United States 

Environmental Protection 1200 PennsylvaniaAvenue, N.W. 

Agency Washington, DC 20460 May 2012 EPA O ce of Solid Waste and Emergency Response 

Support Document for the 

Revised National Priorities List 

Final Rule – Southern Avenue Industrial Area 
 

 

Support Document for the
 

Revised National Priorities List
 

Final Rule
 

Southern Avenue Industrial Area
 May 2012 

Site Assessment and Remedy Decisions Branch
 

Office of Superfund Remediation and Technology Innovation 

Office of Solid Waste and Emergency Response
 

U.S. Environmental Protection Agency
 

Washington, DC 20460
 
 

Table of Contents
 

Executive Summary................................................................................................................................................. ii
 

Introduction ............................................................................................................................................................ iii
 

Background of the NPL....................................................................................................................................... iii
 

Development of the NPL ..................................................................................................................................... iii
 

Hazard Ranking System....................................................................................................................................... iv
 

Other Mechanisms for Listing ...............................................................................................................................v
 

Organization of this Document ..............................................................................................................................v
 

Glossary ............................................................................................................................................................... vi
 

1. List of Commenters and Correspondence .....................................................................................................1
 

2. Site Description ................................................................................................................................................1
 

3. Summary of Comments...................................................................................................................................3
 

3.1 Support for Listing .....................................................................................................................................3
 

3.2 Site Name ...................................................................................................................................................4
 

3.3 Liability ......................................................................................................................................................4
 

3.4 Stigma of Listing ........................................................................................................................................5
 

3.5 Extent of Site ..............................................................................................................................................5
 

4. Conclusion ........................................................................................................................................................7
 

Southern Avenue Industrial Area NPL Listing Support Document May 2012 

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Southern Avenue Industrial Area NPL Listing Support Document May 2012 

Executive Summary 

Section 105(a)(8)(B) of CERCLA, as amended by SARA, requires that the EPA prepare a list of national 

priorities among the known releases or threatened releases of hazardous substances, pollutants, or contaminants 

throughout the United States. An original National Priorities List (NPL) was promulgated on September 8, 1983 

(48 FR 40658). CERCLA requires that the EPA update the list at least annually. 

This document provides responses to public comments received on the Southern Avenue Industrial Area site, 

proposed on September 16, 2011 (76 FR 57702). This site is being added to the NPL based on an evaluation 

under the EPA’s Hazard Ranking System (HRS) in a final rule published in the Federal Register in May 2012. 

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Southern Avenue Industrial Area NPL Listing Support Document May 2012 

Introduction 

This document explains the rationale for adding the Southern Avenue Industrial Area site in South Gate, 

California, to the National Priorities List (NPL) of uncontrolled hazardous waste sites and also provides the 

responses to public comments received on this site. The EPA proposed this site on September 16, 2011 (76 FR 

57702). This site is being added to the NPL based on an evaluation under the Hazard Ranking System (HRS) in a 

final rule published in the Federal Register in May 2012. 

Background of the NPL 

In 1980, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), 42 U.S.C. Sections 9601 et seq. in response to the dangers of uncontrolled hazardous waste sites. 

CERCLA was amended on October 17, 1986, by the Superfund Amendments and Reauthorization Act (SARA), 

Public Law No. 99-499, stat., 1613 et seq. To implement CERCLA, the EPA promulgated the revised National 

Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, on July 16, 1982 (47 FR 

31180), pursuant to CERCLA Section 105 and Executive Order 12316 (46 FR 42237, August 20, 1981). The 

NCP, further revised by the EPA on September 16, 1985 (50 FR 37624) and November 20, 1985 (50 FR 47912), 

sets forth guidelines and procedures needed to respond under CERCLA to releases and threatened releases of 

hazardous substances, pollutants, or contaminants. On March 8, 1990 (55 FR 8666), the EPA further revised the 

NCP in response to SARA. 

Section 105(a)(8)(A) of CERCLA, as amended by SARA, requires that the NCP include 

criteria for determining priorities among releases or threatened releases throughout the United 

States for the purpose of taking remedial action and, to the extent practicable, take into account 

the potential urgency of such action, for the purpose of taking removal action. 

