8.1 POLICY Action Groundwater " CITY OF SALINA
REQUEST FOR COMMISSION ACTION DATE TIME
4/25/! i 4:00P'M'
AGENDA SECTION: ORIGINATING DEPARTMENT: P OVED FOR
NO. 8 AGENDA:
City Manager
ITEM:
NO. 1 Dennis M. Kissinger ~//
BY: BY
Item
Staff report and recommendations regarding a Policy and Action Plan for
addressing groundwater contamination issues in Central Sa]ina, as identified in
the K.D.H.E. report (Sa]ina Pub]ic Water Supply Wells Site).
Background
City staff was previously assigned to research and prepare a formal report to
the City Commission regarding this important topic area. That i report is
attached, and provides the staff's recommendations which constitute the
beginning outline of an Action Plan.
Action
Discuss the report with staff available to answer questions. Co~sider the
recommendations presented.
COMMISSION ACTION
MOTION BY SECOND BY
THAT:
CITY MANAGER · DENNIS M. KISSINGER
City-County Build~n~J * :~00 West Ash ~ · po ~x 736
~alina. Kansas 67~2~
Mli3IOR~DUM
TO: Salina City Commission ~ ....
DATE: Apt'fl 22, 1994 ~
SUBJECT: Staff Report and Recommendations Re~arding Policy a~td Action *
Plan for Add,easing Groundwater Con*-~-tion lssue~ in the
central pa~t of Saiina, as identified by K.D.H.E. in t~s Report
on 8aiina Public Water Supply Wells Site~
I. BACKGROUND
A. General - In June 1993, the Kansas Department of Health and
~ment issued a report on its Expanded Site Inspection l (ESI) of
an area in the central part of Salina now described as the SI L!!__na
Public Water Supply Wells Site (PWS Wells Site). This ESI w ~s
primarily conducted through field activities in 1991 and 1992, based on
the presence of volatile organic chemicals (VOCs) in some municipal
wells as early as 1985. A copy of the ESI is available for p~blic
review in the City Managerts Office or available from KDHE. The
"Summary Conclusions and Recommendations" section of the K DHE
report is attached to this report. ~
Since receiving the report, at the City Comm_/ssion s direction~ the
city staff has been researching the issues surrounding groundwater
contamination, including the following: federal and state law~ and
· regulations; technical issues; liability and other legal issues; case
studies of similar situations in other communities; and ~
economic/development issues. The City Commission has been [ept
regularly apprised of the legal issues involving the city of Sa ina.
B. The Site: - The Salina PWS Wells Site is located~Jn the centre portion
of Salina (site location map attached). The sttets a long, na~.row
area avereKing less than one-half mile in width and i~ slightly more
than one and one-half miles in length. It is bounded on the orth
and ~outh by Walnut and Claflin Streets. From north to south, the site
is bounded on the west by Seventh, Highland and Ninth Streels. On
the east, the site is bounded by 8 diagonal lin~ from Front to S~nta Fe
Streets. The site consists of slightly more th~m 300 acres, an~
encompasses 98§ parcels of land, (852 residenfl~tproperties; 9:
commercial properties; 20 vacant; and 1 "othe~!~). The northm n
one-third of the site is pr~dom.h'mntly business.property, with the
Memorandum 94-7
Page 2
southern two-thirds predominantly residential, with some sm~l
commercial businesses along south Santa Fe, Crawford and 9th Streets.
C. The Contaminants - Several VOCs have been detected in the Salina
PWS wells at the site, indicating various types of contaminan~ sources.
The major contaminants of concern (with concentrations exceeding
maximum contaminant levels for wells) are the chlorinated hydrocarbon
PCE (tetrachloroethylene or perchioroethylene) and the Kasoli~e
constituents 1, 2-DCA and benzene. PCE is a nonexplosive Solvent
which rapidly dissolves certain substances (offs, Kreases, tarS, etc.).
