FELL IRON AND METAL DECISION AMENDMENT PROPOSAL PUBLIC MEETING Fairview Elementary School Bloomington, IN May 9, 1995 FELL IRON AND METAL DECISION AMENDMENT PROPOSAL: PUBLIC MEETING PARTIES PRESENT: Dave Novak Community Involvement Coordinator U.S. EPA Dan Hopkins Remedial Project Manager U.S. EPA Jeff Cahn - Counsel for EPA Sona Chambers - Information Center Gustavo Morales - Information Center Diana Lynn Stultz - Manager/Court Reporter Depositions, Inc. INDEX OF PUBLIC MEETING Opening Remarks By Dave Novak . . . . . . . . . . . . 4 Project Background By Dan Hopkins. . . . . . . . . . . . 7 Questions by Audience. . . . . . . . . . . 15 Comment Period . . . . . . . . . . . . . . 95 Closing Remarks. . . . . . . . . . . . . . 121 OPENING REMARKS: BY DAVE NOVAK If some more people come in, fine. We'll get started. Just to introduce ourselves, I'm Dave Novak, the community involvement coordinator with EPA out of Chicago. The other person on the agenda this evening--- and that's why we didn't give you an agenda because there's only two of us; it's easy to remember that, and we save a tree during the process---Dan Hopkins, the project manager for the Fell Iron and Metal site. Our purpose this evening is, of course, to talk about a proposal that we received from Westinghouse to change the decision on the removal of the soil that's stockpiled at Fell Iron and Metal. The way the evening will work, I'll give you just a brief overview of how things will go, the ground rules. We'll start out with the presentation. He'll give you the idea of what's going to be happening, and what the proposal was. We'll go into questions, and we'll answer all your questions. We'll make a definite break between the questions, and then we'll go into comments. The reason we do this is because every time we come up on a decision for a record of decision, where we are going to make a determination or a remedy, we seek comment from the public. In this case, we are coming under a new proposal for this. We are going to go back and seek comments again for a thirty (30) day period. The comments---I'll have to see what the dates are---will be accepted through the 27th of May, and for the first time, we are trying a variety of ways of getting those comments via the Internet, via fax or via the mail. They can also be dropped off at the Public Information Center in Fountain Square, and they will get the comments to us. Once we've received those comments, we'll finalize our decision on what will be done at Fell Iron and Metal. Again, when we get into the comments, I'd like to make the distinct separation between questions and comments. Tonight, we will not respond to any comments. We'll just take them as we did for the ABB meeting and the other public meetings that we've had and come out with the responses in a Responsive Summary. That summary will take into account all the comments we get. We'll answer them in that document. That document will go in the information repositories. It will be at the Information Center in Fountain Square and at that time, we are shooting for the end of June. The date escapes me right now what the end of June is. The third week in June roughly to have that determination on what will be done. Again, no determination will be made until we get all the comments and have reviewed them. I have been receiving them already for the past week or week and a half, and we do have some on record back at the office. Basically, what it was---and Dan will go into it in a little bit more detail---we did have the proposal. Westinghouse Electric Company came along and said, "Hey, we would like to entertain the idea of changing that proposal", and that's what we are looking at. Again, that is the primary thing we will address tonight. Now, again, if we want to get into a few more minor details on some of the other sites around the city in a little bit more discussion, I'd appreciate if we hold those until after our comments, and then we will close the Fell portion of the meeting, and then we can get into that. Just so we don't mix too many different operations at one time here. When you do ask a question, and especially when you come up with a comment, I'd ask that you come up to the microphone so that the court reporter, who is going to transcribe the entire thing---and this will also be in the information repository---so that she can get your name, the correct spelling of your name, and can hear you clearly. So, I'd ask at that point, questions and comments to come up to the microphone, if you don't mind. I'd like to introduce a new person on the staff at the Information Center here. He's brand new. He's an exchange student from Guatemala, and he's studying for his Master's, Gustavo Morales. He is a part-timer who will be working at the Information Center, along with Sona Chambers. In speaking with him this afternoon, very interesting gentleman to talk to, very quick. He's conducted some risk analyses for PCBs in the area and everything, and he's somewhat familiar with the sites. I'd like to welcome Gus to the staff and look forward to working with him, as I'm sure he will be looking forward to working with you folks also. So, I'll quit now, and we'll get right into the meat and potatoes of the meeting. Dan's going to explain exactly what happened, how we came about to getting to this point, and where we are going to go from here. Again, distinct questions and answers, we will answer the questions, but no comments this evening on the comments. Dan. PROJECT BACKGROUND: BY DAN HOPKINS Good evening, everybody. Again, my name is Dan Hopkins, and I'm the project manager for all the sites in Bloomington and Owen County that are related to the PCB contamination. Actually, we really do appreciate that you are here tonight. I know that there's a lot of other things you could be doing. You could be enjoying the beautiful weather. You could enjoy an unrushed meal, or you could be watching the Indiana Pacers and the Knicks playoff game, but you are here. We appreciate that. I think that speaks for your interest. Tonight, of course, what I want to talk to you about and give you information about relates to Fell Iron and Metal site, which you probably are all familiar is right across the way; specifically, that pile of soil and material that is contained underneath this synthetic liner system. I'm sure you've all seen that. I know that this has been a matter that's strung out for some period now, so, by way of background, I'd like to give you a little bit of, kind of a refresher, of the history that has led up to this point. In July of 1988, EPA ordered Westinghouse and Fell Iron and Metal to clean up the Fell site and remove the PCB contamination. Westinghouse, with EPA oversight, did that. They excavated contaminated soil and rock, decontaminated rocks, excavated debris and capacitors, and placed all but the capacitors and the rocks that had been decontaminated, into that storage pile. By April of 1989, approximately sixteen thousand (16,000) cubic yards, which translates to roughly about twenty-four thousand (24,000) tons of material, had been stored on site and awaited ultimate disposition or disposal. Currently, it's stored in this synthetic liner system that completely encapsulates. It goes completely underneath and over the pile. In September of 1989, EPA released a document that we called an Engineering Evaluation/Cost Analysis. The purpose of that document was to identify a number of alternatives. Different ways that this material could be dealt with included landfilling, included incineration, a number of chemical processes, biological processes, and also a technique called vitrification, which is, basically, passing a current with a large potential through the material, essentially melting it and turning it into a glass-like substance. The Engineering Evaluation/Cost Analysis looked at technical feasibility and environmental impact. It looked at cost. It looked at a number of factors in evaluating each of those alternatives one against the other. When we released it, we identified