General Motors/Central Foundry Division - Update

Appendix C: Summary of Public Comments and Responses

Summary of Public Comments and Responses

This summary was prepared to address comments and questions on the public comment draft of the General Motors/Central Foundry Division - Update. The public was invited to review the draft during the public comment period, which ran from September 26^th 2006 to October 26^th 2006. Some statements were reworded for clarity. If you have any questions about this summary, you can contact the New York State Department of Health's (NYS DOH) project manager for the site at the toll-free number: 518-402-7870 or 1-800-458-1158.

General Comments: The Draft Public Health Consultation (PHC document) makes no reference to the Five-Year Review Report for the site prepared by US EPA in July 2005. This document provides a much more precise summary of actions completed and remaining work to be performed at the site and should be included in the list of references to the report.

Because the final PHC document will become a public record, NYS DOH should make every effort to provide an accurate summary of site information, including generalizations of activities both past and present. Much of the information presented in the report is incomplete or misleading.

Response to General Comments: The Five-Year Review will be included as a reference. NYS DOH has revised the summary of site information based on available references and according to Responses to Comments #1 through 14 below.

Comment #1: The Background and Statement of Issues, first paragraph on page 1, discusses USEPA's Records of Decision (1990 and 1992) and Records of Decision Amendment (1999). There is no mention of USEPA's issuance of Explanation of Significant Differences documents also released for the site in March 1992 and April 2000. These documents are considered by USEPA as significant and should be discussed in the text.

Response #1: Discussion of the March 1992 and April 2000 Explanation of Significant Differences documents was included in the Background and Statement of Issues section of the text. The documents were included in the list of references.

Comment #2: The Background and Statement of Issues section under Site Description & History, first paragraph on page 1, states:

"The GM plant is an aluminum casting facility built in 1959 to manufacture automobile components, including engines, transmissions and cylinder heads. The process used at the plant is known as the "lost foam" casting method; a process that historically had been the source of air emissions that had produced odor complaints by nearby residents."

These statements mischaracterize the nature of the historical operations that led to the site listing and ongoing remedial program. The historical site operations involved large die-cast metal forming. The current manufacturing process, the lost foam process, was not introduced at the facility until the early 1980's. The text should be clarified regarding the types of manufacturing operations and the timeframe in which they were used at this facility. In addition, the mention of odor complaints in this section is not appropriate. The styrene odor issue is not mentioned anywhere else in the PHC document and was not assessed in any way in the 1999 PHA or in this PHC document. Unless the NYSDOH intends to provide detailed information regarding the public health issues related to this issue, the discussion regarding odor complaints should be omitted.

Response #2: The issue of styrene is no longer a potential exposure issue as the operations were modified years ago and emissions are monitored under an air permit by the NYSDEC. The styrene odors were a minor issue that has been addressed by General Motors and the regulators and no longer present a potential health concern. It is a historical issue that had been the subject of odor complaints by residents, thus it is mentioned solely in the site background component of this document. It is not addressed as a contaminant of concern in the 1999 Public Health Assessment or the 2006 Public Health Consultation. No modification was considered necessary.

The timeframe of the use of the "lost foam" technique is specified as occurring in the 1980s and that the system was upgraded for pollution controls in the 1990s. This language was not modified.

Comment #3: The Background and Statement of Issues section under Site Description & History, first paragraph on page 1, states:

"Subsequently, wastewater containing PCB-laden oil was sent to four on-site lagoons where solids were settled before wastewater was discharged into the St. Lawrence River. PCB sludge was periodically removed from the lagoons and wastewater plant for disposal into the North and East Disposal Areas and Industrial Landfill."

This summary presents an inaccurate description of historical site operations. There were numerous changes to the GM wastewater treatment system throughout the facility's history including closure of certain lagoons, treatment buildings, and structures, as well as the construction of various lagoons and treatment facilities. The complete history of operations is presented in the remedial investigation reports for the site and in subsequent design documents submitted to USEPA as part of the remedial program. The text in this section of the report should be revised to reflect an accurate summary of past site activities.

