Global Settlement
EPA and Viacom met during December of 2001, and the issue of a global settlement for the sites was discussed. Issues categories identified by the Parties in a December meeting were: Remedial/Technical, Costs Past and Future, Natural Resource Damages, and the Consent Decree Amendment.
Viacom may liable for the remaining remedial work, future and past costs, and natural resource damages. However the Consent Decree is still in effect and under it Viacom claims no responsibility for new water treatment at Neal's Landfill, and they have steadfastly refused to pay for the ICS water treatment plant. Viacom also holds the position that there are no natural resource damages for any of the sites, again citing the Consent Decree. If these issues went to Court, Viacom could sue the State for blocking the Incinerator, and would probably sue EPA as well.
Viacom has spent over $198 million, $100 million of that on the failed incinerator plan, and they feel they have met their obligations under the Consent Decree. The EPA has substantial past costs they have planned to recover from Viacom, dating back to February 1994. Viacom says they paid a million dollars at the beginning, and they don't owe anymore. All of these issues must be resolved by the Parties, and gain approval by the new district court judge, Richard L. Young, who has not yet met with the Parties. Otherwise the issues will go to court, with one of the world's fattest corporations suing the cash strapped State of Indiana and puny Bloomington. There should be a 60 day public comment period prior to the Consent Decree amendment.
The Sampling/Analysis of Fish in Conard’s Branch and Richland Creek is complete and has been released, while the Status Report for Water, Sediment and Fish is nearly complete, and will be released this spring.
The EPA has discussed obtaining data with the Rogers Group, and got a positive response. Even with no cooperation from Rogers, EPA can issue a request that is backed with penalties.
The Parties are discussing Gas Vent Sampling at Neal's. The vents installed
are intended to release the methane that comes from most landfills like
Neal's, and EPA wants to know if PCBs being released with the methane.
Draft Treatability Study Results The treatability study of Oct 2001 provided enough data to to justify more testing this spring. There is great volume of water at Neal's, compared to Lemon Lane, that use of a sediment basin may be appropriate, if the data from more testing shows that this is workable.
Neal's Landfill Long-Term Groundwater Monitoring Plan
The Plan should be released in March as required under the State of Indiana's Work for Source Control document. There are minor issues remaining to be resolved before approval, including biweekly influent samples at the water treatment plant, and monthly grab samples from North and South Spring for PCBs/TSS. EPA also wants flow/conductivity studies during non-storm conditions, with a minimum of 1 storm/year, as well as semi-annual sampling at Branham and Taylor Springs.
Piezometer monitoring within Landfill continues, as does water level in Monitoring Well 5A which is thought to be connected to a main conduit. Viacom has proposed fish sampling in 2004, while the EPA just completed their 2001 Fish Assessment at a cost of $80,000.
Groundwater Investigation Plan
This plan is in progress and the final report is due in August 2002. EPA plans to investigate the basin around Neal's Landfill, including the Roger's Quarry area. Aerial photographic analysis will be used, and a dye trace study of the Cave Creek watershed is planned. (If Viacom will not do it, EPA will.) They will also review the Field Stone retention pond records in detail. The closing of the detention pond gates seems to have an effect on the peak flow at Neal, though not on the total volume of water. Water level data in Monitoring Wells will be taken, and interim reports are to be submitted quarterly. Grab samples at North Springs and South Springs show steady releases of PCBs over time.
Neal's Landfill Water Flow Records Four
Gages were used by USCG for a year and a half from June 6, 2000 to
November 14, 2001
Gage 0, Partial Flume – Northwest Spring System Overflow 0
Gage 012, V-Notch Weir, - Overflows 0, 1 and 2
Gage 34, V-Notch Weir, - Overflows 3 and 4
Gage NS, V- Notch Weir, - North Spring Overflow
[Q Conard’s Branch Gage = Q Gage 012 + Q Gage 34 + Q South Spring Spillover]
Full data will be released in Water Resources Data for Indiana Water Year 2000, published by the
USGS, and it will be available at the PCB Repository in the MCPL.
There was an overlap of records for the new Viamcom gage and the USGS gages from the period October 9 to November 14, 2001. The Summed flow from Gages 012 and 34 compares well with new Viacom gage at Conard’s Branch
Water Flow Graphs
During storm events, the overflow springs at Neal's are activated. This water is not treated, and is higher in PCB concentration than at low flow. Releases from North Spring are minimal, about 1 percent of the total water released to Conard's is from North Spring, and the water is lower in PCBs. However, 124 million gallons of water were bypassed during the period June 6-Nov 13, 2001, estimated using the USGS data. About 167 gpm are bypassed on average. By looking at the Storm Events data, it is reasonable to assume a 4 inch storm would occur about every 5 years. This all seems to indicate the need for better water treatment at Neal's Landfill.
