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Meetings: CIC | |||||||||||||||
Citizens Information CommitteeUnapproved MinutesJune 23, 1998
Tom Alcamo, EPA Approval of Minutes Tom Alcamo Winston Thomas - I have been sending the weekly reports to Mike. And a couple a months to the Monroe County Public Library. But if you really want to see the latest up to date information keep checking with the COPA web site. They are about half done with the trickling filter. Actually they are calling the pile of rock Mount Langley. The results are coming out real well. The standard is 10 parts per 100 meters. 100 micro grams per hundred square cm. The trickling filter process is working well. The Tertiary Lagoon area has been sampled. I have not seen the results yet. I'll give them to Mike as soon as I get them. That is completed. That excavation will begin later on in the summer. The drudging has begun on the Tertiary Lagoon. They just started this week, a filter process. Things are going real well. They are doing a good job. Winston Thomas is doing well to date. The dredge is on the Tertiary Lagoon. That material is being pumped to the ISF building. And there are filter presses there. It's all in an enclosed building. Personnel are wearing personal monitors. We are looking probably to mid November, but it's going very well. I'll keep reports coming. Mike Baker I have been working with the Bloomington Voice, BCAT, HT, and Hoosier Times to run a public service announcement on a regular basis to direct people to the web site for PCB updates. Bob Zaltsberg will try to do that on a regular basis for no charge. Tom Alcamo Behind the scenes, concerning past documentation, I have got a contractor right now working and organizing the files. It is going to take time, but all the documentation will be in the repository now. I will get it all in there. By sites, etc. It will ALL go out. Correspondence as well. It is a lot of work, but it will be there. Jim Cartmell There was a thing before about air monitoring that I had a question about. They have the air monitors, and they are sucking air through and they go through a pre filter first. And the state sent me this thing that what test system 86/97 (whatever it is), that this information says that they filter out with these pre filters and they throw them away. And they are trying to find out what the PCB vapors are in the air rather than whatever PCB are on the dust. Or whatever. Tom Alcamo They are doing puff samples. And personal monitor samples. So the data has come up good. I think they are 1/8 the action level for personal protection. After they drain the lagoon and then do additional sampling. That is when we need to be careful with dust generation. We told CBS that we could increase the monitoring if it gets to a point that we view there is problems. Yes, Jim, if there is no water there, then the dust problem we will be careful with that. Jim Cartmell I have some more questions concerning Winston Thomas. Tom Alcamo I'll tell you this from the last meeting, Jim. I wish John Langley was here. The last meeting you had some issues associated with additional sampling at Winston Thomas. They have got a bunch of additional sampling and they said they are going to get it to you. There has been a number of tests done at that facility, including the sink holes. I talked to EarthTec directly after the meeting. In terms of Dick Powell, who did the analysis, the only area that came up that could be problematic was around the grit chamber. And we have not worked that out with CBS, but we are expecting them to do additional sampling. But the other areas, my understanding, depending on the city, they say it's fine. John Foster In one of those areas they found by the ________ was east side of the entrance road. And I don't know how many cubic yards they pulled out of there. But they pulled that out while West side clear creek was going on. They poked like 56 borings at that site. Tom Alcamo If we need to do additional sampling. I will, if it's justified. Jim Cartmell So this is just down the street from clear creek. This is 1976. This is a result of flooding. Will this be addressed at some point? Tom Alcamo Yes. We were concerned with it. We'll get to it. Let me go through some of it. This is a flow record from January to July, 1996. Why is 1996 important. When you look at the past history from 1961 to present, this is considered a wet year. And so we are using this as a basis for our discussions associated with water treatment. And this is Illinois Central Spring. This doesn't include storm events. Look at COPA web page to look at it more closely. Back in mid April we negotiated to do some additional storm sampling. This is results from April 15 and 19, 1998 storm. About 1.7 pounds PCBs were released during the storm event. 190 parts per billion, 3,000 gallons a minute. 2.14 inches of precipitation. Obviously this is probably a pretty small storm. We are very much concerned about it. We are trying to get something out there as soon as possible. They are monitoring this continuously. We are certainly concerned. Neal's Landfill. About .7 parts per billion PCBs were results during this storm event. Much much more water, much lower concentrations. 9,000 gallons per minute. You can see south spring and north spring. There has been as much as 50,000 to 60,000 per minute. This is a 2.14 inch rain fall event. Unknown Man Is this just at the springs or also the surface flow? Tom Alcamo At the springs it's the culvert and bridge. It's measured at the culvert. Surface flow. It's part of the problem, but nothing like Lemon Lane. Good news is the levels are lower. Bad news is that it's a lot of water. David Porter What percentage of the water flowing through Neal's does that spring represent? Tom Alcamo We don't know. We don't have a lot of data from this site. That is why we are putting these (pizometers) in Neal's Landfill. We want to see what is back flooding. Back to Lemon Lane. If the conduit study is successful, we are looking at going to Neal's Landfill with that. PCB levels are all over the place. I want to introduce someone. Costess DeVantes (??) He's with Tectro Tec (?). We have hired him as a consultant along with Dr. Polin (?) And Dr. _________(?). Jim Cartmell Is it up stream, down stream, and west