Removal action involves cleanup or other actions that are taken in response to emergency conditions or on a 

short-term or temporary basis (CERCLA Section 101). Remedial action is generally long-term in nature and 

involves response actions that are consistent with a permanent remedy for a release (CERCLA Section 101). 

Criteria for placing sites on the NPL, which makes them eligible for remedial actions financed by the Trust Fund 

established under CERCLA, were included in the HRS. The EPA promulgated the HRS as Appendix A of the 

NCP (47 FR 31219, July 16, 1982). On December 14, 1990 (56 FR 51532), the EPA promulgated revisions to the 

HRS in response to SARA, and established the effective date for the HRS revisions as March 15, 1991. 

Section 105(a)(8)(B) of CERCLA, as amended, requires that the statutory criteria provided by the HRS be used to 

prepare a list of national priorities among the known releases or threatened releases of hazardous substances, 

pollutants, or contaminants throughout the United States. The list, which is Appendix B of the NCP, is the NPL. 

An original NPL of 406 sites was promulgated on September 8, 1983 (48 FR 40658). At that time, an HRS score 

of 28.50 was established as the cutoff for listing because it yielded an initial NPL of at least 400 sites, as 

suggested by CERCLA. The NPL has been expanded several times since then, most recently on March 15, 2012 

(77 FR 15276). The Agency also has published a number of proposed rulemakings to add sites to the NPL. The 

most recent proposal was on March 15, 2012 (77 FR 15344). 

Development of the NPL 

The primary purpose of the NPL is stated in the legislative history of CERCLA (Report of the Committee on 

Environment and Public Works, Senate Report No. 96-848, 96th Cong., 2d Sess. 60 [1980]). 

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Southern Avenue Industrial Area NPL Listing Support Document	 May 2012 

The priority list serves primarily informational purposes, identifying for the States and the public 

those facilities and sites or other releases which appear to warrant remedial actions. Inclusion of a 

facility or site on the list does not in itself reflect a judgment of the activities of its owner or 

operator, it does not require those persons to undertake any action, nor does it assign liability to 

any person. Subsequent government actions will be necessary in order to do so, and these actions 

will be attended by all appropriate procedural safeguards. 

The NPL, therefore, is primarily an informational and management tool. The identification of a site for the NPL is 

intended primarily to guide the EPA in determining which sites warrant further investigation to assess the nature 

and extent of the human health and environmental risks associated with the site and to determine what CERCLAfinanced remedial action(s), if any, may be appropriate. The NPL also serves to notify the public of sites the EPA 

believes warrant further investigation. Finally, listing a site may, to the extent potentially responsible parties are 

identifiable at the time of listing, serve as notice to such parties that the Agency may initiate CERCLA-financed 

remedial action. 

CERCLA Section 105(a)(8)(B) directs the EPA to list priority sites among the known releases or threatened 

release of hazardous substances, pollutants, or contaminants, and Section 105(a)(8)(A) directs the EPA to 

consider certain enumerated and other appropriate factors in doing so. Thus, as a matter of policy, the EPA has 

the discretion not to use CERCLA to respond to certain types of releases. Where other authorities exist, placing 

sites on the NPL for possible remedial action under CERCLA may not be appropriate. Therefore, the EPA has 

chosen not to place certain types of sites on the NPL even though CERCLA does not exclude such action. If, 

however, the Agency later determines that sites not listed as a matter of policy are not being properly responded 

to, the Agency may consider placing them on the NPL. 

Hazard Ranking System 

The HRS is the principle mechanism the EPA uses to place uncontrolled waste sites on the NPL. It is a 

numerically based screening system that uses information from initial, limited investigations -- the preliminary 

assessment and site inspection -- to assess the relative potential of sites to pose a threat to human health or the 

environment. HRS scores, however, do not determine the sequence in which the EPA funds remedial response 

actions, because the information collected to develop HRS scores is not sufficient in itself to determine either the 

extent of contamination or the appropriate response for a particular site. Moreover, the sites with the highest 

scores do not necessarily come to the Agency's attention first, so that addressing sites strictly on the basis of 

ranking would in some cases require stopping work at sites where it was already underway. Thus, the EPA relies 

on further, more detailed studies in the remedial investigation/feasibility study that typically follows listing. 