2001 Mean Concentrations of PCBs in fish tissue
[Shows high concentrations of PCBs in fish close to Conard's Branch.
Comparison of Mean PCB Concentrations in Fish Tissue from 1998 and 2001
On August 6–8,2001 there was a combined effort by USEPA, IDEM, and USFWS in Conard’s Branch and Richland Creek to collect whole-body fish and fillets to be analyzed for PCBs.
Sample Locations
Fish species collected for whole fish analysis
BRH – Black Redhorse (4 – 6)
CP – Carp (5 – 6)
CRC - Creek Chub(1 and 3)
GS – Green Sunfish (1)
LS – Longear Sunfish (2 and 4 – 6)
WS – White Sucker (2 and 4)
(Reach in which each species was collected)
Chemical Analysis
USEPA – whole-body fish and fillets
Total PCBs (Aroclor 1248)
Did not detect 1016, 1221, 1232, 1242, 1254, 1260
PCB congeners (14 dioxin-like)
77, 81, 105, 114, 118, 123, 126, 157/156, 167, 169, 170, 180/193, 189
IDEM – fillets
Focused Ecological Risk Assessment
Draft notes for a Focused Ecological Risk Assessment were presented
by EPA Ecologist James Chapman, Ph.D. The full report will be available
this spring.
The main receptors for the study are Mink and Kingfisher. Though mink are no longer in resident in Indiana, they should be, and would be if allowed to return. Otters are already established, and would have a similar profile, ie, subsisting mainly on fish in the creeks. Kingfishers are common along Richland Creek.
The EPA is developing a Status Report for Bennett’s Dump. They will summarize all the water, sediment and fish data for review. EPA has been talking with Viacom, and has worked out most of the minor issues remain for both a Groundwater Monitoring Plan and Groundwater Investigation Plan. EPA is developing their Five-Year Review for the site, as the remediation did not stop PCBs from escaping from the springs and seeps at the site. Further investigation is necessary prior addressing the contaminated springs and seeps. EPA needs an agency decision document that more work is needed at Bennett's.
Bennett’s Dump Long-Term Groundwater Monitoring Plan will have the following:
- Quarterly PCB Sampling of Middle & Mound Springs
- Middle Springs flows all the time, Mound
spring does not flow in dry weather. North and South Springs flow only
during storm events.
- North and Mid-North Quarterly if flowing
- Quarterly PCB Sampling Upstream and Downstream in Stout’s Creek
- Creek Flow Measured Continuously
- Minimum of One Storm Event Sampling
- In 2003, Fish and Sediment Sampling
- EPA may fund additional sampling before
then.
- Semi-Annual Monitoring of MW 6I, 6D and 5 (all
adjacent to creek)[MW 5 has yielded pure PCBs in the past]
Bennett’s Dump Groundwater Investigation Plan was developed by the insistence of EPA in negotiations with Viacom, and will include:
- Objectives-Define Site Hydrogeology and Recharge Area (relationship between groundwater elevations, water levels in quarry pits and spring flows)
- Monitor PCBs into Stout’s Creek under varying hydrogeologic conditions
- Determine Impact of Route 46 Highway Construction
- Air Photo Analysis
- New Topographic Map
- Install Staff Gages in Quarry Pits
- Stream Gaging in Stout’s Creek
- V-Notch weirs on Middle and Mound Spring
- Piezometer in Grid H7
- Quarterly Reports and Summary Report End of 2002 – Phased Approach
- Periodic Pumping of MW 5 and Evaluation
- Pump and treat or Lower groundwater elevation to stop seeps. But
- Mound Spring is the problem, 2-7 ppb flowing directly into Stout's Creek
- Monitoring Well 6D - 10 ppb
- Stout's Creek down stream
EPA is updating the Status Report for Water, Sediment and Fish, while
Viacom is to submit the Long-Term Groundwater Monitoring Plan soon.
PCB Levels at ICS, 1-26-00 through 10-19-01
The draft report was received by the EPA on February 2, 2002
Tests were conducted October 31 to November 23, 2001
The data are preliminary and analysis is ongoing. It is the best reporting Viacom has done yet, according to the EPA's Tom Alcamo. John Bassett of EarthTec gave a report on the data. He commented that the report's data showed that it is unlikely Viacom will be able to find a single conduit to ICS that they can pump and thus reduce the flow at the Springs. However, Viacom is not done with testing at the Landfill, they are planning to test in the epikarst area along the southwest corner where they know water is flowing through the phreatic zone of fractured limestone (epikarst) from the Landfill through Valhalla Cemetary towards the ICS.