four (4) alternatives that we thought passed muster, and that we gave to the community as what we thought would be worthy of comment. We preferred, at that time, landfilling, but we also took comment on incineration, in situ vitrification---and actually, the incineration was both on-site and off-site. At that time, you might recall, the incinerator that was to be constructed to destroy the PCBs in the materials from the other sites in Bloomington---which would be Lemon Lane, Bennett's Dump, Neal's Landfill, Neal's Dump, Winston Thomas Sewage Treatment Plant and the materials from Anderson Road that are stored out at Winston Thomas---that incinerator was to be constructed and treat that material. As part of the Consent Decree, it was allowed that other materials could go into it, and Fell was considered as a candidate for that type of an arrangement. So, we took comments on the Engineering Evaluation/Cost Analysis from the community, and in April of 1993, we issued a decision and an order that required Westinghouse and Fell to incinerate the materials, using the Bloomington incinerator if it were to be constructed, and under rigorous timeframes to determine whether or not it was actually going to be constructed. If it turned out that it wasn't going to be constructed, then they had to incinerate the material off-site in a commercial facility. There were three incinerators that were identified in the Consent Decree for commercial incineration. Since the time that we issued the order in 1993 for incineration, there have been some considerations that have come to our knowledge, and something that I want to share with you and ask you to reflect on, too. You probably remember that beginning in 1991, and I think through 1993, the Indiana State Legislature enacted, well, they passed several bills which were later enacted into law, that initially delayed, and ultimately road blocked the construction of the incinerator. So, one component of our decision remedy had already been really forestalled. In June of 1993, Westinghouse met with EPA, and they recognized that the incinerator remedy had been stalled. This was the incinerator for all the sites. They came to us, and they expressed an interest in looking at alternatives, which, as you know, we are still doing. We announced publicly in February of 1994 that we would be about the business of identifying alternatives to that remedy. So, in light of that development, EPA stayed its decision with regard to the Fell disposal; in other words, we said we are not going to pursue this right now. We are going to wait and see how the selection of alternatives transpires for the other sites. Now, one other thing that's of note is that in February of 1995, EPA approved a proposal by Westinghouse and ABB to dispose of the materials that are stored out at ABB. For those that may not be familiar, there was a similar cleanup action that had been undertaken from about 1989---the cleanup actually started about in 1992 through 1993, and resulted in the storage of a similar pile of material as what you have out here at Fell at ABB, approximately eleven thousand three hundred (11,300) cubic yards, which translates to about twenty thousand (20,000) tons of material. In March of 1995, as Dave mentioned earlier, Westinghouse sent a request to EPA that asked us to reconsider the incineration remedy for the Fell materials. They said, "We would like to landfill that material." Just to give you a sense of how this would work, at ABB, for instance, that work may be completed--- it is being undertaken, and it will probably be completed about late July or maybe early August, dependent, to some extent, on the weather---and the crew that would be at ABB who is doing the removal work for Westinghouse, could be able to come to Fell, and they could handle that similarly. So, there's a logistical consideration there in terms of having the people mobilized to be able to do the work after they've finished with ABB and go to Fell Iron and Metal. As part of the request that Westinghouse made to EPA, they also included some additional information, which I'm going to share with you. One is one I've already mentioned, that the Consent Decree incinerator would probably not be built or may not be built, especially if the parties are successful. If we can identify alternatives to incineration for the other sites, then the incinerator won't be needed. Two out of the three incinerators that were identified by EPA in their Engineering Evaluation/Cost Analysis are no longer accepting PCB material. That's a consideration. Also, there's limited storage capacity at the Aptus incinerator, which was the third incinerator that was identified. That facility can process about five hundred (500) tons of materials per month. So, if you figure that there's about twenty-four thousand (24,000) tons of material at Fell Iron and Metal, it's going to take about forty-eight (48) months to process that material. They can't store a huge amount of material at the incinerator. So, it would require opening up the pile, taking material off month by month for a long period of time. There are other incinerators that are operational now, but even they would have a similar problem to the tune of about sixteen (16) to twenty-four (24) months, to be able to process the material from Fell. There's also the matter of cost effectiveness. Under the Engineering Evaluation, it was estimated that the cost of incineration would be about twenty-nine (29) to forty-five (45) million dollars, and the cost of landfilling is significantly less, less than five (5) million. So, given those considerations, if landfilling is to be something that is approvable and is going to happen, and EPA needs to make its decision---with regard to Fell---needs to make its decision fairly soon, so that if there is a possibility of being able to do this efficiently, take advantage of the fact that the crew is mobilized and be able to come to Fell and to be able to complete that project as well. We need to make our decision fairly soon. We do want to make sure that we get the comments from the community before we do that. That's a very important part of this to us. I don't have a very specific proposal from Westinghouse at this point. We expect to get a work plan that details out very specifically what the activities that are to be undertaken at the site will entail. I don't have that available yet, but we have had some preliminary conversations, and I can tell you a little bit about that, and also, there are some people from Westinghouse and also from the facility itself that would be receiving the material, that may be able to answer some questions that I might not be able to. One, it would entail moving the material by rail, and a rail spur, or an addition onto the tracks that are existing near Fell, into the facility would be constructed. The soils would be loaded onto the rail cars on that spur and then moved out of town. There would be air monitoring. There would be dust control measures, and there would be strict control of storm water to make sure the storm water does not contact the contaminated material, and if it did, then there would be provisions for collecting that water and treating it before it could move off site. This will be done under EPA oversight. We will have a person out on site during the operation. I understand that the hours of operation would be about 7:00 to 7:00. Now, that's really all I have, other than to emphasize again that the comment period for this proposal began April 28, and it's going to run through May 27. We do want to get your comments, so, tonight is the opportunity to do that. First, I would like to make sure that if you have any questions that can assist you in formulating your comments, I'd be very happy to take a crack at them and see if I can answer any. Joe. QUESTIONS BY AUDIENCE JOE LA MANTIA: I'm not sure what the technical information---have you done a risk assessment on that site? DAN HOPKINS: There hasn't been a risk assessment per se done, but what we do with the