The most common use of PCE is in dry cleaning, where it ha! been
used as a solvent since 1934. PCE is also used as a deKreas/ng solvent
for cleaning of metals. Petroleum constituents 1, 2-DCA and l benzene,
etc. found in Kroundwater in some areas of the site are components of
~asoline, either currently or in the past.
D. Potential Sources - Information state officials collected from the ES1
indicates, currently and historically, numerous types of commercial
businesses and l~ht industries have utilized and/or ~enerated
VOC-containing materiais or wastes in and near the PWS Well~ Site.
The majority of these business properties are located in or n~ar the
northern portion of the site and along the major streets (CraWford,
Santa Fe and 9th).
Groundwater contamination by VOCs at the site is presumablyi
(according to the ESI) due to improper handling and disposaliof
VOC-contA~n~ng products and wastes by past commercial or private
operations. Activities leading to this may include spffla~e, leakage
or discharge onto the ~round, burial of materials, under~l'ound
storage tanks, e.g. ~asoline leakage, or even improper disposal into
the municipal stormwater or sanitary sewer systems.
The ES1 confirmed PCE contaminant source ar~as at five curr~nt or
former dry cleaning businesses. Si~Jficant ~asoline contamination has
been confirmed at numerous locations, primarily active or rolm er
Lmsoline filling stations.
° E. Federal/State Law and Rezulations - The maximum conmminanl levels
(MCL) for substances in Kroundwater taken in by public wate supply
wells or which may teach water wells, is established under fei eral and
state law and regulation. The MCL is often expressed as ug!
(microKrams per liter) which is comparable to "parts per b!!Uq=". EPA
and KDHE proKrams involving testing of public water suppliesl.for
VOCs have been in place for many years. Regulations ~over~Jng
contaminant Hmjts exist for water supplies in their "raw or un~reated"
form, e.g. at the well head, as well as strict MCLs for "finisl~ed"
water, as it is distributed to consumers, i.e. in Salina after
through our water treatment plant. Discoveries of contaminants in
public water supply wells may lead, as in this case, to furthe~
investigations of contaminant sources through the authority of[the
Comprehensive Environmental Response, Compensation and Liability Act
of 1980 (CERCLA) and the Superfund Amendments and Reauth~rization
Act of 1986 (SARA). To~ether, these federal acts are commo~/ly
referred to as the Supe~fund laws. In Kansas, investiKations~[of
Memorandum 94-7
Page 3
selected contamination sites are conducted by the state, under
cooperative agreements with the U.S. EPA. Ultimately, a
contanfination site may be placed on the federal National Priority List
(NPL) for remedlation under the Superfund laws.
The Supe~fund laws themselves, as they relate to addressing
environ_mental problems such as these related to hazardous lsubstanees
in the soil or groundwater, are extremely broad, complex, strong and
far-reaching. When environmental contamination is diseove .-ed,
businesses, local governments, and/or proper~' owners ma~'~ be held
liable for costs associated with environmental clean-up. L~
provisions such as "joint and several liability", "third part~ l
contribution", and others lend considerable f!~a,~e~_A~ and le~a.
exposure to many parties who may not meet'tl~e common usl~definition
of ~polluter'. ~..:
F. Other Cases - Contaminated sites such as this~ have been f~und and
are being dealt with throughout the United States. The p~.me and
best example for our comparison, and the research concentration of
the city staff is the Gflbert-Mosely Site in the center of Wic ~ita,
Kansas. While there are both significant differences and s~ ~ilarities,
there has been and continues to be much to learn from the ..~xperienee
in Wichita since 1990 at their site. This staff report and
recommendation relies heavily on what we have learned from/the
Wichita Gtlbert-Mosely project, and general lessons learned f~om other
cases across the country. ~'~:~
II. ISSUES AND POTENTIAL IMPACTS ON THE CiTy OF SALINA
A. City Water Utility - As has been pointed out, the initial testing of
our public water supply wells in 1985 led to the g~oundwate~ studies,
investigations and reports in the subsequent years. Our city water
utility, as the supplier of d~nking water to approximately 4~,000
individuals is seriously and directly impacted by the groundwater
contamination issues from this site, both in the matter of dri~,~king
water quality an.d supply. It must be emphasized that no VOCs have
exceeded MCLs ~n our city water distribution SYstem (our dr~tking
water is safe), and the supply is adequate. ~
1. Water Quality - Obviously the first prioldty of our city iwater
system is to assure our residents of ~~~~j~. We are
extremely fortunate that our water system has an extensive
treatment facility, capable of removing most contantinant~ to the
standards.
