letter from Gregg Townsend (DEC Regional Hazardous Waste Remediation Engineer) to Derek Chase of EPT, spelling out modifications that EPT is to make to their proposed Work Plan. The next 6 pages are relevant excerpts on "REMEDY SELECTION" from the "DRAFT DER-10 Technical Guidance for Site Investigation and Remediation, December 2002". The last page is a color map (right) showing the proposed expansion of the home testing area for "Phase VI" - expanding the area eastward up Prospect, Pleasant, and Columbia Streets, and Hillview Place, to their intersections with South Aurora Street. This is a significant expansion of the area being tested, and seems to have been dictated by the high levels of TCE found at test points on the EPT site near South Aurora Street, east of the existing study area.

EPT's response to this DEC letter was issued on June 20, 2007, in the form of a 5-page letter from Sheila M. Harvey, Esq., of Pillsbury Winthrop Shaw Pittman LLP, listing points of agreement and points of contention with the plan revisions requested by DEC. EPT does NOT want to drill and take borings in the bottom or sides of the fire reservoir. EPT wants to go (very) slowly on testing in the proposed Phase VI area, and EPT feels "it is not physically possible to meet the deadlines in the specified timeline" spelled out in the DEC letter.


(Please click on the map for a PDF version.)


Full Report of Phase V Indoor Air Tests Released

On June 15, 2007, WSP released the full report of the "Indoor Air Assessment Phase V Sampling Event". While the results of testing at the Ithaca Police Department and City Court building were made public earlier, this report has full details for all the tests performed in Phase V. The search for the "clean perimeter" of the toxins plume does not seem to be making much progress - almost every TCE test performed in this round on properties also tested in Phase IV had higher results this time.  The Police properties and City Court building were the only properties added for Phase V. The full report is now online and split into segments for easier retrieval: Main Report, Pre-Site Visit Questionnaire and Product Inventory Form, "Data Usability Summary Report" (cover page only), Summary Tables Part 1, and Summary Tables Part 2.

WSP Releases EPT "Supplemental Remedial Investigation" Work Plan

WSP Environmental Strategies has submitted a Supplemental Remedial Investigation Work Plan, dated June 29, 2007, on behalf of Emerson, responding to the changes requested by the NYSDEC in a letter dated May 31 (below). The report is lengthy, attempting (as requested by NYSDEC) to coordinate more of the intended activities into single planning documents. The Plan discusses:
- soil borings and investigations into the identified "Areas of Concern",
- further investigation of the Fire Water Reservoir,
- installation of additional monitoring wells and more exploratory borings to continue the geophysical surveys,
- soil vapor testing in the Phase VI area (for which NYSDEC has requested indoor air testing), and
- soil vapor testing in "groundwater discharge" areas.

In addition to the Work Plan text (discussed above), WSP released various maps:
- Topographic map of the EPT Site Location,
- Areas of Concern, showing intended soil borings, soil vapor points, and test locations,
- Former and Proposed vapor point locations, downhill from the plant,
Former and Proposed vapor point locations, uphill from the plant, along the "NCR Sewer",
- Proposed Exploratory Boring and B-Zone monitoring Wells, most downhill from the plant,
- Identified Structural Features and points for further exploration
This last map shows some of the fractures and other structures that were identified through the electrical resistivity studies performed last year, showing "fracture trends" that seem to correspond with some of the locations of the higher TCE readings found in indoor tests.

Community Leaders and Residents ask DEC to Maintain Scope of Work and Timetable for Remediation

84 residents, including officials of the City, Town, and County, Landlords, and other concerned citizens signed a letter sent July 17, 2007 to NYS Department of Environmental Conservation Commission Alexander "Pete" Grannis to request that he not accept any delays or reductions in the scope of his agency's landmark proposal to investigate and clean up 25 "Areas of Concern" involving the contaminated Emerson Power Transmission facility.  "We are extremely grateful that Commissioner Grannis recently took a firm stand on cleaning up hazards associated with Emerson's chain factory, but we asked him to oppose the company's attempts to reduce the effectiveness of the DEC's plan of action," said Walter Hang, who wrote the letter.

