flr500031 - semspub.epa.gov · 1 ms. barnett: could everyone take 2 a seat, i'd like to get...
TRANSCRIPT
U.S. ENVIRONMENTAL PROTECTION AGENCY
In Re: Proposed Plan Meeting for EasternDiversified Metals Superfund SiteOperable Units 1 and 2
PUBLIC MEETING
Held at the Hometown Fire Company,
Route 54 West, Hometown, Pennsylvania, on Tuesday,
February 19, 1991, commencing at 7:30 p.m., before
Mary E. Porter, Registered Professional Reporter.
BEFORE:
AMY BARNETT, CommunityRelations Coordinator
CHRISTINE CHULIK, RemedialProject Manager
PAT ANDERSON, Chief, South-EasternPennsylvania Remedial Section
ROY SMITH, Toxicologist
* * *SLIFER, VOICE & SHADE
1228 Walnut StreetAllentown, Pennsylvania 18102
(215) 434-8588
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1 MS. BARNETT: Could everyone take
2 a seat, I'd like to get started? All right. Good
3 evening. Thanks for coming out on such a terrible
4 night. I know it was probably hard to get here. My
5 name is Amy Barnett, and I'm the community relations
6 coordinator for the Environmental Protection Agency
7 and I'm the community relations coordinator for the
8 Eastern Diversified Superfund which is what we're
9 here to talk about, and specifically what we're here
10 tonight to talk about is the proposed cleanup
11 methods for the Eastern Diversified Superfund site.
12 If you did not get a copy of the
13 proposed plan document, which is what we were
14 handing out in the back, if you raise your hand now
15 I'll have somebody bring one to you. Tonight we
16 have — in addition to myself, we have here on my
17 left Christine Chulik who is the remedial project
18 manager for the Eastern Diversified Metals project
19 site. We also have Roy Smith who is the
20 toxicologist for the site.
21 In addition, we have Pat Anderson
22 here in the audience who is the chief of the
23 Southeastern Pennsylvania Remedial Section at the
24 Environmental Protection Agency. And we also have
25 Tom Ziemba, who is the remedial project manager for
' • •• - AR500032
1 the site. And in addition we also have various
2 community officials and we also have Senatorial and
3 Congressional representatives in the audience
4 tonight.
5 Our agenda tonight is fairly
6 simple. I'm going to start out, after I give a
7 brief introduction, talking about the Superfund Law
8 and the Superfund process just so you have a basis
9 for what we're going to tell you tonight. And then
10 Christine Chulik is going to give a technical
11 presentation about the various cleanup alternatives
12 and then about the preferred alternative that we
13 have identified. Following that we are going to
14 have a question and answer session during which Pat
15 Anderson, myself, Christine or Roy Smith will answer
16 questions or take comments. If you just have a
17 comment and don't have a question, that's fine, too.
18 One thing that's important to know
19 is that we're going to be here as long as you all
20 have questions. We don't have a specific time we
21 have to be home or anything like that. So as long
22 as anybody has something to say we're still going to
23 be here. However, we do ask that one thing is that
24 you hold questions until the person presenting is
25 finished with their presentation, and there are a
ftR500033
1 couple of reasons for that.
2 Number one, we want to make sure
3 that we get out all the information and that we
4 don't get sidetracked by some of the things that we
5 may be asked. And the other thing is that if you
6 have a question in the middle of the presentation it
7 may be answered by the end anyway. We also want you
8 to know that no question is too silly. Anything you
9 feel like asking is fine because chances are that if
10 you're wondering about something there's five other
11 people in the audience wondering the same thing.
12 We will do our best to answer the
13 questions that you have tonight. We're going to try
14 very hard to do that, but if people come up with
15 very technical questions it may take a little bit of
16 research back at the office to answer them, so we
17 will be sure to coordinate that with you and contact
18 you by letter or telephone, whichever you prefer, if
19 you have something we can't answer tonight.
20 Any questions and comments that
21 you have will be addressed in something called the
22 responsiveness summary. The responsiveness summary
23 is something that is attached to the decision
24 document. In other words, we go over all the
25 questions and comments we receive and answer them
AR5Q0031*
1
1 there.
2 Right now we are in the middle of
3 something that's called the comment period. In
4 other words, we have put out our proposed plan
5 document which talks about the cleanup alternatives
6 and about the alternatives that we have identified,
7 and then we have 30 days in which the public can
8 look it over and comment on it and ask questions
9 about it, and that comment period runs from the 5th
10 of February of this month until the 6th of March.