point of meeting or exceeding all safe droning water
Unlike a rural water system (or some municipal systems in
Kansas) which merely disinfect and send mw water dir~ ;tly from
the well directly to the consumer, our centralized treatn~ent
plant mitigates many of the concerns of mw water qualit [, at the
well-head or from the Smoky Hill River. However, the :aw
water quality at our well-heads and river intake is impo: ,tent, in
that significant presence of contaminanta ~an nmke treat~ent more
difficult and expensive. If the contamlnA~ta now presen in a
portion of our groundwater would grow to a higher
Memorandum 94-7
Pal~e 4
concentration, or would miKrate to additional wells in our
system, additional treatment issues would be faced.
2. Water Supl~l¥ - The city currently Kets its raw drinkinj~ water
from two sources in substantially equal quantities: (a)!Suvface
water from the Smoky Hill River, taken, in near Bill Bu~'ke and
Indian Rock Parks; and, (b) eighteen Eroundwater wells (15 in
town; 3 in the airport area). It is possible that incr~-ased
concentrations or the migration of contaminants to othez~ wells in
our intown system could cause those wells to be unusable as our
supply. This could require a difficult and expensive search and
implementation of a replacement water supply source.
B. Potential Liability as a Property Owner - The city of Salina cUrrently
owns a piece of property (216 S. 5th Street, now a parking .10t) which
was the location of the former (~uinley's Master Dry Cleaner's~ Even
though the city purchased the property long after the dry cleaning
business was closed and removed, we are now, merely by our
ownership, a Potentially Responsible Party (PRP) under the ~upe~fund
laws. We would certainly be involved in any efforts to determine and
impose liability for a cleanup at this parking lot, which may have been
a contributing property as a source of VOC contamination.
C. General Economic Vitality Impact - It has been shown in numee°us
cases that the local economy in a contaminated az~a can be d .a~l~ed
from liability fear associated with Superfund and environmental cleanup
costs. Superfund was designed to provide the EPA with the !egal
authority for exped.t.tious environmental cleanup. Superfund i~ives EPA
the power to take direct action for cleanup and cost recovery~ intended
to be from "polluters". Actually, in cases such as Salina, the
pollution is the result primarily of hazardous substance releases in
the distant past. Many of the environmental "culprits" are nO longer
in business. Often we are not finding the traditional "polluter", such
as a chemical plant, but instead finding "mom and pop" dry cleaning
or small business establishments, or even subsequent owners Of the
property. In many cases, the EPA is then able to use unpree~edented
legal authority under the very broad Superfund laws, to recover
· cleanup costs from "innocent parties", including reaching into;~ the
"deep pockets" of lending institutions.
Market trends can interact with contamination discoveries to cl~eate
specific areas of disinvestment in or near the site. With uncertain
liability for cleanup, property transactions and development can
severiy decline, in the site area. Potential buyers are reluctant to
involve themselves in the complex legal issues surrounding
environmental cleanup and look elsewhere to locate.
institutions are reluctant to become involved in new lending
tl-ansactions out of fear of becoming potentially responsible patties
under the provisions of environmental law. Lending insfltutiol~s
(banks) also are concerned about the impact of iToundwater
contamination on collateral values of property in the particuiar~: site
area. Continuing lending activity and property transactions a~e
critical to the economic vitality of this central Salina a~ea.
