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CIC Summary, July 6, 2004

The next meeting of the Citizens' Information Committee for the PCB Cleanup will be held at 6:30 p.m. on Tuesday, September, 2004 at the MCPL.

Following is a summary of the Citizen's Information Committee meeting of July 6, 2004, with links to the relevant PDF files.

A full version of the EPA's Powerpoint presentation is available at: http://www.copa.org/2004/cic/july/cic-july-04.pdf

Neal's Landfill

Viacom has submitted comments on the EPA's Human Health Risk Assessment for Neal's Landfill. The main points of Viacom's comments are:
  1. Productivity of the 1-mile reach is too limited to support a recreational or subsistence fishery
  2. Fish consumption rates selected are not appropriate for the type of fishery being evaluated
  3. EPA's conclusion about trends in fish tissue concentrations is prematur
  4. e
  5. The toxicity assessment is biased in that it fails to present human exposure information which suggests that humans are less susceptible than laboratory animals to cancer and noncancer effects of PCBs
  6. Use of the TEQ approach to estimate risks is not necessary or scientifically sound
  7. Reference dose for non-cancer effects of PCBs is overly restrictive, and is not supported by human data

On June 18, 2004, EPA, with help from the FWS and IDEM, completed fish sampling at the State Route 43/48 bridge near Whitehall. This data will be used to supplement the data already collected for the human health risk assessment. Fillet samples in the three feeding guilds were prepared for both Aroclor and congener analysis.
http://www.copa.org/2004/lemonlane/cc-sediment-plan.pdf
http://copa.org/2004/cic/july/richland-fish2.pdf

The EPA's Office of Research and Development will be assisting in the response to Viacom's comments, as they have raised questions about research methodologies and data interpretation.

In related news, Viacom is preparing sediment sampling plan for Conard's Branch and Richland Creek, with sampling scheduled for late July or August. Viacom still reviewing EPA's Ecological Risk Assessment, and more critical comments are expected.

Bennett's Dump

Viacom completed fish sampling in Stout's Creek May 25-May 28, 2004 at three locations: Hunter Road (1 mile from site), Acuff Road (3 miles from site), and Maple Grove (5 miles from site). EPA split samples with Viacom, and the data is being reviewed.
http://copa.org/2004/cic/july/stouts-sampling.pdf

The Bennett's Dump Groundwater Investigation Final Report was received on May 20, 2004, and revealed several interesting perspectives. The springs show small variation in flow, with little response to precipitation (unlike Neal's and Lemon Lane). There is evidence of causal relationships between the springs and the water levels in the nearby quarries. In reviewing the Mass Balance calculations, it is evident that there are unaccounted for PCB sources to Stout's Creek (other than the known springs). Middle Spring flow may be related to a prior gravel-filled channel, more like a French drain than a groundwater/karst spring

.

Improved instrumentation has been installed at Mound Spring. A dye tracer test has been done, and a quarry pit pump down test is planned, as well as a piezometer evaluation of Middle Spring flow source.
http://copa.org/2004/cic/july/bennetts-water.pdf

Illinois Central Spring

The Consent Decree parties are co-funding the operation of the ICS Water treatment facility, and they have been evaluating contractors. A contract should be awarded this summer. As of July 5, 2004, 506,737,900 gallons of water have been treated, while 45,151,65 gallons were overflowed from the tanks, and 36,817,356 gallons were bypassed since startup of the plant. These numbers include the 13 months that the tanks were not fully operational. Timely reports are expected to be available soon after a new contractor is selected.

Lemon Lane Landfill

The EPA has completed a draft ecological risk assessment for Lemon Lane, and has submitted the document to Viacom for review.

In early April EPA completed sampling for the swallow hole and Quarry Springs area, with approximately 150 samples taken. The swallow hole is quite hot, and there is an obvious need for remediation.
http://copa.org/2004/cic/july/quarry-sediment.pdf
http://copa.org/2004/cic/july/swallow-quarry-tests.pdf

EPA has scheduled for an additional sediment survey of Clear Creek starting from the ICS, while fish sampling in Clear Creek is scheduled for late summer/early fall.

The Clear Creek Sediment Sampling will use the EPA's "Data Quality Objectives Decision Error Feasibility Trials" software to calculate the number of samples needed for data quality. The study will be used to better understand the exposure pathways between sediment and fish in Clear Creek. The first phase of sampling covered the surface, cores and banks, using GPS to locate sampling locations. 50 locations downstream of Old Highway 37 in a 3-mile reach and 10 locations upstream for the 3-mile reach were chosen, and EPA did split sampling with Viacom. It is hoped that this and the subsequent upstream study will help quantify why fish in the lower reaches of Clear Creek show an increase in PCB levels, rather than the decrease that would be expected for fish farther from the source of the contamination.
http://copa.org/2004/cic/july/cc-sediment2.pdf
http://copa.org/2004/cic/july/ll-tests.pdf

At Lemon Lane Landfill Viacom is still pursuing its Karst Investigation Plan, and gathered additional data by conducting several flush tests at the railroad tracks just south of the landfill. The railroad cut into the limestone when they laid tracks, and the cut opened channels into the karst below. By backplugging several wells at the landfill during the pumptest, Viacom was able to gather data about where and when PCBs and water seem to move during storms. There are connections between the tracks cut, the eastside of the landfill, and the wells in Valhalla Cemetery on the other side of the tracks, but the exact nature of the relationships is still undetermined.

Viacom still holds the position that the ICS plant is too big, and sited at the wrong place, and that they are therefore unwilling to pay for its construction or maintenance. They are hoping to find a place to pump at the Landfill that will reduce the PCB output at ICS.

EPA maintains that the plant is well sited at the outflow of the spring, and that even if Viacom is successful in reducing flow or PCB concentrations at the spring, water treatment will be needed. The current interim configuration captures about 80% of the PCBs, and if Viacom can effect no changes in the discharge at ICS, will require additional storage.

http://copa.org/2004/cic/july/poten-map-ll.pdf
http://copa.org/2004/cic/july/rr-flushtest.pdf
http://copa.org/2004/cic/july/ll-may20.pdf
http://copa.org/2004/cic/july/ll-junetest.pdf




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