The HRS uses a structured value analysis approach to scoring sites. This approach assigns numerical values to 

factors that relate to or indicate risk, based on conditions at the site. The factors are grouped into three categories. 

Each category has a maximum value. The categories are: 

•	 likelihood that a site has released or has the potential to release hazardous substances into the 

environment;
 

•	 characteristics of the waste (toxicity and waste quantity); and 

•	 people or sensitive environments (targets) affected by the release. 

Under the HRS, four pathways can be scored for one or more threats as identified below: 

•	 Ground Water Migration (Sgw) 

- drinking water 

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Southern Avenue Industrial Area NPL Listing Support Document	 May 2012 

•	 Surface Water Migration (Ssw) 

The following threats are evaluated for two separate migration components, overland/flood migration and 

ground water to surface water. 

- drinking water 

- human food chain
 

- sensitive environments
 

•	 Soil Exposure (Ss)
 

- resident population
 

- nearby population
 

- sensitive environments
 

•	 Air Migration (Sa) 

- population
 

- sensitive environments
 

After scores are calculated for one or more pathways according to prescribed guidelines, they are combined using 

the following root-mean-square equation to determine the overall site score (S), which ranges from 0 to 100: 

4 

S + S + S + S =S 

2 

a 

2 

s 

2 

sw 

2 

gw 

If all pathway scores are low, the HRS score is low. However, the HRS score can be relatively high even if only 

one pathway score is high. This is an important requirement for HRS scoring because some extremely dangerous 

sites pose threats through only one pathway. For example, buried leaking drums of hazardous substances can 

contaminate drinking water wells, but -- if the drums are buried deep enough and the substances not very volatile 

-- not surface water or air. 

Other Mechanisms for Listing 

There are two mechanisms other than the HRS by which sites can be placed on the NPL. The first of these 

mechanisms, authorized by the NCP at 40 CFR 300.425(c)(2), allows each State and Territory to designate one 

site as its highest priority regardless of score. The last mechanism, authorized by the NCP at 40 CFR 

300.425(c)(3), allows listing a site if it meets the following three requirements: 

•	 Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S. Public Health Service has 

issued a health advisory that recommends dissociation of individuals from the release; 

•	 The EPA determines the site poses a significant threat to public health; and 

•	 The EPA anticipates it will be more cost-effective to use its remedial authority than to use its emergency 

removal authority to respond to the site. 

Organization of this Document 

The following section contains the EPA responses to site-specific public comments received on the proposal of 

the Southern Avenue Industrial Area site on September 16, 2011 (76 FR 57702). The site discussion begins with a 

list of commenters, followed by a site description, a summary of comments, and Agency responses to each 

comment. A concluding statement indicates the effect of the comments on the HRS score for the site. 

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Southern Avenue Industrial Area NPL Listing Support Document May 2012 

Glossary 

The following acronyms and abbreviations are used throughout the text: 

Agency U.S. Environmental Protection Agency 

ATSDR Agency for Toxic Substances and Disease Registry 

cDCE cis-1,2-dichloroethene 

CDCPG Cooper Drum Cooperating Parties Group 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 

U.S.C. Sections 9601 et seq., also known as Superfund 

CFR Code of federal regulations 

COC Chemicals of concern 

D.C. Cir U.S. Court of Appeals for the District of Columbia Circuit 

EPA U.S. Environmental Protection Agency, also USEPA 

FR Federal register 

HRS Hazard Ranking System, Appendix A of the NCP 

HRS score Overall site score calculated using the Hazard Ranking System; ranges from 0 to 100 

NCP National Oil and Hazardous Substances Pollution Contingency Plan, 40 C.F.R. Part 300 

NPL National Priorities List, Appendix B of the NCP 

RI Remedial Investigation 

RI/FS Remedial Investigation/Feasibility Study 

SARA Superfund Amendments and Reauthorization Act 

TCE Trichloroethene 

VOC Volatile organic compound 

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Southern Avenue Industrial Area NPL Listing Support Document	 May 2012 

1. List of Commenters and Correspondence 

EPA-HQ-SFUND-2011-0645-0003	 Correspondence, dated May 10, 2011, to Governor Jerry Brown 

seeking the State of California’s position on the United States 

Environmental Protection Agency (U.S. EPA) proposed listing 

of the Seam Master Industries and the Jervis B. Webb Co. sites 

on the Superfund National Priorities List (NPL). 