November 2001 Tracer/Pumping Tests Goals
- To determine if any of the wells surrounding the site were on or near a major conduit which would integrate all three dyes into one flow path towards the ICS [they were not]
- To determine travel times from various areas of the site to the ICS [21 hours at 170 gpm]
- To determine if Quarry B would receive dye under controlled flow conditions, and hence could be presumed to be an Illinois Central underflow discharge point [it is not]
- To determine if pumping wells at Lemon Lane
Landfill would impact PCB levels at ICS [it did-they increased when MW-21 was pumped.]
November 2001 Tracer/Pumping Tests Test Phases
Monitoring Wells at Lemon Lane & Valhalla Cemetary
- Multiple dye injections under natural gradient conditions (October 31 – November 7)
- MW–21 Pump Test (November 7 – November 9)
- MW–16 Pump Test (November 13 - November 19)
- Injection test at Sargent’s Pond (November 20 - November 23)[Last minute testing, had little relevance]
- November 2001 Tracer / Pumping Tests Dye Injections Natural Gradient Conditions
- Eosine at NN700 10/31/01 at 10:15 (phreatic well open in the 795’ – 800’ zone) [Main artery to ICS]
- Phloxine B at SP1 10/31/01 at 11:15 (phreatic well open in the 795’ – 800’ zone)[Did not work well]
-
Fluorescein at LF6-8 10/31/01 at 11:50 (vadose 'epikarst' well, high PCB area)
Natural Gradient Conditions Fluorescein Results
- Difficult to detect Eosine in presence of large concentrations of Fluorescein
- Eosine concentrations much lower than Fluorescein
- Eosine detected in Valhalla wells (OO-370, OO-587, OO-387, NN-300 and NN-625)
- Eosine detected in Lemon Lane MW-15, -16, -18, -19, -20 and 21
- Ground water from NN-700 area flows east and
northeast to MW-21 - MAYBE!
Natural Gradient Conditions Phloxine Results
Phloxine was not detected unambiguously in any well or spring.
November 2001 Tracer / Pumping Tests MW –21 Pump Test
- Could significant levels of PCBs be recovered from a pumping well?
- Would PCBs levels at ICS be reduced as a result of pumping?
- Pump on 11/7/01 10:00 - Rate = 17 gpm
- Pump off on 11/9/01 14:00 - 52 hours
- Secondary dye flush at LF 6-8
Results
- ICS flow rate reduced
- The well received some Fluorescein from LF- 6, but ICS received much more
- PCBs at pumping well in the 5-7 ug/l range.
- Pumping did not lower the PCBs at ICS after 52 hours, in fact PCB levels appear to have increased at the onset of pumping
- MW-21 is not on or hydraulically well connected to a major conduit that carries a large amount of PCBs to the ICS
- Pumping of MW-21 will not capture most of the materials that are flushed from the epikarst near LF-6
November 2001 Tracer / Pumping Tests MW – 16 Pump Test
-
Pump on 11/13/01 12:00 Rate = 17 gpm
- Pump off on 11/19/01 08:30 140 hours
- Secondary dye flush at LF 6-8 11/16/01 15:30
- Secondary dye flush at SP-1 11/14/01 15:30
- Secondary dye flush at NN700 11/15/01
11:30
- Monitoring Well Levels during test
- ICS flow rate reduced
- The well received some Fluorescein from second flush at LF- 6, but ICS received much more
- PCBs at the pumping well decreased from 8 to 2.5-3 ug/l [Viacom was hoping they would have high numbers]
- PCBs at ICS varied during pumping, and drops in PCBs were not consistent or large enough to be considered a direct benefit of pumping
- MW-16 pumping will not significantly lower PCBs
at ICS.
- Pumping of MW-16 will not capture most of the materials that are flushed from the epikarst near LF6, where PCBs are high. [There may be another hot spot along the southside]
Injection test at Sargent’s Pond (November 20 - November 23)
- 200,000 gallons treated water discharged to Sargent’s Pond
- No large rise in water levels observed in any monitoring well
- ICS may have shown a 4 –5 gpm flow increase
- Sargent’s Pond has a low seepage rate
LF6 and PCB recovery in the epikarst below it is the new focus of Viacom's investigations. The pump and dye tests have shown they can not recover PCBs at the central conduit as they had theorized, so they are pursuing recovery from the epikarst.
ICS
Illinois Central Spring Water Treatment Plant
January 2002 Report
During the storm of Jan 31, 2002, PCBs come from ICS at 110 ppb.
- Total gallons treated as of 12/31/01 – 176,781,606
-
Roll off-box sent for disposal on 2/4/02
- Roll-off sent to Safety-Kleen PPM in Ohio, then transferred to approved landfill in Clive, Utah
- Two Storm Events: 12/14/01 and 12/17/01
-
Peak flow on 12/17/01 – 2,777 gpm
-
PCB peak – 28 ppb
-
Volume Stored – 8,181,195 gallons
-
Volume Overflowed (from tanks) – 6,353,035 gallons
-
Total storm volume treated – 11,615,539 gallons
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