DEC allows Emerson six extra weeks for "field work" and initial testing

Despite the letter sent by community residents and local leaders to the DEC (see below), requesting that the DEC not allow the timetable to slip, the DEC has extended the deadline for finishing the "field work" steps of the Remediation Investigation Work Plan by six weeks, from August 31 October 12.  Subsequent deadlines have been similarly pushed back. The DEC letter is here, and a "Question & Answer" summary the DEC prepared is here.  An item of great concern is the DEC's apparent willingness to accept the curbside soil vapor testing to be performed in the Phase VI expanded test area as an indicator of which homes in the area to choose for indoor air testing.  We feel this is very ill-advised.  The many well and soil vapor tests that have been performed throughout the study area have shown very little correlation to the indoor air test results inside the structures away from the curb. The DEC's ongoing "temporal" testing has shown great variations even within single homes where multiple test points have been installed. The area's residents are most affected by the air inside their homes - not the vapor in their curb lawns!  Testing should be performed on all homes in the affected area, and blanket mitigation should be offered to all homeowners in neighborhoods where homes have had TCE air detects.  The results of one or two tests cannot be justified as a basis for a declarations of "No Further Action".

The "Final Soil Vapor Testing Report - South Hill Elementary School", dated August 21, 2007, details how "low concentrations of certain VOCs were detected in the soil vapor samples collected on the school property. Trichloroethene (TCE) was detected at concentrations ranging from 0.492 to 8.36 ug/m^3." The report presents results from tests along and around the "NCR sewer", which runs down S. Aurora Street from the former NCR site further up South Hill, to support the theory that the toxins found on the school grounds originated at NCR, not at Morse or Emerson.  We are told that follow-up testing (involving 18 canisters of air taken from the school's sub-slab and from crawl spaces, but NOT from classroom or office space) has been performed, but further details or results have not been released.

Supplemental Remedial Investigation Report Released by WSP/EPT

A comprehensive report on the 2007 tests and studies performed by Emerson's consultants, WSP Environmental Strategies has been released, and an electronic copy was provided to us by the NYSDEC - Thank you!  The report discusses the findings of tests performed in and around the "Areas of Concern" on the EPT site, the continuing investigations into the "Fire Water Reservoir" (see Figure 8), the evaluation of the bedrock under the plant (which extends into our neighborhoods) and the results of soil vapor tests throughout the study area, including the Phase VI expansion area, bounded by Columbia Street, Turner Place, Prospect Street, and South Aurora St. (see Figures 13-14)  There are discussions, tables of results, maps, and "conceptual block diagrams" of the bedrock.

Much attention is placed on the "NCR Sewer", which has been the site of high TCE readings where it runs along the EPT plant site and South Aurora Street. These new readings confirm the path of pollution along Aurora Street, Columbia Street, Turner Place and down to East Spencer Street. The readings also confirm the suspicion that TCE has been leaking all along from the Fire Reservoir area down the hill into our neighborhood.  We look forward to analysis of the raft of new material by the representatives of NYSDEC and NYSDOH at the next Public Meeting.



The first significant event of the new year was the Public Meeting with representatives of NYSDEC and NYSDOH, held January 24 at the Ithaca Town Hall.  With the release of the exceptionally high test results from November 2007, the most immediate task-list discussed at the meeting included the re-testing of those properties with the high results. These re-tests were underway when two properties on East Spencer Street were damaged by fire, so the tests were conducted yet again.