EPA-HQ-SFUND-2011-0074-0005	 Comment and attachment, dated November 3, 2011, from Carlos 

Velasquez, public commenter 

EPA-HQ-SFUND-2011-0074-0006	 Comment and attachment, dated November 5, 2011, from 

Maritza Velasquez, public commenter 

EPA-HQ-SFUND-2011-0074-0007	 Comment and attachment, dated November 5, 2011, from 

Mehnoosh Anwar, public commenter 

EPA-HQ-SFUND-2011-0074-0008	 Comment and attachment, dated November 1, 2011, from Paul 

M. Vidor, President, Seam Master Industries 

EPA-HQ-SFUND-2011-0074-0009	 Comment and attachment, dated November 15, 2011, from 

Elizabeth Velasquez, public commenter 

EPA-HQ-SFUND-2011-0074-0010	 Comment and attachment, dated November 15, 2011, from 

Daniel E. Vineyard, Jackson Walker L.L.P., Common Counsel, 

Cooper Drum Cooperating Parties Group (CDCPG) 

2. Site Description 

The Southern Avenue Industrial Area site (formerly identified as the Seam Master Industries site, hereinafter 

referred to as the Site) comprises ground water contamination in South Gate, Los Angeles County, California (see 

Figure 1). The Site is located in an urban area, in which numerous drinking water wells are located. The HRS 

evaluation for the Site scored the ground water migration pathway. The source identified at proposal for HRS 

purposes is volatile organic compound (VOC)-contaminated soil located in the southeastern portion of the Site on 

the Seam Master Industries property, which since 1972, has been operating as a hot-melt adhesive manufacturing 

company. The Seam Master Industries property, the location of the source of contamination at this Site, is located 

at 5211 Southern Avenue, South Gate, Los Angeles County, California. 

The Site was scored based on the finding of soils contaminated with VOCs and the identification of observed 

releases of VOCs by chemical analysis to a drinking water aquifer. The observed releases were identified based 

on ground water samples collected from five boring locations and two monitoring wells throughout the Site area. 

The contaminants found were trichloroethene (TCE) and cis-1,2-dichloroethene (cDCE). Background samples 

collected upgradient of the Site that draw from the same aquifer showed no-detection or comparatively low 

concentrations for these contaminants. 

The HRS target evaluation included eight drinking water wells located within two miles of the sources at the Site; 

the wells were screened within the Semi-Perched/Gaspur/Exposition/Gage interconnected Aquifer. These wells 

were evaluated for potential contamination and provide drinking water to approximately 65,256 people. Four 

municipalities, which are located within four miles of the sources at the Site and have public water systems, were 

scored for potential contamination. Those water systems include: City of South Gate, Walnut Park Mutual Water 

Company, Maywood Mutual Water Company #3 and City of Lynwood. The four municipalities serve 

approximately 188,840 people. 

1 
 

 

 

Southern Avenue 

Railroad 

Atalantic

Avenue 

Rayo Avenue 

Firestone Boulevard 

Groundwater 

E

Flow Direction 

Legend 

Property Boundary 

U+ Monitoring Well 

&. CPT Sample 

+

Jervis B. Webb Co. 

Property Groundwater Sample Location U+

with TCE and DCE concentration 

in micrograms per liter. MW-10 

TCE: 15 

DCE: 32 TCE = Trichloroethylene 

DCE = cis-1,2-Dichloroethene 

CPT = Cone Penetration Test 

MW = Monitoring Well 

ND = Not Detected 

U

Grab Groundwater Sample 

Feet 

0 400 

MW-14 

TCE: 0.63 

DCE: 3.2 

Cooper Drum CPT-20
 

TCE: 24
 

DCE: 9
 

SM-7-GW
 

TCE: 4,100
 

CPT-21
 

TCE: 8,000
 

DCE: 4,900 +U

Property 

MW-10 U+

TCE: 15 

DCE: 32
 

CPT-16
 

TCE: <0.5
 

&.+U

U+

&.

