Hazardous Waste Cleanup: Eastman Business Park in Rochester, New York
On this page:
- Cleanup Status
- Site Description
- Contaminants at this Facility
- Site Responsibility
Cleanup Status
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 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 EBP's Corrective Action Program and have been addressed accordingly.
Historic releases from these units have mixed with plumes from other solid waste management units (SWMUs) at the facility making it impractical to perform independent ground water remedial programs. This is due to the release of dense non-aqueous phase liquids (DNAPLs) into fractured bedrock underlying this site, and restoration of ground water quality to drinking water standards may not be technically achievable. 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 EBP’s wastewater treatment plant.
In addition to the groundwater, there are five outstanding cleanup tasks to be completed:
- The implementation of the remedy selection for Eastman Business Park South consisting in a subsurface injection, was performed in May 2014. The groundwater monitoring in this area has been incorporated into the site-wide groundwater sampling program.
- The final remedy for Building 514 was selected in March 2014 and the remedy consisting primarily of monitored attenuation of the groundwater, and the imposition of institutional controls (environmental easement, and a site management plan) have been implemented.
- The area known as Spector Tire (SWMU E-156) which is a former auto gas station/repair shop that EBP had purchased in the past for possible site expansion, has undergone several interim measures including tank pulls, soil removal, ozone injection and oxidant injection to address a BTEX/petroleum release that affected groundwater. Further investigation performed in 2016 recommended "no further action".
- A complete assessment for the industrial sewer was conducted in three outstanding buildings in KPW; evaluations in other areas of EBP (KPE, KPM and KPX) have been completed. EBP/RED has completed the integrity assessment for KPW. NYSDEC has evaluated the findings and concluded that the existing remedial systems at the site are adequate.
- Lower Genesee River Investigation and Cleanup. In 2014, Kodak funded a Trust to NYSDEC of $49 million to investigate and cleanup. EPA approved the RFI Work Plan and RFI Report in 2015 and 2016 respectively. Corrective Measures Studies (CMS) have been conducted in 2017 and 2018. Remedy Selection has been proposed by Parsons Technology (contractor of NYSDEC) and it’s been under evaluation by EPA.
Excavation, armoring and a minimum six (6) inches isolation layer, with a minimum 18-inch erosion (armor) layer cap for contaminated sediments are proposed which seems to be conventional remediation process for sediments in rivers. Sediment removal in the River and Wetland D will be dredged with earthwork equipment installed on floating barges due to accessibility problems. An estimated 20,000 cubic yards of contaminated sediment (70-100 ppm of silver) will be removed under 2-3 feet at a cost of about $10 million. Once the sediment is removed, impacted areas will be covered with sand and gravel. The final draft CMS Work Plan will be submitted by April 2019 and the Statemen of Basis and Public Notice is planned in May 2019. Part 373 renewal and remedy construction is projected for FY’2020.
Site Description
Eastman Business Park "EBP" (formerly Eastman Business Kodak Park) is approximately 1,100 acres complex across nearly four miles through the City of Rochester and the Town of Greece. It filed for bankruptcy on January 19, 2012. EBP continues to have manufacturing plants producing photographic films, synthetic organic chemicals, and toner and ink materials for printing. It is the company’s headquarters for research and development. A large portion is now occupied by tenants and companies that lease or have bought buildings at the site.
In early 90’s, there were approximately 200 manufacturing buildings at the facility and 15,000 workers supported by an infrastructure that included nearly 30 miles of roads, power generation facilities for steam and electricity, sewer system, railroad, fire department and water treatment facility. About 150 buildings were demolished and sold off. The rest of the manufacturing buildings are still in business employing approximately 1,500 workers. EBP has been segmented into four sections identified as EBPE, EBPW, EBPX, and EBPM (formerly named as KPE, KPW, KPX and KPM). As of 2008, there were two additional sections KPS and KPT. The site is bounded on the east by the Genesee River to NYS Route 390 to the west. A mix of commercial, industrial and residential properties surrounds the facility perimeter.
Historically EBP had various permitted Treatment, Storage, and/or Disposal (TSD) activities including a rotary kiln incinerator and hazardous waste container and tank storage units, which have been closed in 2007. EBP’s current waste management activities include a Multiple Hearth Incinerator at the Kings Landing Wastewater Treatment Plant and two hazardous waste permitted storage tanks at the Distilling West operations in Building 322 for the storage of off-site solvent prior to reclamation. EBP’s on-site generated hazardous waste is sent off-site for treatment and/or disposal within the time period allowed for exempt storage (less than 90 days).
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 EBP has completed more than 82 hydrogeologic investigations. For the majority of the SWMUs corrective measures studies (CMS) have been completed and for most final remedies have been implemented.
For the last 26 years, EBP 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. The Part 373 permit was issued on 01/26/2016 and is due for renewal on 01/25/2020. 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 small number of SWMUs undergoing RCRA corrective action (industrial sewers, ungrouped SWMUs, and Genesee River).
The interim corrective measures (ICM) and investigative activities at the site continues. The ICM along with the Industrial Sewer Assessment Program, Soil Management Plan and the Ground Water Monitoring Program (with minor enhancements or variations) will be adopted as final corrective measures.
EBP is currently operating 850 groundwater monitoring wells and 41 active pump-and-treat wells. The primary function of these pumping systems is to provide ground water hydraulic control of contaminated ground water. Water levels and flow rates for each well in the system are monitored. Pumping rates for the systems are monitored by magnetic or mechanical flow meter instrumentation.
Contaminants at this Facility
Investigations conducted by EBP 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 EBP.
To address these areas, EBP 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 EBP, 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 vapor intrusion investigations were conducted in several residential areas adjacent to Eastman Business Park in the past (1988-1990) and also again 2006-2008. These studies did not indicate an impact to the community. EBP also completed an extensive on-site soil vapor intrusion investigation. Based on this work, EBP and the NYSDOH/NYSDEC concluded that no mitigation was necessary, and an approved Vapor Intrusion Change Control Management Plan has been put into place for Eastman Business Park to address potential future changes at the facility.
Site Responsibility at this Facility
EBP’s current NYS Part 373 permit was issued jointly to EBP and Recycled Energy Development, LLC (RED). RED is in charge of operation of the Multiple Heart Incinerator (MHI) and utilities at the site while EBP has the lead on corrective action, including groundwater treatment (and monitoring) and the storage of hazardous waste in tanks and containers. NYSDEC has the lead responsibility on clean-up of the Lower Genesee River.