11 So if you have any comments that you would like to
12 make tonight, that's fine. If you have any comments
13 that you want to send in, we ask that you postmark
14 them on or before March 6th.
15 Here on my right we have somebody
16 who is recording everything that we say so we can
17 make sure to go back and make sure we've addressed
18 everything, and what this means, also, is that when
19 you stand to speak or ask a question, please state
20 your name and if it is sort of a difficult name --
21 in other words, if it's Smith you don't have to
22 spell it, but if it's something else, then please
23 spell it so she can make sure to get it right in the
24 transcript then.
25 If you would like to see
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1 additional information about the Eastern Diversified
2 Metals site, we do have a place where we put
3 technical information about the site, and that's at
4 the Rush Township Municipal Building. Ms. Carol
5 Opet, who is in the audience somewhere, is the
6 contact for that. If you have any questions and you
7 want to see that, please call Carol, she can arrange
8 to let you look at that information. I don't have
9 the phone number on me, but Miss Opet is sitting in
10 the back row.
11 MS. OPET: 668-2938.
12 MS. BARNETT: Also at the Rush
13 Township Municipal Building we have what is called
14 an administrative record. Probably the easiest way
15 to recognize it is that it's in big black binders
16 and it says administrative record on the side, and
17 what those binders hold is all the documents that we
18 use to make any cleanup decision on the Eastern
19 Diversified site. So that's important if you want
20 to see- what we base our decision on, then you can
21 look in there.
22 As I said, my name is Amy Barnett.
23 I'm community relations coordinator for the site. I
24 have cards in the back if anybody needs to contact
25 me. My phone number is on there. If any questions
AR50QQ36
1 pop up after the meeting, please feel free to call
2 me, I'd be happy to call anybody back so that we can
3 save a toll call.
4 We also have a couple of sign-up
5 sheets in the back. We use that to update our
6 mailing list so you can get information about the
7 site. If you don't want to sign your name, you can
8 just put your initials down there so we can tell how
9 many people we had here tonight. That would help us
10 out a lot.
11 Also, attached to the proposed
12 remedial action plan is a sheet that just asks a few
13 questions. If you could just take a few minutes to
14 fill that out before you go home tonight, it would
15 help us out a lot in making documents such as these
16 more useful and understandable. So we would really
17 appreciate that if you would take a few minutes and
18 do that.
19 Okay. At this point I'm just
20 going to give a little bit of information about the
21 Superfund process and the Superfund Law. Superfund
22 is pretty much an informal name for something that's
23 called the Comprehensive Environmental Response
24 Compensation and Liability Act. It's pretty easy to
25 see why we give it a shorter name. That law was
HRSOQ037
1 enacted in 1980, and what it enabled the
2 Environmental Protection Agency to do was respond to
3 the releases or threatened releases of hazardous
4 materials. And it also authorizes us to enforce
5 action; in other words, make parties that may be
6 responsible for the toxic waste problem clean those
7 things up.
8 Now, in 1986, October 17th of
9 1986, we have the. Superfund Amendments and
10 Reauthorization Act, and what that did was it
11 reauthorized the Superfund Act for five years. And,
12 also, it's important to note that when the budget
13 went through we also got reauthorized for a number
14 of years then, so we stretched past 1991 now.
15 But anyway, the most important
16 things about SARA, which is what we call the
17 Superfund Amendments and Reauthorization Act, is
18 that it increased the fund, the Superfund, in the
19 amount of money that we can use to respond to
20 hazardous waste emergencies from $1.6 billion to
21 $8.5 billion, so that was quite a jump. It also
22 strengthened and expanded our cleanup program, and
23 it also provided for community emergency
24 preparedness.
25 In other words, you know, what
4
5R500Q38
1 would happen in the community if there was a
2 hazardous waste emergency? It would enable
3 communities to better prepare for that, and it also
4 has a provision for community right-to-know. In
5 other words, it made it easier for citizens to know
6 what the industries from their area were using, what
7 sort of chemicals they were using.
8 Under the Superfund Law we have
9 something called the National Contingency Plan, and
10 what that does, it pretty much tells, you know, who
11 are we going to use to do this stuff and how are we
12 going to do it. In other words, it provides the
13 guidelines for the planning and conducting our
14 responses to hazardous waste problems.
