April 4, 2002

Ms. Huxhold-Fliss:

Thank you for your response (dated March 18, 2002) to my letter of January 12, 2002 addressing questions resulting from my visit to the Illinois Central Water Treatment facility. It is clear that IDEM and EPA experts do accept the concept of PCB vaporization. However, I am disheartened that IDEM has decided to ignore the significance of it. Somehow, the only issue of relevant importance appears to be the adequacy in meeting OSHA PEL for industrial workers, but little concern for what it indicates of the system's operation and the impact on the community and the release of additional PCB contamination to the global environment. You state that "The purpose of the plant is to reduce the risk of human exposure through reduction in the PCB content of the water emerging from ICS." However, this misses the all-important goal of reducing human and environmental exposure in how the plant is operated. Workers are impacted and the contaminants are released to the environment in another form.

IDEM is involved in an environmental remediation program and is failing to do the job correctly. Spending millions of dollars to supposedly clean the water (What is the basis of the effluent limit?), yet actually transferring contamination to the air and releasing untreated water misrepresents the facts. Disregarding the well-known, fundamental physical characteristics of the contaminants in the processing is willfully ignoring the purpose of the water treatment as a time-critical action as designated by EPA. Dumping water from the storage tanks to Clear Creek without actual processing in the facility and calling it "passive treatment" is not treatment. And how could relatively minor rainfall events recurringly exceed the 25-year storm design leading to bypassing? It's this sort of "spin" that the community should not hear from the government. The only response that will prove creditable is that the system operates effectively to fully extract the contaminants without releasing contaminants to further harm the community.

Some specific comments.

1) Henry's Law conceptual errors. I have not gone through your expert's analysis of the Henry's Law effect in detail, but some observations are appropriate. I see that since they used an Aroclor as the basis, the vapor pressure cited is for the commercial mixture itself. The Henry's Law relationship involves the partial pressure of a compound in the air phase above the solution compared to the concentration of the compound dissolved in the water. The calculation your experts use is actually derived from the mix's vapor pressure(1) and not the partial pressure. As can be seen in the data that I sent to you(2), the factor is different for each congenor(3). Because we are not dealing with an Aroclor, the calculations are off the mark.

What dissolves in the water from an Aroclor mixture is different from the mixture composition. And then, what volatilizes shows a different congenor mix than is present in the water. What is sorbed to the sediment also differs from the Aroclor mixture. Also, the conclusions about vapor pressure and solubility changes with temperature, and therefore the Henry's law relationship are incorrect. First, the solubility of organic substances such as PCBs frequently increases with decreases in temperature and can vary depending on the substance and the temperature. Benzene is a notable example. Solubility decreases with increasing temperature below about 15o C and then increases with temperature above about 20 o. Further, the solubility of dissolved, volatile substances appears to decline with higher temperatures due to the increasing tendency to volatize. Additionally, the concentration of salt present also reduces the solubility of organic compounds. In any case, concentrations for large organic molecules such as PCBs tend to increase slightly with increasing temperature, but not usually more than a factor of 2. Considering that one is dealing with substances that have solubilities less than 0.00001 moles/L, the solubility differences may be difficult to measure and are significantly different from the single congenor relationship because of the presence of organic and sediment phases. As can be seen from work done by Brunner and others (3) the best way to determine, or at least as a starting point for the Henry's Law relationship is to measure congenor concentrations in both phases. Finally, although we may discuss details, I am satisfied that the volatilization potential is now understood and accepted by your experts. Unfortunately, it was not communicated early enough to your system designers to incorporate in their plans, which address water and sediment management alone.

And yes, the laboratory calculations of equilibrium are different from field conditions due to such variables as airflow, and the presence of sediment. Releases are actually greater in your facility's conditions than in the laboratory. They don't get to the maximum concentration, but they release a greater quantity because the process is unconfined. The sediment acts as a reservoir of PCBs to fuel the cycle of partitioning, which is further enhanced by air circulation. Expose the system long enough such as in the storage tanks, or agitate it in a sump, and much of what can vaporize, will vaporize. Further, the congenor pattern will progressively vary in all phases. (Again, a very good reason why the congenor analytical method is far more accurate than the Aroclor method.) The system needs to be enclosed to prevent releases from any point (including the spring collection and storage tanks) throughout the treatment process.