air monitoring is to evaluate the concentrations that we are seeing and relate that to risk, but not a risk assessment per se. JOE LA MANTIA: Is it like the one back four years ago? DAN HOPKINS: Yes. JOE LA MANTIA: Isn't it your policy to do a risk assessment before you move that contaminated material? DAN HOPKINS: Not really. EPA has a distinction in terms of the sites that we work with. Some sites have to be handled immediately, like an overturned tanker truck or a spill of a dangerous material, and that would be handled very, very quickly, on an emergency type response. There are other similar types of responses that would be handled under what's called a non-time critical matter, which is the way Fell Iron and Metal is being conducted. There's a third grouping of sites which a long period of time can be used in evaluating it. There is a procedure for ranking these in numeric evaluation that's undertaken in order to qualify for remedial action. Now, that third group is the kind of site that would qualify for what you are talking about. Fell Iron and Metal isn't one of them. As a matter of fact, it scored too low to be handled. It wasn't considered a high enough priority, if you will, under that type of a scenario, so, we used a non-time---I know I'm throwing a lot of stuff at you, but that's the way it is, and we typically don't do that for this type of site. JOE LA MANTIA: So, what you are saying is we don't really need to do a risk assessment for this site? DAN HOPKINS: Not per se, no. JOE LA MANTIA: And as citizens and community, can we ask that that be done? DAN HOPKINS: You can always ask. I think that the expectation would be, though, that what we are doing really satisfies the concern. Ultimately, you want to get back to is this protective, and that's what we are really looking at. Is the activity that's being undertaken there protective, and that, I think the air monitoring goes a long way. The control of dust---and the control of the last two sites during their excavation has been very, very good, and I've seen both of them. JOE LA MANTIA: I understand it's very convenient for Westinghouse to do one site and then go to the other. DAN HOPKINS: Yes. JOE LA MANTIA: But one thing that wasn't considered in that convenience is the fact that at that time, the children would be starting school again. We are talking about late August and September. The summer seems to me also inappropriate in moving dirt because the winds. There's more chance of that material getting into the air than, say, in the winter. So, as a citizen, I object to that consideration of the timeframe. I don't object to the fact that, yes, it would be nice to get rid of that stuff, but I object to the timeframe out of convenience to Westinghouse, not considering the fact that we have children, my children, going to this school, and they are going to be exposed to those shovels of contaminated earth. We know that there's heavy metal in that, as well as PCBs. I think I have one more question. That was more of a comment than a question. I'm sorry. DAVE NOVAK: Everybody take some time. Go ahead. We'll get back to you if you want to think about it. JOE LA MANTIA: Those are my concerns. A risk assessment, the timing that was going to be involved. I'm also concerned that this is going to be still taking and putting it in someone else's backyard. I'm not so happy about that either, but I'd like us to hear what Westinghouse has to say about that. I'm sorry, Dave, this sounds like another meeting that we had before where all the information wasn't at the meeting. You gave a little scenario about what you were going to do, and when are we really going to find out what they are planning to do? When is that going to happen? DAN HOPKINS: Do you mean in terms of Fell Iron and Metal? JOE LA MANTIA: Yes. DAN HOPKINS: I think that's what they really intend to do. It is. Let me respond to something, because I think you raised two excellent points. I really do. This is actually something that we thought about as far as the summer months, high wind. That would be included and must be included in a plan to deal with high wind and storm conditions, because we recognize the influence of wind on scattering dust particles. That has to be minimized. So, there will be a limit on the type of weather conditions that this type of material will be able to be loaded, first of all. Secondly, to the point that this is going to be done in August, it's also going to be done in September and November. It's going to take about three months to do this, and it gets really awkward to do it in January and February. I really think that that period of time---were it be June, July and August, that's probably the worst time that you could pick---but that it would be the end of August, September, October, November. From what we did out at ABB, we had a meteorological station set up, and there was a ton of data that was taken. We pretty much were able to correlate that when the temperature is real high, when the wind speed is real low, and when there's a lot of material available, like there would be a big excavation of contaminated material, that was when we were getting the highest readings. We had monitors set up around the area that was being excavated, and we also had a monitor set off next to the nearest community, and we never got that monitor tripped. But even when there wasn't anything going on at the site, we could still get high readings at some of those monitors, whether or not any dust was in the air, or whether or not any movement of material. It looks to me that it's chiefly dependent on temperature, and also how fast the wind is blowing. What this proposal will do is it bumps you pretty close up to winter in the September, October, November timeframe. So, those aren't really bad months. We were finding that when the temperatures were down, I think it was around sixty-five (65) degrees, there was a dramatic reduction in the concentration of PCBs that we were seeing. You are going to be hitting several of the cooler months. JOE LA MANTIA: That's good, but it's just the fact that as a parent, I feel protective. I guess I would rather that if that was going to happen, it did happen in January, because this school is out for a month, and if it took a month to do it, that's the month to do it, even though it might be colder out there to do it, you would have less risk of your kids inhaling any dust particles. I just feel the timeframe is not acceptable. DAN HOPKINS: Thanks. LOU SCHWITZER: My name is Lou Schwitzer, and I represent COPA, and we have several questions and concerns we'd like to bring up if I can. Once again, like the ABB site, no alternative technologies or any of the other technologies that have been approved in the other regions are even being considered to put on a good faith presentation to the community that something else could be done, because this would be an ideal location to do a private project for alternative technologies, vitrification or whatever it might happen to be, so that you could sell that on what you are going to try to do with Lemon Lane or any of the other sites. No, what we see here once again, for an economic convenience to Westinghouse, we are going to vacate the stuff, get it out of town, and leave everybody holding the bag again. As I'm sure you are aware, but I have no knowledge of this, do you have a copy of the State Local Emergency Planning Committee report as required by SARA that it's going to be required to have an emergency preparedness plan in place, because nothing moves until that's in place. That's a federal law under SARA, that we have to have a local district emergency preparedness plan. You don't even worry about building a spur until that's in place. So, I was wondering if you know if that's in place? That's a county requirement or district that's going to be part of IDEM, but it is a federal law under SARA, Title 13. DAN HOPKINS: What did you call that again, Lou? LOU SCHWITZER: It's called the Local Emergency Planning Committee as required by Emergency