U

+U

Seam Master 

+

Property DCE: <0.5
 

SM-1-GW
 

TCE: 7 MW-34 DCE: 1
 TCE: 46
 

DCE: 420
 

MW-35 

TCE: 120 

Base Map: USA Prime Imagery, Los Angeles, Aerials Express 2009.
 

CPT and Well Locations from: Innovative Technical Solutions, Inc.,
 

Cooper Drum Company Superfund Site Remedial Design Technicall
 

Memorandum for Field Sampling Results, Addendum No. 4, February 26, 2010.
 

Grab Groundwater Samples Locations from: Weston Solutions, Inc.,
 

Preliminary Assessment/Site Inspection Report, Seam Master Industries,
 

South Gate, California, May 8, 2003.
 

&.+U

SM-8-GW
 

TCE: 4,000
 

SM-6-GW
 

TCE:1,700
 

Site Area Map

Southern Avenue Industrial Area 

South Gate, California Figure 

SM-9-GW
 

TCE: 17,000
 

DCE: 8,000
 

U+U+

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Southern Avenue Industrial Area NPL Listing Support Document May 2012 

An adjacent NPL site, the Cooper Drum Company Superfund Site (Cooper Drum site) (EPA ID: CAD055753370) 

is located at 9316 Atlantic Avenue in South Gate, California (see Figure 1). The Cooper Drum facility is located 

approximately 300 feet northwest and hydraulically upgradient of the Seam Master property. Contaminants or 

chemicals of concern (COC) associated with the Cooper Drum facility include TCE and cis-1,2-DCE. The Cooper 

Drum site was proposed to the NPL on January 11, 2001, and added to the NPL on June 14, 2001. 

3. Summary of Comments 

Six comment submittals were received on the proposal of the Site to the NPL. Five commenters supported 

placement of the Site on the NPL. Two commenters in support of placement of the Site on the NPL expressed 

concern that if the Site is not cleaned up it could cause “hazardous health problems.” Two other commenters in 

support of placement of the Site on the NPL stated that they have seen the negative impacts that high levels of 

pollution have had on the city and “would hate to see this pattern of environmental damage continue to happen in 

this community.” 

Cooper Drum Cooperating Parties Group (CDCPG) also supported placement of the Site on the NPL. CDCPG 

stated that it appreciated the EPA’s efforts to fully characterize ground water plumes in the Site area, and 

identification of the Site as a major contributor to ground water contamination in South Gate, California. In 

addition to supporting the listing, CDCPG expressed concerns that close proximity to the Southern Avenue 

Industrial Area site has complicated the interpretation of plume boundaries, specifically, that it objected to the 

statement in the Site narrative that the plumes from this site and the Cooper Drum site were commingled, and 

requested that certain technical issues related to plume boundaries be clarified. 

One commenter contested the listing – Seam Master Industries. Seam Masters Industries objected to naming the 

site Seam Master Industries and requested that any reference to Seam Master Industries be deleted. Seam Master 

Industries asserted that Seam Master Industries does not own the referenced property nor is in any shape or form 

responsible for any contamination. Seam Master Industries added that “there could be a perception of ‘guilt by 

location’ which could damage the reputation of our company, which could have dire consequences in these tough 

economic times.” 

3.1 Support for Listing 

Comment: Linda S. Adams, Acting Secretary for Environmental Protection for the State of California, agrees that 

the environmental threats identified need to be addressed, and the State of California supported placement of the 

Site on the NPL. The Cooper Drum Cooperating Parties Group (CDCPG) supported placement of the Site on the 

NPL. CDCPG stated that it appreciated the EPA’s efforts to fully characterize ground water plumes in the area of 

the Site, and that the EPA identified the Site as a major contributor to the ground water contamination in South 

Gate, California. CSCPG’s submission also included comments regarding whether the plume from this site was 

commingled with that from the Copper Drum Site; these comments are addressed in section 3.5 of this support 

document. 