2) The measured levels are below PEL - I understand that you feel that the facility may not be immediately affecting workers in the plant and it is meeting effluent "requirements", but I wonder if the facility has revealed to its employees the medical consequences of working there. You do have responsibility to require that your contractor does comply with SARA right-to-know requirements. Please make available the documentation that the facility meets those requirements prior to exposing employees. These should include both informed consent and medical monitoring of workers for the accumulation of PCBs. Any women entering the facility should be specifically informed of the health risks from PCBs. This includes the risk to a developing fetus due to the mother's level of PCBs, which involve the potential for neurological effects on their children by exposure in utero, and transfer from breast milk to affect the growing infant. In addition, I request that your facility be required to meet Clean Air and Clean Water Acts reporting requirements as an industrial facility releasing a hazardous substance.

3) The sediment is also an air-contamination source. It is also important to remind you that in spite of your confidence that you are doing a good job, even your handling of the removed sediment is seriously deficient. How is it that your contractors have not taken precautions to control exposure of the wet sediment? Close to 75% of the PCB content of wet sediment can be vaporized within as little as seven days of exposure (4). Although the EPA tried to control vapor-phase releases of PCBs from the Lemon Lane site during removal by wetting the surface, a check of the literature would have revealed that water actually amplifies the partitioning of PCBs to the vapor phase. That is another consequence of ignoring the Henry's Law relationship. Again, a mass balance approach would allow you to assess the level of release. Finally, is the facility meeting RCRA management requirements to store hazardous waste no more than 90 days?

4) PCB emissions are a significant problem - It is apparent that IDEM and EPA do not think so. Your letter cited the 1994 Panshin and Hites paper(5), but has failed to absorb its significance. What you use of this paper is the claim that the air concentration and thus fallout on Bloomington haven't changed much over the years between the early sampling, 1986-87 to a second round in 1993. Panshin and Hites cite the apparent ineffectiveness of the sequestering of Winston-Thomas and Anderson Road materials in the storage facility to reduce airborne PCB levels. Important also to note is the ineffectiveness of the 1987 Lemon Lane cover to prevent air emissions despite a water-impenetrable, but vented plastic cover. It is also obvious that the other local sources, and the most important exit route, the streams running unabated from the sites were continuing to supply the atmosphere with PCBs. It is appropriate to calculate how much contamination Bloomington was receiving based on that data. Because the releases continue, it will give us a strong indicator of how much the community continues to receive.

How much was Bloomington receiving from these sources? Using the Panshin and Hites average flux to Bloomington of 67 ug/m2 and an estimated area for the most densely populated area of the community as a square 12 km. on a side yields a fall of PCBs of over 21 lbs. per year.

Considering that Panshin and Hites on warm days measured concentrations at the Courthouse of 20 ng/m3, the center of town was receiving PCBs at levels closer to 220 lbs. per year.

Using standard EPA risk assessment figures for inhalation absorption published for Bloomington(6), calculation using the average concentration yields a four-fold higher lifetime exposure for residents than what EPA initially predicted (0.231 mg):

Lifetime Inhalation Exposure (mg) = (Ca) x (IR) x (AB) x (F) x (Dur)
where,
     Ca = 70 yr. avg. estimated air conc. (1.95 X 10-6 mg/ m3 PCBs)
      ZR=inhalation rate (20 m3/day)
      AS=fraction absorbed (1.0)
     F = frequency of exposure (365 days/yr.)
     Dur=duration of exposure (70 yr.)

Exposure = 0.996 mg

Lifetime Risk = Lifetime Exposure x Potency Factor/ Body Weight x Life Expectancy
               =0.996 mg x 0.43 (mg/Kg day) -1/ 70 Kg X 25,550 days

This yields a lifetime risk of 2.4 additional cancers or 4.3 times higher cancer incidence from inhalation than the EPA initial estimates of 0.56 per million people⁽⁶⁾. And, these exposures levels don't include the additional exposure (particularly for children or gardeners) of the dermal and soil ingestion pathways. This is also without considering the other non-cancer health impacts induced by PCBs. It is also important to consider that the average community PCB levels are five times what are considered the global background cited by Panshin and Hites, and the downtown area was receiving 25 times that background. Bloomington is getting far more than its global burden because of these sites and what is being done with them. It is also falling most heavily on the densely populated area in the center of the community. Many college students and community leaders live in that area.

Does it continue? Considering that no significant changes in spring emissions has occurred. Yes, it is likely, because the new cap at Lemon lane is more permeable than the original plastic cover, and the sites are still leaking unabated to many springs. There is even a suggestion that the levels in Illinois Central Spring and Stout's Creek are actually higher after the remediation. Although, it is somewhat reasonable to see a temporary increase due to the disturbance of the waste and exposure of new sources, it is of concern that the remediation may have worsened the situation for a long time. This is very much due to the fact that no actual removal of PCBs from the karst occurred, and only limited removal from the surface debris. Considering these circumstances, we can suspect that the rain of PCBs on Bloomington has continued after the 1993 data and continues today.

