Public Comment for Proposed Modification to Final Remedy, Crown Cork and Seal Facility, Omaha, Douglas County, Nebraska
EPA Region 7 invites the public to comment on the proposed modification to the cleanup at the Crown Cork and Seal Company facility (Crown). The public comment period will run from January 24, 2014 through February 24, 2014. Written comments on the proposed cleanup should be mailed or emailed no later than February 24, 2014, and should be sent to:
EPA Region 7 (AWMD/WRAP)
11201 Renner Blvd.
Lenexa, KS 66219
The Crown facility, 4133 South 72nd Street, is on a 38-acre parcel located southeast of the intersection of South 72nd and F Streets. The building occupying this site is approximately 300,000 square feet and surrounding land use is predominantly light industrial with no residential development. Constructed in 1954, the facility produces food cans. Chemicals used in the manufacturing processes have included chlorinated and non-chlorinated volatile organic compounds and some semi-volatile organic compounds.
In April 1998, Crown entered into a Resource Conservation and Recovery Act (RCRA) Administrative Order on Consent for Corrective Action (Consent Order) with EPA. As part of the Consent Order, Crown agreed to conduct a Focused RCRA Facility Investigation (FRFI), including a human health risk assessment, to define the environmental impact and potential human health risk from any potential releases of hazardous wastes and/or hazardous constituents.
In 2008, based on the work completed by Crown under EPA oversight, EPA established a final cleanup decision for the site incorporating public comment. That decision included: the requirement for engineered caps over several areas of the facility; institutional controls (ICs) to prevent future exposure to residual contamination in the subsurface; monitored natural attenuation (MNA) of groundwater contamination; and the operation of a skimmer pump in one area of the site to remove floating contamination in groundwater. Upon review of current conditions, and based on the limited potential risk posed by contamination remaining at the site, EPA has determined that the proposed engineered caps are not necessary to protect human health under current and future potential exposure scenarios. ICs to prohibit the installation of water supply wells and limit future use of the property to industrial/commercial uses are sufficiently protective of the exposure scenarios evaluated in the human health risk assessment.
CONTAMINATION AT THE FACILITY
EPA requires the investigation of Solid Waste Management Units (SWMUs) and Areas of Concern (AOCs), which are areas where hazardous constituents have been released or have the potential to be released into the environment. At EPA’s direction, the following areas were investigated by Crown:
|SWMU A||North Yard Disposal Area|
|SWMU B||Fuel Oil Underground Storage Tanks|
|AOC #1||Virgin Solvent Storage Tanks|
|AOC #2||Southeastern Drainage Ditches|
|AOC #3||Drum Storage Area|
|AOC #4||Scupper Drain Area|
|AOC #5||Lacquer Storage Tank Area|
|AOC #6||North Access Road|
Soil: Contamination in soil was found at the North Yard Disposal Area, the Virgin Solvent Storage Tanks, and the Southeastern Drainage Ditches. No significant soil contamination was found in the remaining areas investigated by Crown.
Groundwater: Contaminated groundwater was found beneath the North Yard Disposal Area, the Virgin Solvent Storage Tanks, and the Southeastern Drainage Ditches.
Indoor Air: Based on the findings of the investigations conducted by Crown, contaminant vapor intrusion to indoor air was determined by EPA to be insignificant.
Crown evaluated ecological and human health risk posed by contamination at the facility and followed EPA guidance. The potential adverse impact to the ecology of the site and surrounding area is insignificant.
Potential human health risk was evaluated for indoor facility workers, outdoor facility workers, construction workers, trespassers, recreational users of Papillion Creek, and off-site residents. Of the SWMUs and AOCs investigated, only the surface sediment in a portion of the Southeastern Drainage Ditches was determined to pose a potential low-level human health risk, slightly above the level at which EPA requires action to reduce contamination or prevent human exposure.
Groundwater beneath the Crown facility is not currently used as a potable water supply. Local municipal code requires a permit for the installation of water wells in the Omaha area. The State of Nebraska has designated the aquifer to be of poor quality and yield. Based on these considerations, the ingestion of groundwater on site was not considered a potentially complete exposure pathway. EPA believes the elimination of the requirement to install engineered caps will still achieve these objectives through the use of ICs to prevent human exposure to subsurface contamination. Ongoing groundwater monitoring will also be required to ensure conditions at the site remain protective of human health.
Interim measures conducted by Crown to reduce contamination prior to development of a final remedy have included: removal of the virgin solvent storage tanks and as much contaminated soil around the tanks as could be safely excavated up to the foundation of the manufacturing building; ongoing removal of solvent product floating on the water table in that area; removal of contaminated sediments in the southeastern drainage ditches in 1989 and again in 2009; and removal of the lacquer storage tanks and surrounding contaminated soil.
The proposed remedy for the facility consists of the following:
- Site-wide ICs, as described in the revised Statement of Basis, to prevent the installation of drinking water wells and to maintain future use of the property as industrial/commercial, consistent with the scenarios evaluated in the risk assessment.
- MNA of groundwater contamination related to the Southeastern Drainage Ditches AOC, coupled with a contingency plan for alternative cleanup measures should ongoing groundwater monitoring demonstrate that MNA is ineffective or that the contaminant plume is expanding.
- Removal of solvent product floating on the water table in the former Virgin Solvent Storage Tanks AOC as long as the product persists, along with groundwater monitoring to demonstrate the contamination is diminishing in extent.
- Routine groundwater monitoring in the North Yard Disposal AOC to demonstrate the contamination is diminishing in extent.
DIFFERENCES FROM THE 2008 REMEDY
This proposed plan for cleanup differs from the remedy proposed in 2008, in that the requirements for engineered barrier caps in the North Yard Disposal Area, the Virgin Solvent Storage Tank Area, and the Southeastern Drainage Ditch have been removed. Based on the previous investigation results and the human health risk assessment, these caps are not necessary to protect human health and the environment, and EPA proposes these no longer be required elements of Crown’s cleanup efforts.
FOR MORE INFORMATION
EPA encourages the public to review the Administrative Record and comment on the proposed cleanup plan. Comments or requests should be submitted by February 24, 2014.Guidelines for Commenting:
- Explain your views.
- Tell us if you support or disagree with the recommendation. Please be specific.
- Can you provide alternatives?
The Administrative Record is available at the following locations during normal business hours:
EPA Region 7 Records Center
11201 Renner Blvd.
Lenexa, KS 66219
Willa Cather Branch
Omaha Public Libraries
1905 S. 44th St.
Omaha, NE 68105
A public hearing has not been scheduled, but will be held if there is sufficient public interest. Requests for a public hearing must be made in writing to the EPA contact at the address listed on Page 1, and must state the nature of issues to be raised at the hearing. EPA will evaluate any request and hold a formal hearing if it finds that a hearing will contribute to the decision-making process by clarifying significant issues affecting the cleanup remedy.
EPA will make the proposed remedy final only after the public comment period ends and all comments are reviewed. EPA may modify the proposed remedy based on any new information and comments from the public.
Individuals may write to the EPA contact on Page 1 to join the mailing list. Joining the mailing list will allow an individual to receive any updated information directly throughout the cleanup process. If you have questions or want to receive further information, please contact:
Office of Public Affairs
U.S. EPA Region 7
11201 Renner Blvd.
Lenexa, KS 66219