Planning and Community Right to Know Act, also SARA, Title 3, excuse me. DAVE NOVAK: I don't think that would be required until the actual approval or whatever. Then, everything must be in place at that point. LOU SCHWITZER: But the point I'm getting at, Dave, is the fact that if we don't have it in place, why even talk about it. Let's get all the ducks in order while we're talking about the planning committee, and once again I bring up the issue, I still think it would be a golden opportunity for the parties to show that there are alternative technologies approved by EPA, and I have to admit, that when we have done our research on these technologies, we find out that Westinghouse owns or controls many of these technologies. So, the fact that they don't want to say that they exist or whatever, I find very hard to believe. You guys in other regions have approved some of these alternative technologies that would work fine here on site, and this is just an opportunity to show that. I may have other comments as it goes on. DAN HOPKINS: If I can just to respond to that. One thing that we will have and must be prepared is a Health and Safety Plan that does have emergency provisions in it. I'm going to investigate what you had identified. I know when this type of work is done, typically, for instance, a permit that would otherwise be required is not required for a Superfund site, but we would need to do the substantive requirements of that permit. So, it may not be that we would have to comply specifically with getting a plan approved, but we would have to comply with the substantive requirements of it. That, I will check. As far as the alternative technologies, I'll just tell you, there's one thing that we kept running into at Fell Iron and Metal. It's a five point four (5.4) acre site. It's loaded with trash. It's an odd configuration, and it's accessible to the public. There's a lot of movement around, as you know, around the office. We had a lot of trouble, when we first came up with the incineration remedy, finding a place for it and the attendant, all the sizing equipment that's needed and the various different unit processes that would be available, that must be a part of whatever remedy is selected. That was a big consideration for us at this site, and it still is. It's not an ideal site. There might be something else that could be done there, but it's not an ideal site for that. You are very constrained by the size of it, and what it is. LOU SCHWITZER: Once again, this was declared, like a lot of things in this community, an emergency. We are now fourteen (14) years later. Fell and ABB were declared emergencies, and we are not four (4) and five (5) years after they were declared emergencies. So, to me, this sudden rush to get this stuff out of town seems to be more in keeping with the mayor wanting to move them down here, than perhaps the alternative of studying some alternative technologies at a public meeting or discussing that. I find that our public input time is so short compared to the amount of time that you guys have had to work on this. For the public to be informed, we haven't had that many people log on to our BBS, let alone trying to get the word out to people. Since we are not taking full-page ads out in the newspaper to tell people about meetings, you've got thirty (30) people here tonight, if that. I'll bet you there could be a lot more people that could be aware of what's trying to be accomplished here with you all. DAVE NOVAK: Just as a comment on not getting the information out, we did mail out over twelve hundred (1,200) to our mailing list. We hand delivered over eight hundred (800) individual copies to the immediate neighborhood, and we took up the ad in all the local newspapers. All the requirement is is to put an ad in the paper, and we have tried our darndest this time to get the word out about the meeting this evening. JOE LA MANTIA: Did you try the local TV stations, too? DAVE NOVAK: That was sent out. Press releases were sent out. The ads were sent out. This is probably more, from my own experience on the other sites I have, more announcement notification than we do at other sites. Gosh, Sona spent several days hand delivering these eight hundred (800). How else can we get it out, you know. A lot of time and effort did go into this because of its proximity to the downtown area, to the school and everything else. So, we really tried our darndest this time to get the word out. Yes, sir. JOHN FERNANDEZ: My name is John Fernandez. Back when the '93 decision was made, and the decision summary was generated by EPA, it identified various concerns that you wanted to evaluate proposals by. If I understand, one of the reasons we are here is that we are, in essence, amending the previous decision? DAN HOPKINS: As a possibility, yes. JOHN FERNANDEZ: And the concept is that we need to amend it because circumstances have changed. I think a lot of us would feel more comfortable if we had a similar kind of decision summary prepared by EPA, you know, by our representatives in this process, as opposed to just the Westinghouse proposal, which that's not a slam on their proposal. It's just procedurally, I guess my question is, why doesn't the EPA do that? DAN HOPKINS: Doesn't the EPA? JOHN FERNANDEZ: If the point is to amend the proposal that was originally an EPA decision, why isn't the EPA preparing a similar kind of alternative technology review and assessment, and letting us know that this is a fact, landfilling on site is the current preferred alternative. I think we'd feel more comfortable seeing it come through a different process that involved our government reviewing the various alternatives instead of just relying on the proponent's decision. DAN HOPKINS: A couple of things, I guess, when EPA released its Engineering Evaluation/Cost Analysis back in 1989, we did identify landfilling as the preferred alternative. We did respond to public comments. We also responded to Westinghouse's comments regarding incineration, and at that time, they were in favor of using incineration, I think primarily because the Bloomington incinerator, you know, as much as I know there's a lot of negatives associated with it, there's some positives, too, like you can really get rid of the stuff, and it would be a small amount of material compared to the rest of the Consent Decree site material. So, there was some reasoning behind that. As far as the procedural part of this, we are going to be evaluating their proposal very carefully, and we will do that prior to making a decision. What we are chiefly doing at this point is bringing the proposal up, talking about it, giving people an opportunity to comment on it. If it were the case that alternatives were reviewed, I think this opportunity---and I see it as an opportunity---would pass us by. It would probably take us a substantial period of time and I would estimate between six and eight months in order to recreate an EE/CA. I don't really think that, you know, we see that as necessary to do. What we do see is an opportunity here that this can happen, and happen fairly efficiently. I don't think that the only beneficiaries are Westinghouse. Just considering that the pile will be gone. It's also true that it will be taken to another facility and not treated, and the PCBs will remain in it, but I think in balance, if you look at PCBs they are relatively well bound to the soil. This is a commercial facility that is in the business of doing that type of work, and they have a large facility for the purpose of taking these materials there. So, I'm not pooh-poohing what you say, and I'm not pooh-poohing the thought about alternative technologies. This, I think, we see as an opportunity, both for the community and Westinghouse, and to be able to get the site resolved. You know, we are very sensitive to the stringing out of decisions, the stringing out of the cleanups. We want to put that behind us and really make an appropriate decision, but move on with it. Yes, ma'am. MARTI CROUCH: Marti Crouch. I have some