stream. So you are talking in the creek. Tom Alcamo Again we are talking in the creek. We had no storm monitoring sampling at all. We are looking at the sampling to see if we need to do sediment removal. Source removal, water treatment, sediment removal. Unknown Woman In terms of interputation of these. At Lemon Lane there wasn't all these zero points. Were as a little bit at Neal's and here at Stouts Creek, there is a lot of up and down stuff. Can someone that understand this better explain is this real for those points. Do they have to be averaged in? Should they be dropped? Could someone explain why there are so many zero points. I know it has to do with concentrations. Is there all of a sudden lots of flow. Tom Alcamo I don't know. Maybe there as been a push of sediment. We are looking at this. We have people looking at it to come up with what can make sense. We took fish data and sediment. I'm not prepared to answer right now. We are getting data. Unknown Woman I'm not familiar with the sampling. If you guys haven't measured how much sediment is in each water sample, you can't determine what is going on. Tom Alcamo We need more of the data. Jim Cartmell Can Milton Clark talk about _____. What that means and doesn't mean. Level of concern. Dr. Milton Clark The state has an _____ of water quality criteria of .79 parts
per trillion. And so you would be comparing those numbers relative to
that .79 as being your desired ------criteria. So these are still above
that even in this situation. Tom Alcamo As we get more data and we analysis it we'll discuss it in
more detail. These are the sampling locations for both the fish samples
and the sediment samples at Stout's Creek. This is the fish samples. Three
locations for fish. Dr. Clark As Tom pointed out, we are giving this to you just as we get it. We will supply all of the data. But just to give you a quick basis of comparison. The first level of the fish consumption advisory kicks in at .05 parts per million or greater. And basically what the state of Indiana does is if it is between about .05 and roughly about .1 then they would be saying that should be a mil per week. And then something from (roughly)about .1 to .5 would turn out to be about a mil per month. About .5 to about 1.5 it's 6 mils per year. And then actually the break point is 1.9. And 1.9 above is do not eat. So you can take a look at your PCB columns there. And if I'm correct, currently all these streams and creeks have a do not eat advisory. And so they do that because of not enough data. Historicaly it's been very high. Larime When we talk about Filets we are talking about no liver, no fatty skin. Recognize that a filet, that is if you take a raw fish, cut it out, and you cook it like that. A lot people cook the whole fish and then cut out the filet after cooking it, which means that the PCBs migrate into the muscle tissue afterwards. Dr. Clark Certainly you can have that. In our studies of filet verses whole fish, it's roughly a factor of 2 between that. While there is certainly a concern of people eating whole fish, that's not a huge portion of the population. All of these are a skin on filets. It's a standard great lakes filet. With a trimming method. It doesn't eliminate all the fat. Tom Alcamo As indicated, I have not seen this data yet. Mike Baker Can you give us a brief idea of the importance of lipids? What does that tell people? Dr. Clark These have been uncorrected. Obviously you tend to find often fish that have higher concentration of PCBs and higher amounts of fat. That's not always true. It depends on the eco system structure and which fish are at the top of the food chain. Sometimes Walleye which are at the top of the food could be low in lipids but high in PCBs. But your bottom feeders tend to be higher in lipids and higher PCBs. The reason we take lipid data is you can do what they call lipid adjusted. You look at the PCBs relative to lipid. That allows you to look at trends over time. Fish at different times of the year will have different levels of fat. So you normalize that relative to the fat to take care of different time variations. The other thing that lipids does when in conjunction with total organic carbon measurements of the sediment, you are allowed and permitted to do what they call a sediment to fish relationship. And you have a total carbon there in the sediments. And with the lipids of fish, you can lipid normalize and carbonize the sediments. And you can then come up with a mathematical relationship there. In simple terms, it's called a D.S.A.F. relationship. That allows us to have a little more understanding of what is going on. Jim Cartmell Did the fish data get broken down to _________ PCBs? Tom Alcamo No. Like I said, I don't know about this data. I haven't looked at it yet in terms of analyzing it. Here's the sample locations. You can see I yellowed in. There is a third sample location here, Hendricksville, at Neal's. This report will be in the library and to Mike when we get it. Station 3 is farthest from the landfill. Station 1 is nearest to the landfill. I am surprised we didn't get any Crayfish. Because they were suppose to do _____ at Stout's, but maybe they didn't find any. Mike Baker Is the PCB levels in the fish. ..... 1.9 PCBs and above, is the same factor used for like Crayfish. Steve Ellis (?) No. Technically they don't do human health assessments on Crayfish. Even though people do eat them. Technically you could assume that a little bit. Tom Alcamo Chart 2, it's getting smaller. And three. Let's look at the map with the central locations again. You got the landfill right here. With station one, two, and three. Unknown Man Can you explain how far that away? When you talk about a station, how far away from Neal's you might be. Steve Ellis (?) Connard's Farm sample there on the right is probably a half a mile or so from the treatment plant. The other one is probably an additional three quarters to a mile. So it's a total of a mile and a half from the landfill. And then another one again, is about 3 miles from Hwy. 48. An area where fish are going to get bigger. And I think the thing to look at in station three are the large mouth Bass filets. 