CPAC Request for Action
Response to SSRA Human Health Assessment, Crompton
July 2003


Introduction:
CPAC recommends the following actions as both the appropriate response to the SSRA data and as actions to be incorporated into the Comprehensive Long Range plan for the Crompton site.

The recommended actions include removing some of the sources of the COC's. Eliminating once and for all some of the hot spots of contamination on the site is a key element of the Long Range Plan and essential to protecting our community for the future. Containment alone is not sufficient. Nor is capping of creekbanks, since contaminated groundwater flows through the banks into the Creek. Elminating hot spots on a reasonable schedule, starting with the worst spots, will speed the cleanup of the off-site aquifer as well as the downstream sediments.

Note that these recommendations are based on available data to date. We see appropriate modifications to the recommendations being made in the future as additional data is gathered and additional technologies become available.

Our Action List, with some of the justification, is as follows, roughly in order of priority.

1. Downstream Contaminated Sediment
* ACTION: Fence off and revegetate as a buffer strip the
floodplain of the Canagagigue Creek downstream
of the site as far as the Grand River, providing
appropriate compensation to farmers.

2. GP-1 and GP-2
* ACTION: Excavate and investigate thoroughly the full extent
of contamination, both laterally and vertically.

* Extremely high levels of dioxins in soil, highest on site
55,897 ppt (5 times the MOE ceiling for contaminated sites)
* Very high levels of DDT-47,000 ppb
* Area is near the creek, with surface flow and uncontained
shallow groundwater flowing to Creek.

3. RPW-1 and RPW-2
*ACTION: Excavate these unexcavated waste pits

* Once these pits are excavated, allowing some form of
"optimization" flow off site becomes more reasonable
* Only one storage building interfering with easy excavation
* Historic disposal pit for DDT, 2,4-D, pilot plant waste
* A major source of DDT
* Near location of highest DDT levels in creekbank soil. May
be the source of that DDT, since shallow groundwater, recharged
by the pond above dam, flows through the pits before discharging
to Creek below the dam.
* Historically, RPW-2 was a pond that overflowed continuously.
A pipe installed to carry flow to below dam. These residuals also
source of DDT to creekbank area.
* Borehole evidence of DNAPL in RPW1 & 2
* Very high chlorobenzene in groundwater sampling (UA3), making
DDT mobile.
* Evidence of DDT in groundwater samples
* evidence of dioxins in area (MISA 0400)
Timeline: 2003-2005
Actions 1,2,3

4. P-1
* ACTION: Excavate worst spots in P-1 area and contain shallow
groundwater
* Remediate and/or pump and treat under buildings
* Excavate and cap adjacent creekbank (some capping has been done)

* Highest DDT in soil on site (Borehole 7-461,670 ppb), over MOE
ceiling levels
* Also source of adjacent creekbank DDT-highest creekbank DDT
levels on site
* Groundwater from west and north flows through here into Creek
* Shallow groundwater wells show very high chlorobenzene,
benzene, as well as DDT after purging.
* 1943-48 all process wastes dumped in P-1 and P-2
(MOE Report-Jackman)
* Location of Bldg 8 sump, a major contaminant source
Timeline: 2005-2006
Action 4

5. Creekbank downgradient of M-2 (and RPWs)
* ACTION: Excavate entire dry channel and island. Cap with clean fill.
* Highest creekbank levels of dioxins and high DDT
* LNAPL in area mobilizes dioxins and DDT (a 1996 LNAPL sample
showed 209,070 ppt dioxin TEQ)
Timeline: 2006-2007
Action 5

6. M-2
* ACTION: Selectively excavate and/or remediate soils

* Area is relatively free of buildings
* Location of high exposure for workers
* Free phase DNAPL found at OW-88 and on border of M-2 and
TPW-2 (no exploration done into M-2)
* LNAPL in north end of M-2 huge plume from Bldg 15 area. DNAPL
and LNAPL mobilize dioxins and DDT in groundwater.
* Historically, a disposal site for Uniroyal and town. Waste
disposal of DPA, filter cloths, 2,4-D, 2,4,5-T, sump sludge
from 2,4-D and Bldg 15
* Little current monitoring done in whole area
* Adjacent (upgradient) of the worst dioxin contaminated
creekbanks
* Site of most highly contaminated portion of Municipal aquifer
* May contain unexcavated drums of waste chemicals
Timeline: 2007-2008
Action 6

7. RPW 6,7,8
* ACTION: Selectively excavate and/or remediate soils. Remove
LNAPL plume.

* Very few buildings
* Historically, these lagoons were the major source of
contamination in Municipal Aquifer
* Highest levels in soil of most Uniroyal contaminants, still
in place (1992 Dames and Moore)
* 3,400 liters per day estimated leakage of process wastes,
downward, after ponds clay lined (CH2MHILL); more leakage before
lined
* DNAPL source (RPW 6)
* Currently contained in UA and MU
* If this area gets excavated, the off-site cleanup becomes
possible in 30 years.
Timeline: 2008-2009
Action 7

8. East side
* ACTION: Excavate all locations with high levels of dioxins

* More testing needed in RPE-1, an unexcavated pit on east side,
used for DDT and 2,4-D waste, both liquid and solid. Possible
excavation needed.
* Historic DNAPL site
* Nearby worms contaminated
Timeline: 2009-2010
Action 8