Eastman Kodak Company - Kodak Park

EPA Identification Number:	NYD980592497
Facility Location:	1669 Lake Avenue, Rochester, New York
Facility Contact Name:	Joan F. Berner, (716) 477-1300
EPA Contact Name:	Wilfredo Palomino, (212) 637-4179, palomino.wilfredo@epa.gov
New York State Department of Environmental Conservation (NYSDEC) Case Manager:	Keith Gronwald, 518-4028590, khgronwa@gw.dec.state.ny.us
Last Update:	March 2008
Environmental Indicator Status:	Human Exposures Under Control: No status has been recorded. Groundwater Contamination Under Control [PDF 48.32 KB, 21 pp] has been verified.

Site Description

Kodak Park covers over 1,100 acres, across nearly 4 miles through the City of Rochester and the Town of Greece. There are more than 125 manufacturing buildings supported by an infrastructure that includes nearly 30 miles of roads, power generation facilities for steam and electricity, its own sewer system, railroad, fire department and water treatment facilities.

Kodak Park is has been segmented into six sections identified as KPE, KPW, KPX, KPM, KPS, and KPT. Most of the developed portion of the facility is confined to the first four sections from KPE bounded on the east by the Genesee River to KPM that borders NYS Route 390 to the west. A mix of commercial, industrial and residential properties surrounds the 22-mile facility perimeter.

On March 5, 2007, we received a notification from Kodak to close all permitted tank and container areas at the facility (Building 218 tank and container storage areas) by the end of summer 2007. Also, the storage of hazardous waste from off-site Kodak-affiliated facilities and local nearby municipalities will be discontinued. All on-site generated hazardous waste will be shipped off-site for treatment and/or disposal within the time period allowed for exempt storage (less than 90 days). Once the closure of tanks, container storage areas, and Rotary Kiln Incinerator are completed, most requirements of the EPA Resource Conservation and Recovery Act (RCRA) permit will be substantially modified as there will no longer be any active RCRA units.

New York State Department of Conservation (NYSDEC) has public noticed the Part 373 RCRA Permit which covers generation and storage of hazardous wastes in all active RCRA units. The draft Part 373 permit covers several units such as tanks, containers, and wastewater sludge incinerated in the multiple hearth incinerator. The public comment ended on March 12, 2007, and the same day a Legislative Public Hearing and Issues Conference will be held in the City of Rochester, New York. Also, a pre-adjudicatory hearing issues conference was held on March 13, 2007. At the time of the Legislative Public Hearing, NYSDEC and Kodak made a joint petition to adjourn the Issues Conference and pre-adjudicatory hearing for a later date since there are several outstanding issues to be clarified and resolved as a result of Kodak's notification to close all active RCRA units at the Facility.

Presently, Kodak is regulated under an EPA permit issued in 1986 (extended in accordance with 40 CFR 270.51(a)) and under NYS Interim Status, a Consent Decree with EPA and Department of Justice entered in 1995, and Consent Orders for investigation and remediation issued by DEC. DEC public noticed a draft Part 373 permit in February 2004, and for a second time on February 20, 2007. We anticipate issuance of permit in FY08.

In early 2007, Kodak closed the Building 218 chemical waste Rotary Kiln Incinerator. It will continue to operate the the multiple hearth incinerator, which treats sludge from the on-site wastewater treatment plant.

The closures are part of the continued reduction in Kodak Park assets and infrastructure, reflecting Kodak's transformation to a digitally oriented company. The decline of about 50% in production volumes during the last 5 years of traditional photographic products is the biggest factor leading to the decision to close the Rotary Kiln Incinerator, tank and container storage areas. The multiple hearth incinerator will be included in the Part 373 permit.

Approximately 670 solid waste management units (SWMUs) were identified during the RCRA Facility Investigation (RFI). SWMUs have been grouped into twenty eight (28) investigation areas for the administration of corrective actions. Since 1988 Kodak has completed more than 82 hydrogeologic investigations. As of March 2007, Kodak had formally completed the RFI step for approximately 450 of the 670 SWMUs. Corrective measures studies have been completed for more than 269 SWMUs. Final remedies have been implemented for more than 202 SWMUs. For the last 26 years, Kodak has conducted numerous subsurface investigations and interim remedial actions (source removal, pump-and-treat programs and containment trenches) on-site on a voluntary basis, and off-site in response to Consent Orders.

