Work Plan to Develop
Health-based PCB Cleanup
Goals for Winston-Thomas Facility
Bloomington, Indiana
by ChemRisk for Westinghouse
December 19, 1996
Cover Letter which Accompanies the Draft Work Plan:
Dottie Alke's cover letter (dated 12/23,96) regarding the above plan
contains two statements in the third paragraph with which we strongly disagree.
An accurate assessment of risk cannot be accomplished from looking at surface
soil concentrations alone. Regulated concentrations of PCB-contaminated
media exist at various depths throughout the Consent Decree metes and bounds
as well as in contaminated areas outside the metes and bounds. The area
east of the Gordon Pike entrance road is an example. The Westinghouse sampling
event of July and August 1996 indicated significant PCB contamination at
depth in the area west of Clear Creek (flood plain) which could easily become
available to the ecosystem and humans in the future.
In the same paragraph, Ms. Alke suggests that ' once the tertiary lagoon
is drained, the site should pose no ecological threat and no other pathways
of concern." This statement is wishful thinking based on conjecture.
To believe this, at a minimum, Westinghouse would have to conclusively demonstrate
that there is no connection between the plant site and the groundwater and
that PCBs in contaminated Clear Creek fish did not originate in the Winston
Thomas Plant.
Section 1.0, page 1-1, paragraph 5, lines 6-9:
The draft ASTM (1996) document is missing from the list of references.
The City of Bloomington would like to request a copy of this document from
Westinghouse/ChemRisk when it becomes available.
Section 1.0, Figure 1-1:
The known contamination east of the Gordon Pike entrance road and the
contaminated area west of Clear Creek are outside the facility boundaries
shown in this figure. The figure and paragraph 3 on page 2-1 seem to indicate
that the facility extends to Highway 37 on the east. This is correct for
only a portion of the facility in the northeast corner by the Interim Storage
Facility. For your reference, a map (1 color copy, 2 black and white) with
the facility boundaries is attached. The facility is comprised of two parcels:
a triangular strip on the west by Clear Creek and the main parcel for the
central portion of the plant. The Monroe County Humane Association leases
a portion of the main parcel to the southeast. The approximate boundaries
of this portion are inked in on one of the black and white maps (the leased
portion is 390 ft (north-south) and 448 ft (east-west)). Also attached are
two other maps of Winston Thomas showing: 1) the approximate locations of
contaminated areas and 2) labeled process units.
Section 2-0, page 2-1,
first paragraph, last sentence: The contaminated area west of Clear Creek
is not currently fenced, although Westinghouse and the City of Bloomington
have reached a tentative agreement to fence this area. The contaminated
area east of the Gordon Pike entrance road is not currently fenced.
Section 2.0, page 2-1, paragraph , line 2:
Reword to indicate that there is a contaminated area which is part of
Winston Thomas and is west of Clear Creek.
Section 2-0, page 2-1, paragraph 4:
This paragraph states that there are no known connections between the
process units and groundwater. This is a critical fact. It is obviously
very important to know if there is any way that PCBs on the site can move
off the site. The report makes mention of finding PCBs in some groundwater
monitoring wells. This information is then dismissed since it was not clearly
determined that the PCBs came from the site. The prudent approach would
be to assume that the PCBs found in the wells did come from the site until
it can be proven otherwise. Westinghouse should assume that connections
exist between the process units and groundwater when establishing the HBCGs
unless they can unequivocally prove otherwise. Establishing HBCGs from surface
soil concentrations makes sense only if we know that other pathways are
insignificant.
Section 2-0, page 2-1 and 2-2, paragraph 5:
City of Bloomington maintenance personnel enter the site frequently to
monitor the lagoon level and the pumping system for the tertiary lagoon.
Mowing crews (usually 4-6 persons) frequent the site during the 8 month
mowing season and are on site for 3-5 consecutive 8 hour days. Tow truck
operators are permitted on the site to drop off or release impounded vehicles.
Police evidence technicians visit the property frequently. Utilities management
personnel visit the site sporadically for inspection purposes.
Section 2.0, page 2-1, paragraph 5, line 2:
Please include in this discussion the existence and purpose of the Interim
Storage Facility (ISF) on the site (it is mentioned in Section 3.0, page
3-1, paragraph 2, fumes 2-4, but this passage lacks an explanation as to
what the ISF is).
Section 3.0, page 3-1, paragraph 2:
We disagree that human exposures are severely restricted by current site
control measures. Security fencing would have to be substantially upgraded
before this can be considered accurate.
Section 3.0, page 3-1, paragraph 3:
We suggest a more conservative assumption offuture land use. While commercial
or retail land uses are certainly anticipated, other land uses are possible
under current zonmg scenarios. For example, some in local government have
suggested future land use as a multi-function recreation area, which would
certainly promote exposures of longer duration by more sensitive human populations
than are currently anticipated by the work plan.
Section 3.1, page 3-2, paragraph 2, lines 6-7 and Table 3-1 and page
3-5, paragraph 1:
Shouldn't incidental inhalation also be considered for the trespasser
scenario?
Section 3.2, page 3-2:
The exposure of construction workers during future site preparation and
building construction is not given adequate attention. It assumes that the
exposures will be similar to lawn workers' exposure to surface soils. We
disagree with the report's conclusion that it would be too difficult to
estimate exposures to subsurface soils during construction. One could consider
the types of buildings that could be built on the site, estimate the nature
of site preparation and construction, and estimate the number of workers.
and exposures via inhalation, absorption and ingestion. Certainly if one
can estimate ingestion by teenage trespassers, one can estimate exposure
to construction workers. These potential future exposures could be significant.
Also in this section, the report suggests that the lawn care workers
and gardeners at a future commercial building on the site will be exposed
no more than will maintenance workers at the current site. We believe that
this greatly underestimates exposures. Lawn care workers and gardeners will
be down on their hands and knees in direct contact with surface and subsurface
soils. These exposures could easily be much greater than those at the site
in its current condition. Additionally, the exposure frequency will probably
be more frequent than the one day per week described in paragraph 4 on page
3-4. |