15 It talks about the players, people
16 who are going to do that, and it also talks about
17 what steps we are supposed to use when responding to
18 those. Very briefly, the players are the
19 Environmental Protection Agency and other federal
20 agencies, the State -- various states across the
21 U.S., the communities and their representatives, the
22 people who may have been responsible -- the parties
23 who may have been responsible for the hazardous
24 waste problems, we call them potentially responsible
25 parties, and then the contractors and the
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10
1 consultants who help us respond to hazardous waste
2 problems.
3 Now, the Superfund, which is that
4 $8.5 billion that we're talking about, is made up of
5 a variety of taxes. Number one, it's an
6 environmental tax. The fund gets money from the
7 environmental tax, it also gets money from the
8 feed-stock tax, from the petroleum tax, some general
9 revenues, and also any cost recovery that we get.
10 In other words, money that potentially responsible
11 parties pay to us in reparation for what we have
12 done with toxic waste product. So a lot of people
13 think that it is a pretty direct tax, in other
14 words, that the money comes directly out of income
15 tax, and that's not really true, it really comes
16 mostly from the petro-chemical industry.
17 So at this point I would just like
18 to go over a few of the items in the Superfund
19 process. Okay. Starting right up here we have
20 what's called discovery, and this is -- this is a
21 good way to look at it, that the Eastern Diversified
22 Metals site has gone or will go through all of these
23 steps. site discovery can occur in a number of
24 ways, it can be anything from somebody calls on the
25 telephone and says, you know, somebody has been
11
1 . dumping barrels in the field next to my house, or it
2 could be that the State calls and says, well, we're
3 having a chronic problem with this firm here, we
4 think that they may have some toxic waste products.
5 In other words, site discovery is
6 where we run a few investigations and studies, that
7 are fairly limited in scope, which try to tell us
8 whether we actually have a problem in this area or
9 at a particular place. If there is a sufficient
10 problem, then we try to rank it on the national
11 priorities list. The national priorities list is
12 EPA's list of top priority abandoned or uncontrolled
13 hazardous waste sites in the U.S.
14 Following the national priorities
15 list ranking we have what's called a remedial
16 investigation and a feasibility study. A remedial
17 investigation is an investigation which determines
18 the extent and the nature of the contamination. in
19 other words, how far has it gone and what exactly is
20 there. That's what we try to find out with the
21 remedial investigation.
22 Following the remedial
23 investigation, or sometimes concurrently with the
24 remedial investigation, the feasibility study takes
25 that information and tries to find out, you know,
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12
1 what are the possible cleanup methods that we could
2 use at this site, what looks like it's going to deal
3 with the products there in the best way possible.
4 And that's really where we are tonight, we're at the
5 conclusion of the . remedial investigation and the
6 feasibility study.
7 We've put out the proposed plan,
8 which summarizes the possible cleanup options and
9 which talks about the alternative that we've
10 identified that we think is the best. And now we
11 take it to you all and try to find out what you
12 think about it. After the proposed plan we have
13 what's called the record of decision. The record of
14 decision really just chooses a cleanup method and
15 finalizes the process there.
16 Following that we have remedial
17 design, remedial action. Remedial design really
18 means just designing a remedy, planning how we're
19 going to do it. Remedial action means putting that
20 remedy into action, actually constructing it, and
21 then that's followed by operation and maintenance,
22 just keeping that remedy running, keeping it up so
23 that it continues to work.
24 And the final thing to emphasize
25 is that Congress mandated to us that we have an
HR5000H2
13
1 enforcement policy. In other words, our preference,
2 as Congress told us that it must be, is to try to
3 get the potentially responsible parties to pay for
4 any investigations or cleanup actions that we take
5 at the site, and that can add some time to the
6 process. And that's one of the reasons why the
7 Superfund process can take a long time, but that's
8 the way that we've been told we have to do it.
9 We do prefer to get most people to
10 conduct it and we pay for it, and we were having a
11 lot of success with that policy. We offered up to
12 $50 million nationwide and we've also had
13 settlements that were upwards of $600 million, so
14 that's pretty good numbers there. Are there any
15 questions at this point?
16 Okay. At this point then I'd like
17 to turn it over to Christine Chulik, who is the
18 remedial project manager. She's going to talk about
19 the possible cleanup alternatives and the preferred
20 alternatives.
21 MS. CHULIK: Good evening. Again,
22 I'm Christine Chulik, the project manager for the
23 Eastern Diversified Metals site. We are here
24 tonight to tell you what contaminants we found out
25 at the site as a result of our remedial
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1 , investigation, what risks these contaminants pose to
2 Y°u, what cleanup alternatives we looked at for the
3 site, what our preferred alternative is, and also to
4 listen to your questions and concerns about our
5 preferred alternatives.