According to the Draft Part 373 permit, most of the SWMUs at the site present no threat to human health or the environment and presently require no further action. However, there are still a large number of SWMUs that require further investigation or are undergoing RCRA corrective action. Due to the large number of SWMUs and the size of the facility, Kodak has prioritized corrective action through a Facility Stabilization Program that has included interim corrective measures and investigative activities. The interim corrective measures along with the Industrial Sewer Assessment Program, Soil Management Plan and the Ground Water Monitoring Program (with minor enhancements or variations) have been adopted as final corrective measures.

Kodak is currently operating 33 ground water pumping systems. The primary function of these pumping systems is to provide ground water hydraulic control of contaminated ground water. As of August 2006, these systems remove over 55 million gallons of water per year for treatment at the on-site wastewater treatment plant.

Most of the pumping wells are monitored via a telemetry system. Data loggers record water levels and flow rates for each well in the system where these devices are in use. Kodak polls the data loggers via modem from a computer. Pumping rates for the systems are monitored by magnetic or mechanical flow meter instrumentation. Since 1988, it is estimated that over 600 million of gallons of ground water have been removed and treated at the facility.

Potential Threats and Contaminants

Investigations conducted by Kodak indicate soils on site have been contaminated with metals, as well as volatile and semi-volatile organic compounds. Ground water is contaminated primarily with volatile organic compounds, although other constituents have also been detected at elevated concentrations. Contaminated ground water in the shallow flow zones is generally contained on-site. Limited off-site migration of contamination in deeper bedrock ground water has been previously identified adjacent to several areas of Kodak Park. To address these areas, Kodak has installed containment/treatment systems which are currently in operation. Off-site ground water in the area is not currently used as a potable water supply. Potable water is supplied by the Monroe County Water Authority, and is obtained from surface waters nearby. Based on sample data obtained by Kodak, there is no evidence that any surface water used for drinking has been impacted from this facility. The extracted and treated ground water is discharged into the Genesee River under a New York State Pollutant Discharge Elimination System (NYSPDES) permit.

Soil gas and indoor air testing have been conducted in several residential areas adjacent to Kodak Park in the past. These studies did not indicate an impact to the community. However, Kodak is currently performing an off-site Soil Vapor Intrusion. There are areas where soil gas data gaps exist along Kodak's perimeter that need further evaluation. With regard to the on-site Soil Vapor Intrusion, EPA is conducting a nationwide investigation on how to approach it. Currently, there are discrepancies between the facility and New York State Department of Health (NYSDOH) on the exposure limits and guidance standards. Kodak and the agencies are currently negotiating the appropriate evaluation/mitigation criteria for an industrial facility such as Kodak Park.

Cleanup Approach and Progress

Access controls are in place, which limit potential exposures to contaminated soils. These measures include capping, fencing, paving or otherwise covering the soils to preclude direct contact. An Excavation Control Master Plan has also been implemented. This plan sets out the procedures and operating controls that must be followed for all subsurface excavation activities at the site. The active tank systems (HWMU-07 and -20) are closed. The previously closed tank systems (combination of permitted and interim status tanks that were closed as a part of the STIP program and consent order) have been included in Kodak's Corrective Action Program and are being addressed accordingly. Historic releases from these units have mixed with plumes from other SWMUs at the facility making it impractical to perform independent ground water remedial programs.

Finally, there are two NYSDEC active orders for corrective action (Study Area No. 1 and Weiland Rd. Landfill). Kodak will perform an evaluation whether these investigations are redundant or duplicative in view of the issuance of the permit. EPA has issued an administrative order requiring an assessment or investigation for the Industrial Sewer. The federal order, however, does not address corrective action. Although Kodak has upgraded or repaired a large portion of the sewer system under the EPA order, an investigation and remediation (if warranted) of potential environmental release is still outstanding in some sewer areas.