Four additional commenters, Maritza Valasquez, Mehnoosh Anwar, Carlos Velasquez, and Elizabeth Velasquez, 

supported placement of the Site on the NPL. Maritza Valasquez and Mehnoosh Anwar, expressed concern that if 

the Site is ignored and not cleaned up it “can cause hazardous health problems.” Carlos Velasquez and Elizabeth 

Velasquez stated that “the community is already one of the most polluted in the region” and that they “see the 

negative impacts that high levels of pollution have had on the city” and they “would hate to see this pattern of 

environmental damage continue to happen in this community.” 

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Southern Avenue Industrial Area NPL Listing Support Document May 2012 

Response: Southern Avenue Industrial Area site is being added to the NPL. Listing makes a site eligible for 

remedial action funding under the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), and the EPA will examine the Site to determine the appropriate response action(s). Actual funding 

may not necessarily be undertaken in the precise order of HRS scores. In addition, upon more detailed 

investigation may not be necessary at all in some cases. The need for using Superfund monies for remedial 

activities will be determined on a site-by-site basis, taking into account the NPL ranking, State priorities, further 

site investigation, other response alternatives, and other factors as appropriate. The EPA will not stop work at 

some sites to begin work at other higher-scoring sites added to the NPL more recently. 

As discussed in the remainder of this support document, all specific comments received on the proposed addition 

to the NPL of this site have been addressed and the Site still qualifies for the NPL listing. 

3.2 Site Name 

Comment: Seam Master Industries objected to naming the site Seam Master Industries. Seam Master Industries 

commented that “any reference to Seam Master Industries be deleted.” 

Response: The Site was named Seam Master Industries based on information obtained by the EPA at the time of 

proposal. The Site name has been changed to Southern Avenue Industrial Area at promulgation to better reflect 

the site location and for the location to be more clearly understood by the public. The HRS documentation record 

at promulgation has been revised to reflect this change. For the limited purpose of the NPL, as stated in RSR 

Corporation v. Environmental Protection Agency No. 95-1559 (D.C. Cir. 1997), when naming a site, the “EPA 

prefers names that accurately reflect the location or nature of the problems at a site and that are readily and easily 

associated with the site by the general public“ and that “listing does not require any action of any private party, 

nor does it determine the liability of any party for the cost of cleanup at the site.” 

Concerning the commenter’s request to delete any reference to Seam Master Industries, it would be inappropriate 

and to some extent misleading to describe the Site for public understanding without mention of Seam Master 

Industries. The Site Description correctly discusses the history of the Site including the businesses that operated 

on the Site; therefore Seam Master Industries is appropriately discussed in the HRS documentation record at 

proposal. In as much as this comment concerns liability for contamination at the Site, as discussed in section 3.3 

of this support document, liability is not considered when evaluating a site under the HRS, nor is liability 

established or apportioned based on the decision to place a site on the NPL. 

This comment results in no change to the HRS site score and no change in the decision to place the Site on the 

NPL. 

3.3 Liability 

Comment: Seam Master Industries stated that it “has been brought to our attention that the article in your 

September 2011 publication states that “Seam Master Site” is proposed to be added to the Superfund List.” It 

commented that “Seam Master Industries does not own the referenced property nor is in any shape or form 

responsible for any contamination referenced in the article published in your September 2011 issue.” 

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Southern Avenue Industrial Area NPL Listing Support Document May 2012 

Response: In as much as this comment concerns liability for contamination at the Site, liability is not considered 

when evaluating a site under the HRS, nor is liability established or apportioned based on the decision to place a 

site on the NPL. The NPL serves primarily as an informational tool for use by the EPA in identifying those sites 

that appear to present a significant risk to public health or the environment. It does not reflect a judgment on the 

activities of the owner(s) or operator(s) of a site. The listing does not require those persons to undertake any 

action, nor does it assign any liability to any person. This position, stated in the legislative history of CERCLA, 

has been explained more fully in the Federal Register (48 FR 40759, September 8, 1983 and 53 FR 23988, June 

24, 1988). See Kent County v. EPA, 963 F.2d 391 (D.C. Cir. 1992). 