Memorandum 94-7
Page 5
city of Salirm has substantial investment in infrastructure in the
downtown and central city area.
D. Tax Revenue Impact - Contamination within the Salina PWS! Site area
and the effect such contaminants may have on lending, prqperty sales
and development has the potential to result in devaluatio] Of the
properties in and around the site area, and an eventual lo~s of tax
base value to the city of Sa]ina and other taxi_ ng subdivisions. This
may threaten the ability of the city and other governmenta~ entities to
provide the current level of services to our citizens. We l~ave
calculated that the 965 properties located within the Sali_na pWS Site
Area contain 4% of the city's property tax base, generatin~ just under
$9.00,000 in city revenue annually, and nearly $700,000 in t,~tal
property tax revenue. Based on experience elsewhere, a
devaluation of properties in the site area could occur, with a
substantial loss in tax base and revenues. While such a su'~stantial
value loss in residential properties is unlikely, it is uncertain how
much residential or commercial properties could decline in vldue under
the Supe~fund scenario.
III. OPTIONS
There are really three potential options for the city of Salina to tiike in
this matter:
Option A. Do Nothinff - Under this passive policy option, the cit]' would
cooperate with KDHE as required, but would simply allow the envi~ onmental
law process to run its course. Under this scenario, it is unlikely that any
other PRP would step forward to take a lead role in assessment an
remediation. The state of Kansas would continue the investigation~ "scoring"
the site as to its potential public health and hazard impact, submit ing it
to the EPA for further consideration and listing on the National P~ ority
List under the federal Superfund pro~vam.
The likely result of this would be:
1. The negative economic impact and potential devaluation of business and
· other properties may begin vex-/ quickly. Absent a "lead res ~onsible
party or major contributor, the uncertainties involved in the iabtltty
for a possible Superfund cleanup and associated civil lawsuits would
likely be so negative for lenders or buyers that there would )e few
property transactions in the area, particularly for commercial.
properties, with an uncertain impact on residential properties land
properties near the PWS Site area.
2. If property devaluation occurred, property tax receipts used for public
services could decline.
3. The city, through our water utility, would enter a lengthy period of
uncertainty as to its public water supply quality and quantity.1 The
negatives for our water system previously noted could occur d~lring
this period, with g~eat cost and service impacts;!
Memorandum 94-7
Page 6
4. The city, as an owner of a property (former dry cleaners) cited as a
possible contributor, would still be involved in investigations i and
legal actions. Without a large viable polluter" to look to, the "deep
pockets" of a local government may look extremely attractive~o a
federal agency or private party looking for someone to pay n/ost of the
costs of remediation.
5. Experience nationally has shown that projects handled by the i federal
government under Superfund become massively more complex and
expensive. The time involved for Superfund cleanup activity! is often
up to ten years, as costs continue to rise and negative commUnity
impacts multiply. Transaction costs (legal, administrative,
engineering) often grow to millions of dollars before any actual
cleanup is accomplished.
Option B. Involvement only as a PRP - Because of the city's ownership of
the former dry cleaner's property, we are a Potentially Responsible! Party
(PRP). We could involve ourselves only as far as actions to defend our
"innocence" and attempt to negotiate a "de ntinimis" settlement for OUr
parking lot property, letting everyone else "fend for themselves".
This passive approach would not be much different in actual result~ than
Option A. The likelihood of virtually all the same negatives occurmng is
great.
Option C. Assume a Pro-Active Role - The city of Wichita can be m~ed as
the prime example of this response. Having studied the issues and
recognizing the severely negative outcome for the community by taking a
passive approach, Wichita decided to minimize the threat to the city's
livelihood by taking an active role in cleaning up the K~oundwater
contamination.