Response #3: The statement is accurate as presented. A reference to the Remedial Investigation Reports, including the Five-Year Summary Report will be made for additional site history and completed remedial activities.

Comment #4: In the Background and Statement of Issues section under Site Description & History, first paragraph on page 1, it is stated that:

"The contamination was discovered in the late 1970s through routine monitoring."

This statement is also incorrect. General Motors initiated discussions with both NYSDEC and USEPA in 1980 to inform the government agencies of the presence of PCB contamination at the GM facility and to begin the process of addressing the issues associated with the site contamination. The text should be revised to accurately reflect the program's history.

Response #4: The NYS DOH historical files indicate that the presence of PCBs in the tributaries and cove in the area of the General Motors and Reynolds Metals facilities was determined through fish and turtle sampling by NYSDEC Wildlife Pathologist Ward Stone in the 1970's. These data led to the subsequent listing of both facilities. Discussions between NYS DEC, NYS DOH, US EPA and GM were initiated in the early 1980s for remedial investigation of potential PCB releases.

Comment #5: The Background and Statement of Issues section under Site Description & History, second paragraph on page 1, states:

"GM initiated a remedial investigation (RI) in 1985, …."

GM began remedial investigation and other actions to address PCB contamination at the site in 1980 as part of the discussions GM initiated with the government agencies. The remedial investigation in 1985 was the first work performed under the CERCLA program, but significant activities had been underway prior to then, including information and plans presented to NYSDEC as early as 1980. The text in this section should be revised to accordingly.

Response #5: This sentence was modified to specify the CERCLA remedial investigation was initiated in 1985.

Comment #6: The Background and Statement of Issues section under Site Description & History, second paragraph on page 1 and top of page 2, states:

"The off-site contamination was primarily identified as PCB-containing sediment in the St. Lawrence River and in Akwesasne at Turtle Cove."

The text incorrectly states that Turtle Cove is in Akwesasne. The referenced cove is entirely in St. Lawrence County which is not part of the St. Regis Mohawk Indian Reservation. The report should refer to the cove as an embayment on the St. Lawrence River near the St. Lawrence and Franklin County boundary line.

Response #6: The language was clarified to indicate Turtle Cove is an embayment on the St. Lawrence River near the St. Lawrence and Franklin County boundary line.

Comment #7: The Background and Statement of Issues section under Site Description & History, first full paragraph on page 2, states:

"To facilitate remedial activities, the site was split into two operable units. The first operable unit (OU-1) includes all on and off-site areas except for the on-site Industrial Landfill and the East Disposal Areas. A proposed remedial action plan for OU-1 was prepared by US EPA in March of 1990 and a ROD was signed in December 1990. A ROD was issued in March 1992 for operable unit 2 (OU-2), which includes the Industrial Landfill and East Disposal Area."

The proposed plan issued by USEPA in March 1990 addressed the entire site, including the Industrial landfill and East Disposal Area. In August of 1990 USEPA issued new national PCB guidance related to remediation of wastes containing PCBs. After receipt of public comment, USEPA decided to withhold making a decision regarding remedial action for the Industrial Landfill and East Disposal Area in order to more fully consider the newly released PCB guidance. The site was then divided into operable units and a ROD for operable unit 1 was issued in December 1990. A second record of decision for operable unit 2 was issued by USEPA in March 1992. In addition, USEPA also released in March 1992 an Explanation of Significant Differences which acknowledged the USEPA would consider additional data to reevaluate the OU-1 remedy including the treatment requirements and PCB cleanup levels.

Response #7: Additional language was added to clarify the status of OU-1 and OU-2 and the issuance of Explanation of Significant Differences statements by the USEPA regarding treatment requirements and PCB cleanup levels.

Comment #8: The Background and Statement of Issues section under Site Description & History, middle of first complete paragraph on page 2, states:

"The modifications allowed for the excavation and off-site disposal of contaminated material rather than on-site treatment."

This sentence should more accurately read: "The modifications allowed for the excavation and off-site disposal rather than on-site treatment of materials from a specific subset of remedial activities."

Response #8: The sentence was modified to indicate that the modifications applied to a specific subset of remedial activities.

