July 15, 1996                                    

Michael Baker, President 
Coalition Opposed to PCB Ash
in Monroe County ("COPA") 
P.O. Box 665
Bloomington, Indiana


Dear Mr. Baker:

Thank you for your May 14, 1996 letter, addressed to me.  In your letter, 
you raise concerns about historical site work and current conditions related 
to the Lemon Lane Landfill.  

In the first paragraph of your letter, you write that, "After years of
debate and discussion of if an RI/FS was ever done for the Bloomington
Sites it has been acknowledged by EPA that one was not done."  Although, I
was not involved with the Bloomington PCB sites prior to 1989, my
understanding is that U.S. EPA performed the functional equivalent of a
Remedial Investigation/Feasibility Study ("RI/FS") that supported the
incineration remedy required by the 1985 Bloomington/Westinghouse Consent
Decree.  I am not aware of any change in U.S. EPA's  position that the
functional equivalent of an RI/FS was done, and that U.S. EPA complied
with all applicable laws and regulations in effect, at that time. To the
extent you that you are relying on recent statements made by Bill Sanjour,
it is also my understanding that Mr. Sanjour does not represent U.S. EPA
on issues related to the characterization of early investigative work at
the Bloomington sites, the selection of remedy, or the legality of the
1985 Consent Decree.    

As you know, the work leading to the incinerator remedy identified in the
Consent Decree, and the Consent Decree itself, predated my involvement
with the Bloomington PCB sites. U.S. EPA has provided COPA with a
voluminous amount of data and documentation from U.S. EPA's files, related
to the Bloomington sites and to the events preceding the approval of the
Consent Decree. In addition, I have discussed the issues raised in your
letter during numerous meetings with you and other citizens in the
Bloomington community, to the extent that I have knowledge about those
issues.  I believe that you have been provided with everything available,
at this time, to shed light on these historical issues that apparently
continue to linger. It seems unlikely that I will be able to answer some
of the lingering concerns, related to an RI/FS and the Consent Decree, to
your satisfaction.  Of particular importance to me, is that the fact that
issues related to the 1985 Consent Decree and the incinerator remedy have
been exhaustively addressed in litigation and ultimately ruled upon by the
courts, which have upheld the legality of the Consent Decree.  

As U.S. EPA's project manager for the Bloomington PCB sites, I must work
within the legal framework that exists concerning the sites for which I am
responsible. The legal framework, in this case, includes the Consent
Decree, determinations by the courts, and the statutory and regulatory
framework for conducting Superfund cleanups.         
 
The exploration of alternative remedies for the Bloomington area sites
(began by the Consent Decree parties in early 1994), has been undertaken
within the framework of the Consent Decree.   

From a procedural standpoint, the process of exploring alternative
remedies may lead to U.S. EPA's current process of amending a  Record of
Decision "ROD".  The investigations being conducted and planned by the
Consent Decree parties will be used to assess site conditions and evaluate
alternatives to the extent necessary to select a remedy. The work includes
utilizing existing data and information, collecting additional data,
assessing human health and ecological risk, and analyzing alternatives.
The work being undertaken by the parties will address the nature and 
complexity of the problems associated with the Bloomington area PCB sites
and will consider the appropriate response alternatives. Also, throughout
the efforts to gather additional data, evaluat
e risks, and analyze alternatives, the Bloomington community will be
provided with forums and opportunities to learn about the activities
underway, to question the activities, and to provide comments and
suggestions.

In developing the scope of additional data needs for the Lemon Lane
Landfill site, I have used U.S. EPA guidance documents.  Chiefly, I have
used the guidance entitled Conducting Remedial Investigations/Feasibility
Studies for CERCLA Municipal Landfill Sites, dated February 1991.  I 
expect that the parties will use this approach for identifying additional
data needs for Neal's Landfill and Bennett's Dump.  For Neal's Dump, a
much smaller site, a more extensive clean-up may be appropriate. 
Accordingly, for Neal's Dump, the investigative studies may be tailored to
accomplish a more extensive clean-up. At Neal's Dump, which is
approximately one-half acre in size, it may be more practical to remove
the PCB contaminated material than to attempt to identify and
remove hot-spots. Typically, U.S. EPA's guidance is written in such a way
to give flexibility to its project managers in applying the guidance to a
specific site.  If you compare the U.S. EPA's guidance for conducting
remedial investigations for municipal landfills, I believe that you can
see that the work, underway and planned by the parties, is consistent with
the guidance that U.S. EPA project managers across the country would use
for investigating landfill sites.  Actually, some of the work already u
ndertaken by the parties (e.g. storm sampling at the Illinois Central
Spring) is more comprehensive than the investigative activities identified
in the previously mentioned guidance document.

