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Citizens Information Committee
Minutes of Public Meeting
September 2, 1997
Bloomington, Indiana
Attendees:
Dan Hopkins - EPA
Derrick Kimbrough - EPA
Michael List - Chair
Lou Schwitzer - COPA
David Porter
Diane Henshal
Resa Ramsey IDEM
George Hegeman
Laramie Wilson
Deb Backus
Bob Aten
Bob West
Corrections of Minutes
Dan Hopkins
RCRA Meeting - The Consent Decree resolved RCRA issues, and when
we revise the Consent Decree we must make a covenant that all the complaints
are resolved under RCRA with this amendment.
Emergency conditions
Can you act at a site if there is an emergency at one of the sites? My response
was not that that it would upset the balance of rights amongst the parties.
If there is an emergency, we will act.
David Porter
At the big storm event (1993), how many pounds of PCBs were released?
Dan Hopkins
Six pounds
David Porter
Don't you think that six pounds of PCBs warrants an emergency action?
Dan Hopkins
Not by itself. It is a lot and causes me concern.
The PCBs that come out are dispersed, and can not be considered an emergency.
I agree that Lemon Lane is a significant problem, but what would we do about
it?
David Porter
Take action.
Dan Hopkins
I don't think we can take an emergency action here, we need to consider
the longterm solution. We decided to approach the cleanup with the idea
of expediting two sites, both a small site (Winston-Thomas) and a large
site (Lemon Lane).
Lou Schwitzer
I think that many citizens are concerned that the cleanup goals set for
Winston-Thomas will be carried over to the cleanup at Lemon Lane.
Why did it take so long to fence the spring, it seemed to take years?
Dan Hopkins
I think it was weeks, well, perhaps a few months.
Michael List
We had some communications problems regarding our guests from Earth Tech
who are here to give an overview of alternatives at the Winston-Thomas site.
Dan Hopkins
I'll supply some background. For the remainder of the work that is going
to be done at Winston-Thomas in 1998, we are going to do an Engineering
Evaluation/Cost Analysis. We are starting this now, and I wanted the CIC
to know about it before it was done. We have taken data at the site, and
we are going to take more data at the site. We have performed a Health Based
Risk Cleanup Goal Evaluation, which we hope the parties will come to closure
on soon. We have some data and a risk assessment that has already been done,
and we would like to make use of that in the ECA. It will also evaluate
alternative remedies based on factors that make sense.
I have copies of the Federal Register that identify the National Contingency
Plan under CERCLA (Superfund). They are our regulations for implementation
of Superfund. There are 3 levels of criteria that we must consider.
(In order of importance, but weighted equally within each category)
1. Threshold Criteria
Protection of Human Health and the Environment
Compliance with other State and Federal Rules
2. Primary Balancing Criteria
Long term effective and permanence
Reduction of Toxicity, Mobility, or Volume through treatment
Short Term Effectiveness
Implementability
Cost
3. Modifying Criteria
State Acceptance
Community Acceptance
Diane Henshal
Is there a standard approach to this, these criteria seem rather loose.
Dan Hopkins
Well EPA usually uses cancer risk as a tool. Between 10 to the minus 4 and
ten to the minus 6 cancer risk is used. I expect we will use somewhere between
10 to the minus 6 and 10 to the minus 5.
Diane Henshal
What about non-cancer effects, do you factor in that non-cancer effects
are more of a concern with PCBs?
Dan Hopkins
That is a concern. I don't know if it has been quantified in those terms.
It is something that would come out in a Health Assessment.
What human endpoints are you using to identify risk for the health based
cleanup goals.
Dan Hopkins
As I said last meeting, I don't know, I will have to bring my risk assessor
here.
Diane Henshal
How much are you considering future risk as well, considering that PCBs
are highly stable, they bioaccumulate, and pose long term risk? This goes
back to Dave's point that with 6 pounds being released in one event, perhaps
less with less severe storms, but still, large amounts of PCBs are regularly
released. This ongoing release, combined with the longevity and bioaccumulatative
properties of make this a real and present concern, more so than Winston-Thomas.