Two Work Plans were released at the time of the public meeting:
A Vent Sampling and Analysis Work Plan (January 23, 2008) and
a Sewer Manhole Assessment Work Plan (January 24, 2008).
These plans address concerns raised during 2007 and at the public meeting. No explanation has yet been given for the 18,900 ug/m^3 TCE reading found in the MH-4 manhole at the corner of Turner Place and Columbia Street - they'll test manholes along Turner Place and East Spencer Street.  The vent sampling will test the vents installed on two homes on East Spencer Street to measure toxin content of the exhausted air. How much can be learned from two short tests on one day at two properties is not clear. The ambient air TCE levels along Spencer Street seem to be rising and increasing in number.

Results have been released for the various re-tests of ambient air levels that were conducted in early February 2008, after extremely high test values were detected in November 2007 - they were sent to the property owners, Postage Due.  These results seem to be more in line with the earlier, lower-level readings, but the levels, both inside "mitigated" homes and in the ambient air around them, are creeping up.

The (Amended) "Final" Supplemental Remedial Investigation Report, dated April 4, 2008 was sent by WSP to the DEC which kindly sent a copy to us. The Report is comprehensive - this portion includes almost 250 pages at over 10 MB PDF size - but seems to have few details on likely remediation steps.


The May 7 edition of the Ithaca Journal contains the front page report, and their web site has the report and links to relevant documents. Morse officials knew of the presence of TCE in their fire water reservoir in August 1972. The online links include one to the 10-page complaint Emerson filed against Borg-Warner (the parent of Morse Chain when it was sold to Emerson in 1983) alleging "fraudulent misrepresentation of the condition of the plant at the time of its sale".


Dated April 25, 2008, WSP released the 133-page "Supplemental Remedial Program / Alternatives Analysis" (SRP/AA) for the Morse site. It contains the usual site history and topographic map we've seen before, but talks more of their theories of what they're finding, presents rehashed summaries of earlier test results, and suggests some possible ways of remediating four of the "Areas of Concern" on the plant grounds.

The following files have this documents sections, but these have been superseded by the "Revised Final" SRP/AA document, released September 23, 2008, below.

The Full (133-page) Report - 11.6 MB PDF
Report text sections (Pages 1-96) - 609
Fig 1 - Site Location Topo Map
Fig 2 - Aerial View of Site
Fig 3 - Conceptual Site Model
Fig 4 - Geologic Cross Sections
Fig 5 - Vapor Migration Model
Fig 6 - Soil Vapor Migration Pathways
Fig 7 - Quarterly Groundwater Results
Fig 8 - Site-Wide Groundwater Results
Fig 9 - Fire Water Reservoir Groundwater Results
Fig 10 - Proposed Supplemental Exploratory Boring Locations
Fig 11 - Proposed Exploratory Well Locations
Fig 12 - Building Layout
Fig 13 - Proposed Boring Locations: AOC 1, 15, 24
Fig 14 - Proposed Boring Locations: AOC 4

Fig 15 - Proposed Additional Soil Vapor Point Locations

The DEC reviewed the April version of the SRP/AA, and asked for revisions. The WSP/EPT response to those requests is here.

The "Revised Final" SRP/AA document, released September 23, 2008, reflects the negotiations between WSP, EPT, and the DEC.

The Full (128-page) Report - 10.6 MB PDF
Report text sections (Pages 1-96) - 279.7
Fig 1 - Site Location Topo Map
Fig 2 - Aerial View of Site
Fig 3 - Conceptual Site Model Beneath Fire Water Reservoir
Fig 4 - Geologic Cross Sections
Fig 5 - Distribution of Affected Groundwater (B-Zone)
Fig 6 - Distribution of Affected Groundwater (C-Zone)
Fig 7 - B-Zone Groundwater Contour Map
Fig 8 - C-Zone Groundwater Contour Map
Fig 9 - Conceptual Model - Vapor Intrusion along Turner Place
Fig 10 - Soil Vapor Migration Pathways
Fig 11 - Quarterly Groundwater Results
Fig 12 - Site-Wide Groundwater Results
Fig 13 - Fire Water Reservoir Groundwater Results
Fig 14 - Supplemental Exploratory Boring Locations
Fig 15 - Proposed B-Zone and C-Zone Extraction Well Locations
Fig 16 - Building Layout
Fig 17 - Proposed Boring Locations: AOC 1, 15, 24
Fig 18 - Proposed Boring Locations: AOC 4
Fig 19 - Proposed Additional Soil Vapor Point Locations

Emerson has proposed steps to "enhance" the groundwater extraction system around the Fire Water Reservoir (FWR) - the results of the system's operation over the last 12+ years are unimpressive.