5 miles away from the site. Unknown Woman Do you base your selection on age of fish or on size? Steve Ellis Typically what happens is what you catch. You try to see what you do. I don't know if that weight is the whole fish or just the filet. In Clear Creek when we sampled EPA we had Bass samples over 400-500 grams. Depending on what you catch. And I don't know what their selection criteria was. Unknown Woman Is there a way you can estimate age? Because a lot of weight has to do with.... Steve Ellis With the fish sampling we did at Clear Creek several years ago, you can see three different age classes in the creek channel. Beyond that, I don't know. Certainly you can start looking at age classes. And a Fishery Biologist, which I'm not, could probably look at scales and estimate ages. Unknown Woman So you don't bother with that, but you just look at the weight. Steve Ellis Weight and length. If you have processed enough fish you can kind of get an age size class. Because they tend to jump out in groups. If you have done enough looking. And I'm sure they probably did. Dr. Clark And that's a good point. If you look at a large mouth Bass filet on the graph there, you can see that the smaller guys - you can see how the concentration drop and vary with he lower number. This is where you look at the lipid adjustive. Mike Baker But if you look at all charts down that we've seen and all the creeks, it's basically saying that there's definitely a need for a fish advisory and that the fish are still contaminated. That's the bottom line. Tom Alcamo I had one of my interns do some of this data on Neal's Landfill. It's also on the COPA web site. In terms of the data, you can see we got some of the locations that we took samples at Neal's. There is a range of concentrations. I will encourage you to see the web site. You will be getting a report sometime in the near future with much more detail. We are working right now with CBS. We submitted to CBS an excavation plan at Neal's landfill. I just got their comments and we are looking at it and will be discussing it in the near future. I just wanted to give you a visual feel for this data and where there is hot hits of PCBs. Unknown Man Is this going to be a series of slides of different depths showing where ..... Tom Alcamo I don't know off the top of my head what is at this point. Mike you have all the data that's on your board. Mike Baker Yes. The data for each one of these color charts is the data and sampling. Jim Cartmell These are like a hundred feet apart. Tom Alcamo Yes. Some are 50 some are 100. Jim Cartmell How do you come up with this? Tom Alcamo That is all solid tires. There is nothing there but tires. We did hand monitoring around there. Unknown Man Yes. There were about 4 locations that the depth was shallow. Tom Alcamo But we do still think some additional sampling should be done.The data is right at that point. Jim Cartmell What other sampling are you going to do outside of that? Tom Alcamo We don't know. We proposed that. Outside the limits. I don't remember where. We think there are a few places here. Jim Cartmell How is this outline here produced? Tom Alcamo That is where the boundary of the landfills. That's where they did the fill. It's basically the outline of the landfill. Jim Cartmell What is the procedure they are going to use to identify other places where capacitors ight be? Tom Alcamo There is a number of maps that we think there are areas were capacitors were dumped by ... CBS did this cap John Foster I was there. I would be happy to show you where they were. Tom Alcamo Sure. I don't have a big map with me. John Foster I'll talk to you after the meeting. Tom Alcamo This is just a visual outlook. I encourage you to go back to the raw
data. Tom Alcamo When you get the report you are going to be able to see thickness, cross sections, things of that nature. It's a mess. Those are interpretations. Jim Cartmell On the _______ quotes of Neal's landfill. It said hot spots. Isolated hits of 5ppm or greater are not consider hot spots. What's the difference between an isolated hit and a hot spot? Tom Alcamo Basically if there is a hit out there by itself, we would not consider it a hot spot. It's an aggregation. Jim Cartmell When you got samples that are 100 feet a part. Let's say you have 500 ppm. That's going to be an isolated hit or a hot spot? Tom Alcamo We can make some judgements. And certainly when we distribute the excavation plan you can look at that. Our view that if there is an aggregation of contaminants in an area then we will consider that a hot spot. One isolated hit does not mean it is a hot spot. It's a judgement in terms of if there is an aggregation of contaminants. David Porter When you have a spot that has a high level and another spot 100 feet away that has nothing. How far do you go between one and the other? And if you dig something out, how far laterally are you going to go? Tom Alcamo We probably would make a judgement of half way between the points. David Porter Why not all the way? Because then you would know. Tom Alcamo You have to make some professional judgements. David Porter But it's based on no data. Tom Alcamo Yes it is. David Porter You use sampling when you've done the excavation to make sure you've got it. Tom Alcamo The purpose here is to remove hot spots. Jim Cartmell Step back to the color maps that we just saw. Put up the three. Put up the surface one and put up the ____. Larime What's the diameter of the composites? Tom Alcamo Two inch. Jim Cartmell The ______ _______ is four inches in diameter. Tom Alcamo And we took composites within that. Some of the holes were 5 feet deep. Every 3 feet we did a composite. Jim Cartmell So what is your visual identification of the contaminated zone? What characterizes it? Tom Alcamo You look for anything that can be described as waste. Jim Cartmell Anything other than clay. And the clay can't be contaminated then? Tom Alcamo If it is, you might see where it's floating on top of the clay. They are breaking open the cores too, to look inside the clay. But mostly it's too thick. It doesn't migrate through the clay. So if there is a core and the bottom of it is clay, they will open that and look inside. But it's basically if it's anything it's sitting on top of the clay if it's migrated that far in depth. Larime Let's say like Lemon Lane where there is at least one sample where I recall that they talked about it being