Comment #9: The Background and Statement of Issues section under Site Description & History, top of page 3, item 4, states:

"1999: ROD modification allows for off-site disposal, rather than on-site treatment, of material that is contaminated with PCBs above 10 milligrams per kilogram (mg/kg)."

This sentence should more accurately read: "1999: ROD modification issued by USEPA to allow for off-site disposal, rather than on-site treatment, of material contaminated with PCBs above 10 milligrams per kilogram (mg/kg) from certain remedial actions."

Response #9: This sentence was determined to be redundant and was therefore removed from the document.

Comment #10: The Background and Statement of Issues section under Site Description & History, page 3, item 6, states:

"2000: Work begins to excavate PCB-contaminated sludge, soils and debris from the 350,000 and the 1.5 million-gallon lagoons for disposal. Cleanup goals have not yet been achieved because of difficulties in excavating around underground utilities. Additional work to address this residual contamination is planned".

A reference to item 10 should be added such as: (see item 10 for completion of additional work.)

Response #10: A reference to item 10 was included in the revision that also changed the verb tenses from present to past, and updated information.

Comment #11: The Background and Statement of Issues section under Site Description & History, page 3, item 9, should have the following sentence appended: "Installation of a groundwater collection trench and collection sump along the southern face of the excavation. Groundwater was initially collected manually from the trench using vacuum trucks until a permanent collection system was installed to transfer the collected water to the GM wastewater treatment system. The system continues to operate at the site"

Response #11: Information regarding the installation of the groundwater collection system was included in the item description. The groundwater collection trench is discussed in more detail in other items in this section.

Comment #12: The Background and Statement of Issues section under Site Description & History, page 3, item 10, states:

"2004: Remedial work completed at the 350,000 and 1.5 million-gallon lagoons. Not all of the contaminated soils could be removed from the area adjacent to the 350,000 million-gallon lagoon due to stability issues. A localized groundwater collection system was installed to collect and treat groundwater from this location. The 350,000 and 1.5 million gallon lagoons were backfilled, lined and put into service to collect and hold storm water".

This item should read: "2004: Remedial work completed at the 350,000 and 1.5 million-gallon lagoons. Not all of the contaminated soils were removed from active areas due to soil instability issues adjacent to the 350,000 gallon lagoon supporting above and below ground utilities. For potentially impacted groundwater and lagoon maintenance, a localized groundwater collection system was installed to monitor, collect and treat groundwater from this location. The 350,000 and 1.5 million gallon lagoons were backfilled to near pre-remediation grades with imported clean material, lined and put into service to collect and hold treated process water and storm water respectively."

Response #12: Clarification was made regarding the instability of the soil preventing removal of all contaminated soils, and the lagoons were backfilled to pre-remediation grades with imported clean fill. Language was also added to clarify that the lagoons collect and hold treated process water and storm water.

Comment #13: The Background and Statement of Issues section under Site Description & History, page 3, item 11, states:

"2004: Work began to install a groundwater collection system transfer line from the north side of the on-site landfill to the wastewater treatment system".

This sentence should read: "2004: A groundwater collection pump and transfer pipeline from the collection trench north of the Industrial Landfill to the GM wastewater treatment system was installed as part of the Soils Northeast of the Industrial Landfill project initiated in 2003."

Response #13: Clarification was made in describing the trench relative to the Industrial landfill and the wastewater treatment system. The sentence was revised to indicate that the installation was completed in 2004.

Comment #14: In the Background and Statement of Issues section under Site Description & History, paragraph at top of page 4, last two sentences state:

"There are five sediment stockpiles from the recent Turtle Cove remediation project which have not been shipped off-site. Areas of concern that have not yet been remediated include the unnamed tributary (also known as Turtle Cove Creek) which flows into Turtle Cove and localized areas on Raquette Point. These areas are all on the Akwesasne Reservation."

This should read: "There are five stockpiles of soil and sediments from remediation projects that have not been shipped off-site. The stockpiled materials were placed over a bottom liner and are covered. Any residual water that drains from the stockpiles is collected and treated at the GM wastewater treatment plant. Areas of concern that have not yet been remediated include an unnamed tributary which flows into the embayment on the St. Lawrence River at the northeast corner of the site and upland soils on the St. Regis Mohawk Reservation immediately to the east of the GM facility. Additional delineation of these areas was performed in 2006 where property access was granted and remediation is planned in 2007."