To say that there is no number that releases have reached to trigger action
misses the point that the ongoing releases are just as bad if not worse
than any single event.
Dan Hopkins
The amendment to the ROD that we will do before beginning work at Lemon
Lane will follow the same criteria as we have for Winston-Thomas.
The creek is the receptor here. Portions of the creek have been cleaned
up, but I don't think it is part of any plans now to do any downstream cleanup.
Lou Schwitzer
Does this mean that Westinghouse is not responsible for contamination downstream?
Dan Hopkins
I didn't say that. At the moment what we have as a commitment from Westinghouse
to clean up the sites, the creek is not mentioned in the Consent Decree.
Lou Schwitzer
There are level 5 warnings not to eat fish all the way down to Bedford,
and the PCBs are working their way into the ecosystem all through that area.
I don't think this problem should be ignored anymore.
Concerning the ROD, are we going to handle it like the last time when the
public was not involved until it was signed and delivered?
Dan Hopkins
No
Earth Tech - WINSTON-THOMAS
Dan introduces Bob Aten and Bob West of Earth Tech.
They present a summary of alternatives considered for Winston-Thomas.
Bob West
We have just begun the ECA, and we are looking at 4 areas:
Trickling Filter
Tertiary Lagoon
Abandoned Lagoons
Interim Storage Facility
We developed our list of alternatives by looking at PRC study that was done
for IDEM, and then searching for other sites that have similar contamination.
We are searching for options are viable, proven, and applicable.
Preliminary List (similar that supplied by MVA for COPA, handed out at the
beginning of the meeting.)
Bob Aten
1. Hauling to a TOSCA landfill.
2. Treat and encase in place
3. High Temperature Thermal Destruction
4. Stabilization and fixation
5. Base catalyzed decomposition
6. Anaerobic biological reduction for lower level areas
- Biological reduction is quite effective, but takes time
7. High Pressure Washing - Trickling filters - water used will be treated
with
carbon filtration
We will analyze the technologies, and then we will create a combination
of technologies that will be applied so that each technology is matched
to an appropriate portion of the site.
If we use high temperature thermal destruction or base catalyzation we will
have waste that is no longer TSCA controlled and can look at putting it
in special waste facility.
We will consider building a Subtitle D type landfill on the site, and seeing
what that would do on a cost basis.
The next scenario would be to treat or ship the TSCA material, and then
the lower level could be left in place, or used for fill in other areas.
We would then put down an impermeable layer and cover it. We could use the
trickling filter media as roadbed over the cap.
George Hegeman
So it seems that the price to beat is the $125 per cubic yard charged for
a TSCA landfill.
Dan Hopkins
It is not always the lowest price that is the determining factor, we have
to follow the Superfund guidance that I outlined earlier. We are trying
to get the most benefit from the cost.
We are working with the technologies that are viable and demonstrable now.
We are working with the data we have. We need more data to do a full evaluation,
and so some our work will have caveats the will depend on future data collection.
Laramie Wilson
What are your plans for public comment? Will you have a public forum to
take comment?
Dan Hopkins
There will be public comment period on the ECA.
When the ECA is prepared, there will be a proposed alternative.
Laramie Wilson
Will there be a public forum to take input?
Dan Hopkins
No, not formally.
Laramie Wilson
I understand that vaulting is not to be considered.
I would like to see vaulting on site considered as an option. It should
be evaluated by the same criteria as the other options.
It seems that you are dismissing the idea without even considering it.
Dan Hopkins
I'll make a distinction here. It is possible that we could have material
left on the site in a vaulted fashion. That is what landfills are. But I
don't think that is what you are talking about, you mean to store it until
a better technology comes along. This, however, is not deciding on a remedy.
With the ECA we want to decide on a remedy. If the material were vaulted,
who in the future would pay for the remedy?
What we are looking for is a permanent solution.
David Porter
A TSCA landfill is basically a vault.
