Joe Hailer Comments on Bennett's Dump

General:

One of the recurring statements/situations presented in the "history" of these Superfund sites by the EPA is that under the Consent Decree a perfectly adequate solution involving complete removal of contaminants and incineration was planned, but rejected by the community. And by implication the resulting delays and difficulties in arriving at alternative solutions is the consequence of the community rejection of incineration. Complete removal was always acceptable, but coupled with incineration of the material along with the community's municipal waste and then, disposal of 600,000+ tons of contaminated incinerator residues in a local hazardous waste landfill was rejected for very good reasons:

1. Incineration a mix of hazardous and municipal waste was an untried technology
2. The mix is inherently a "dirty" burn and could release products of incomplete combustion, volatized PCBs, dioxins, furans, and mercury and yield uncontrollable contamination to the atmosphere and to local drinking water supplies
3. It would have required the community to fuel the incinerator through abandoning its recycling program or buying petroleum fuel to replace it,
4. And was unlikely to work as shown by the state legislation which essentially required that it actually meet the "6-9s" (99.9999%) destruction goal. The federal 6-9s rule is actually destruction/removal effectiveness. By transferring the contamination to other media (air, water, or to another form) that goal is "met". What the state required was not a diversion, or sleight of hand, but actual destruction to non-hazardous forms. And even that was weak, in that it allowed creation of incomplete combustion by-products and release of mercury.

The destruction criterion set by the State was the "kiss-of-death" for the incinerator. It couldn't work when "push-came-to-shove" So, please stop blaming us for the rejection of the poor technology proposed in the Consent Decree. We recurringly smell a collusion of our government agencies and the polluter Westinghouse/Viacom/CBS to absolve them of complete cleanup. The inadequate water treatment at Illinois Central Spring and Neal's Landfill are examples of a poor remedies allowed by the Consent Decree based on inadequate site investigation, ineffective cleanups, and possibly worst of all, too much of it done at taxpayer expense.