Response #14: Several comments were received addressing the soil stockpiles. Language in this paragraph was clarified to specify the stockpiles are within engineered containment cells that are lined, bermed and capped. It was also clarified that additional delineation occurred in 2006 and remedial actions are anticipated in 2007.

Comment #15: In the Discussion section under Environmental Contamination and Exposure Pathways, Off-Site Contamination, Surface Water & Sediment, on page 5 states:

"PCBs were detected in some on-site groundwater monitoring wells. The movement of groundwater beneath the site is predominantly northeast towards the St. Lawrence River and the Akwesasne Reservation. An area north of the Industrial Landfill has been excavated in preparation for the installation of a permanent groundwater collection system that will reduce the movement of contaminated groundwater into the St. Lawrence River. Historic groundwater data may be found in Table 2 of the 1999 PHA. Exposure to contaminated groundwater is not expected as the water supply for the site is taken from the St. Lawrence River and has been monitored yearly for PCBs. In addition, bottled water is used for most drinking water purposes."

The discussion of on-site groundwater conditions is not reflective of current site conditions, does not take into account groundwater sampling performed since the 1999 PHA was issued or the remedial actions implemented at the site. The following information provides a current assessment of on-site groundwater conditions and should be considered for incorporation into the text in this section.

PCBs have been detected consistently in only five monitoring wells at the site. Four of these wells (MW-16A, MW-16B, MW-304, and MW-306) are/were located immediately north of the Industrial Landfill in an area where GM performed soil excavation in 2004. The fifth well (MW-22B) was located immediately adjacent to an on site lagoon that collected oily wastewater and has since been abandoned to allow for contaminated soils to be removed from that area. There have been sporadic detections of PCBs at other wells on-site including background wells upgradient of the site. Many of these sample detections were not confirmed in repeated sampling and therefore are not representative of groundwater quality. The five wells with consistent detections were drilled through waste material and the presence of PCBs in samples from these wells may be attributed to particulate contamination from these soils or the presence of PCB containing oil in the groundwater sample. A comprehensive program to characterize on-site groundwater quality at the site is currently underway and will be completed after a second round of sampling is performed in 2007. Groundwater collection and treatment is currently in place and operating both north of the Industrial Landfill and beneath the restored lagoon – areas where these five wells are located.

Response #15: New information regarding groundwater quality and monitoring programs for groundwater, as well as changes with drinking water resources, has been obtained since the public health consultation was originally written. These changes clarify that groundwater is not used as a drinking water resource at this site, and that PCBs have not been detected in the surface water intake, used as a potential potable water source, since 2000. The comment references "Off-Site Contamination, Surface Water & Sediment" but for clarification, the referred passage is from the "On-Site Contamination, Groundwater" section, page 5.

Comment #16: The Discussion section under Environmental Contamination and Exposure Pathways, Off-Site Contamination, Surface Water & Sediment, on page 5, states:

"Data from the GM Phase I and Phase II RI/FS indicate that PCBs were detected as high as 3,101 mg/kg in the Turtle Cove/unnamed tributary."

Based on our review of the RI/FS reports for the site, the sentence should be corrected to read: "Data from the GM Phase I and Phase II RI/FS indicate that PCBs were detected as high as 9.0 mg/kg in the unnamed tributary."

Response #16: The RI/FS report lists a sample from the unnamed tributary to Turtle Cove as containing up to 3,101 mg/kg PCBs. This paragraph was modified to clarify the sample was obtained from Turtle Creek and not from Turtle Cove.

Comment #17: The Discussion section under Environmental Contamination and Exposure Pathways, Off-Site Contamination, Surface Water & Sediment, on page 6, states:

"Direct contact with and ingestion of PCBs while swimming or wading in Turtle Cove or the unnamed tributary has occurred in the past."