The DEC is continuing limited testing in some of the homes in the Phase VI expansion area. Full Soil Vapor Intrusion testing, if they decide it is needed, will take place during the upcoming heating season.


The September 23, 2008 Vent Sampling Report is not much reassurance to those of us who have complained that the toxins levels in the ambient air - especially along East Spencer Street - have been getting higher. The report details the procedures used to determine that the output from the stacks, each tested three times during a day in July, 2008. Though the TCE levels detected, measured in micrograms per cubic liter, are almost all higher than the NYS indoor air standards, that's not the standard that is applied here. WSP gets to use "the 1.0 pound per hour (lb/hr) control requirements stated in 6NYCRR (Part 212.)"  - from page 2 of the report. A pound per hour - for toxins normally measured in micrograms per cubic meter!  This allows them to conclude (on page 6 of the report) that "emissions from mitigation systems are not a source of concern for TCE and PCE in the ambient air in the South Hill community."

While they cite stack emission rates of all the site-related volatile organic compounds (VOCs) tested to be no higher than 0.1101 pounds per hour, at that rate, it takes less than 10 hours for that vent stack to spew out a POUND of these toxins for which air standards are measured in micrograms per cubic meter. The data appendix with all the results is here, but it's a 24 MB file.


The Vent Sampling Report was released September 23, 2008, but the problems with some of the data presented were not acknowledged by WSP until August 16, 2011. As discussions heated up on the proposed "remedial step" of installing a vented sewer along East Spencer Street, concerns developed about the many stacks in the neighborhood and the fact that the WSP report suggested that pounds of toxins were being released daily through the SSDS vent stacks. This is the explanation sent to us for the source of the error:

A review of Table 3 (Mass Emission Rates) shows the reported emission rates are incorrect (actually lower by 10,000). First, the conversion from ug/m3 value to g/m3 was incorrect by a factor of 1,000 and the conversion factor (CF) used to convert cubic feet per minute (cfm) to meters cubed per second (m3/s) for use in developing the emission rate via EPA Method 18 was incorrect by a factor of 10 (original calculation spreadsheet used a value to 4.719 x 10-3 and it should have been 4.719 x 10-4 The corrections of these two conversion factor errors are incorporated into a revised Table 3 (Attached).

The corrected "Table 3" is here. Please note that the originally values reported were 10,000 times higher than what they now believe to be coming out of those stacks.



Interested neighbors, City officials, and members of the media met with representatives of the NYS Department of Environmental Conservation (DEC) and the NYS Department of Health (DOH) on in two sessions on March 5th, to discuss the proposed amendments to the 1994 "Record of Decision" and the steps proposed to "upgrade" the clean-up efforts on the Emerson Power Transmission (EPT) site.

The agency officials expressed their belief that the "infamous" Fire Water Reservoir still needs to be cleaned up, but the main source of the soil vapors now intruding into neighborhood homes seems to be the sewers. EPT admits that TCE was dumped into the sewers running down South Cayuga Street and Turner Place. Test readings along those sewer lines remain high. Test readings along Columbia Street and East Spencer Street are also high, but the toxins in those lines also include contaminants from the Therm and NCR/Axiohm sites.

