Eastman Business Park
Other (former) Facility Name: Eastman Kodak Company, Eastman Business Kodak Park
|EPA Identification Number:||NYD980592497|
|Facility Location:||1669 Lake Avenue, Rochester, New York 14652|
|Facility Contact Name:||Mark E. Miles, (585) 722-4727, mark.miles@EBP.com|
|EPA Contact Name:||Wilfredo Palomino, (212) 637-4179, firstname.lastname@example.org|
|New York State Department of Environmental Conservation (NYSDEC) Case Manager:||Larry Thomas, NYSDEC, (518) 402-9813, email@example.com|
|Last Updated:||July 2014|
|Environmental Indicator Status||Human Exposures Under Control [PDF 971.56 KB, 19
pp] has been verified.
Groundwater Contamination Under Control [PDF 48.32 KB, 21 pp] has been verified.
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. Although it has filed for bankruptcy on January 19, 2012 and is undergoing a major restructuring of its operations, EBP continues to be a large, integrated manufacturing plant producing photographic films, synthetic organic chemicals, and toner and ink materials for printing. It is the company’s headquarters for research and development and also includes tenants and companies that lease or have bought buildings at the site.
Currently, there are approximately 120 manufacturing buildings at the facility supported by an infrastructure that includes nearly 30 miles of roads, power generation facilities for steam and electricity, sewer system, railroad, fire department and water treatment facility. 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. As per the Part 373 permit, 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 that require further investigation or are undergoing RCRA corrective action (industrial sewers, ungrouped SWMUs, and Genesee River).
The submittal of the RFI Workplan for Genesee River by NYSDEC has been extended until October 15, 2014. EPA will review this RFI Workplan.
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 41 ground water pumping systems. The primary function of these pumping systems is to provide ground water hydraulic control of contaminated ground water. In 2013, these systems removed over 66 million gallons of water for treatment at the on-site wastewater treatment plant.
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. Since 1988, it is estimated that over one billion gallons of ground water have been removed and treated at the facility.
EBP’s current NYS Part 373 permit was issued on March 10, 2008 and expired on March 9, 2013. The review of a Part 373 renewal permit application submitted by EBP and co-applicant Recycled Energy Development, LLC (RED) submitted on September 20, 2012 has been completed. The public notice begins on July 2, 2014 and comments will be accepted until September 2, 2014. We anticipate issuance of this permit by February 2015. 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.
Potential Threats and Contaminants
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.
Cleanup Approach and Progress
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 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 will be incorporated into the site-wide groundwater sampling program.
- The final remedy for Building 514 was selected in March 2014. The remedy consists primarily of monitored attenuation of the groundwater, and the imposition of institutional controls (environmental easement, and a site management plan). EBP is currently pursuing the environmental easement and preparing the site management plan. NYSDEC will use E&E (a contractor) to perform the next sampling event in the late fall of 2014.
- 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. If further studies show no residual contamination, a remedy report justifying "no further action" will be prepared by NYSDEC or its contractor.
- A complete assessment for the industrial sewer is still outstanding for three buildings in KPW; evaluations in other areas of EBP (KPE, KPM and KPX) have been completed. EBP/RED are completing the integrity assessment for KPW. NYSDEC will evaluate the findings and make recommendations regarding the adequacy of the existing remedial systems. Sampling is expected to be initiated by 2015.
- Sediment investigation at the Genesee River. NYSDEC proposes that before addressing the impact of EBP's outfalls downgradient, it would conduct investigations of releases to the river from other facilities upgradient. A RFI workplan (sampling program) will be submitted by October 15, 2014.
On March 12, 2014, the US Department of Justice on behalf of EPA has reached a Settlement Agreement with the United States Bankruptcy Court for the Southern District of New York under which EBP has agreed to fund a trust in the total amount of $49,000,000 to allow the New York State Department of Environmental Conservation (DEC) to clean up the site including the adjacent Genesee River. Under this agreement, DEC will add the cleanup cost above $49,000,000 up to $99,000,000, and DEC and EBP will each pay 50% of the cost of should the remediation exceed $99,000,000. The public comment period for this Settlement Agreement expired on April 17, 2014.
Copies of supporting technical documents and correspondence cited in this site fact sheet are available for public review at:
USEPA Region 2
RCRA Records Center
290 Broadway, 15th Floor
New York, NY 10007-1866
Division of Environmental Remediation
625 Broadway, 8th Floor
Albany, NY 12233-7252
The New York State Department of Environmental Conservation (NYSDEC) makes its public records available for a review under the Freedom of Information Law (FOIL).