Groundwater
Due to the release of dense non-aqueous phase liquids and the fractured bedrock underlying this site, restoration of ground water quality to drinking water standards may not be technically achievable (even though NYS classifies all ground water as potential drinking and its goal is to restore aquifers, the State recognizes that there are circumstances where this is not possible). Therefore, the general approach that has been used is hydraulic containment of all ground water on site. Ground water recovery methods in use include overburden french drains, conventional pumping wells, hydro fractured bedrock wells, and fractured bedrock trenches created through controlled blasting (using explosives on-site to create rock fractures). Recovered water is treated at Kodak's wastewater treatment plant.

Interim Corrective Measures
Kodak has implemented ground water actions at many locations. Kodak also implemented a dual phase soil vapor/ground water extraction system in response to a major spill from a solvent transfer line. Since 1990, Kodak has also excavated approximately 150,000 cubic yards of contaminated soil for proper disposal. In 1999 Kodak also completed a storage tank improvement program. Under this program, initiated in 1988, Kodak eliminated, upgraded or replaced tank storage facilities across Kodak Park, reducing the overall number of tanks from approximately 1,100 to approximately 450. Kodak has also implemented a sewer integrity assessment and upgrade program for sewer lines in hazardous waste service. Under this program approximately 11 miles of industrial sewer have been evaluated and/or upgraded to lower the risks of potential releases. Re-inspections of sewer lines are ongoing. In 1998 Kodak also started a five-year capital improvement program, costing approximately $27 million, to upgrade sewer lines in hazardous waste service. This is an ongoing program to be completed in 2007.

Environmental Indicator Status or Projection

Current Human Exposure Under Control
Kodak didn't achieve a positive determination of human exposures due to the complexity of this site and the ongoing evaluation of risk assessments on emissions of incinerators and other sources. Kodak's human health risk assessment's that included historic measurements of indoor air from nearby residential areas demonstrated that volatilization of hazardous constituents from the site were not a public health problem off-site.

Additional off-site Soil Vapor Intrusion evaluations will be implemented in 2007-8 (second phase) to confirm results of previous studies and fill Soil Vapor Intrusion data gaps at specific perimeter locations. Upon agreement of study protocols, an on-site Soil Vapor Intrusion evaluation will be conducted since there are contaminated plumes under buildings. Kodak has conducted a human and ecological risk assessment report for its two on-site incinerators. A positive determination for human exposures controlled is expected to be achieved in FY'2009.

Migration of Contaminated Groundwater Under Control
Preliminary data of ground water monitoring wells placed on the facility boundary suggests that presently there is no migration of contaminated ground water off-site in the shallow aquifer. However, there was off-site migration from the deep aquifers in areas Kodak Park West (KPW) and North East Kodak Park East (NEKPE).

A ground water migration under control was achieved in September 2005 once the remedial systems at KPW and NEKPE were found to be effective. The NEKPE remedial system, consisting of four recovery wells and two deep trenches measuring 80 by 190 feet and 80 by 420 feet is operational since June 2003. Kodak has also enhanced two deep-bedrock hydro fracture recovery wells operating since 1992 to address the off-site migration at area KPW. Data submitted by Kodak as part of its 2004-2006 annual ground water report showed that hydraulic control is being achieved at NEKPE and KPW.

Site Repository

Copies of supporting technical documents and correspondence cited in this site fact sheet are available for public review at:

USEPA Region 2
RCRA Records Center
290 Broadway, 15th Floor
New York, NY 10007-1866

The inspection of some of the documents cited in the site fact sheet may require a formal request under the United States Freedom of Information Act (FOIA).

NYSDEC
Bureau of Radiation and Hazardous Site Management
Division of Solid & Hazardous Materials
625 Broadway, 8th Floor
Albany, NY 12233-7252

The New York State Department of Environmental Conservation (NYSDEC) makes its public records available for a review under the Freedom of Information Law (FOIL).