mostly oil. Where there was some pure oil, does the oil leak out? Do you lose it? How is the core contained as you pull it up to prevent something that is that liquid from moving around from contaminating elsewhere and/or leaking out and losing it? Tom Alcamo It's enclosed. We use something that's called ______ drilling, which vibrates. We do that because it gives an excellent core. It's in this long core. It's a long like sausage casing that is like 10 feet long. Larime But if you have something that is liquid in the middle of it and how do you know that it's not going to start going up the sides? Tom Alcamo Well, if you saw oil, then there is no way in hell you are going to see low concentration. From my experience from seeing this stuff. We were also looking for capacitor paper. Every three foot section is composited. Jim Cartmell Is the red spot in the upper isolated corner. Is it an isolated spot or a hot spot.? Tom Alcamo I would consider that probably a hot spot. I would have to look at other
data. But we would propose to CBS what it was. I would be concerned about
that. Because nearby it looks like it is flowing into that area. The purpose
here is to remove the most highly contaminated material that we feel is
most problematic. Larime Why don't we start with Karst? Jim Cartmell You guys said that we don't know what is going on in Karst. We can't know. There's nothing that has changed. That's why we can't do an ---------That's why we don't think water treatment isn't enough. David Porter If you are leaving 50% of the material behind, that's pretty half-assed. If you take it all you know you got it all. In between, isn't it. Tom Alcamo As much as you don't like it, we do it as a landfill. We don't dig them up and move them elsewhere. That's what we do. David Porter It's not a landfill. Landfill contains things. Tom Alcamo It is. David Porter A lot of things can be said about the selection of locations. A lot of these locations came from previous history of disposal at the sites. Larime Have you personally reviewed _______ street? Tom Alcamo Yes. The areas that were wet. So they tried to come up with this based on what they thought. And we did some trenches we thought from past reports. Jim Cartmell If you reviewed that history you would know what Mr. Foster here knows. John Foster I just wanted to show you something on your map. I was a project engineer for Rogers Group which actually did the capping there. I said I easily picked up a couple thousand papers outside the fence line. We had the office trailers here. When we moved them out there was visible capacitors laying there. It was in a contaminated area. I always say you can find something if you look for it. You won't if you don't look. Tom Alcamo That's good information. And I'll take that information back to CBS. Jim Cartmell He said that they took everything that they knew from the site. He is just telling you this. Tom Alcamo I can't pick the man's brain. Where is this written up. Jim Cartmell Half the town knows and you guys don't know. John Foster I have walked the whole place with him half a dozen times. But it may be where you have to see it to believe it. Tom Alcamo I certainly will go in there and sample if need be. I will sample it. He's giving me good information. I didn't have it. John Foster For 15 years I have been telling this to EPA. The point that this raises is if you guys didn't know about this outside. And you are claiming to base your sampling locations that exist. And you don't have it right outside there. How can you have it about inside there? Tom Alcamo It's a random chance. I hate to tell you, but it is. It's all a part of making judgement off sampling. I can't sample every piece of dirt. Larime If it's anything like Lemon Lane, which I'm more familiar with. It's not only based on historical use, it's just the opposite. It was built by Westinghouse to miss historical use places. Tom Alcamo I can only say it's a landfill and that's what we do with landfill. And we think getting hot spot out of there is important. We will make judgement off this data. Jim Cartmell He just told you there is something outside. So you don't feel comfortable. David Porter You talk as if you have some insight into how these sites were operated. You haven't interview the people running the Bulldozers, driving the trucks, salvaging the materials. You've looked at a couple of pictures. The pictures maybe only represent a one or two week time period over the entire year. And you are putting way too much faith in this idea that you understand how the sites are operated. You've got to go talk to people. Tom Alcamo But the issue with this, David, is being exposed to PCBs. That is the issue. Protecting people from being exposed. We view it as removing the hot spots, capping it, water treatment, and sediment removal is the way to go. Jim Cartmell Okay, so what is a hot spot? We got 50 capacitors, 100 capacitors? What? Give us a definition. David Porter How many pounds constitute a hot spot? Tom Alcamo I'm giving you a part per million value back. Jim Cartmell Tell us what a hot spot is. Tom Alcamo It's an aggregation of contaminants. Jim Cartmell. How big is the aggregate? Tom Alcamo We use judgement on that. Jim Cartmell So what is your judgement? Tom Alcamo You are looking at me to look it up in Webster's dictionary and say hot spot and Neal's landfill.......... David Porter Well, you are using the term. Surely it has some sort of meaning. Larime If you can't define it how can you clean it up? Tom Alcamo We are. David Porter Is one yard of soil with 10 pounds of PCBs in it a hot spot? Tom Alcamo I think, yes. John Foster Just for your information, this area outlined here is what the government had picked out originally at the original law suit. And that map is made for the stipulation and order. Unfortunately I don't think they did any sampling along here. The white part is where we put the cap. The other areas they claimed that there was enough of a cap on it that we didn't need to add additional clay. Tom Alcamo I have not a problem doing additional sampling if it's justified. You have told me, so there is enough to justify. Jim Cartmell This isn't the first time we have told you. I have personally told you this. Every meeting we have had. We say the same stuff. There