The remediation of the sewers is expected to be proposed in the next months and will be the subject of an additional Public Meeting. Expansion of the areas in which homes and the soils under them will be tested will also continue. Susan Shearer of the NYS DOH commented on testing the vapor exposure pathways into the various neighborhoods: "We follow wherever the data takes us and we haven't stopped yet." Tests have been performed along South Aurora Street already and released to the homeowners. Results of preliminary tests along the sewer lines from Therm have just been received and are being evaluated.

An Adobe PDF version of the slide show presented by the NYS officials is here.

The Amendment document is here - a 3.4 MB PDF. Public comments in written form are invited, and should be sent to the DEC's Gregg Townsend by March 20. We are grateful to Gregg for providing us with these documents as well as the slide show copy.

The Remedial steps discussed in the Amendment are limited to changes ON-SITE at Emerson.  They have already "upgraded" the groundwater extraction system which has been attempting to remove contaminants from the Fire Reservoir Area since the early 1990s.  A plan is in place to better evaluate the system's effectiveness. The document notes that
"A TCE concentration of 43,000 parts per billion (ppb) was detected in a sample collected from this area as recently as July 2007. (The corresponding groundwater quality standard for TCE is 5 ppb.)"
- So there is clearly a LONG way to go toward remediating this area.

In Situ Chemical Oxidation (ISCO) is proposed for the initial cleanup of the "Former Department 507 Degreaser" area groundwater, followed by Monitored Natural Attenuation (MNA). This is proposed with various tests needed to determine if the groundwater is really being cleaned up and to what extent nearby groundwater is affected. The contaminated soils in this area simply will be capped in place, with various restrictions implemented to limit access and use, to avoid disturbing the encapsulated contaminants.

Other areas on the plant grounds will be capped with asphalt to try to keep the contaminants from reaching the ground surface, while some areas which now have "a weathered petroleum product" will be excavated and removed.  Basements of on-site buildings into which the contaminants have been leaking will be sealed and caulked.  Building 24 (once home to some operations of the PRI and other non-profit groups) will be abandoned and access to it restricted.

Though the Amendment document discusses (on page 6) the residual contamination of the Turner Place and South Cayuga Street sewers and acknowledges the adverse impact on air quality in neighboring homes, no solutions or proposed remedial steps are presented.  The document states:
"Remedial actions to address the off-site migration of contaminated soil vapor will be selected by the NYSDEC following EPT's evaluation of the investigation results and completion of an alternatives analysis."
In other words, real remediation of the toxins "off-site" - in our neighborhoods - is left for discussion some time in the future, even though the "final" SRP/Alternatives Analysis report was released last September (above, in 2008 section).

Discussions of test results along the sewer lines coming down the hill from Therm, IC, NCR/Axiohm, as well as Emerson are in this web site's Sewers section.

At the end of March 2009, Emerson's Consultants, WSP, released two documents concerning the significant changes made to the groundwater treatment and extraction system in the Fire Water Reservoir area. This is considered an "Interim Remedial Measure" (IRM) and activities supporting it were accomplished before the "final" amendments to the Record of Decision for the plant site were approved. The reports issued are the IRM Construction Completion Report and the IRM Operation, Maintenance and Monitoring Plan. (The OM&M document is about 26 MB - it will take a while to download.)

We are very grateful to Karen Cahill of the Syracuse DEC office for passing along these documents along to us. Ms. Cahill tells us, "This effort was very extensive on Emerson's part and it is anticipated that the addition of the Dual-Phase Extraction system will enhance CVOC removal efficiencies.  It will take a few years of monitoring the system and removal rates before any firm conclusions can be drawn, but the first two progress reports are very encouraging."

We are very grateful to Gregg Townsend of the Syracuse DEC office for passing along this document. Very little was changed from the "Proposed ROD Amendment" issued in February and presented at the March 5 Public Meeting. The document was formally approved on June 18 by Dale A. Desnoyers, Director, Division of Environmental Remediation. Some details of the EPT on-site work have not yet been submitted for DEC review, including the "work plan" for testing needed to select the appropriate technology for in-situ treatment.