If by “article in your September 2011 publication” Seam Master Industries is referring to the HRS documentation 

record at proposal, that record does not state that Seam Master Industries owns the referenced property. The HRS 

documentation record at proposal on page 9 states that “[s]ince 1972, the Seam Master facility has been operating 

as a hot-melt adhesive manufacturing company.” (See also section 3.2 of this support document regarding the Site 

name.) 

This comment does not change the HRS site score and does not change the decision to place the Site on the NPL. 

3.4 Stigma of Listing 

Comment: Seam Master Industries stated that “[u]nfortunately there could be a perception of ‘guilt by location’ 

which could damage the reputation of our company, which could have dire consequences in these tough economic 

times.” 

Response: Any negative impacts associated with listing the Site, as noted by Seam Master Industries, would be 

engendered by the contamination in the area, not by placing the Site on the NPL. Inclusion of a site or facility on 

the list does not in itself reflect a judgment on the activities of the owner(s) or operator(s), but rather reflects the 

EPA’s judgment that a significant release or threat of release has occurred and that the site is a priority for further 

investigation under CERCLA. Both costs and benefits can be associated with listing a site. Among the benefits 

associated with listing a site on the NPL are increased health and environmental protection as a result of increased 

public awareness of potential hazards. In addition to the potential for federally financed remedial actions, the 

addition of a site to the NPL could accelerate privately financed, voluntary cleanup efforts. Listing sites as 

national priority targets also may give States increased support for funding responses at particular sites. As a 

result of the additional CERCLA remedies, there will be lower human exposure to high-risk chemicals, and 

higher quality surface water, ground water, soil and air. Therefore, it is possible that any perceived or actual 

negative fluctuations in property values or development opportunities that may result from contamination may be 

countered by positive fluctuations when a CERCLA investigation and any necessary cleanup are completed. 

This comment does not change the HRS site score and does not change the decision to place the Site on the NPL. 

3.5 Extent of Site 

Comments: CDCPG requested that the EPA revise the September 2011 Site narrative and an EPA Fact Sheet 

(Seam Master Industries [Southern Avenue Industrial Area] and Jervis B. Webb Co. Sites Proposed for Superfund 

List, September 2011), to reflect that it is not known that the plumes from the Cooper Drum site and the Southern 

Avenue Industrial Area site commingle. CDCPG identified that the Southern Avenue Industrial Area site and the 

Cooper Drum site are relatively close and share some of the same chemicals of concern (COC). CDCPG 

commented that close proximity to Southern Avenue Industrial Area site has “complicated the interpretation of 

‘plume boundaries’” and requested that certain technical issues related to plume boundaries be clarified. 

CDCPG gave several rationales for why the two plumes might not be commingled: 

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Southern Avenue Industrial Area NPL Listing Support Document	 May 2012 

•	 that the “HRS documentation record at proposal shows that the background COC concentrations at the 

northwest (upgradient) corner of the Seam Master [Southern Avenue Industrial Area] site, south 

(downgradient) of the Cooper Drum site, were very low.” Therefore the contamination may not be in high 

enough concentrations to migrate to where it might commingle 

•	 that the ground water flow direction is such that the contamination from the sites would not commingle 

•	 that the contaminant mixes in the two plumes are significantly different. 

CDCPG continued that: 

Both the CDCPG and [the] EPA acknowledge that the plume boundaries are ambiguous due to 

the similarity in COCs and close proximity of the Seam Master [Southern Avenue Industrial 

Area] and other sites to the Cooper Drum site. Moreover, it is a fact that the Seam Master 

[Southern Avenue Industrial Area] plume has not yet been characterized and its boundaries are 

yet to be defined. Thus, it simply is not known whether or not these two plumes actually 

commingle. Thus, we respectfully request that the statement in the NPL Site Narrative quoted 

above be clarified to reflect these facts. 

Response: The Site for HRS scoring purposes is delineated in the HRS documentation record at proposal as 

consisting of a source and the releases of hazardous substances to ground water from the Site source. The 

potential commingling of ground water plumes associated with this site and the Cooper Drum site was not a factor 

in the development of the HRS Site score and is not relevant to the listing decision for the Site. The full extent of 

the Site will be determined during other stages of the Superfund process. 