is stuff outside the fence at Neal's. There is stuff outside the fence at Bennet's. ________ We've agreed to go in and look at this. Tom said we will sample beyond. Tom Alcamo What do you want? Do you want my blood? You've said the same thing at Bennet's dump. You have been screaming at me the last three meetings. There is stuff outside the fence. I know there is stuff outside the fence. When we put together the proposed plan, and all that. Trust me Jim. Jim Cartmell At Lemon Lane they said there was a 1/1,000 cancer risk. Larime At other meeting you said you needed evidence first. You did not say.... Tom Alcamo There is a report that he has read, that I have read that says at Bennetts dump we stopped at the fence, but there are capacitors outside the fence. And I told you at the last meeting I went to the site and we discussed it. There are a huge amounts of blacks now put on that. And I told some guys we are going to have to move this to sample. I would like to excavate that area out. I told you that at the last meeting. Larime You just said that in a place you are not sure, that there is probably a problem outside of Bennetts. That you would rather just go in and not sample and just pull it out. Why are you telling us that you want to do sampling of hot spots at Neal's and Lemon Lane? Tom Alcamo Based on EPA policy. Guidance of size of site justify a hot spot removal. Larime Which is the most highest exposure at risk for the population? Is it Bennetts or is it Neal's and Lemon Lane? Tom Alcamo I don't know. All of them are a problem. Mike Baker Is the amount of tons and the concentration levels an indication of risk? Tom Alcamo No. Mike Baker Okay. So is the karst geology! In combination with the million pounds and concentration. In other words, Neal's landfill and Lemon Lane both have more problematic karst geology than Bennett's dump. Tom Alcamo Yes, right. Mike Baker They also have the highest concentrations and highest volumes of dumped PCBs in those sites. So why wouldn't Lemon Lane and Neal's landfill be the highest risk to the community? Those two sites. Tom Alcamo I would view probably based on what I see, I view the PCBs being released from Illinois central spring. Which yes, I don't know why there hasn't been something on there years ago. It has probably the worse. Just because of the concentrations. I viewed the water coming from Neal's landfill going down Richland Creek probably the second. I don't view the sites in terms of people going onto the site building a house or digging down and eating PCBs after we have had a cap on it as problematic as water treatment at those facilities. People are being exposed to fish. People are playing in the creeks. People are getting exposed to sediment. To me I view that as a higher priority than going back at Neal's landfill and digging up that site. Why we are doing the principal threat and the source removal is to hopefully help the water treatment. That's why we are doing it. Jim Cartmell Steve Hacker, in 1983, came up to the onsite coordinator and said I want to show you were there is PCBs. And he ignored him. But some of the citizens there thought it was important. You never investigated this area. This is the south side where they hit the fence posts. Steve said they were there before they hit the fence posts. Tom Alcamo What have I told you about that area? I told you that we are going to go in there. Jim Cartmell It's a different area. This is the south side. See this area over here. This area right here is as big as Bennett's quarry. Steve said it was dumped there. Tom Alcamo I have no problem with that. If it's an issue. How about doing some water monitoring. How about figure out where the water is going at these two places. _______ I've been on this committee since it started. And I have heard a lot of discussion. I think the citizens input over all was really not listened to. It was as if citizens information committee meant EPA to the community and to the citizens and not the other way. And I think this is part of the frustration. This is the history, and we are a part of the history. We have a long history and you have a short one. So you are coming from a different set of values and so forth. But the thing I really want to address is when this whole issue started. Granted it was with incineration. We were dealing with getting rid of the PCBs in the community. And this is where it was still thinking. And now we have a new proposal. And I'm not saying it is a bad one or a good one. But it is one that is very difficult to understand. And the main reason I feel this is that we do not have adequate definitions of certain words. I don't understand what hot spot means and I am relying on your expertise to remove hot spots. But I'm uncomfortable with that because I really don't know what you mean by it. I need more concrete definitions. We are going to be living here the rest of our lives. And I want clean water, and I'm sure you do to. But in order to come to some sort of comfort level, we have to know what it really means. What you are doing? I know it's a difficult assignment. But I would like for you to translate. Tom Alcamo It's not a true science. A lot of it involves judgement. What our approach is here is dealing with a large landfill and dealing with a source material that we think is getting out of the landfill and going into the water. Or has the potential to do that. David Porter What goes into your judgement? Tom Alcamo Concentration of PCBs. How we look.... David Porter The wetness. Tom Alcamo Leakage. I can't give you a straight answer. David Porter Could you just in a paragraph say these are some of the things that we think about in defining a hot spot. Tom Alcamo We have listed that. It's on the COPA web page. I can't tell you in regards.....We have not put together a final plan in terms of expectation yet. In terms of what's a hot spot and what's not. I can't tell you any other way. It's an aggregation of contamination that we view that is highly concentrated of PCB material that has a tendency or could have a tendency to leave that landfill. And that's one of the main things. Because we view that cap that people are not going to be exposed to that. John Foster I would like to add something to that. I put the cap on Bennetts and Neal's. I did what