What is the NYSDOH's basis for this statement? Does the NYS DOH have any reliable direct evidence of contact or ingestion of PCBs by individuals swimming and wading in these areas? If not, the sentence should be deleted.

Response #17: The language in this paragraph was clarified to indicate the potential existed for direct contact and/or ingestion exposure routes from recreational activities at Turtle Cove and/or Turtle Creek.

Comment #18: In the Off-Site Contamination Section, Biota, on page 6, fish consumption advice is provided for the general public and children under 15 and women of child-bearing age as presented in NYS DOH (2006). However, the advice for children under 15 and women of child-bearing age implies that the "do not eat" advisory is specific to only the St. Lawrence River and the Raquette River, when in fact; the same advice is provided for all water bodies listed in NYS DOH (2006). This should be clarified in the PHC document.

Response #18: The language in this section was clarified so that readers are aware that the fish advisories pertain to the entire St. Lawrence River and are not specific only to the waters in the immediate vicinity of General Motors.

Comment #19: In the Off-Site Contamination Section, Biota, on page 6, the discussion regarding current waterbodies that contain fish with elevated levels of PCBs is vague and without reference to data sources. The text seems to be making conclusions about fish concentrations based on the presence of fish consumption advisories. For instance, the report seems to indicate that fish with elevated PCBs are present up to the first impassable barrier of the Raquette River. What data does NYS DOH have to support this claim? Is there data that the NYS DOH has obtained since the remedial actions have been implemented at the site?

Other than the site specific advisory related to the embayment on the St. Lawrence River at the St. Lawrence and Franklin County line (an area that was remediated in 2004 and 2005), the fish consumption advisory applies to the entire St. Lawrence River and is not specific to the GM site. The text should be clarified on this point.

Response #19: The section was changed to clarify that the discussion is about the advisory and is not meant to refer to site-specific data on fish.

Comment #20: The text regarding consumption of snapping turtles and wild waterfowl (Page 6 and 7) is consistent with the information presented in NYS DOH (2006). Although the document briefly mentions that the advisories are statewide (in the biota section on Page 6), additional language should be added to the text pertaining to snapping turtles and wild waterfowl to clarify that the advisories for these species are not specific to just the St. Lawrence River.

Response #20: A heading was inserted to clarify that the snapping turtle and wild waterfowl advisories are statewide.

Comment #21: The Discussion section under Environmental Contamination and Exposure Pathways, Off-Site Contamination, Wild Waterfowl, page 7, states:

"Ingestion of PCB-contaminated fish and wildlife has occurred in the past, is presently occurring and may continue to occur."

This statement is also without basis, or is at least misleading given the context of a site specific health assessment. Does the NYS DOH have reliable direct evidence that ingestion of PCB-contaminated wildlife has occurred, is occurring and may continue to occur? Does the NYS DOH have reliable direct evidence that ingestion of PCB-contaminated fish is occurring and may continue to occur? What evidence does the NYS DOH possess that indicates that PCBs currently in the fish that may be ingested are associated with the General Motors site?

Response #21: Clarifying language was added to the paragraph. However, this paragraph does not specifically state that the PCBs in the fish are associated with the General Motors site.

Comment #22: The Discussion section under Environmental Contamination and Exposure Pathways, Off-Site Contamination, Wild Waterfowl, page 7, states:

"NYS DEC routinely monitors contaminant levels in fish and game and NYS DOH issues advisories when sportfish have contaminant levels greater than federal standards."

This use of the term 'routinely' is misleading. When did NYS DEC last perform sampling to monitor contaminant levels in sportfish and game in the vicinity of this site? When is the next scheduled monitoring event? What is the federal standard for PCBs in sportfish that triggers the need for consumption advisories? Does the NYS DOH have data that show that the fish concentrations in this area exceed these criteria? The text should be revised to be more specific as to how the government assesses modifications to its fish advisories.

Response #22: The statement from the document referred to in this question is not meant to be site-specific. That is, NYS DEC routinely monitors contaminant levels in fish and game, but may not do so frequently in any particular water body. The document text has been revised to adjust the concerns raised in this comment.