However, to reflect that the full extent of the two plumes has not been completely delineated, the EPA Site 

Narrative has been revised to clarify that the ground water contamination from the Southern Avenue Industrial 

Area site appears to be commingling with the down gradient portion of the Cooper Drum plume. The revised Site 

Narrative is in the docket at promulgation. 

The EPA Fact Sheet, Seam Master Industries [Southern Avenue Industrial Area] & Jervis B. Webb Co. Sites 

Proposed for Superfund List, September 2011, is a published document in the public realm. When the site is 

finalized, the region will issue a new, and separate, fact sheet reflecting that the plumes possibly commingle. This 

new fact sheet will be updated to the site website. 

However, that the HRS site evaluation does not rely on the commingling of the two plumes does not mean that the 

sites may not be found to overlap based on further investigation. 

For HRS evaluation purposes, the site is defined in HRS Section 1.1, Definitions, as: 

[a]rea(s) where a hazardous substance has been deposited, stored, or placed, or has otherwise 

come to be located. Such areas may include multiple sources and may include the area between 

the sources. 

The extent of contamination at the Site is described in the HRS documentation record at proposal by identifying 

the extent of contamination in ground water samples and establishing that observed releases have been 

documented in ground water samples. 

The HRS directs the identification of the contaminated areas that constitute the site for scoring purposes. HRS 

Section 3.1.1, Observed Release, directs the identification of observed releases to ground water HRS Section 2.2, 

Characterize sources, directs the identification of sources. 

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Southern Avenue Industrial Area NPL Listing Support Document May 2012 

The extent of the Site for HRS scoring purposes is described on page 9 of the HRS documentation record at 

proposal as follows: “The [S]ite includes the contaminated soil source and releases of volatile organic compounds 

(VOCs) and associated ground water contamination, which pose a hazard to people.” The commenter did not 

contest the identification of the source or the observed releases at the Site. The scored source is identified as 

Source 1, contaminated soil at Seam Master Industries, which is described on pages 11-16 of the HRS 

documentation record at proposal as “contaminated soils located on the Seam Master property.” Multiple 

observed releases have been documented in ground water samples collected (pages 22-31 of the HRS 

documentation record at proposal). Specifically page 30 of the HRS documentation record at proposal states: 

Hazardous substances that meet the criteria for an observed release by chemical analysis were 

detected in Source 1 (see Section 2.2.2 of this documentation record). Background samples used 

to evaluate an observed release by chemical analysis are located upgradient of the source at the 

Jervis B. Webb site. An observed release of TCE and cis-1,2-DCE is documented from the Seam 

Master property based on chemical analysis (see above tables in Section 3.1.1 of the HRS 

documentation record). 

In addition, the delineation of the site boundaries is not completed at the time of placing a site on the NPL. As 

stated in the footnote on page 1 of the HRS documentation record at proposal: 

Generally, HRS scoring and the subsequent listing of a release merely represent the initial 

determination that a certain area may need to be addressed under CERCLA. Accordingly, the 

EPA contemplates that the preliminary description of facility boundaries at the time of scoring 

will be refined as more information is developed as to where the contamination has come to be 

located. 

Until the site investigation process has been completed and a remedial action (if any) selected, the EPA can 

neither estimate the extent of contamination at the site, including whether the two plumes have commingled, nor 

describe the ultimate dimensions of the NPL site. Even during a remedial action (e.g., the removal of buried 

waste) the EPA may find that the contamination has spread further than previously estimated, and the site 

definition may be correspondingly expanded. In addition, if another, unrelated area of contamination is discovered 

elsewhere on the property, the EPA may decide to evaluate that release for the NPL. 

This comment results in no change to the HRS site score and no change in the decision to place the Site on the 

NPL. 

4. Conclusion 

The original HRS score of this site was 50.00. Based on the above responses to public comments, the score 

remains unchanged. The final scores for the Southern Avenue Industrial Area site are: 

Ground Water 100.00
 

Surface Water Not Scored
 

Soil Exposure Not Scored
 

Air Not Scored
 

HRS Site Score 50.00
 

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