The city of Salina, following the path of the city of Wichita, could ~ssume
the initial and direct responsibility for the cleanup, reaching al~eements
with state environmental officials to use certain aspects of federal
state environmental laws to expedite the assessment and remediation! of the
groundwater contamination problem. As part of the Wichita action ~lan, they
· were able to develop an innovative concept which enabled the city t! enter
into agreements with local banks to protect lending activity within t.~e site
area. The Wichita plan provides for a system in which the city was able to
issue liability releases to most property owners in the site area. T]lese
actions have effectively averted the property devaluation and lendin~ and
sales "dead zone" problems in Wichita, and could presumably be replicated in
Salina. ,
Under the Wichita pro-active example, they did not have the direct ~vater
system impact as in Salina. They chose to develop a payment syste~ for the
remedlation which involved a Tax Increment Finance District, which would
not be necessary in Salina.
A pro-active approach can serve to avoid most of the neL, atives outlined in
this report, but it cannot be accomplished without siLmificant cost t~ the
city. The Wichita ~roundwater remediation project is now estimated iat $15 to
$20 million in total costs to be incurred over many yea~s. The Wichita
Memorandum 94-7
Page 7
Gflbex~t-Mosle~r Site is much larger than Salina's (Wichita - 6 square mi!es)
and contains much higher levels of contamination concentration, th. oul~h the
substances involved are generally the same as the SAl~nA PWS SiteI. It is
impossible at this time to accurately estimate the potential cost of ~uch a
groundwater ramediation project. It is safe to sa~r that the cost iS likely
to be in excess of five million dollars, over a period of years,
substant~a_i_iy less than Wichita. However, staff .m~u~st admit that tl~e cost
estimate is only speculation at this time. A pro active lead approach by the
city does allow us to have significantly better control of costs tha~ a
Superfund approach led b~r the federal government throul~h the
IV. STAFF RECOMMENDATION
All the staff re~s.e, arch into this arum leads us to the stront~ belief that
Option C, a pro active policy approach and action plan is clearly ia the
long-term best interests of the city ~overnment and the Salina corn nunity.
We believe from a legal, economic, environmental and water utility ~perator
standpoint, taking a passive approach would be ineffective, ultimal ply more
expensive and lead to unacceptable negative outcomes for the community.
City staff has developed an outline of a recommended action plan tile city of
Salina could begin, if the Commission agrees that a pro-active lead~rship
role by the city is the proper course to take.
Memorandum 94-7
Page 8
PROJECT INITIAL ACTION PLAN SALINA PW~ WELLS
GROUNDWATER
SITE
A. City of' Salina assumes remedlation responsibility primarily as a
necessity to protect current and f'uture d~ki~g water supplies.
B. City pursues a Settlement Agreement with the Kansas Departr~ent o£
Health and Environment (KDHE) providing for:
(!) accelerated cleanup under provisions of' £ederel and state il aw.
(2) the site remaining outside the Superfund and National PriOrity
List; KDHE would be the lead regulatory a~ency.
(3) the city's ability to issue release letters to 'tinnocent" ov~ers,
lenders, etc.
(4) the city's retaining the right to pursue responsible partie~ for
participation in costs, etc.
C. The city retains Clark, Mize and Linville as lead leLml counse! for the
project.
D. The city contract with Camp Dresser and McKee (Wichita/DenVer) as
its EnL,~neering and Environmental Consultant.
E. The city establish its intent to finance water utility capital
improvements through Utility Revenue Bonds.
F. The city establish its intent to finance non-capital remediationl and
other project expenses through water department operating budgets.
G. The city conduct public information meetings for the ~eneral Citizenry,
residential property owners in the PWS Site area, financial
institutions, and business property owners/operators.
Attachments
Walnut St.
II
First resbyterian
Surface
Lilly
Cmwford Ave.
Site Bourn
Claflin Ave.