The fish and game advisories are important to note in this document as the population in the immediate region of the General Motors facility and St. Lawrence River have potential ingestion exposure concerns specifically related to consumption of fish, waterfowl and game in this area.

Comment #23: The Discussion section under Environmental Contamination and Exposure Pathways, Off-Site Contamination, Air, page 8, states:

"Twelve background samples were collected, including three upwind and nine downwind of the remediation area. PCB air concentrations downwind averaged 0.009 mcg/m³; upwind averaged 0.038 mcg/m³. During excavation activities, one air sample was collected per day at each of the three downwind sample locations for PCB analyses. PCB concentration in these air samples ranged from non-detect to 0.227 mcg/m³ (average of 0.0066 mcg/m³; the value of 0.0003 mcg/m³ –one-half of the lowest reported value- was used for samples that had no detection)"

Based on our review of the data included in the Remedial Action Completion Report for the Cove Area, the sentence should read: "Eleven pre-construction baseline samples were collected, including two upwind and nine downwind of the remediation area. PCB air concentrations downwind averaged 0.009 mcg/m³; upwind averaged 0.047 mcg/m³. During excavation activities, one air sample was collected per day at each of the three downwind sample locations for PCB analyses. PCB concentration in these air samples ranged from non-detect to 0.227 mcg/m³ (average of 0.0088 mcg/m³; the value of 0.0003 mcg/m³ – one-half of the lowest reported value - was used for samples that had no detection)." It appears the NYS DOH may have unintentionally included field blank samples in their calculations and sample counts.

Response #23: The data used in making the listed calculations was revisited as requested by the commenter. It was confirmed that there were twelve sampling points analyzed in determining the upwind and downwind baseline levels. The field blank was not included. The language in this paragraph was modified to specify the locations where the baseline sampling occurred and the time period. In addition, the downwind samples collected during the remedial activities was also recalculated, with an average value of 0.0088mcg/m³, which is a modification from the specified 0.0066 mcg/m³. The data have been corrected.

Comment #24: The Conclusions section, on page 8, should note that GM has been denied access to the unnamed tributary area, preventing further sampling and remediation from being conducted.

Response #24: Access issues as they related to remedial work have been discussed in the Conclusions section, Item #3.

Comment #25: The Conclusions section, under item 1, page 8, states:

"Although some source removal has been done, migration of contaminated groundwater to the St. Lawrence River has not yet been controlled."

Remedial actions to date have addressed all areas of consistent groundwater detections at the site. Additional sampling, which is currently underway and will be completed in 2007, will establish a final assessment of groundwater conditions at the site. The need for any additional groundwater collection will be made based on the results of this sampling program. This sentence in the text should be deleted or modified to reflect current site conditions.

Response #25: As of September 2007, contaminated groundwater continues to flow into the St. Lawrence River. A groundwater containment trench is in the remedial design process. New wells were installed and sampled in 2006-2007, as outlined in the Site Description & History section.

Comment #26: In the Conclusions section, under item 2, page 8, it should be noted that the soil stockpiles are in areas that are lined, covered, and maintained by site personnel.

Response #26: Several comments were submitted regarding the state of the stockpiles. This section has been revised to clarify the soil is stockpiled within engineered containment cells that are lined, capped and bermed.

Comment #27: The Conclusions section, under item 3, page 9, states:

"However, areas downstream of the Raquette River remedial work should be considered for additional sediment sampling."

What is the basis of this conclusion? Sediment sampling in the Raquette River downstream of the area subject to remedial action was performed by GM in 2005. Results from sediment samples indicated no significant increase in sediment concentrations from pre-remediation levels. The NYSDOH should explain their rationale for further sediment sampling or delete this sentence from the text. With respect to sampling at the unnamed tributary, it should again be noted in this conclusion (item 3) that GM has been denied access to perform sampling and remedial work along the bank of the unnamed tributary at Raquette Point.

Response #27: Remediation of PCB contaminated sediments along the Raquette River has been conducted; however, there have been some, thus far, only minor exceedances of PCBs downstream of the remedial activities along this river. Discussions between the governmental bodies and General Motors have occurred regarding future remedial need for this downstream area. As of September 2007, this area has not been determined to be fully remediated. The delineation sampling and remedial work along the unnamed tributary at Raquette Point, on the St. Lawrence River side of General Motors, has been addressed as modifications to this document in both the Site Description & History section and in the Conclusions section.