6 First I'll start off with a brief
7 history of the site. The Eastern Diversified Metals
8 site was a metals reclamation facility which
9 operated from 1966 until 1977. They recovered
10 copper and aluminum from communication wire and
11 cable and then sold the recovered metal. The waste,
12 plastic insulation material or fluff material, as we
13 call it, was deposited in piles on the site. The
14 pile boundary in this figure is outlined in red.
15 The dimensions of the pile as it exists
16 currently are approximately 1,500 feet long by 250
17 feet wide by 40 to 60 feet high and it covers 7
18 acres. In 1974 the Pennsylvania Department of
19 Environmental Resources ordered Eastern Diversified
20 Metals to install a leachate collection treatment
21 system on-site. Leachate is a liquid, such as
22 water, that when it passes through a contaminated
23 media it retains some components of the waste and
24 becomes self-contaminated.
25 So in response to that order,
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15
1 Eastern Diversified installed a shallow ground water
2 tank system which you can see here in yellow. They
3 also installed surface water diversion ditches,
4 which are shown in orange, to collect the leachate.
5 The-collected wastewater was then transferred to the
6 wastewater treatment facility, which is the small
7 building shown in green. Another figure I want to
8 point out is the stream, which is shown in blue to
9 the southern boundary of the fluff pile, because
10 I'll be talking more about that later.
11 In 1987 Theodore Sail, who's the
12 current site owner, and AT&T Nassau Metals
13 Corporation, who was a company that brought some
14 waste to the site, signed a consent order with EPA
15 to conduct the remedial investigation. Now, as Amy
16 said, the remedial investigation is basically a
17 study where we -- we want to find the nature and
18 extent of any contaminations out there. Basically
19 we sampled all the media that was out at the site,
20 we sampled the fluff material, the air, the soil,
21 ground water and surface water, and we analyzed
22 those samples. The results of the remedial
23 investigation show that there is approximately
24 225,000 cubic yards of fluff material, which is
25 considered a hazardous waste.
ARSOOQ^S
16
1 One of the ways to determine
2 whether a material is a hazardous waste is by
3 conducting a leaching test on it. This fluff
4 material leaches too much lead, and that's why it's
5 considered a hazardous waste. Of that 225,000 cubic
6 yards, approximately 500 cubic yards are
7 dioxin-contaminated material. The dioxin was
8 created during a series of fire events during the
9 late 1970's. We believe that this material is in a
10 very localized area of the fluff plot.
11 There is also approximately 5,000
12 cubic yards of PCB or polychlorinated
13 biphenyl-contaminated fluff material, and about 400
14 cubic yards of PCB contaminated soils. Those three
15 areas, the dioxin fluff, the PCB fluff and the PCB
16 soils, we refer to as the hotspot areas.
17 There's also approximately 500
18 cubic yards of lead-contaminated soils surrounding
19 the pile, about 100 cubic yards of
20 metals-contaminated sediment in the stream which I
21 referenced earlier to the southern boundary of the
22 pile. Those levels are not -- those contaminants
23 are not present at levels that are toxic to humans.
24 There is approximately 14,000
25 cubic yards of miscellaneous debris on-site. The
4
17
1 miscellaneous debris consists of wooden wire spools,
2 crushed barrels and unprocessed wire, amongst other
3 things. The surface water is contaminated with
4 metals, again, at levels which are toxic to aquatic
5 life. The leachate seeps from the -- which come
6 from the piles, are contaminated with
7 trichloroethylene or TCE metals and other
8 contaminants. The ground water is contaminated with
9 TCE and manganese.
10 Now, the risk posed by these I'll
11 describe now. Basically there's three components to
12 risks, there has to be a source of the contaminants,
13 there has to be a receptor, either human or animal,
14 and there has to be an exposure group by way the
15 contaminants reach the receptor. If any of these
16 three components are not present, then there is no
17 risk.
18 Once the contaminants reach a
19 receptor then it can be taken in by various
20 pathways. The inhalation pathway, that is basically
21 breathing in contaminants. The ingestion pathway
22 is, for example, if someone went on-site and ate the
23 fluff material. Dermal contact provides that
24 someone went on-site and either the fluff or
25 contaminated soil made contact with their skin. And
flRSOOOU
18
1 contaminated fish ingestion. And the receptors we
2 looked at through this study were children, adults
3 and workers.