In your letter, you express the concern that contaminants in the spring
water at the Illinois Central Spring should be immediately controlled.  I
agree that the release of PCB contaminated spring water from the Illinois
Central Spring needs to be addressed as soon as possible.  I have set a
meeting of the project managers, for this month, to discuss what steps
need to be taken to solve that problem.  I cannot, at this time, specify a
date by which a control system will be implemented.  As you are aware, the
management of storm water will be a significant factor in arriving at an
acceptable solution.  Although I cannot specify a date for control, I will
endeavor to specify the studies or activities that need to be undertaken 
to determine an appropriate solution and by when those studies and
activities will occur. 

In your letter, you state that "It took years of citizens complaining
about discharges from Illinois Central for a fence to be erected around
the site."  This statement does not accurately characterize  the events
leading to the erection of fences in the area of the Illinois Central
Spring.  U.S. EPA moved to have security fences installed around the
Illinois Central Spring and Swallowhole areas in response to test results
that showed elevated levels of PCBs in sediment in and near the stream bed
between the Illinois Central Spring and the Swallowhole.  As you know, the
elevated PCB levels had not been detected during earlier sampling efforts.
When the elevated levels were found, efforts to site and install the
fences were started immediately.  Although the installation of over 2,500
feet of fencing took longer than my estimate of two to three weeks, a
number of unforseen problems (e.g. legal and physical access problems,
unfavorable weather conditions, and very rugged terrain) were encountered.
You might refer to my August 8, 1995 letter to you in which I have
previously provided an account of this matter.  Of course, the fence does
not stop PCB contaminated water from flowing to the Swallowhole and
eventually resurfacing at the Quarry Springs. The fences are intended to
keep individuals (particularly children) from coming into direct contact
with high levels of contaminated sediments and stream banks. The PCB
contaminated water will have to be addressed separately, as I described in
the previous paragraph.  Also, based on sampling conducted in the Quarry
Springs area, the PCB levels found there have been shown to be
substantially lower than the PCB levels found in the Illinois Central
Spring and Swallowhole areas.  

Also in your letter, you state that "when any of these questions have been
raised you have indicated that constraints of the consent decree or
present EPA practices at municipal landfills as a defense".  I do not know
specifically what you refer to in your statement.  I have, during previous
conversations with you, tried to explain the relationship between U.S.
EPA's activities in the context of the requirements and agreements
described in the Consent Decree, the statutory and regulatory framework,
and U.S. EPA's current policy guidance.  I hope that this letter has shed
some light on the issues raised in your letter.  

Lastly, you ask me to list superfund sites in the United States that are
also municipal landfills, located in sink holes on karst, and contaminated
with the concentrations of PCBs known to exist in Bloomington.  I know of
no sites, besides two of the Bloomington sites, that completely fit the
qualifications you identify.  During earlier research concerning the type
of remedies implemented at other landfill sites, I became aware of a
superfund site in the southern United States that is located on karst.
The remedy for that particular site was capping.  However, the site was
not located over a sinkhole.  My recollection is that there are very few
(if any) superfund sites that are both located in karst terrain and over
sinkholes.   

I have included, with this letter, the executive summary of the guidance
document that I have referred to previously.  If you would like a copy of
the entire document, I will assist you in obtaining one.  If, upon
reviewing this document and comparing the current and planned work for the
Bloomington sites, you have additional concerns, I will be very happy to
discuss those with you.  If I can be of further assistance, please do not
hesitate to contact me.

Sincerely,


Dan Hopkins,
Remedial Project Manager