comments I'd like to make later, but right now, I'd just like a little more information about this place in Utah. I'd like to know, you mentioned that the PCBs will be landfilled there, but I was wondering whether there's any plan to detoxify them at any point in the future, or whether they are just going to sit there as toxic waste, and if they sit there as toxic waste, how long is it expected that they remain toxic? I'm particularly interested in that because even though a site can be monitored for stability, over a long enough period of time, stability is not very good. I really don't know what the chemistry is of PCBs, so, I'd like an answer to that. DAN HOPKINS: Actually, we have a gentleman in the audience. Randy, I don't know if you'd like to briefly speak to the issue. I mean, first where it's going and what type of a cell it's going to, and maybe even what type of community this is here, and what, you know, provisions are taken to make sure that the PCBs are stably confined, and if they do leak, what type of monitoring systems are available for detecting that. RANDY MILLER: My name is Randy Miller, and I'm the general manager of the USPCI Grassy Mountain Gray Back facility near Salt Lake City, Utah. DAVE NOVAK: Could we get you to come to the microphone? RANDY MILLER: The Grassy Mountain Gray Back landfill facility in Utah has been in existence for ten to twelve years dealing with the type of material we dispose of there. We've been disposing of PCBs since 1985 at the facility. We are located approximately eighty (80) to ninety (90) miles west of Salt Lake City, Utah, in the old Great Lake desert, the (inaudible) basin. There is no community to speak of. I believe the closest partially occupied residence is thirty-five (35) to forty (40) miles away. We are essentially on six hundred forty (640) acres of ground with current facility boundary. We sit on a total of one thousand nine hundred twenty acres (1,920) that we own, and we sit in the center of that and operate on a six hundred forty (640) acre parcel. We are permitted by the EPA Region 8, the State of Utah and Environmental Quality Department also, permits and regulates our facility. We dispose of PCBs in essentially a slightly different design, but not much of regular hazardous waste and landfill design. Basically, we build a three point one (3.1) foot compacted clay base liner, and with the coefficient of permeability, which is the EPA standard. On top of that, we put the initial synthetic liner, which is high density polyethylene synthetic liner. We put a leachate collection system. We put some material on two feet of compacted clay. We put a second PCB liner system, with leachate collection, and that, basically, forms the base of the landfill site. That capacity has seldom been closed. Again, we put the equivalent of two (2) feet of compacted sediment clay and another HDPE liner system on the top of the landfill. So, as far as a site, one of the reasons we are where we are is that it's a very effective landfill site. One of the greatest historical problems or concern of the landfill has been the production of leachate. We are out in the desert, and essentially, at closure we produce almost no leachate. So, there is no driving mechanism to ever detoxify the PCBs to ever leave an ample track. The question about detoxification technology, I don't know of any commercial technology. We are certainly not evaluating one today, but that doesn't mean we would not evaluate one in the future, but we build these landfill cells as long term permanent disposal repositories. MARTI CROUCH: How long do the PCBs last? RANDY MILLER: I've read some studies of certain biodegradation of PCBs. As a scientist, I doubt that our landfill conditions are susceptible to initiating that biodegradation, so, I would imagine that a PCB is a fairly stable molecule, chemically speaking, and I would imagine it's going to stay put, but that's what our landfill is designed for. MARTI CROUCH: One hundred thousand (100,000) years? Two hundred thousand (200,000) years? What are you talking about? RANDY MILLER: To tell you the truth, I'm not a strong enough chemist to know what the chemical breakdown of PCBs is. I don't know if there's anybody else here that could address that, but perhaps someone here could, but the design of our landfill certainly, we anticipated that landfill being in place with integrity, in my personal opinion for thousands of years. Beyond that, I don't know what technologies will be available in ten years. DAN HOPKINS: It's the case though that that is monitored systematically, and--- RANDY MILLER: Oh, absolutely. (Inaudible) We have to monitor groundwater on our site. We have seventy-five (75) monitored miles, approximately. These numbers change with every addition to the facility. I think we monitor actively approximately fifty-seven (57) to sixty-three (63) of those wells. We monitor, from our PCB landfill, we monitor our leachate, we look for PCBs in our leachate. We do that periodically. That monitoring has to continue long after the site is closed. Our site has an available life span of probably to about the year two thousand fifty (2050) or over. We are there for the long-term. We wouldn't be here doing this if we didn't believe in the technology and our ability to do it. LOU SCHWITZER: Have you tested for dioxins and furans in your collection of leachate? RANDY MILLER: We have in the past, not necessarily from the TSCA landfill, but some of the other landfills we have had to contend with. LOU SCHWITZER: With the new technology, will you go down first with (inaudible) things that are hazardous waste? RANDY MILLER: We had at that time the evidence that (inaudible). I can't remember which method that we ran, but there's basically two methods for analyzing for dioxins. One is the (inaudible) and I am sorry I can't quote you the method numbers. The one that is considered the lesser method is really not a lesser method because of its lack of detection but it tends to be rather involved. Whereas the other one tends to eliminate false positives (inaudible) metal detection. DAN HOPKINS: I think that analysis provides a level of detection about in the parts per trillion range. It's nanograms per liter. JOE LA MANTIA: You're not, you are a separate entity, you're not federally funded or anything? You're a corporation? Is that right? RANDY MILLER: Yes. USPCI is, in some of the literature here, we are formerly a subsidiary of Union Pacific Railroad, around January of this year, January 1 or maybe it was January 3, Union Pacific Railroad sold USPCI Group (inaudible). JOE LA MANTIA: You say that's the EPA or government---do they also check your findings? Do they investigate? RANDY MILLER: All data that we have previously submitted to both the State of Utah or the EPA Region 8, they on occasion, both agencies have come out, have collected samples from our monitoring systems and taken them back to their labs. Everything that we do is monitored by the agencies. I can't think of anything that is not part of the record. DAVE NOVAK: Part of the information that we got, if you didn't get one of these little packets, it's got quite a detailed little piece on USPCI, certainly much more than he said in about five minutes here. You are welcome to take some more of this, and I think in the Information Office, Sona has a little bit more than this. So, there is more literature available. We just didn't bring it all here tonight. Any other questions? MELISSA VALENTIN: Just a quick question. One is just earlier on, you listed four alternatives that were proposed to the public for consideration in 1989. You listed three. You listed landfilling, incineration and vitrification. What was the fourth? DAN HOPKINS: on-site and off-site incineration. MELISSA VALENTIN: Oh, that is two? DAN HOPKINS: Yes, that counted as two. MELISSA VALENTIN: My next question is that you said in 1989, you presented the findings of the EE/CA, EPA's preferred remedy was landfilling--- DAN HOPKINS: Correct. MELISSA VALENTIN: you extended the public