4 I want to point out that during --
5 as part of our risk assessment we made some very
6 conservative assumptions. We assumed that the fence
7 was down at the site, which is not the case. We
8 assumed that anybody could walk on the site, but
9 they are totally restricted as it is now. We also
10 assumed that there was a hypothetical downgradient
11 well, which does not exist and probably never will
12 exist because the downgradient lands are State Game
13 Lands.
14 EPA's acceptable risks level is
15 one additional cancer or other toxic effects per 1
16 million people. If the site has a risk at that
17 level, then we feel that a cleanup action is not
18 warranted. At the Eastern Diversified Metals site,
19 more than one additional person could contract
20 cancer or experience other toxic effects and,
21 therefore, we feel that a cleanup action is
22 warranted at this site.
23 MRS. FRACKE: Have you made any
24 assumption yet on how many people it is because of
25 this that could contract cancer?
19
1 MS. BARNETT: Excuse me, would you
2 mind if we just got to this at the very end because
3 we might get to that as we go on?
4 MS. CHULIK: So in order to better
5 manage the various contaminated sites, soil, ground
6 water, surface water and fluff material, we divided
7 the media into three separate parts of what we refer
8 to as operable units. And the operable unit
9 approach allows us to expedite action for certain
10 parts of the site which present the most risk and
11 for which we have the most data. It also gives us
12 time to look at cleanup alternatives for other parts
13 of the site for which we need to collect more data.
14 What we are addressing at this
15 time, and in this proposed plan, are operable unit
16 number 1 and operable unit number 2. Operable unit
17 number 1 consists of the hotspot areas, which again,
18 are the dioxin, PCB, fluff and soil areas, the
19 metals-contaminated soil and sediments and
20 miscellaneous debris. Operable unit number 2, which
21 we are also addressing at this time, is the ground
22 water. In operable unit number 3, which is the
23 remainder of the fluff pile, we will be addressing
24 later on this year. We need a little bit more time
25 to look at some treatment alternatives for that
AR5000lf9
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1 media. At that time, which as I said is later on
2 this year, we will be issuing another proposed plan
3 and have another public meeting to discuss that.
4 Now, as Amy mentioned, the
5 Superfund Reauthorization Act was passed by Congress
6 in 1986. This act directed EPA to give a strong
7 preference to treating waste before disposing of it.
8 If you look at table 1 in your proposed plan, we
9 looked at many different treatment technologies for
10 the hotspot areas. The technology that came out as
11 a clear choice for the hotspot areas is
12 incineration. Incineration is the only technology
13 that destroys virtually all or 99.99 percent of the
14 dioxin and the PCBs. I'll talk more about
15 incineration later.
16 So in formulating the five
17 alternatives, which were also shown in your proposed
18 plan, we developed alternative number 1, which is
19 the no action alternative. EPA is required to
20 consider this alternative mainly as a basis of
21 comparison to other alternatives that do require
22 action, it involves taking absolutely no action at
23 the site at all.
24 Alternative number 2 is a limited
25 action alternative which consists of exactly what is
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1 at the site right now, the existing ground water
2 trench system, the existing wastewater treatment
3 facility, the existing surface water diversion
4 system and maintenance of the fence that is up at
5 the site.
6 Alternative number 3 includes
7 limited -- the limited action alternative, or
8 alternative number 2; incineration of the hotspot,
9 fluff and soil areas; stabilization, if necessary,
10 of the incinerator residuals, the miscellaneous
11 debris and the metals contaminated sediments and
12 soils. Now, stabilization is a process whereby we
13 find contaminants in a cement-type matrix thereby
14 making them immobile. This alternative also
15 includes a disposal off-site of the stabilized media
16 or consolidation on-site with other media and
17 upgrading of the surface water diversion system.
18 Alternative number 4 includes
19 incineration of the hotspot areas; stabilization of
20 the residuals, debris, sediments and soils, disposal
21 or consolidation; upgrading of the surface water
22 diversion system; enhancing the shallow ground water
23 collection treatment system through deepening the
24 existing trench system and upgrading the wastewater
25 treatment facility, if that's determined to be
AR50005I
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1 necessary. We also, under that alternative, would
2 want to collect additional data to determine
3 feasibility of deep ground water restoration.
4 Alternative number 5 is
5 incineration, again, of the hotspot areas;
6 stabilization of the residuals, debris, sediments
7 and soils, disposal off-site or consolidation
8 on-site; upgrading the surface water diversion
9 system; enhancing the shallow ground water
10 collection, treatment system and deepening -- and
11 treatment for the deep ground water collection and
12 treatment through some kind of a pump and treat
13 system and we — under that alternative we would
14 treat the deep ground water without further
15 consideration as to whether that was really
16 feasible.
