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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.