comment period, and in 1993, the decision was for incineration--- DAN HOPKINS: Correct. MELISSA VALENTIN: I don't understand the link. How, during the public comment period, you shifted from landfilling to incineration, and now that incineration isn't feasible anymore, you are going back to landfilling. DAN HOPKINS: At that time, there were a couple of considerations. At the end of the public comment period that we got, we had a number of comments, and as I was saying, there were some that wanted this material to be treated, and incineration was, at that time---using the Bloomington incinerator, of course---was the most cost effective provided the destruction for PCBs, and what could be an acceptable alternative. We also got a lot of comments from not only Bloomington residents, but also--- and I think the way that this worked was the Bloomington residents got on the phone and talked to people in Model City, New York and Alabama---and we got a slew of comments that were anti-landfilling. So, considering those altogether, and in the absence of really a death knell---now, I shouldn't say a death knell---but really, the incinerator for the Consent Decree site is not being completely roadblocked pending, you know, unless there was some legal action taken. That looked to be, that looked like to be an acceptable alternative. Initially, we thought landfilling would be acceptable because landfilling PCB contaminated soil, at fairly low levels, we think it's pretty much bound to the soil. We don't think that it's really an unstable matrix, but in response to public comments, and given the situation that existed at that time, incineration was an acceptable alternative and looked to be workable. DALE STATON: My name is Dale Staton. I have about four questions here. They're all quick questions. You mentioned the biological solution to this. How much is that going to be? What was the cost on that? DAN HOPKINS: I think it was screened out relatively early because it really wasn't a satisfactory solution. It wasn't really technically feasible, not for these types of materials, and to the levels that we would like to have it treated. DALE STATON: So, you are saying about the only on-site solution is incineration? DAN HOPKINS: Well, that's what was selected. We also looked at in situ vitrification, and in situ vitrification was a technology that you put a large potential current through this mass of material. It becomes molten. It turns into an obsidian or glass-like material, and it pyrolyses or destroys by heating the organic material in it, and it encapsulates the rest of it in this very solid glass like structure. Not too long after we had---I don't remember exactly when it was---but the company that manufactured that facility in Washington State had an accident where some of this molten material splashed up onto the hood and burned it. I mean, it really put a crimp in that technology for quite a while, and I understand that they are still working some bugs out with that. But in answer to your question, on-site incineration was considered. We had a lot of trouble in terms of siting it because of the spacial constraints of the site, as well as the number of processes that would be involved and the pattern of traffic and so forth. DALE STATON: You said you were going to treat the leachate in the clean up? DAN HOPKINS: I'm sorry, one more time? DALE STATON: You are going to treat the runoff, the water that came from the clean up operation? DAN HOPKINS: Yes. I mean, that presumes that you are going to get a rain that contacts the soil. The idea here, and I know that Westinghouse has spent a lot of time trying to design a way to make sure that rainwater does not contact the material; however, if it does, it's going to be collected and treated. DALE STATON: So, the technology to treat the water is there? DAN HOPKINS: Yes. It's basically a filtration using activated carbon. DALE STATON: And how is the balance of the sites? How is the balance (inaudible) of the clean up? How did you select that? DAN HOPKINS: Do you mean as opposed to the Consent Decree sites? DALE STATON: Right. DAN HOPKINS: Both Fell Iron and Metal and the ABB sites were handled differently for EPA. We issued an Administrative Order to get those sites cleaned up. The Consent Decree Sites involve a Consent Decree where there are five (5) different parties, four governmental agencies and a private company, who have come to an agreement, set that out in a legal document, and is currently overseen by the Federal Court in the Southern District of Indiana. I mean, it's different. We've got a lot more flexibility and a lot more of an ability to make up our own decisions, and to execute those for Fell Iron and Metal and for ABB. They are really distinct. DALE STATON: All right. Thank you. DAN HOPKINS: You're welcome. GREG MOORE: For the record, my name is Greg Moore. I'd like to know what are the chemicals Westinghouse used at the plant that may have found its way to Fell Iron and Metal? DAN HOPKINS: Well, I can tell you what we found at ABB when there was excavation going on. There was tetrachloroethylene and trichloroethylene. There was zinc, and I think those chiefly were it. There were a couple of incidental other findings, but those were the chief ones. GREG MOORE: Was there any cyanide or benzene? DAN HOPKINS: Not to my knowledge. GREG MOORE: Were these capacitors ever burned at Fell? DAN HOPKINS: I don't think so. GREG MOORE: Were there any fires? DAN HOPKINS: I think, you know, in all the depositions that were taken, there was no indication of that. GREG MOORE: Have you ever tested around here in this area or any of the extending area around Fell Iron and Metal for dioxins, pyrines or PCBs? DAN HOPKINS: I know that the outside of Fell Iron and Metal, along the sidewalk, I believe, was tested for PCBs. I'm not sure what the other compounds were. We sampled the material that was excavated for other compounds. We found a lot of anthracenes and pyrines, as I recall, typical compounds that you might find in diesel fuel or coal tar type derivatives. GREG MOORE: Just off-site, did you do anything around Lemon Lane like that either? Do you have test results from around there? DAN HOPKINS: Do you mean around the site prop---outside the boundary of it? GREG MOORE: Outside the boundaries? DAN HOPKINS: Not to my knowledge, no. GREG MOORE: How deep are you intending to go with Fell Iron and Metal to excavate the material? DAN HOPKINS: Well, the pile right now is sitting at ground level, and the whole thing will be gone. GREG MOORE: The pile will be gone, but are there any core samples to find out how deep any of this material may have leaked? DAN HOPKINS: First of all, we don't expect that because of the way that it's encapsulated, but there will be post-excavation sampling; in other words, once the tarp is removed, there will be sampling. GREG MOORE: I'm a little concerned about, are you doing this under TSCA now? DAN HOPKINS: No. This is still being done under the Comprehensive Environmental Response Liability and Compensation Act of 1980, as admitted by SARA in 1986. This is being done as a Superfund action. GREG MOORE: Okay. Well, I find the characterization, if that's the word you'd like to use, for the comprehensive testing of the variety of dangerous chemicals by far exceeds the little code word which seems to be used which is PCBs. I think that a real comprehensive test would expose cyanide, solvents, benzene, paints and probably a myriad of other chemicals, and I think this is really a very fast, inadequate clean up. I'll tell you, he asked the question how did you pick Fell Iron and Metal. It occurs to me, this is really ironic, that the two sites that all these parties to the Consent Decree denied in federal court before Judge Dillon even existed, the two sites that are not covered by the Consent Decree are the ones that are being cleaned up. In my opinion, I think they're the two sites that Westinghouse has open liability to, and after they take this mediocre, superficial step of so-called cleaning