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Meetings: CIC

Citizens Information Committee Minutes of Public Meeting June 10, 1997 Bloomington, Indiana Attendees: Dan Hopkins (DH) - EPA Dereck Kimbrough (DK) - EPA Mike Baker (MB) - COPA Sona Chambers (SC) - Earth Tech John Langley (JL) - CBU Michael List (ML) - Chair Resa Ramsey (RR) - IDEM Sally Hegeman (SH) - IU Deb Backus (DB) - IU Flynn Picardel George Hegeman (GH) - Monroe County Health Board No Minutes were take at the last meeting, which was a presentation by the EPA, not a regular meeting. DH I would like to introduce Derek Kimbrough, who has taken over Dave Novak's role with the EPA. Winston-Thomas: Digesters and Drying Beds Work is to begin in late August. We are working with the Conceptual Plan, and we have submitted to the Court on June 2 or 3 an amendment to the Consent Decree, under which the work will be done. The Justice Department has declared a public comment period, notice of which has appeared in the Federal Register, which is available from the Library, and on the Internet. After the DOJ takes public comments, and responds to the comments, we will be looking to the Court for approval. I don't know if the Judge will look at the comments to the DOJ, but the documents will be made available to him. There will be a detailed work plan for the digesters and drying beds, and is due by July 21, 1997, and it must be approved by all governmental parties. It will follow very closely the Conceptual Plan you have already seen. This work will be done without closure on the issue of risk assessment. This is totally a performance based standard at present. We are working on risk assessment for the rest of the cleanup at W-T. This includes the tertiary lagoon, the interim storage facility, and trickling filter. We are also looking at doing additional sampling around the units, or anywhere else on the site. [This does not include the West Side of Clear Creek.] We are currently looking at risk issues, and the Health Based Cleanup Goals as proposed by Westinghouse. There are two approaches to this. One is to do a risk assessment, the other is to do an assessment that is consistent with the degree of risk which is acceptable. We (the EPA) usually base this on cancer risk, which is 1 in 100,000. We consider use of the site and risk to the most vulnerable of people at the site. In this case we considered a maintenance worker who would be there for 20 or 25 years. This can be refined to a number (ppm) that determines cleanup goal. MB How do you account for the current understanding that the primary risk for PCBs is not cancer, but rather reproductive and hormonal defects, which are also reflected in the ecological risk? DH We are looking at human health risk only right now. And we are looking at both cancer and non-cancer effects. In "Inside EPA" [an independent subscription magazine] I recently saw an article that questioned how we should use the new cancer slope factors that EPA recently promulgated. The non-cancer effects are having an influence on the application of the new slope factors, and the situation at the Agency is still a bit fluid, and there are many levels of review. There are several factors that must be worked out, including the non-cancer effects, the new slope factor, and the inter-relation between the science and the guidance. There will be changes, but what they finally will be is not yet clear. What I want here is come to closure on the risk factors, and to apply a number at the site. For instance the EPA proposed the 15 ppm as the not to exceed cleanup number. Well, Westinghouse came back and said, we can accept that if it can be averaged over all the site. So it goes like that, and we have not reached closure. It is very important that we move quickly with this process at this time so that we can begin early next year; it will take a full season to get the work done. We have to go through the same steps as we have to get started with the digesters and drying beds, so we need to come to closure soon. We have agreed to the performance standards with the digesters and the sludge drying beds only because we could not come to closure on the risk issues until after the point where we couldn't get the work done this year. Some things could happen along the way, public comment could cause a change in the conceptual work plan, the judge may not approve right away, these sorts of things could slow the process. I do not expect these sorts of things, but we are on a very tight schedule to get going. I think it is a good thing that we went with performance based standards in order to get something done this year so that we can get the rest done next year. But this is still in jeopardy. GH Is the use of a performance based standard going to be applied to the rest of Winston-Thomas and to the other sites? I am worried that the standards set here might be applied to another site where it is not as appropriate. DH I don't think so, I don't want to say absolutely not. The digesters and drying beds are discrete units, and could be dealt with in this manner. There are other places where the risk based assessment would be more appropriate. The more uncertain you are of future land use, the more conservative you must be in risk assessment. We all want to meet the time frame, but I do not want to feel we are leaving contamination behind, just to make the time frame. Maybe it is time to step back and look at the situation. MB There seems to be a problem with the time frame problem causing us to accept PCB values that are higher than might be prudent, just to get the job done quickly. It seems that the governmental parties are in agreement as to reasonable numbers here, but Westinghouse is not. We need to move towards full agreement here. DH That type of situation seems to have been set up, and maybe it is time to step back and look at it again. We should not leave behind high levels of residual PCBs just to get the job done quickly. Lemon Lane DH We don't have perimeter sampling at Lemon Lane, and we need it as part of the human health assessment phase. Westinghouse has proposed a conceptual sampling plan, but only for PCBs. EPA will do limited sampling for other chlorinated organic