5) The problem extends beyond Bloomington - We are sharing our damage with the global community. As I indicated above, the site Panshin and Hites used to compare with Bloomington indicated that even a "pristine" environment such as Bermuda out in the Atlantic gets a bit of Bloomington's contribution to world-wide pollution. Closer to home, you might take a look at the Clean Water Act 303(d) list for Indiana. We now have 485 streams (up from 208 in the last list) with levels of contamination that makes them dangerous for human contact. Of those, 50 have fish consumption advisories (FCA) from PCB contamination. Although this is only about 10% of the streams (most of the rest are contaminated with sewage), the FCA streams are some of the largest in the state that are capable of supporting fish that someone might eat. Many smaller streams have non-game fish and only the ecosystem has to be worried about the PCBs in those streams. By continuing to operate the plant as your contractors are doing, it releases contamination that the facility should be capturing. By distorting the operational reports and failing to properly assess performance you are complicit in the ongoing pollution.

6) The Sampling and Analysis Plan - I appreciate your inclusion of the draft SAP section of the operations manual. I do have a number of comments and questions:

a) Why are there two types (operational and reportable) of sampling? All data, including what is used for monitoring performance and what impacts on changing the operation has on performance should be included in the reporting to the government and community

b) Why are two 700-ml aliquots being combined into a 2,000-ml sample? The exposure to loss of PCBs through splashing samples into the container, two sampling events, the uncovered container for up to three days, and 600 ml of air space will all significantly aggravate losses.

c) Which samples (there are 16 700 ml. Samples in a carousel of 8 2-Liter containers) will be analyzed for a storm event? The plan says the first, the middle, and the final of 16 will be analyzed. How can you separate the 700-ml aliquots once they are mixed?

d) Will dissolved oxygen, pH, and specific conductance be done on both influent and effluent? For example, if all are done only on the influent, it is difficult to understand how the dissolved oxygen results could be used to assess the potential impact on stream life, if not done on the effluent. Will temperature be taken with both DO and Specific Conductance which are quite variable with temperature.

e) Sludge sampling may be for waste disposal, but until the system performance is well understood, sludge and granular activated carbon PCB levels are critical to knowing the system and optimizing performance.

f) Sludge analysis includes TCLP which is a RCRA method, yet for the most part non-RCRA analysis methods are cited, specifically Standard Methods (which edition and what methods) and 40 CFR 136.3 (Appendix A). The citations appear to address provisions of the Clean Water Act and in particular to meet NPDES requirements. Does the facility have a NPDES permit for its discharge? TCLP is not a CWA requirement, but a RCRA requirement under SW-846. The cited Method 608 from the 40 CFR is somewhat older than SW-846 methods and usually those do not have the data quality requirements of the RCRA methods. Also, the cited method for PCB in the reference is for Aroclor mixtures. It is inappropriate for weathered, environmental samples, which should be done using the congenor method of SW-846, Method 8082 if accurate results are desired.

g) Because PCB levels and sediment levels are strongly correlated, it is important to correlate analyses of these two components. It is also important to ensure that the total samples are analyzed and not distorted by separating the PCB-laden sediments from the water before analysis as is now being done.

h) Finally, please double-check the use of effect and affect. Sometimes they are confusing.

1) Agency for Toxic Substances and Disease Registry (ATSDR), 2000) Toxicological Profile for Polychlorinated Biphenyls (PCBs) November

2) RP Schwarzenbach and others (1993) Environmental Organic Chemistry, John Wiley and Sons, NY,NY

3) S Brunner and others (1990) Henry's Law Constants for Polychlorinated Biphenyls: Experimental Determination and Structure-Property Relationships Environ. Sci. Technol., 24, 1751 - 1754

4) J Chiarenzelli and others (1996), Volatization of Polychlorinated Biphenyls from Sediment During Drying at Ambient Conditions, Chemosphere, 33, 3, 899 - 911

5) SY Panshin and RA Hites (1994) Atmospheric Concentrations of Polychlorinated Biphenyls at Bloomington, Indiana, Environ. Sci. Technol., 28, 2008-2013

6) R Kinerson (1987) Exposure and Risk Estimates for PCBs, Dioxins, and Furans for the Anderson Road and Lemon Lane Landfill Sites in Bloomington, USEPA memo to Margaret Pearce, (1/16/1987)

Sincerely,
Joseph G. Hailer

Environmental Geochemistry & Quality Assurance
650 Dittemore Rd.
Bloomington, IN 47404