Comment #28: The Conclusions section, item 4, page 9, states:

"Fish and wildlife, including snapping turtles and waterfowl, continue to be contaminated."

This conclusion does not take into consideration that significant remedial actions have been performed over the majority of off-site and on-site areas. Unless fish and wildlife sampling has been conducted post-remediation, it is inappropriate to conclude that contamination continues.

Response #28: Additional information on contamination levels in the fish, waterfowl and wildlife has not been received. It is acknowledged that significant remedial work removing elevated PCB levels from the St. Lawrence River in the area of this site has been conducted; however, it has not been demonstrated that the biota of this region no longer reflect bioaccumulated PCB levels. The text was revised to indicate that fish and wildlife may continue to be contaminated.

Comment #29: The Recommendations section, under item 1, page 9, references the need to install a groundwater interceptor trench as a critical component of the site remedy. As stated in comments 14 and 24, the need for a site-wide groundwater interceptor trench may not be necessary, given the other remedial actions that have been implemented at the site and more recent groundwater quality data. The groundwater characterization program currently underway will provide another representation of groundwater quality and will form the basis for any decisions regarding future remedial actions regarding groundwater.

Response #29: Until additional data are received demonstrating the groundwater is no longer contaminated, the remedial proposal currently accepted by the US EPA, NYS DEC, NYS DOH and the SRMT discusses a groundwater interceptor trench. This trench is currently in the design process. The text was clarified to indicate that the groundwater trench remedy is currently in the design phase, but the necessity of the collection trench remedy is currently being re-evaluated.

Comment #30: The Recommendations section, under items 2 and 3, page 9, the NYS DOH should note that GM has been denied access to address off-site soils and sediments.

Response #30: The issue relating to current off-site access approval has been addressed in this document. These recommendations remain the same. The wording was clarified to specify contaminated areas in OU-1 and OU-2.

Comment #31: In the Recommendations section, item 4, page 9, NYS DOH should make specific recommendations regarding what sampling is necessary in the cove area in order to remove the fish consumption advisory specific to that area. The other advisory, for the St. Lawrence River, covers the entire length of river from Lake Ontario to the international border, and is not associated with site specific contamination.

Response #31: As a recommendation, the wording is adequate as presented. The process for removing a fish and game consumption advisory from either a specific area of an impacted river or from the entire river, is beyond the scope of this document. For information on how NYS DOH derives fish advisories, see new text on page 8. Note that an important part of advisory evaluation is the status of source impacts, and the design of fish sampling plans to provide appropriate fish contamination data. NYS DOH routinely consults with the NYS DEC Division of Fish and Wildlife to insure that fish collections and analyses adequately represent post-remediation fish contaminant levels.

Comment #32: In the Public Health Action Plan section, under Public Health Actions Planned item 1, page 10, the discussion should be modified to specifically encourage government agencies' efforts to obtain site access in order to complete the off-site remedial actions.

Response #32: The government entities, US EPA, NYS DEC and NYS DOH, continue to work with the SRMT, also a government entity, in implementing the public health action plan to ensure public health hazards are being mitigated and adverse health effects are being prevented. Modifying the wording in this section is not considered necessary.

Comment #33: In the Public Health Action Plan section, under Public Health Actions Planned, the NYS DOH should add a specific action to determine what sampling is needed to assess whether the advisory at the cove area should remain

Response #33: It is not within the scope of this document to set a remedial requirement for sampling delineation, which is the domain of the US EPA, as the lead agency in this remedial action. However, for your information, removal of the specific advisory for Turtle Creek Cove is contingent on the review of appropriate post-remediation fish contamination data. Because of ongoing site impacts and potential effects of remediation, this review can not occur until remediation is complete and an appropriate fish monitoring program is completed. We recommend consultation with NYS DEC Bureau of Habitat and NYS DOH Bureau of Toxic Substance Assessment staff in the design of such a program.