compounds, dioxins and furans, and also metals. The objective is to get this done this year, as soon as possible, so that we can get assessments done this year. We have ecological samplings of fish and crayfish in Clear Creek. Sediment and water samples have been collected. We have had extensive discussions with all the parties under very tight time frames, we are running out of time on the risk assessment phase. At this point we believe Westinghouse will do an adequate job of writing the risk assessment. I said either we are going to do it, or you are going to do it, but this is the way it is going to be done, and they said they would do it, and they are moving forward. Now we know there are things we must watch as we move forward, and we have really good people watching it, and the risk assessment is moving forward Larime Wilson What about dioxins in the landfill and the associated risk? DH We tested for dioxin in the bottom of the sinks, and in the stream sediments and the fish in the creek. If we do not find dioxin in any of these places, then we can feel confident that there is little dioxin risk. However, we have not received the validated results as yet. We need to do more fish sampling, some of the fish we got last year were too small for analysis. MB Westinghouse has been working on their berming plan, trying to divert water around the landfill, and reduce the amount of PCBs getting to ICC Springs. We brought in Gareth Davies of Oak Ridge, Tenn., a noted karst hydrologist to look over the current situation, and evaluate Westinghouse,s current work. He met with Mike McCann, toured the site, and is reviewing all the data. He went over their most recent data, and talked about some future testing the Westinghouse team is going to do. After these initial meetings, I felt there was a free flow of information, and we are hoping to propose some new testing methods, or at least a peer review of the current work. We can see that Mike McCann has done good job of convincing Westinghouse to do some testing that perhaps they did not want to do, but Mike felt was necessary. Gareth will review all of the data, and provide a review of the issues, as has Senes in regards to risk assessment. DH We have found that during large storm events, concentrations as high as 527 ppm PCBs come from the Spring. There is also a continuing release of about 15-20 pmm coming out of the Springs. Westinghouse has been testing the theory that diverting water from the most highly contaminated section of the site, (thought to be the southwest corner), they could lower the concentration of PCBs at ICC Springs. So they have bermed over the compound sinkhole on the southwest corner, and are diverting the water to top of the site, and then on to Sargent,s Pond. Subsequent sampling showed this to not be effective in reducing PCP concentrations, and so they then bermed three quarters of the way down the south side, where we have identified high concentrations of PCBs at a ground level. Let me be clear that EPA advocates excavating the PCBs here, and we also see other hot spots that should be excavated. This is an exercise in seeing if it can,t be controlled without taking it out. MB There is news that the new antifreeze available now will show the same wavelength as the dyes they are using. This could give them some problems with validation. They (Westinghouse) are still collecting data points. ML If Westinghouse is looking to leave everything high and dry at Lemon Lane, what are they going to do about liability? (If it were to leak?) DH There is also the problem of water backing up in the system, it is like a giant pipe, and water can travel up when the pipe is filled. West Side of Clear Creek DH A woven wire fence about seven feet high has been constructed around the site. It is in the ten year flood plain, so the wide mesh was necessary, as during a flood debris could get caught smaller mesh and cause a dam effect. ML Would it be possible to put a row of the no climb mesh at the top? RR I don,t think they would allow that. DH We still want to see the excavation done this year, but there has been resistance by Westinghouse. Time is short to get started. We have not formalized how the work will be ordered, whether by a consent order, or by an administrative order, or how it will happen, but we want to get it done this year. There is interest in folding it into the Consent Decree. GH From the perspective of the County Health Department, we would like to see a speedy resolution, the site is in close proximity to homes, and it is an attractive riverine environment. DH It would be good if we could get a joint agreement, but the time is becoming too short if we are to act this year. MB Would the EPA be somehow liable if no action is taken? To draft an emergency order and then not take action seems wrong. DH We have followed up, and the question is how it will get done, what form it will take. ML What cleanup level are you going to use? DH I identified in the action memo a limit of 15 ppm. Westinghouse made a proposal on April 22 that actually made some sense, and I will sketch it out for you here. There are 4745 cubic yards of material greater than 25 ppm that will be removed. This will leave a hole that will be filled with dirt scraped from the area surrounding the highly contaminated area. This dirt should average to less than 10 ppm. After it is put into the hole, it will be covered with 12-18 inches of clean dirt. This has the effect of is isolating the contaminated dirt from the biologically active layer. I think this is a reasonable plan, and the plan implemented here will be similar to this. There will likely be some material that must be transported to a special waste landfill. All of the material above 25 ppm must go to a TSCA landfill. It may need to be trucked to a rail head. GH It would be nice to see movement at this site, but I am not happy with leaving behind contaminated material in the flood plain. Diane Henshal How will the material be transported? Is there a plan? DH We are considering using rail if possible, though we will have to truck to the rail head. Next Meeting: July 22, 1997, 7:00 pm, McCloskey Room, Showers Complex

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