EPA told me to do at the time. Plus another foot of material at Neal's. More than they required. They were capped and they are still leaking. The only way you can stop those from leaking is a total clean up. A hot spot will not work. Tom Alcamo It's about water treatment as well. John Foster Of course. David Porter Okay. Let's move to the question of water treatment. To you water treatment is Like that of the after burner on the incinerator. And you are saying that your water treatment is what's going to guarantee that this material is not escaping. Tom Alcamo The problem is between the landfill and where it's coming out. It's already escaped. I have not control over that. David Porter Yes you do. By removing everything that's the source of it. Tom Alcamo That may not be only those small areas that are feeding them. Sally Hegeman Do we have a cost analysis of total removal as opposed to.... Tom Alcamo No. We don't have that. Mike Baker To address Sally's question. For a minimum of ten years all the parties have told this community and sold this community on piles of data that we had to excavate totally these sites. That's what we were told. We were told by EPA for ten years. EPA risk people. Consultants from everybody. The city, the state. Even Westinghouse, the company, and now which is CBS. They told us we had to have excavation because of all the risk. Because of the karst geology. They selected a remedy that was suppose to take care of that. And again, later, because of the community's effects, we were able to show that we were going to create more of a problem. But for ten years this community has been told that we have to do this. But now all of a sudden we are giving some hints of plans that are significantly less than that, and yet there has been no change in the situation. Tom Alcamo You knew back when the incinerator was thrown out that it opened up the whole ball game. You knew that as well as anyone. Mike Baker I know that. David Porter But we didn't know that it changed the basic facts. That you cannot have this sort of material left on top of karst. That didn't change because the incinerator was no longer the solution. Mike Baker Let me finish first. _________ To answer your first question. There was an assumption in the decree that there wouldn't be water treatment in a place like Lemon Lane. And there was an assumption water treatment would stop at Neal's. That was what the foundation for the decision that all the material must come out. Mike Baker And this data has shown that even if it all came out it would not stop that problem. ______ You are right. There may be things coming out for a period of time. But the assumption of the decree was...... David Porter There's another assumption that you are missing. If you have a factory that makes toxins and there is a pipe coming out of it. And you put a water treatment plant at the end of that pipe that can clean up whatever is coming out. That is one thing. But you don't have a human being made pipe from Lemon Lane to Illinois central springs. Remotely. That's not what you are dealing with. And you are pretending that you are. By saying that water treatment is the answer, you are pretending that you have a clue where that water is going. And you don't. Or where that will go in the future. Because it will change. ______ I think what they are saying is that it is a combination of things. David Porter Then you are really going light on the front end. ________ They are looking at removing the source, or part of the source. Capping the source. And then collecting and treating water here. ____ Can I tell you that it is exactly what we did before. They were going to remove the surface capacitors. Put a cap on it. That was suppose to take care of it. Tom Alcamo No it wasn't. That was interim measure. Until the incinerator was built. _______ You have not got mass balanced data on any of these sites that is creditable. ____ And it's almost impossible to because it's karst. Tom Alcamo It's impossible to get a mass balance because you have a very inaccurate amount going in. You don't know the exact amount points. You have an estimate. But you are taking certain records from CBS/Westinghouse and making some estimate off that. You can be 150% off. _______ That's with the PCBs but we are talking the dye. ______ Why can't you take all the source out. At least to the terms of the consent decree. And this water treatment outside of the consent decree. Just go in and order that water treatment which should have already been ordered and been out there. On any source where you can identify that it is coming out. Which is more than Illinois central spring. Mike Baker It doesn't have to be an issue of the consent decree. Or the parameters of the consent decree. I think that's where this community is going to have a hard time accepting. Because basically what it is coming down to is that EPA is coming back and using EPA policy that they say makes these landfills different. And the way they have to be cleaned up then if it were not a landfill. But that same policy wasn't used for ten years when EPA and all the other parties said no we have to take it all out. So now it's being used to justify cost limitations. So at the very least, if the EPA does come back actually with a limited excavation of any of these sites, I would hope the community would see the cost differences of total excavation and disposal compared to limited excavation and leaving and treatment. Tom Alcamo Disposal where? Mike Baker Wherever it makes sense. And if you think Bottom Road is site able, then go for it. Tom Alcamo I don't. It's on the table. You know it's there. Mike Baker if you don't think it's siteable, then go for it. Then where's the next
closest place that's got the capacity - let's say Michigan. What would
the cost be for total excavation for Lemon Lane starting today compared
to the limited excavation that we have planned. And you have to factor
in all contemplated sampling that you would start. If you were going do
another 50 different types of sampling at Lemon Lane and that's going
to cost a million dollars. Forget that million dollars, and subtract that
from the total cost of excavation and disposal. I just would like to see
the difference. We are talking about a very limited excavation of over