it up, they'll be back in Pittsburg, and we'll never see them again. DAVE NOVAK: Gentleman in the back. (William Baus makes comments. See comment section.) Just a reminder for some of the folks who came in late, I think what he was just speaking on we'd consider a comment. You were not here when we had the introductions. What I'd like to do is keep the questions at the beginning and save our comments for the end, so we can kind of group them together. No problem with yours there, but for the remainder, if we could do that. If you have questions here, we'll answer the questions, and we'll only respond to the comments such as this in the Responsiveness Summary. So, do we have some more questions? LOU SCHWITZER: Dan, you mentioned again that you were going to take some core samples. Are we going to be under budgetary constraints as you said the other night at the CIC meeting, and only take a few samples, or are we going to use an exhaustive search of the properties to check for any in-depth PCBs? DAN HOPKINS: Do you mean at Fell? LOU SCHWITZER: Yes. DAN HOPKINS: I think the area that will be looked at will be restricted to the area immediately under the pile. LOU SCHWITZER: Have you done core samples around the rest of the place where that stuff was dug up in the meantime, and how far down did you go to check? JEFF CAHN: I don't know the exact amount of sampling that was done, but I know that in at least one area, the excavation was down to the bedrock. DAN HOPKINS: Sixteen (16) feet, as I recall. I don't know. To be honest with you, I came in at kind of the latter stages of that, and I don't know how the sampling was done per se. I can tell you what will be done regarding that pile, is it will be looked at carefully, and you know, one of the things that you look for when you take the material out of the containment cell, and part of this even goes back to before you get it out of there, that you will make sure---I know Westinghouse will make sure--- that the material that's taken out of there is done carefully so as not to breach the liner system. Now, it's possible that there are, you know, that there's a hole in it, you know, a pin hole or something, where you can see, where it can be seen that the liner has been compromised. There will be sampling in that area, and notwithstanding that, over the entire area that is going to be dug. But I would have to say, one of the things that they did when they put the material into the pile was to mix it up with a drying agent to make sure that what went in there was dry and wouldn't leach. It doesn't mean that there can't be something leaching out of it, but there had been precautions taken in the past. They are going to take additional precautions in removing it, and will do sampling underneath it. I don't think that anything that's, you know, really significant is going to escape this. DAVE NOVAK: Yes, sir. RICHARD FISH: A couple of questions. For the record, my name is Richard Fish. A question that was raised earlier that's got me a little unclear on this point, although some others of you may know it, why is Fell Iron and Metal not a Consent Decree site? How did that happen? DAN HOPKINS: I don't know the answer to the question. Do you know the answer? JEFF CAHN: Number one, I don't think it was identified as a site at the time of the negotiations of the Consent Decree. I don't think people were really aware of it, and number two, I wasn't involved in the negotiations, but it wasn't on the priority list of sites that we knew about. RICHARD FISH: I understood that it was part of the Consent Decree process and that people went and that the parties went to the judge and said, "Here, we have six sites, and this is all that there are. As far as we know, this is all that there are." That's one of the things that's caused, I think, some problems. That's an interesting question why Fell and ABB are not Consent---how did they happen to be missed? The answer to that question, I think, would be a very good thing to put out in public, if somebody would research that and find out exactly how that was done. LOU SCHWITZER: You can't do the research until you have a full understanding of the problems before it. RICHARD FISH: That's right. This is a problem in court. How are we going to know when the site is clean; in other words, you come in, you do the job, you take away things, so forth and so on. EPA is doing testing of the site, and the EPA will then certify that this is clean and the cleanup is done, and a certification will come from EPA? DAN HOPKINS: Well, the way that it works is that the company submits to us how they are going to do the sampling, and to whom they are going to send their samples, and what are the methodologies involved in terms of sampling and analyzing the material so that we can determine the quality of the results. I mean, you need to do that. Secondly, we would take confirmatory samples to make sure that there was a verification. We won't take a confirmatory sample for every single sample they take, but we might take ten (10) or fifteen percent (15%) to verify. RICHARD FISH Again, I think a concern here is the worrying, is getting to a situation where a cleanup is done, and they say, "Okay, we've finished now, it's clean here now," and then later on, we find out, no, why there's---are you aware, for instance, of a story about a sink hole on Fell Iron and Metal property? DAN HOPKINS: A spring, not a sink hole. RICHARD FISH: A sink hole on the property? DAN HOPKINS: I'm not aware of a sink hole. I'm aware of an underground quarry that used to exist years ago before it was filled, and a spring that was--- RICHARD FISH: You don't know how deep that underground quarry was? DAN HOPKINS: No, I don't. RICHARD FISH: Allegations, I've heard, that maybe sixty (60) feet, seventy (70) feet or something like that. Are there plans to test that and see if we have leaching down in there, if we have contamination down that far? DAN HOPKINS: No, not really. What we've done is, basically, assess the groundwater contamination through a series of monitoring wells. There's kind of a valley, if you will, a bedrock valley, that we believe that the water flows, and the contaminants appear to flow as well. RICHARD FISH: How deep are those monitoring wells? DAN HOPKINS: Oh, boy. I don't really know. I think they're about twenty (20) feet or something like that, maybe a little less. I mean, it depends on where it is with respect to the valley. I mean, at the point that we had dug up or that Westinghouse had dug up a portion of the site, went down to sixteen (16) feet. So, the monitoring will would be located above the bedrock, but you know, at different parts--- RICHARD FISH: The underground quarry, if actually other things were thrown into that underground quarry, they could be well below that. DAN HOPKINS: It's got to get down there. It's got to go down through a lot of material to get there. It's going to get soaked up as it goes. RICHARD FISH: I mean if it was placed there by people. DAN HOPKINS: I'm sorry. RICHARD FISH: If it was placed there? DAN HOPKINS: Oh, boy. You know, you are straining my recollection of the site history. I know that at one time it was a quarry operation, followed by another operation. There was burning that went on at the site, and it was a different site altogether. Westinghouse built their plant in 1957 or '58. I don't know the juxtaposition of the two histories to be able to say exactly, but my recollection was that that was a lot older facility, and I don't know, maybe somebody else knows who's been here for a long time. RICHARD FISH: If additional information can be found, would you be interested in looking at it? DAN HOPKINS: I'd certainly look at anything. RICHARD FISH: Okay, that end the question part. DAN HOPKINS: Okay. BETH McCALL: Basically, the removal will be just like the excavation was six years ago, as far as monitoring and that type of thing? In other words, you are going to repeat what happened with the original excavation as far as piling it up and capping it. That's