..~
LEGEND: ~ Salina PWS Well
· ~=~"~'=' "'~ FIGURI 2-2
sc,~:, ~ ~.0. __ o.~ .~. S~E LO~ ION MAP
SO.CE: Kansas Depa~ent of Health and ~nV~ronment'~' GIS Center
June 1993 27 Salina PWS Wells ES1
7. SUMMARY, CONCLUSIONS AND RECOMMENDATIONS
7.1 Summary
The Salina Public Water Supply (PWS) Wells ESI was designed to gather inforn~ ation and data
to evaluate the site as a candidate for the National Priority List. Soil vapor an( ground water
samples were collected and analyzed to identify sources of the PCE contamin Ltion found in
several of the city's m~micipal water supply welh. In addition, information w; ~ collected to
delineate, the contaminant plume(s) and confirm target populations potentially a risk from the
contamination.
- A statewide 'sampling and analysis of public water supplies c.onducted '.m 198.5 ru~t revealed
presence of volatile organic chemicals (VOCs) in the Salina muniapal distribution system.
Included were the. VOCs tribalomethanes, tettachloroethylene (PCE), benzene~ aaand toluene.
Subsequent sampling of the Salina PWS wells also indicated ..c0n~tion by ~ese and other
VOCs in several of the wells. Continued moa/toting by the C~ty of Salina and in?esfigafions by
the Kamas Department of Heath and F_~vironment (KDHE) indicate petshtent ~:ontamination
by PCF_, sometimes at levels exceeding its maximum contaminant level (MC:L) bf $.0./~g,/L in
PWS weUs ~1, #3, ~4, ~$, #8 and #13. Contamination by gasoline constituen~ particularly
benzene and 1,2-DCA, has aho been significant in pws wells #3 and #13. WeUs ~3, ~4, and
#5 have been placed out of service by the City of Salina due to the high leveh oflPC~ detected
in these wells..
In the fall of 1991 and again in the s!~mmer of 1992, KDHE staff resampled the Salina PWS wells
and mobil/zed a field crew to Salina to collect a total of 26 ground water s~mples w ith a hydraulic
probe unit. Eight private water wells were sampled or'resampled and one equi ~ment rinsate
sample was prepared at that time. In-field analysis was conducted on seven soil' ',apor'samples
and many of the collected ground water samples. All of the ground water samples v ere preserved
· and transported to the KDHE laboratory in Topeka where they Were analyzed for w)latile organic
· compounds. The results indicate PCE contaminant plumes originate from., at leaslt five sources:
three former and two currently operating dry cle. aning facilities. Gasoline contamination of
ground water had been confirmed a.t. three LUST roes by the KDHE Underground t Storage Tank
Section and potent/ally eight additional UST sites may be responsible for ¢ontamiantion
discovered during this investigation.
7.2 Conclusions
The KDHE has identified VOC contamination in ground water at Salina, Ka~as, and the
contain/nation poses a risk to the city's public water supply welh and population. I
Since September 1988, no VOCs have exceeded 'MCI-s in the Salina mun/cipal ware t distribution
system.
June l~ 28 Salinn PWs Wells ESt
~~ ~~d ~ve~ ~o~ ~d smpeaed use~ of P~n~g ~e~ p~~ly
~ cle~g ~fi~. Seve~ ~ent ~d lerner unde~d ~el stooge ~ gt~ were ~o
~ leve~ of P~ ~nmlnn~on' were ~~ed in ground ~ter at ~e up ~er posen of the
~M ~er on ~e do~adient side of fo~ d~ cle~ng, fa~es while ~one w~ dete~ed
~ ~ples on ~e up~ent side. ~e ~~ resul~ ~~ ~ro~r s :omge or d~
of ~te solven~ ~nlnlng p~ at ~e fa~des h~ res~ted ~ con~l ion of ~e ~u~
~er ~d su~e~ent con~gon of seve~ water supply ~ at ~e sit, bo~ publio ~d
~a~on of ~e dele P~ pl~es is ~uenced by the high pe~eabiliv of ~e lower ~d ~d
~avel posen of ~e ~U~ aq~fer and the confi~ration of ~e underling b~drock s~ce in
· e ~ of ~e site. A topo~aphic~ low area is situated ne~ PWS Well ~3 ~d buried
c~els ~!!ed ~ ~e co~e ~u~al deposi~ trend toward it. One mjor bug~d ch~el tren&
~om ~e sou~ to ~e no~ adjacent to ~d p~leling a l~e ~om PWS welM ~5, ~4, ~d ~1
to Well ~3. Two of,~e co~ed P~ source ~e~, in ~e sou~em poffioa of ~e site, ~e
sima~d ne~ly over this chnnnel ~d ~e most likely the source of P~ ~n~ ~on dete~ed
~ ~ we~. P~ mn~gon dete~ed ~ ~o private we~ ~o ~ong ~ ~e (o~ be~g
d~~ent of ~e source ~e~ ~d up~a~ent of the PWS we~), co~ ~ h~es~.