17 EPA's preferred alternative is
18 alternative number 4. Under this alternative we
19 would incinerate the hotspot areas, either on-site
20 or off-site. This would most likely be done
21 on-site. For one thing -- the reason for this is
22 that for one thing it's much easier to bring a
23 mobile incinerator in and burn the material on-site
24 rather than transporting it to an off-site facility.
25 And the most important reason is that currently no
4
AR500052
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1 off-site facilities are permitted to accept
2 dioxin-contaminated material. This could change,
3 but that's not the case right now.
4 We would do a risk assessment for
5 the incinerator to ensure that emissions would be
6 safe for human health and environment. We would fit
7 emission controls to the incinerator such as
8 particularly controlled devices and scrubbers to
9 meet the standards. To do this we had to also
10 conduct frequent monitoring to ensure that safe
11 levels are being met. Our best estimate on
12 incineration time is approximately 200 -- this could
13 vary depending on information we get when we do our
14 design studies, but that's considerably our best
15 estimate.
16 This alternative also includes
17 stabilization of the incinerator residuals if we
18 find that they are too toxic, and by that I mean if
19 we find that the residuals contain too much lead,
20 and after conducting a leaching test then we would
21 stabilize them in the cement-type matrix that I
22 discussed earlier so that the lead would become
23 immobile. The miscellaneous debris and metals,
24 contaminated sediments and soils would also undergo
25 the same leaching tests and stabilization if it was
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1 . found to be necessary. The stabilizing material
2 would be disposed off-site or else consolidated with
3 other media on-site, and the surface water diversion
4 system would be upgraded.
5 For operable unit number 2, which
6 is the ground water remedy, we're proposing an
7 interim remedy, which includes enhancing the shallow
8 ground water collection and treatment systems by
9 deepening the trench to the bedrock surface. Now,
10 this -- the current trench system that's there now
11 allows some shallow ground water to underflow it,
12 and by deepening the trench system we would capture
13 that shallow ground water and prevent this water
14 from migrating into the deeper ground water and also
15 discharging into the intermittent stream, which is
16 what a lot of this water does now.
17 For this alternative we want to
18 collect additional data on the deep ground water
19 system rather than going ahead and selecting a
20 common treat type of system for the deep ground
21 water. And there's several reasons for this. The
22 contamination that exists underneath the site is
23 relatively low-level contamination considering --
24 when you compare it to other EPA sites.
25 The hydro-etiology underneath the
4
4
25
1 site is very unlevel, there's many fractures. It's
2 in a steep valley, it would be very difficult to
3 recover the contaminated ground water and treat it.
4 There's also no downgrading of receptors from the
5 site. There's no -- in other words, there's no
6 downgrading of wells. The land is all State Game
7 Lands and, therefore, there would most likely not be
8 any receptors in the future. And another reason,
9 downgrading of the site, as you can see in green,
10 are wetlands and we're afraid that the deep pumping
11 system will dry up the wetlands and maybe cause some
12 irreparable damage, so we want to look into these
13 issues further to see whether, for one thing, if a
14 deep ground water pump and treat system is
15 necessary, if it would be effective, and how badly
16 it would damage the downgrading of wetlands.
17 To recap, what we're proposing is
18 a final remedy for operable unit number 1, an
19 interim remedy for operable unit number 2 or for the
20 ground water, and for operable unit number 3, which
21 is the remainder of the fluff pile, we will address
22 that later this year, and at that time we'll issue
23 another proposed plan and have another public
24 meeting.
25 MS. BARNETT: Okay. At this time
26
1 I'd like to open it up to questions and comments,
2 but I want to take the woman in the green first, if
3 you could give us your name.
4 MRS. FRACKE: Sue Fracke,
5 F-R-A-C-K-E. I don't like the idea of risk
6 assessment. To begin with, it means that you're
7 allowing now a certain amount of people to die no
8 matter — that's what I call murder, that's what
9 risk assessment means. And people should be aware
10 of what exactly risk assessment means.
11 When you're saying you are
12 allowing one in a million to die, if I went to
13 Philadelphia where there's at least maybe three to
14 six million people there and I said I'm just going
15 to stand here and randomly shoot six bullets, I'll
16 only kill six people out of so many million, nobody
17 would allow me to do that. But you're making it
18 legal to murder people by saying you must have a
19 risk assessment. And near a facility you allow more
20 people- to die. Like people near a nuclear facility,
21 you're allowing one out of ten thousand people to
22 die instead of one out of a million. To the general
23 public, this is what they call risk assessment, I
24 don't think it's very nice. I don't believe in
25 murder. There's a lot of other questions.