going to be repeated? DAN HOPKINS: No--- BETH McCALL: And it's going to be removed at that point. It's just going to be taken away? But are you going to do any extra things this time as far as monitoring? I know there's a monitor in the park. I know that there was one on the school, but as a parent, I'm very concerned with that. I have a child who goes to school here, and I will make a comment also that I am in favor of, if that's going to happen, it happening in the dead of winter, when the children are inside as opposed to when they are outside. I just wanted to get clear as to if you are going to dig it up and take it away, and like six years ago, and pile it up, so that the same process, the same type of monitoring and everything is going to be used again, but nothing else is going to be added as a precaution? I know, we weren't very happy six years ago when it was excavated and piled up. I know there was a big brouhaha about that, but I'm just wondering the same thing, basically, has happened again, but this time, it's going to be removed? DAN HOPKINS: Well, basically. I mean, it's a different situation. You had material that was being excavated from the ground, and you know, parts of the site dug up and cleaned and decontaminated. In this case, the liner can be peeled back. It can be excavated or taken out with like a front end loader--- I'm not sure what the exact equipment is going to be---and loaded into the rail car, and that can be controlled. To a large extent, that can be controlled, and you can also pull back the cover if the winds are too high, or if there's rain. BETH McCALL: And you are going to be able to put it on and off? DAN HOPKINS: That will be part---I don't know, Jim, if you want to, Mr. Patrick? DAVE NOVAK: Just a quick comment. I'm no where near the expertise or technical as Dan. I was out at ABB this afternoon, talking to the folks out there. A possibility. Why couldn't they just cut a hole in the liner and stick in an auger and put it right into the railroad car, and eliminate any open exposure. So, a possibility. BETH McCALL: I am very concerned about open exposure, because I live five blocks from here (inaudible) and that's probably why we are here. DAVE NOVAK: Monitoring will increase also. It's not going to be that monitor at the park and the monitor outside. We had an interesting discussion on that, but I'm not saying that's the way it's going to go. It's not going to be those two monitors. It's not going to be cut and dry. BETH McCALL: I just wondered if it could be capped at all to just to keep the dust and particles as much out of the air as possible. DAN HOPKINS: That will be done. There will be a lot of precautions taken to reduce dust exposure and dust generation. BETH McCALL: And three months is a solid three months? There's no way that could be done any quicker? DAN HOPKINS: I think it's going to be done, you know, very quickly, you know, in terms of the three months. I don't think it's going to be strung out. There's no incentive for it to be. And, you know, it sort of depends on the weather though, but, you know, barring any unforeseen circumstances like that, I would say so. And, I actually appreciate what you are saying, as a father of two young children myself. The possibility of having them contaminated with something like PCBs would make me nuts, and, you know, there's a lot of care and effort that's taken into doing this. I will say, from the monitor, from the high volume air sampler that was placed on the Fairview School--- and I don't know it's going to be the same place, the monitor would be in the same place---but we didn't get anything. As my recollection was, most of the levels were zero. We are looking at very, very, very low levels, and, you know, I can say with pretty high confidence that, you know, any escaping contamination was pretty minimal. You can't guarantee absolutely because, you just can't. Some of it's going to be volubilized, and some of it's, you know, there's going to be on some other dust. BETH McCALL: To go back to my one question about the date as far as the winter, summer, fall. Who's going to have that final decision? DAN HOPKINS: I think ultimately, EPA will. BETH McCALL: Thank you. DAN HOPKINS: You are welcome. KEVIN COLACK: My name is Kevin Colack. Just to answer the gentleman's first question, and then I'll have a question for you. (Inaudible) hazardous materials response team (inaudible) My question is---it goes back to advanced technology and as a chemist a I.U., since 1993 (inaudible) which has been proposed, my question is, who is evaluating the advanced technology for their use (inaudible) to move this research process, possibly (inaudible). DAN HOPKINS: Who evaluates those? KEVIN COLACK: Yes, who's checking on these processes; granted, this sounds like a good idea moving it to get out of town, but there is a possibility of (inaudible) supposed to be one hundred percent (100%) effective for the destruction of PCBs which are some of the most inert compounds that we have. That's why Westinghouse used them in their capacitors. DAN HOPKINS: Well, EPA has a program, it's an innovative technology site program. I can't think of the acronym right now. What is it? MELISSA VALENTIN: Superfund Innovative Technology (inaudible). DAN HOPKINS: Thank you. That's the arm that basically does that type of work. You know, as a matter of fact, I know in our offices in the Public Information Center, there are---I should say I think there are---there are bulletins that relate to that. If you want more information, we could certainly give you that. DAVE NOVAK: Yes, sir. PAUL PFEIFFER: My name is Paul Pfeiffer, and I am a resident. If the ABB site is similar to the Fell site, how come it is taking so much longer to clean up that site, and how come there's only three months proposed for Fell? DAN HOPKINS: Why it's taken longer to clean up ABB? PAUL PFEIFFER: Yes. I thought you said they were of similar character. DAN HOPKINS: Actually, there's less out at ABB, but out at ABB, that was an effort that was undertaken over a huge area. It was pretty restricted here. I mean, that involved about, I want to say about a dozen different sites. PAUL PFEIFFER: Will the public have access to the air monitoring? How would you be contacted, or what measures would we take if we are interested in finding out how the monitoring was going? DAN HOPKINS: I can make that available. That's not a problem. PAUL PFEIFFER: You said the work was going to be done between 7:00 and 7:00? Is that 7:00 in the morning to 7:00 in the evening? DAN HOPKINS: Yes. PAUL PFEIFFER: Wouldn't it make sense to do 7:00 in the evening to 7:00 in the mornings, just because less people would be around, I mean, as far as children? DAN HOPKINS: 7:00 at night to 7:00 in the morning? PAUL PFEIFFER: Yes. Would that be a possibility? DAN HOPKINS: I don't know. I mean, if I were living in the neighborhood, they bang---I mean, when these loaders hit the bottom of a rail car, they make a lot of noise. That's one of the reasons that I kind of mentioned this was that, you know, I want to make sure that people--- DAVE NOVAK: They would follow normal construction times. DAN HOPKINS: Yes, I mean, otherwise, you would keep people awake at night. PAUL PFEIFFER: And what is Westinghouse's responsibility after the cleanup is done as far as, I think this question has been asked before, but if other complications occur locally or in the Utah site, where does their responsibility end? Does it end with the initial agreement? DAN HOPKINS: I think at Fell, once it is, I don't know---there's no release of liability?---with regard to the landfill, I understand, and if I get this wrong, please correct me, but I understand that the facility itself indemnifies the company, whoever takes it there, to a certain level, and beyond that, the company still does retain liability. Is that close? I don't know what the level is, but that's kind of the arrangement. So, it's never really completely gone from their liability. DAVE NOVAK: The gentleman up in front there is