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Letter to COPA
February 15, 1998
Mike Baker, President
Coalition Opposed to PCB Ash In Monroe County, Inc. (COPA)
P.O. Box 665
Bloomington, Indiana 47402-0665
Re: Proposals for Land Disposal
Dear Mike,
As you requested, I have prepared general comments on the land disposal
options currently under consideration by the Court. According to recent
communication with you, Tom Alcamo (EPA) and John Langley (CBU), the short-listed
remedies currently being evaluated by the Court involve extensive waste
excavation, with four options for disposal of the excavated material:
- Existing, permitted landfills;
- A new landfill to be constructed on CBS/Westinghouse's Bottom Road
farmland;
- A new landfill to be constructed at Neal's Landfill; and
- Consolidate waste at Neal's Landfill, in its present condition.
Unfortunately, this is the extent of the information that has been provided
to me regarding the four remedial proposals, and my comments are therefore
preliminary. A request for information is included in this letter. Comments
on the primary elements of these remedial plans follow.
Removal of waste from existing landfills / dumps
I am in complete agreement that the PCB-bearing waste must be relocated
as soon as possible. It is important to remove as much of the PCBs from
the unlined dumps as possible in order to arrest the continual leakage of
PCBs into groundwater and surface water.
It is impossible to prevent off-site groundwater contamination at Lemon
Lane, Neal's Landfill and Bennetts Quarry because the landfills have direct
access to groundwater and/or surface water. The highly fractured and dissolved
limestone at the base of these landfills transports water very rapidly through
a complex network of channels that change continually. Flow patterns during
low-flow conditions can be completely different from flow patterns during
high-flow conditions, when the water reaches conduits at higher elevations.
As the limestone is eroded by water, new sinkholes form and old conduits
collapse, changing surface water and groundwater flow patterns. Dye trace
studies may be used to map the flow patterns at one point in time, but they
may become inaccurate at any time. Thus, groundwater monitoring in karst
terrane is unreliable as a means of detecting or preventing off-site contamination.
There is enough PCB mass in the landfills to produce groundwater contamination
indefinitely. Some hazardous waste sites become less of a threat over time,
due to natural degradation and dilution of the chemicals of concern. This
is not the case with PCBs. PCBs remain stable and harmful for many, many
years. Dispersion in water or air redistributes the PCBs, but they ultimately
reaccumulate in sediments and organisms. It is critical to contain PCBs
at the source.
The site characterization data collected to date is inadequate to support
delineation (or excavation) of "hot spots", discrete areas of
contamination. These landfills lack a physical or historical explanation
for hot spots. Further, the definition of a "hot spot" must be
closer to 50 ppm, not 500 ppm as proposed.
Comments on land disposal in general
All four of the disposal options would result in consolidation of the PCB-contaminated
waste, which is advisable. Modern land disposal represents a long-term (but
not permanent) containment option for PCBs. Since the PCBs in Bloomington
are currently dispersed among many sites, and migration into the environment
is uncontrolled, land disposal represents a dramatic improvement.
It is a missed opportunity not to treat the waste prior to land disposal,
to reduce the volume, mobility or toxicity of the PCB waste. Although many
viable treatment processes are available, it may be difficult to implement
them within the time frame dictated by the Court. I would encourage the
Court to consider treatment for as much of the waste as possible prior to
land disposal.
PCBs will probably out-last the liners of modern landfills, so it is important
to select a landfill that has a very reliable and well-maintained leachate
control system in place. This is why PCB land disposal in karst is so unreasonable.
Landfill selection should not be driven by cost alone, but also by the adequacy
of the facility to prevent releases of PCBs to the environment.
Construction of New Bottom Road Landfill
I have not been provided with any details regarding the proposed Bottom
Road Landfill. I have visited the site during a flood, however, and I reviewed
geologic maps and reports of the site published by the Indiana Geological
Survey. Based on this information, the Bottom Road site is definitely situated
on karst, and it is in a flood plain, contrary to claims by CBS/Westinghouse.
Gareth Davies, a consulting karst hydrologist, is currently reviewing this
issue, and will prepare comments for COPA.
I have not examined the flood zone delineation for this site, but based
on my experience performing flood control studies, I am aware of how imprecise
these studies can be. The proposed site is also in close proximity to sensitive
wetlands and farmland. Based on technical considerations alone, my initial
assessment of the CBS/Westinghouse's Bottom Road farm is that it is completely
unsuitable for development into a landfill of any type.
If CBS/Westinghouse has geological data that demonstrates the absence of
karst, and hydrological studies that demonstrate an acceptable distance
from the flood plain of Bean Blossom Creek, it must be provided to COPA
for independent review.
Coupled with the reality that development of another PCB site in the Bloomington
area would be vehemently opposed by the vast majority of residents and their
elected officials, legal and political obstacles would prevent cleanup within
the time frame dictated by the Court.
Consolidation at Neal's Landfill
The presence of karst terrane at the Neal's Landfill site cannot be disputed.
Neal's Landfill is a sinkhole dump with springs coming out the bottom. The
nature and extent of contamination at this site has never been established.
Extensive off-site contamination has already occurred. It is astonishing
that this site is being considered as a potential site for consolidation
of PCB wastes from the other sites - with or without construction of a modem
landfill liner.
Request for information
COPA is benefiting from the cooperation of the government parties. However,
by accepting the TAG from EPA, COPA has an obligation to provide the community
with professional, timely and detailed assessments of current events. The
Consent Decree parties have an obligation to provide COPA with more than
superficial narratives of Court proceedings and technical discussions. COPA
should demand detailed descriptions of the conceptual remedial alternatives,
data analyses, cost estimates, and any other information that contributes
to the development of proposed remedies.
I wish you the best of luck with your activities and look forward to speaking
with you soon.
Sincerely,
Melissa Valentin, P.E. MVA Consulting, Inc. |
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