Laramie Wilson
The IDEM study states that landfilling reduces neither toxicity nor mobility.
Dan Hopkins
I think what is meant here by mobility is the ability to be chemically altered.
George Hegeman
Isn't the problem here one of definition? Doesn't vaulting mean temporary
storage on site?
David Porter
Couldn't it also mean vitrification and storage on site?
Vitrified blocks could be stack and sealed for indefinite storage.
Laramie Wilson
My objection is that it is dismissed out of hand, without being tested by
the same criteria as the alternatives allowed in the ECA.
Dan Hopkins
The problem is that it is indefinite, and you can not do a proper evaluation
of something that is indefinite. You can not match a set of criteria of
a supposedly permanent solution with one that is not permanent. You've got
no basis on which to judge cost.
Laramie Wilson
TSCA landfills are not permanent.
Lou Schwitzer
Dan you have told us that every landfill leaks. Unless the materials are
somehow destroyed, they will leak out of the landfill, even in Utah.
Dan Hopkins
There is that possibility.
Laramie Wilson
Let your technical experts handle evaluating it, don't dismiss it out of
hand.
Dan Hopkins
I will take it back to the office and we will talk it over.
George Hegeman
Isn't the term vaulting meant to mean temporary storage, where a landfill
is meant to be permanent?
Laramie Wilson
Not necessarily. If a viable alternative is not found, then the storage
is permanent.
Diane Henshal
TSCA Landfills have an expected life of 30 to 60 years.
Michael List
Perhaps the Bobs could give us an idea of how much it would cost to landfill
versus to vault.
Dan Hopkins
The problem is that if it is vaulted, Westinghouse would not be liable to
do the remediation that is selected.
Laramie Wilson
If it is sent to a TSCA Landfill, then Westinghouse has no more liablity.
Dan Hopkins
They are indemnified at a certain level, but after that they are still on
the hook, cradle to grave.
Laramie Wilson
Have you looked at the Eco-Logic? They have been used in Michigan at mixed
waste site similar to Lemon Lane. They have offered to come to Bloomington
and don a demonstration.
Dan Hopkins
We will take it back and look it over.
Lou Schwitzer
I think we need a public meeting before the ECA is completed.
Dan Hopkins
This is not required, and so I am offering anyone who wants to contact me
with their ideas. Normally we would have the meeting after the ECA is competed,
and we will have that meeting. But perhaps we need another meeting before
that.
Bob West
We should have this meeting fairly soon, two or three weeks. We would need
background on any technologies you offer, how they are being applied right
now, the context they are in.
Lou Schwitzer
Will you consider technologies used in other Regions that are not currently
approved by Region V?
Dan Hopkins
Yes, whatever you have, bring it to the table.
Dan Hopkins
The amendment to the Consent Decree that was sign Aug 18, 1997, is for the
digesters, drying beds and piping. The rest of the site is not included
in the amendment. The ECA will be done, but then the Parties need to agree
on it, which may be difficult. It may be useful for the Parties to evaluate
the different alternatives. Just because we put something in the ECA does
not mean that the Parties will agree with it.
George Hegeman
Hasn't the sticking point been the cleanup level and the sampling
measurement?
Dan Hopkins
It still is. But you can be sure that the remedy will be a problem too.
Lou Schwitzer
If all the parties but Westinghouse agree on remedy, will you force
Westinghouse to accept it?
Dan Hopkins
We are trying to reach consensus if possible.
Lou Schwitzer
Doesn't EPA have ultimate authority here? Couldn't it invoke a remedy whether
or not it was to Westinghouse's liking or not, just as long as it met the
CERCLA guidelines?
Dan Hopkins
We are working with the conviction that the parties can work out reasonable
plans. If we get to a point where we feel that the agreed plans are not
adequate, we will step in.
David Porter
Have you looked for other sites where sludge had been spread? A lot was
distributed for agricultural use. Have you assured yourself that there are
not other sites where large amounts have been spread.
The West Side of Clear Creek is not the only site that needs remediation.