A "Responsiveness Summary" (Appendix A) has been added to include written comments received from the public and from WSP (Emerson's consultants.) Only the WSP comments warranted even text changes in the document. Comments from others were "answered" with unyielding responses. Consider the comment from Walter Hang (Appendix Page A-4):

COMMENT 12: Abandonment of buildings does not eliminate underlying contamination hazards. The pollution should be removed.

RESPONSE 12: The abandonment of Building 24 is an initial step to insure the protection of human health. As discussed earlier, additional remedial measures (e.g., groundwater extraction and treatment, in situ groundwater treatment, free product removal) will be implemented throughout the plant to directly address contaminant sources.

In discussing ISCO (in-situ chemical oxidation), the document refers to how "the oxidant had been successfully distributed throughout the contaminant plume" (Appendix Page A-3), but the reports of the subsequent test results from the Axiohm site show that several of the test wells there were unaffected by the ISCO treatment. It still remains to be seen if any of the proposed steps for the EPT site will actually reduce levels of toxins present.

Also remaining to be seen are any signs of progress toward proposals for cleaning up the surrounding neighborhoods. The pace of this process is frustratingly slow. The January 2008 Public Meeting suggested that we would see a "Proposed Remedial Action Plan" (PRAP) in "Early April 2008", with "Remedial Action Start" in July 2008. The March 2009 Public Meeting told us that the ROD Amendment would be implemented this summer, but also suggested that the Off-site Vapor Migration effort would have the "Proposed Alternative Identified/Public Comment" in June 2009. The latest "South Hill Update" says:

The PRAP will be distributed for public review and comment in late August 2009, with a public meeting anticipated some time in September 2009. Upon the close of the public comment period, a final remedy to address the migration of soil vapor into the surrounding
neighborhood will be selected by the NYSDEC in a separate Record of Decision.

Should you wish to read the latest ROD Amendment document, it is online as a single file or in sections:

Entire Document
Report section
Appendices A & B

On August 12, Emerson Power Transmission (EPT) announced plans to shut down their operation here on South Hill. Most of the 228 current employees will lose their jobs. The facility is over 100 years old in many areas, so it is not the most efficient and up-to-date site for industrial operations. The closure makes consideration of how the plant site is remediated even more important - we've seen how the toxins left behind by a previous operation can become additional expenses for developers and municipalities with the on-going attempts to reclaim the Ithaca Gun site. Simply abandoning the buildings does NOT solve the problems.

Emerson's plans for remediating the South Hill neighborhoods near the plant have not yet been officially announced. We know that extensive clean-up of the sewers and the fill around them is necessary.


A "Preliminary Design" investigation into the levels of toxins under and around the EPT Fire Water Reservoir (FWR) was conducted in June and July 2009. The full report is here. Levels of TCE in the water within the FWR (up to 8100 ug/liter) and the groundwater around it (up to 530 ug/liter) remain high. How these findings may change the approach to on-site remediation is not known. A follow-up investigation report was issued on October 2.

The first "Progress Report" for Dual-Phase Extraction System Operation, Maintenance and Monitoring was issued October 30. It reports that they estimate almost 50 pounds of chlorinated VOCs were removed from the vapor phase passing through the system, and an additional 23 pounds from the aqueous phase, during the January - June 2009 reporting period.



The three-page sales flyer is here. No mention of the on-going clean-up or the buildings which have been closed to prevent them from exposing any more employees to toxic fumes.  It's a lot of land, with ample power, water and sewer. As it's about one-third in the City of Ithaca and two-thirds in the Town of Ithaca, the ultimate use of the site could be subject to various zoning requirements and decisions. Neighbors can only hope that a serious clean-up of the site and the neighborhoods which it affects will be accomplished before new tenants are exposed to the current facility's more toxic "features".