a million pounds conservatively at Lemon Lane of PCBs and we will have
no idea of how many PCBs are removed. What is the cost Tom Alcamo How can I make an estimate in terms of the stuff we excavated. How can I make an estimate of - when you are just assuming everything over 50 ppm is gone - okay. You would have to sample numerous times within the area that we've excavated. The material that we are excavating to find a mass balance that we would be disposed of. Mike Baker It is problematic. So what is the cost difference between just total excavation and whatever you think you are contemplating at each site? And then the community can say, oh, we are trading off a known clean up level for an unknown clean up level for X millions of dollars. I think that is something that people could relate to. The community has been told something for so long that they are going to have a hard time accepting anything less than that. Unless there can be some real strong reasonable data and explanations of what's going to happen and why. It is a cost issue. ______ I don't know very much about the cost of these things. To me, that down the line costs could be worse then just taking care of the thing at the front end. And then you would start having to go back because you are still getting PCBs. And you would have to open up the thing and take many more samples. And you would have to keep the water treatment plant going. It would be real nice to see a comparison of doing it with a hot spot method as opposed to front end clean up. Of course you have monitoring costs too. Mike Baker Do we have a ball park estimate, for example, at Lemon Lane, of what CBS is looking at with the limited excavation. Tom Alcamo It's all really ______ on - you can figure a hundred dollars a ton to be disposed over Michigan. Mike Baker That's for disposal. What's excavation cost? Tom Alcamo I don't know. Probably $15-$30 a ton. Somewhere in that range. I don't have the data here. But we looked at that for the judge. It was a long time ago. Jim Cartmell In 1985 when they did a RAFS at Neal's landfill. And they came up with some cost figures. And it was going to cost forty seven million and eight hundred thousand dollars to excavate Neal's. Not incinerate it. But to ship it away. And it included water treatment. Here's what they say: Removal of all PCB contaminated waste. Other alternative, permanent cover and other source control measures. Source control is infeasible due to subsurface conditions. They didn't suddenly become feasible. The other thing that there is all of this talk about sampling. The PCB spill clean up policy provides that you do sampling that can determine an area of contamination of 2 feet in diameter. Tom Alcamo A _____ landfill. You are talking about apples and oranges. Jim Cartmell No I'm not. Let me finish. Like Fells and the Westinghouse facility. They were both ordered to be cleaned up pursuant to the sampling provisions. Tom Alcamo You are talking about a landfill. No your not. You are talking about a bunch of stuff piled on top of karst terrain. PCB is PCBs. Tom Alcamo Land disposed. _______ Does it have landfill liners. Tom Alcamo Of course not. ____ Then it's not a landfill. ________ That is how EPA looks at a landfill. Other areas we may not have karst terrian. I just finished working with a site in Ohio where the bottom of the site was basically opened into a deep coal mine that went for miles and miles. And again we look at the risk and where the spread is and we develop a solution and contingency plans for 5 years and 10 years. In case our first time with a solution, which was with a cap, didn't work. Then we went to grouting and other things that were designed for that site. Just because you have karst doesn't mean it isn't a landfill. ________ Define a landfill please. Tom Alcamo An area that is land disposed. ______ If I take a truck out and dump a load of stuff in the middle of a field, that is land disposed. What's the difference? Tom Alcamo It's not considered. Because it's too small. ________ A dump is small and a landfill is large? Tom Alcamo Usually. And we cap dumps too. ______ So you are telling me you deal with big problems less satisfactory than you deal with small. Jim Cartmell The point I was trying to make, the PCB spill plan policy says that we want to know about an area of PCBs that is 2 feet in diameter. And that it's important to get that out of here. Tom Alcamo What was the intent for the policy? Jim Cartmell It was ordered by the EPA to be used at Fells and Westinghouse _____ What was the concentration that we decided on? Because I made the decision of clean up level at Fell. The grid sampling sizes were not determined on the basis of tasca. But rather based on the size of the site and the extent of the contamination. Because it pre dates the tasca spill policy it's not relevant in terms of setting up your sampling... Jim Cartmell You guys ordered it to be cleaned up. I didn't order it. Because quote "it established criteria for determining the adequacy of PCB spills and releases". That's why it was ordered to be used. Fells and Westinghouse are the only two sites that have supposedly been cleaned up so far. Tom Alcamo What about Winston Thomas? Jim Cartmell You are not done there yet. But you also clean that of 15 ppm. ______ Lemon Lane is still a residential area. Tom Alcamo It's capped. It's fenced. _______ Last meeting Al said in Neal's and Putnam County is getting a 10 ppm clean up because it is a residential area. And it's no more residential than Lemon Lane is. And I asked you what is the difference and you said size and cost. Jim Cartmell This is where they found the water to come out. In the 1989 study. It comes out in 10 different places. The first pulse came out in 1 1/2 hours at Urban Springs. It takes hours to come out here at ICC Springs. And that's the low flow. _________ They have already done an examination there all around the landfill. They are going to be drilling down the areas to look for where the water is. ______ Yes, but the hot spot clean up was designed and laid out long before they did that. It's a fiction and a fantasy. ______ I'm just talking about where the water is moving. Jim Cartmell Here's the map they supplied. If you read the case study, this is the only one that ended up