The Ithaca Gun Company Site (the “Site”) comprises property formerly occupied by the Ithaca Gun Company at 121-125 Lake Street, Ithaca, New York, as well as an Ithaca Falls parcel which is located directly downhill from the Ithaca Gun Company property (see Attachment A, Figures 1 & 2). The Ithaca Falls parcel which is owned by the City of Ithaca is popular with hikers, swimmers, fishermen and others due to the scenic nature of the Ithaca Falls/Fall Creek gorge area. Lead shot was dumped from the Ithaca Gun Company property into the gorge and lead shot and lead contaminated soils have migrated onto the Ithaca Falls parcel via erosion from a portion of the Ithaca Gun Company property. While the Ithaca Gun Company property is fenced, there are indications that trespassers frequently visit the Site. The City’s property is not fenced and there is clear evidence that this property is actively used. Significant quantities of lead shot and dust are clearly evident on the ground surface on both the Ithaca Gun Company property and the Ithaca Falls parcel. Analytical results from sampling conducted by New York State on the City’s property yielded lead concentrations ranging from 251 parts per million (ppm) to 215,000 ppm.
On August 29, 2000, the U.S. Environmental Protection Agency (EPA) received a request from the New York State Department of Environmental Conservation (NYSDEC) to conduct an emergency removal action at the Ithaca Gun Company Site under Section 104 of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, by the Superfund Amendments and Reauthorization Act of 1986 (see Attachment B). This request was prompted by historical soil sampling that was conducted by the NYSDEC and by Cornell University that revealed elevated lead concentrations. Based upon the sampling results, the New York State Department of Health (NYSDOH) considers the Site a potentially significant health threat, particularly for children.
On September 26 through September 29, 2000, the EPA Response and Prevention Branch conducted a Removal Site Assessment utilizing the Removal Support Team (RST) contractor. The RST contractor collected surface and subsurface soil/sediment samples and screened the samples for lead and arsenic using a field portable XRF instrument in order to determine the extent of contamination. The RST contractor established 25 foot by 25 foot sampling grids in an area approximately 100 feet wide by 200 feet long on the Ithaca Falls parcel. Samples were collected at a depth of 0-6 inches, and four samples were collected from a depth of 15 inches. Soil/sediment samples were also collected, at 25 foot intervals, along Mill Race Creek, located along the southern boundary of the property, for a distance of approximately 500 feet. Soil/sediment samples were also collected along the eastern bank of Fall Creek, located along the northern boundary, at 25 foot intervals. In addition, surface soil samples were collected at ten biased locations on the Ithaca Gun Company property. A total of 110 soil/sediment samples were collected. The results are illustrated in Attachment C.
Results from the Removal Site Assessment revealed total lead concentrations from non-detected to 136,000 ppm. Subsurface soil samples collected at 15 inches contained lead in concentrations up to 28,900 ppm. Arsenic concentrations ranged from non-detected to 3,000 ppm in surface soils samples. Reportedly, arsenic was added to lead during the formation of lead bullets which allowed a more spherical shape.
Further delineation of the extent of lead contamination occurred from July 24 to July 26, 2001. An upper area of a millrace channel and channel banks, including a plunge pool, on the Ithaca Gun Property was assessed. A total of 50 surface and sub-surface soil samples were collected and analyzed in the field with an XRF. Results from this sampling event revealed total lead concentrations from 648 ppm to 24,150 ppm. Subsurface soil samples collected at six inches contained lead in concentrations up to 42,400 ppm. This sampling event also revealed a thin veneer of soils, averaging six inches in depth.
The NYSDEC conducted a soil depth profile in May 2001 that revealed that the soil depths are at their deepest in the eastern boundary and then gradually decrease in depth toward the west, i.e., five feet to 1 ½ feet. In addition, lead contaminated soils were identified at adjacent property to the east and downwind of the Site. This property belongs to the Sigma Nu fraternity and is represented by a heavy vegetated slope immediately downwind from cyclone exhaust fans belonging to the former Ithaca Gun manufacturing facility. The total estimated volume of material proposed for excavation and removal at the Site is 1,820 cubic yards.
The Agency for Toxic Substances and Disease Registry (ATSDR) produced a Health Consultation to assist the EPA in the evaluation of the public health implications of exposure to lead contaminated soils at the Site. Based upon on-site observations, the available sampling data, and the ATSDR’s hazard category classification, the areas of lead contamination at the Ithaca Falls parcel and the former Ithaca Gun facility pose a public health hazard. Direct contact, incidental ingestion, and inhalation of contaminated soils are likely.
Also included on the Ithaca Falls parcel is a small circular area of about 100 square feet where NYSDEC, using very sensitive radiation detection instruments, detected concentrations of the uranium series. The NYSDEC collected surface and subsurface soil samples from two spots in that area. The measured dose rates over the surveyed areas ranged from 3 to 12 urem/hr. These concentrations are not high. Based on the data obtained, the contamination at this location should be limited to approximately 5 yd3 of soil. All dose rate measurements were attributed to the range of background readings.