Laramie Wilson
ATSDR says that sludge was hauled to 1000-3000 sites.
Dan Hopkins
I don't know what the basis of that is. The Search Committee reported finding
182 sites.
We looked at 13 sites that were reported, but did not find any significant
amounts.
David Porter
Are there other sites that need cleanup?
Dan Hopkins
I don't know where to look for additional sites, but I do know where they
are now, and we want to focus on cleaning them up.
Michael List
I'd like to get back to the issue of having another meeting for the public
where Earth Tech can talk about alternatives remedies at Winston-Thomas.
Under whose auspices would this meeting be scheduled, CIC or EPA? Who books
the room, does publicity, etc.?
Dan Hopkins
The EPA will set up the meeting and do publicity for it.
David Porter
I would still like to see vaulting considered as an option for the ECA.
Vaulting, or virtrification and encapsulation, are more permanent than sending
to a TSCA landfill with a life of only 30 years. Why can they not be considered
a permanent solution on par with a landfill?
Winston-Thomas
Dan Hopkins
Work is beginning at both Winston-Thomas and the West Side of Clear Creek.
Laramie Wilson
Is the contaminated vegetation being hauled out? Is it being burned?
Dan Hopkins
No, it won't be burned. We are considered hauling the vegetation in the
sludge beds to a TSCA landfill, but I don't know about the WSCC, we have
a onsite project manager for that job. I will check with him to find out.
I have received a detailed work plan for the drying beds, it was seen and
commented on by the parties, and subsequently revised. All that is left
is the approvals.
The TSCA material will not be shipped by rail as previously reported. It
will be hauled by truck to the Environmental Quality Co. landfill in Belleville,
Michigan. Some non-TSCA material (less than 25ppm) will be hauled to Southside
Landfill in Marion County, a special waste landfill.
Lou Schwitzer
What precautions are taken with these trucks?
Resa Ramsey
The trucks are lined and covered.
Dan Hopkins
The Parties are trying to come to agreement on the remainder of the site,
but we may be at a stalemate. If we can resolve the issues of the cleanup
levels for the tertiary lagoon and the abandoned lagoon, I think we will
be able to come to agreement on the rest of the site.
David Porter
What kind of monitoring is being done during the work?
Dan Hopkins
High volume air monitoring. Polyurethane plugs are used to collect both
particulates and volitilized PCBs.
Lemon Lane - Risk Assessment
Dan Hopkins
This can be a long process, and has several steps:
We have to do all the requisite sampling for the risk assessment.
The Parties need to come to closure on the parameters of the assessment.
The Assessment will be done.
Adjustments are done to the Assessment.
Fish Sampling - Dioxin
On Aug 19, 1997, EPA and Fish & Wildlife electro-shocked two portions
of Clear Creek. One spot was just south Winston-Thomas, and the other was
at the Gore Rd. bridge near the reservoir. We got some large fish, and we
will composite them. We took large mouth bass, suckers, and long-eared sunfish.
We will sample for dioxin, furans, and if possible, PCBS. They will be available
in mid-October.
They will have to shock more fish for PCB analysis.
The ecological sampling done last fall has undergone a Quality Assurance/Quality
Control assessment. There should not be a need for further sampling, except
for the filets.
Perimeter Sampling
We will send out the plans tomorrow, and we will be doing the sampling this
fall, and hope to have it and the fish filet sampling done by November.
Laramie Wilson
Will you do dioxin sampling for the assessment?
Dan Hopkins
No, I was planning on doing this during excavation of the site.
Diane Henshal
We could do some cheap air monitoring around Illinois Springs. We are getting
some volitilization. I think we could allay some fears if we knew how much
volitilization was happening.
Laramie Wilson
There is new housing and a trailer court right next to the ICC Springs.
We should do air monitoring in this area.
George Hegeman
It would be good to have a baseline reading before the work is begun at
Lemon Lane.
Next Meeting
Tuesday, October 7, 1997, 7:00 pm, Showers Complex |
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