investigated. ________ That's not true Jim. They did quarterly sampling at all those springs for over a year. And they found water coming out at slaughter house on occasion that has PCBs. They had some questions about Stoney East and Stoney West. And it may have had to do more with Neal's trailer court sink hole filling then actually... And they did find it in Quarry Springs. As I understand that data, and I did see it, and the primary PCB water concentration - and I recommended that they do tissues in all the spring areas and they wouldn't. - Because I think the critters would probably have given them better data. But the bottom line was that there was still a little bit of water coming out at the slaughter house and the quarry spring series. And then that changed when they built those condo up there. They went back from where the tracers were found. The bottom line is that the sampling didn't really pan out in three of the four quarters. ________ But Dan, were they storm events samples? ______ It depends. I'm not saying it was great, but that is the data that exist. _____ But they are saying that it needs to be investigated. The request is proper monitoring during storm events. _______ In 1990 they did _____ during the storm event. But they waited until it was over to sample for PCBs. That's what it says. _______ The thing is, you are using very low detection limits. Just like your graph here, you have detection limits .02 as being some of the lowest and .01. We know at Lemon Lane even under low flow conditions we've got 5 or 10 ppm. So even if it was low flow sampling there on the tracers studies. Given the fact the detection limits are a couple of orders of magnitude below that, even that at low flow if it was a significant problem, that would have been observed. I think that I would like to try to do, and it is quite clear that you want more PCBs removed and more water treatment, and that is what we are working on. And we are willing to do additional sampling. But we don't want to get so scattered off on all these issues that we don't focus in and maybe helping you with your main objective, which is like we want to get out a lot of material of Neal's. We want to do as much water treatment as we can both at Lemon Lane and Neal's. That is your message and that is what we can take back. _____ That is not the message that you are telling us tonight. That is the message that we are giving. That is not what we are hearing with this whole line up on the wall. ______ I'm just saying, what we are hearing, we aren't that far off. Jim Cartmell He's saying there is some quarterly sampling that shows something. Okay, you provide that to us, like you are suppose to, that you have never done. Tom Alcamo I'm trying. I'm giving it to you. Jim Cartmell There's a thing called the administrative records file, that is compiled as you go along. Tom Alcamo I just got some of this stuff. I'll give it to you. Jim Cartmell Let's talk about the quarterly sampling. Look at some of the sampling done. Here's 100 ppb. Okay, the next quarterly sampling event is .52. The next one is 4. The next one is 1. No, the point I'm making is ...... Some are on the site some are not. ______ Tom, you were at these meeting. We went over and over that Illinois Central Springs was not a source of release. For 10 years we listen to EPA and the state say that there wasn't a trace of PCBs coming out of it. Tom Alcamo If that is the case, it's a tragedy. I look at Illinois Central Springs, I showed you the recent storm water events. I don't understand why something wasn't on there from a long time ago. I believe what you are saying. _______ But suppose it's the case for these other springs that are connected to the system. Tom Alcamo But we'll see it. I haven't studied the reports. But I can tell you that a number of areas have been sampled. ________ But they haven't been sampled in the ways that will reveal the information that you are looking for. They were sampled at low flows to get rid of them as a source of concern. Tom Alcamo I need data. I need to look back at that. If they have not done high flow. And we proposed with this drilling that they should do additional monitoring studies. We have talked to them about this. I don't know the data. ______ There is one thing that Diane wanted to ask Dr. Clark. Diane Henshel Have you done risk assessment? And have you given us the end points of what your ______ is going to be and what you are going to do? Dr. Clark Because last time I said we were going to do a risk based approach for the issue of water and fish. I've got to remember. No, I have not done it. But tell me again what you asked for. Diane Henshel We haven't seen a proper risk assessment. Human health or ______ for any of these sites that would give us some idea of what you are going to be basing your cut off levels on. What the 50 ppm is going to do. What the 500 ppm is going to do. What is your prediction going to be. And what are the end points you are basing it on. And what is the hazard index you are going to be using it for? Dr. Clark I thought your question was more in the area of water and fish and what we wanted to treat it to. That is the major area we are looking at now. How much do we have to do on that water in order to meet the water quality criteria or remove the fish advisory. What it appears to us is that we have to get the mass loadings down from the water from Lemon Lane by roughly a factor of 50 to achieve that goal. And that's a goal that is based upon a .05 ppm bases in the fish. Lifting the fish advisories. And depending upon rates of intakes, that's between a lifetime cancer risk of 1 and 10,000 and 1 and 100,000. It's a state standard. Based upon a neurological in point. And the PCB value of assessable level. That is our goal. Tom Alcamo Certainly we will be doing a monitoring program. After this remedy is done. Which will include fish sampling and additional sediment sampling. Dr. Clark We were wanting to know when part of the ecological write up would be made available to EPA. ________ It's Commission of Wildlife Services report, and it's not done. Dr. Clark I understand that Indiana University is very much involved with this, but slightly behind schedule. But we are looking forward to that.
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