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Ithaca Common Council Oppose EPT Easement Coalition Letter


August 17, 2011

Members of the Ithaca Common Council
City Hall
Ithaca, NY 14850


We, the undersigned, write to request that you review extensive available information documenting high-level toxic chemical contamination at multiple locations on as well as around the Emerson Power Transmission (EPT) plant site in Ithaca, NY.

We also request that you withhold approval of an easement requested by EPT for a proposed passive venting system in a 300-foot trench along East Spencer Street, approximately 850 feet downhill from the plant. That system cannot possibly eliminate all the known toxic pollution on South Hill threatening thousands of local residents.

The New York State Department of Environmental Conservation (DEC) has failed to clean up widespread, high-level contamination hazards posed by the site since at least 1987. Some of those problems were first reported to local health authorities in the early 1960's.

There is currently no meaningful plan to remediate the site in strict compliance with all applicable New York State regulatory requirements. Moreover, the pace of existing clean up efforts is shockingly slow. The proposed passive venting system fails to resolve those concerns.

A total of 59 homes near the plant site have been equipped with sub-slab depressurization systems designed to prevent the intrusion of toxic soil gas vapors that can pollute indoor air. These systems do not function optimally in areas like South Hill with basements built on or very near underlying bedrock.

Despite the limitations of these mitigation systems and DEC’s failure to remove high-level pollution sources at the plant site, there is no on-going testing to demonstrate the effectiveness of sub-slab depressurization systems. We request that confirmation testing be required until the site is fully remediated.

For all these reasons, we ask the Ithaca Common Council to withhold approval of the requested easement pending adoption of a comprehensive site remediation solution that will safeguard all of South Hill's residents. We believe that this is the only way that the plant's contamination problems can finally be resolved once and for all.

Recently Identified Fire Reservoir Contamination

Emerson's consultant, WSP Environment and Energy (WSP), recently released a report that identified extraordinarily high-level contamination under and around the EPT plant's fire reservoir. Portions of that Supplemental Pre-Design Investigation Fire Water Reservoir, EPT Facility, Ithaca, NY, June 30, 2011 are posted for your review at:

As you will see, "Petroleum product" was identified under the fire reservoir as well as in a nearby test pit. Diesel Fuel was detected at a concentration of 330,000 parts per billion (ppb). Lube Oil was detected at a concentration of 3,180,000 ppb.

More than a dozen Volatile Organic Chemicals (VOCs) were identified in groundwater, including Trichloroethylene (TCE) up to 19,000 ppb. The groundwater remediation standard for TCE is five ppb.

NAPL Identified at EPT

WSP earlier released a report that identified Non-Aqueous Phase Liquid (NAPL) contamination at multiple locations at the EPT site. Portions of that Supplemental Remedial Program/Alternatives Analysis, EPT Facility, Ithaca, NY, April 25, 2008 report are posted for your review at:

According to that report: "Solvent odors were noted in three of the borings installed in AOC (Area of Potential Concern, not in the original) 1, the Former Department 507 Degreasing Area."

"A petroleum-type product was encountered from 8-10 feet bgs (below grade surface, not in the original) at AOC 4, former open stone reservoir in Building 6A."

"Monitoring well MW-8B, located adjacent to the eastern side of the fire reservoir (AOC 24), contained an L (light, not in the original) NAPL. A sample of the LNAPL collected from this well contained methylene chloride at 1,800 ug/kg (ppb, not in the original) and TCE at 2,600 ug/kg (ppb, not in the original)."

Historic Contamination Concerns

DEC has failed to require EPT to delineate or clean up contamination concerns documented at nearly two dozen areas. No meaningful plan exists to require EPT to eliminate its legacy of known pollution threats.

A map of areas where historic contamination concerns have been identified is presented at:


In conclusion, the Ithaca Common Council is in a unique position to require EPT to eliminate its legacy of contamination problems before its 100-year-old facility is shut down. That opportunity must not be squandered.

We ask the EPT easement to be withheld until the incoming Mayor, Common Council and Citizens Advisory Group can study this matter thoroughly and effect a comprehensive solution to the environmental health problems that have plagued South Hill for nearly half a century.

Comprehensive “source removal” clean up efforts have been successfully undertaken at the West Court Street Manufactured Gas Plant site, Ithaca Gun and a former gas station on South Corn Street. We request that those rigorous clean up efforts be replicated at the EPT site and the impacted area around it.

We believe that full-scale clean up of all known EPT hazards is essential to safeguard Ithaca’s public health and environment. We request that all applicable toxic clean up requirements be strictly enforced in Ithaca as a matter of City policy.

Finally, we request an opportunity to work with the members of the Common Council to implement our proposed plan of action.

Thank you for your consideration.

Very truly yours,