Specific Comments to Proposal to Bennett's Dump

1. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? Prior cleanup efforts only minimally removed the source of contamination. Field reports cite discoveries of pools of PCB oils with no attempt at removal. In addition to new springs that have developed subsequent to that removal, PCB contamination release to Stout's Cr. continues. The proposed alternatives accept the contamination and provide a "band-aid" fix. The EPA should proceed with full removal of all waste as well as installation of extraction wells directly in the dumps and treatment of water and residual PCB oils.
2. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? Where is the report on the mass balance exercise for PCBs in Stout's? What were the measured parameters, locations, and exact conclusions, particularly where are the other sources? How does the proposed alternative capture this contamination?
3. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? Is Rusty Spring exiting the filled debris where the old course of Stout's flowed? Is it intermittent? How is it flowing at right angles to the other springs in the buried trace of Stout's, yet does not pick up any contamination?
4. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? Assessment of PCB releases from Bennett's account for only a portion of the observed contamination in Stout's Cr. The proposed alternatives do not address the stream contamination identified as coming from elsewhere. Are there other releases around Bennett's, or is this evidence of ongoing release from Lemon Lane which feeds Slaughterhouse Spring above Bennett's? Wasn't it already determined that the release from Lemon Lane went through Illinois Central Spring? Are we seeing a recurring picture here that any movement of waste on the sites changes the flow regime? Neal's and Bennett's developed new springs, and now there is evidence that the pre-"cleanup" assessment of contaminant release is no longer the full picture. Why not capture and treat all contaminated water?
5. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? The use of filet v. whole fish in the risk assessment is unclear. By "taking home a catch", the choice of whole fish or filet consumption is based on total mass consumed in the meal rather than a number of whole fish or filets. From my recollection as a creek fisherman, the smaller fish tend to be consumed as whole fish. Their bones are relatively soft and digestible. What might seem more appropriate is to measure the dioxin-like PCBs in the whole fish and filet, and then base the risk calculation on whichever is greater adjusted for a standard portion size, say 8 oz. Please clarify.
6. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? How are the nine criteria used in the selection of "best" alternative weighted? Are there primary and secondary (or even less important ones)? Can that analysis be presented to help in understanding the selection process? How can it be that other agencies did not comment on the proposed plans?
7. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? Discussion of alternatives cites a reluctance to remove the remaining contamination as "difficult" and therefore less preferred. Considering that the quarrying operation moved blocks of stone at depths during a time when the machinery was quite a bit less advanced than now,… and kept the quarry dry, it is "difficult" to imagine that it is actually too difficult to remove the waste. How difficult is it actually? Digging a 800 ft long trench in solid rock at greater than 30 ft depth to intercept water would also seem to be "difficult". (Hopefully, I have not misunderstood that the 8 ft depth of the trench is measured from the surface of the quarry area. The springs are coming out at some 30 ft below the upper surface and to capture them requires a trench 8 ft below them, or at about 38 ft deep.)
8. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? It is difficult to understand how leaving contamination in an unlined deposit, which is clearly leaking, is to be preferred to excavation and removal to a well-engineered containment facility is better for long-term protection. Although there is no actual destruction proposed anywhere in the alternatives, and any contaminants removed will go to a RCRA landfill, or TSCA combustion facility. There is no reduction in mobility or toxicity inherent in the alternatives. How would the contaminated carbon be treated? There is also the problem of removal of fine soil particles and there disposal. (Without removal, the carbon becomes coated and its removal efficiency plummets.) Please explain.
9. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? The removal alternative (4) is coupled with a passive remediation system. This adds to the cost and is difficult to understand. If the source of contamination is removed what need is there for an additional system?
10. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? Little consideration in the alternatives proposed to simply emplacing an array of extraction wells in the zones of contamination and treating the more seriously contaminated water. Wells seem to be a cheaper alternative to an 800 foot-long trench emplaced below the Bennett's quarry zones which are 30 feet into bedrock. The excavation costs plus the backfill with clean gravel would seem to be prodigious. Please explain the costing of the alternatives.
11. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? The preferred alternative calls for a capture trench on the west side of the contamination source between it and Stout's Cr. Considering that the springs are intermittent suggests that release is induced primarily during rain events. Where does groundwater go when there are only small rain events and little spring addition to Stout's? Also considering that Icebox Quarry which is upgradient from the Bennett's sites shows contamination and that the groundwater flow is not towards the trench and Stout's Cr, but, instead follows more the regional gradient, which is more southerly than westerly. Also, consider other sources of contamination that appear to access Stout's Cr upstream. The system may be in the wrong location. Please clarify.
12. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? The State requirement for a maximum of 0.79 ng/L release to streams is stated without reference to state regulations. Please identify the source and explain why the State granted such a discrepancy (300 ng/L) between what is required and what is proposed? Considering the cited impacts on mink and kingfisher, how can such an exception be used?
13. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? Claiming that there is no analytical method to achieve the required detection level and therefore allowing a 300 ng/L (~380X greater) release level is wrong. First, what method was used to determine the levels in Icebox Quarry as 100 ng/L, or used at ICS Treatment to get to 200 ng/L? Actually, modifications of standard analytical techniques (available under CLP as Special Analytical Service) can achieve detections much closer to the required target to protect the ecosystem. Even the standard method for PCBs (SW-846 Method 8082) can routinely achieve detections of PCB congeners of 5 - 25 ng/L With slight modifications, even lower detections are achievable. Because EPA is dealing with weathered PCBs, Method 8082 recommends congener analysis rather than Aroclors as more accurate. Congener analysis also measures the dioxin-like PCBs that are the really dangerous substances driving the remediation.
14. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology? The proposal of carbon-adsorption for water cleanup is reasonable, but is also flexible. By increasing surface exposure and water residence time significant improvements in removal efficiency can be achieved. Are there inherent limits on the partitioning of PCBs from water by carbon such that there is no way to achieve the state-recommended limit of 0.79 ng/L?
15. The presence of other contaminants such as diesel fuel can interfere with the capacity of carbon-adsorption of PCBs. Has this been taken into consideration in the selection of remediation technology?
16. The similarity of water in Mound Spring and Wedge Quarry is based on specific conductivity and attributed to road salt. Where did the salt come from? Certainly not from deicing gravel roads on the quarry area. Was this confirmed by analysis of sodium and chloride concentrations? Considering that this is used to support plans for dewatering Wedge as a driver of Mound Spring releases, it may need an analytical confirmation. Also, if a source can be identified, what does this tell us about groundwater flow directions? There is a large highway maintenance yard nearby. Could this be the source?
17. More recent data suggests a recontamination of Stout's Cr sediment consequent to the 1999 remediation. It is used as part of the risk assessment and constitutes an ongoing source of PCBs after the new remedies are in place. Yet, no plans for further removal of sediment are included. Please explain.
18. Disposal of contaminated soil and residues captured in the treatment process will be evaluated for consideration as hazardous waste and if so, sent to an appropriate RCRA/TSCA facility. What analytical methods will be used for this evaluation? Somehow there is contamination in the water released to Illinois Central Spring, but none shows up in the treated water or in the removed sediment. Is there an analysis of the carbon to determine disposal needs? What plans are there for analysis of carbon for this new facility?

Joseph G Hailer
February, 2006