AR500056
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First of all, I think a lot of you
people must already have lead contamination because
to come up with a retarded bunch of alternatives,
incinerate, incinerate or incinerate, that's very
foolish
able to
Lead wi
amount
You cannot swear to me that you will be
burn off _safely all the dioxins and PCBs.
11 show up in the water one way or the other.
And any form of lead in any
— according to the Academy of Pediatrics
says only zero is acceptable. And so already you've
come up
all you
so that
-- you're saying that it's contaminated and
want to do is just blow it up into the air
it gets dispersed and then nobody is
responsible for it and, of course, it gets mixed
with al
nobody
1 the other contaminants in the air and so
can point a finger when they get cancer or
lead poisoning.
becomes
people
cancer,
more of
I think
It's very easy this way, so nobody
a potentially responsible party anymore when
get cancer. One out of three people now gets
and I think that's outrageous. And to allow
the same I think is just plain murder. And
it's foolish and stupid on your part to even
consider that. You haven't even considered
above-ground storage. I see — and I mean that is
AR500057
28
1 not the best answer, but it might be the best answer
2 for now, though, not the final answer.
3 And prevention, of course, is the
4 only answer, not to make the crap to begin with.
5 And to use a word like media to throw people off,
6 just use contamination, not media. I love all these
7 words you people come up with. And why not
8 above-ground storage? Make a big building, stick it
9 all in there, then you won't constantly get
10 leaching, then if somebody comes up with a decent
11 answer ever in the future you'll have some kind of
12 solution. But for now incineration, stabilization,
13 they all do the same thing.
14 Everything is going to contaminate
15 people no matter what. I suppose this is like the
16 site over in Foster Township, too, where the ground
17 there is better -- is higher grade. It's just
18 terrible what's being allowed. You people allow it
19 for years and years. Finish so you clean things up.
20 And I see what's going on over
21 there in Foster, for years nothing has been done. I
22 mean it's very foolish and I think it's time to stop
23 thinking of incineration, though, I know that you
24 just love it and that seems to be the only thing
25 that you people are coming up with. Start using the
AR5Q0058
29
1 scientists to come up with something better or just
2 stop allowing this stuff to be made. It's murder.
3 MS. CHULIK: I'd like to address
4 the second part of your comment, and then the first
5 part of your comment can be addressed by the
6 toxicologist, Roy Smith. We've had a lot of
7 incinerator experts look at this issue. As I said,
8 incineration destroys 99.99 percent of virtually all
9 of the PCBs and dioxins on the site.
10 MRS. FRACKE: I don't think --
11 MR. D. PINKEY: Let her finish.
12 MRS. FRACKE: She's talked a lot
13 and she's not necessarily telling the truth. I'd
14 like to see all the --
15 MR. D. PINKEY: Dan Pinkey.
16 I'm --
17 MS. BARNETT: Try to talk one at a
18 time to help our court reporter.
19 MS. CHULIK: So incineration will
20 destroy virtually all of the dioxins and the PCBs.
21 The lead -- it's true that lead will not be
22 destroyed by incineration, however, the incineration
23 experts at EPA have looked at this, they told me you
24 can fit scrubbers and particular control devices to
25 the incinerator so that suction captures amounts of
AR500059
30
9 1 lead so that any lead that is released will be at a
2 safe level.
3 There will always be a very small
4 percentage that will be released, but as I said, a10
5 risk assessment will be done so that any emissions
6 would be at a safe level. There would be a lot of
7 emission controls on the incinerator, so it's the
8 best alternative for these hotspot areas that are
9 highly contaminated with what we call organics or
10 the PCBs and dioxins. It's the only thing that
11 would really work effectively on them, for the
12 entire pile we are looking at. As one of our
13 alternatives we are looking at what we call
14 above-ground contaminant, landfill, whatever, that's
15 one of the alternatives.
16 MRS. FRACKE: That's not what I
17 call above-ground storage landfill. That doesn't
18 sound like above-ground storage. Above-ground
19 storage would be making a building, maybe like the
20 one even there that's existing, putting the stuff in
21 it for the time being, confining it. It's cheaper
22 than incineration and it's not going to cost $12.5
23 million to put up a building.