~o~er con~ed P~ so.ce ~ea (~ a~ve PCE-proce~ du cle~g fa~V) 2 lo~ted
~e~y up~ent of PWS wel2 ~3 ~d ~8. P~ contigen co--ed at a fo~er d~
~ning fa~ in ~e no.em poffion of the site represen~ ~e most likely source of PCE
dete~ed in PWS Well ~13 in ~e ~d-1980's.
~ dele pe~oleum hydrocarbo~ (such ~ g~olinc co~timenu) ~11 tend to float on ~e water
~le or rem~ ~ ~e upper portion of the aquifer. ~e~ of g~o~e cen.ken d2covered
d~g ~e ESI ~11 be refe~ed to ~e ~HE/BER, Under~ound Stooge T~ Se~om
~e l~ge ~u~ti~ of ground water p~ped from Salina's in-to~ well field, ~9 con~butes to
&e ~uon of VOC cont~~ to ~e ~fe~ed PWS welh. A "~ne of dep~ion" created
in ~e ~ of ~ wells being pumped ~11 pull VOC cont~n~ to. rd the pump.s wel2.
A l~ge number of hum~ t~ge~ (43,385) rely on ground water produced fr~m ~e ~u~
aq~er. ~ pop~agon includes the CiV of S~ina rcsiden~ supplied by ~e iSSue Co~v
R~ Water D~ ~3 ~d ne~ly 200 private domestic wells ~tMn four ~les~of the site.
~ere ~e no in~o~ of a rele~e of con~~ to surface water ~ the site ~. Su~ce
~ter runoff ~om ~e site drai~ ~a sto~ sewen to the fo~er Smo~ Hill River ch~el ~d
then to the ~ent river ch~el lo.ted e~t of the site. ~ere ~e no d~nglwater in.es
~in 15 ~es do~tre~ of the site. Seconda~ surface w~ter pa~y targe~ i~clude con.ct
by ~e public to ~re~ow in both the old ~d new Smo~ Htll ~r~ ~e~ ~ f~he~ in ~e
June 1~93 3p Salina PWS ~;Vells ESI
newer river channel, and habitats of threatened and endangered s.pe.c/es in salin~ County w..hich
may coindde with the Smoky Hill River and other major rivers Mthin the targe~ distance limit.
The soil exposure pathway appears to pose a minimal threat at the Salina PWS We Ih site bemuse
of the pavement cover around the suspected source areas. A release to the air is also not
suspected for the same reason. Workers at the active facilities are at the greatest hk of exposure
to PCE wastes.
7.3 la__ _~_ _m m__endaflons ,
Th.e. KDHE recommends working with potentially responsible parties (PRPs) ~nd the City,of
_ Salina, to conduct further investigation and possible cleanup at the site. If a PR]~ group cabot
be formed in a reasonable timeframe, the KDHE will complete an HRS scoring package and
submit it to the EPA for luther consideration under the federal Superfund prograxn.