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West Court Street Coalition Letter

March 11, 2011

William Ottaway, Project Manager
625 Broadway, 11th Floor
Albany, NY 12233-7014

Re: NYSEG Ithaca Court Street Former Manufactured Gas Plant Site OU2, Site #755008, North Plain, West Court, Esty and Washington Streets, Ithaca, NY


We, the undersigned write to request the New York State Department of Environmental Conservation (DEC) to require comprehensive clean up of all identified soil, groundwater, ambient air, indoor air and soil gas vapor intrusion threats at the above-referenced site in strict compliance with applicable remedial requirements.

We similarly request DEC to require the clean up of the contaminated area underneath the Markels Flats building according to the same strict standards.

Highly toxic coal tar pollution is documented to have impacted the former Manufactured Gas Plant (MGP) site, the area immediately adjoining the site as well as extensive areas located to the west and north of the site. That contamination includes a total of more than 40 cancer-causing polynuclear aromatic hydrocarbons as well as organic and inorganic compounds that pose acute and chronic health risks at minuscule levels of exposure.

That is why DEC has designated the site with a classification code of two: “Significant threat to the public health or environment – action required.”

DEC’s proposed remedial action plan is fatally flawed because it would not require all identified contamination associated with the site to be removed in strict compliance with all applicable standards. That is why the proposal is insufficient to safeguard public health and the environment.

Most of the MGP site and the coal tar duct along West Court Street have been cleaned up using “source-removal” efforts. That requirement should be applied to all remaining contaminated areas.

DEC’s proposed remedial action plan would only require “Removal of soil containing visual indications of coal tar and contaminant levels that exceed the cleanup levels established for the site…” in Areas 1-A and 1-B. See attached map.

Areas adjoining 1-A and 1-B would only require in-situ chemical oxidation for Area 1-C or Monitored Natural Attenuation. That proposed solution is insufficient given the fact that many coal tar constituents are elements or compounds that resist chemical oxidation or have the potential to migrate as soil gas vapors, groundwater contaminants and air pollutants.

In conclusion, we request you to require the removal of all the site’s pollution to the extent technically feasible and as required by law. This is imperative given the large number of homes in the area of the MGP site, the potential for the site to be developed for future education use and the likelihood that any toxic contamination left in-situ would ultimately recontaminate areas that were cleaned up at great expense and effort.

Thank you for your consideration.

Very truly yours,