The NYS Department of Environmental Conservation (DEC) conducted the Public Meeting required for discussion of the Proposed Remedial Action Plan (PRAP) for the sewers downhill from the Emerson plant.  The DEC provided us with a PDF copy of the "slides" which provide an overview of the discussion. No one is happy with the proposed remedy, but it is felt that any more substantial (and costly, disruptive) steps would be"technically impractical". As the remedy and the expected "Record of Decision" are considered the final steps in the cleanup, there was discussion about how little measurement of the results of the effort is proposed.

The 66 neighborhood homes which have mitigation systems or have been offered such systems would keep them running for protection. No in-home testing of these or any other nearby homes is required or expected.  This decision applies only to the homes in "Operable Unit 3" - corresponding to Phases 1 -5 of the initial home-testing.  Further work is expected in Phases 6 and 7, extending from lower Columbia Street to Hudson Street.  Phase 7 will probably be expanded.

A letter of comments submitted is here. The supporting figures are here.

The “good news” is that some of the hard-working employees of the NYS Department of Environmental Conservation (DEC) have managed to overcome the obstacles of severe budget cuts (results of Albany dysfunction and economic disaster) to finally release a Proposed Remedial Action Plan (PRAP) for the sewers downhill from the Emerson plant.  The PRAP specifies removal and replacement of about 300 feet of sanitary sewers along East Spencer Street, starting at the intersection with Turner Place.  Vented pipe would be installed along with new sewer line into the sewer trench, to allow any soil vapors to escape.

That’s the only “Remedial” action specified in the PRAP.  The mitigation systems already in place would remain in operation.  The proposed action will seriously disrupt the residents of East Spencer Street, as well as anyone who normally travels this street.  This area contains homes which had high test levels of TCE indoors, but there are dozens of homes with high test levels that are relatively distant from this 300-foot section of street.


The document is here. The DEC seems to fallen back on the relatively UNprotective standard for indoor air TCE contamination still held by the NYSDOH (5.0 ug/m^3), and determined that only the nine mitigation systems installed into homes that exceeded that standard will count in their evaluation of which areas of the hill should be remediated.  Because the homes which received those mitigation systems are clustered at the east end of East Spencer St. (mostly - except for the 3 up hill along South Hill Terrace), they feel that only that section of East Spencer St requires remediation.

They're so sure of their theories that they will not test homes for indoor air to see if their theoretical remediation even works.

Homes that met Emerson's "voluntary" mitigation standard of 0.8 ug/m^3 should be glad they got their systems from Emerson, as other homes exceeding that standard, but not having readings over 5.0, will not get help from the DEC.  The mitigated homes which didn't hit the 5.0 standard were not considered in determining which areas need remediation.  Many other states are more protective of their residents.

The DEC document states:  (ROD pp. A-3 and A-4)
It is not necessary to expand the sewer replacement to include areas on Turner Place and South Cayuga Street.  Elevated levels of TCE and other VOCs were detected in some soil vapor samples collected along Turner Place and South Cayuga Street, however, based on the soil vapor intrusion evaluation, in conjunction with our overall understanding of the site's geology, the areas within OU No. 3 where there is a potential for exposures related to soil vapor intrusion have been identified and appropriate actions have been taken.

Blanket mitigation within OU No. 3 is not warranted.  As discussed in Section 5.2 of the ROD, nine mitigation systems were installed.  The data does not support the installation of additional systems.

No further testing of homes is warranted, however it should be noted that the remedy has been modified to include monitoring of the venting system, which will include, at a minimum, testing of the standpipe(s) emissions after the venting system is installed (see response to Comment 5).

The replacement of the 300-foot section of the East Spencer Street sewer line will certainly cause much disruption to a neighborhood that is experiencing upheaval due to the Prospect Street work and the East Clinton Street bridge work.  Whether the replacement makes much difference in anyone's indoor air will be left as an exercise for the homeowners - DEC will not require any tests to find out.




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