24 MS. CHULIK: It's not a permanent
25 remedy. •
31
10 1 • MRS. FRACKE: Neither is
2 incineration. I mean the air we breathe -- not just
3 right here, I mean I wouldn't want to see it in the
4 people right here -- the air we breathe -- and it
5 gets to a lot of other people. It doesn't stay in
6 one little tiny area.
7 MS. CHULIK: Well, I think putting
8 material -- just putting a building somewhere is not
9 a permanent remedy. We look at permanent remedies
10 for cleaning up the sites.
11 MRS. FRACKE: But that's not
12 permanent, either. I mean you're just dispersing
13 it.
14 MS. CHULIK: Well, I disagree.
15 MRS. FRACKE: You take the ash,
16 you put it in the landfill, what's left -- or you
17 stabilize. Stabilization site, it's not going to be
18 a permanent thing. Where are you going to bury it?
19 MS. CHULIK: If it does pass the
20 leaching test then it can be taken to a municipal
21 landfill.
22 MRS. FRACKE: And all the testing
23 keeps changing all the time, too. One time this is
24 okay, then they find -- jeez, this, they say, is the
25 standard just like lead, they used to say 50 parts
RR50Q061
32
10 1 per million or billion was acceptable for human
2 health, now they brought it down to 25, but now
3 they're saying not even one part, the pediatrics
4 department, not necessarily the EPA, they're saying
5 not one is safe for children or anybody else.
6 MS. CHULIK: Well, I think this is
7 a good time for Roy Smith, who is our toxicologist,
8 to address some of your concerns.
9 MR. SMITH: I would like to
10 address your concerns about the meaning of risk
11 assessment. I think there are a lot of
12 misconceptions about what risk assessment actually
13 means at a site like this. We can say with
14 assurance that between 40,000 and 50,000 people will
15 die on the highways this year, because that's what's
16 happened for the last 15 years running. But these
17 risk assessments are much less certain. To begin
18 with, we don't know that these chemicals cause
19 cancer in humans at all.
20 There is PCBs, dioxins, TCEs
21 and -- four compounds, each one of those is
22 classified by EPA as a B-2 carcinogen, that means
23 that these things have caused cancer in at least two
24 animal species in the laboratory under megadose
25 scenario, but there is no concrete evidence that
AR500062
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33
10 1 they actually cause cancer in humans.
2 However, EPA considers it prudent
3 to assume that they cause cancer in humans, but you
4 have to start with the realization that these
5 chemicals may not cause cancer at all. We. think
6 that they probably do, but we don't have any
7 evidence to indicate that they do.
8 The second thing is that when we
9 assess the exposure to the chemicals we make every
10 worst case assumption that we can possibly make. We
11 assume that someone is going to drill a well in
12 State Game Lands, we assume that children are going
13 to be trespassing on the site, we assume that dust
14 will be blowing off the site, that it won't be
15 remedial. Similarly, in a risk assessment burn,
16 incinerator, feed rates, stack temperatures, wind11
17 directions, receptor locations and everything else
18 that we can make, so that once we actually say what
19 the results of the assessments are they will be
20 accompanied by the words, the true risk is probably
21 less and may be zero. And you should take these
22 words very seriously, these estimates are worst case
23 estimates. We think it is highly unlikely that --
24 the true risk is very low than what we tell you.
25 MRS. FRACKE: Well, I disagree
AR500063
34
11 1 with you. See, your government is working against
2 you. A lot of the things you just haven't tested
3 yet or tested enough, and one minute you say it's
4 toxic, it's toxic. Like the ash, the bottom ash,
5 first it was considered toxic but then the industry
6 screamed because it would all have to go to a
7 hazardous waste landfill, so then they want to
8 consider this specialty waste instead of calling it
9 hazardous so then it can still go to a regular
10 landfill.
11 So you can play all the word games
12 you want and say this is toxic, this isn't. A lot
13 of the stuff you just don't know how toxic it is,
14 lead, if it does or does not cause cancer, and the
15 EPA probably thinks it probably does. It also
16 causes mental retardation, slows children's growth,
17 retards their growth. It does so many other things
18 that are bad, regardless of whether or not it causes
19 cancer.
20 Now, as far as risk assessment, I
21 really resent that constantly referring to the
22 highway, which I hear it everywhere, they all come
23 up with the highway bit. First of all, it's rarely
24 the cars that are dangerous, it's the people driving
25 them, it's also the air emissions from the cars,
4
35
11 1 which had we done something about this years ago,
2 and we could have and should have, and I don't
3 believe Bush's Clean Air Act has helped it any, we
4 could have helped the air emissions, but the cars
5 themselves rarely cause an accident, it's rarely the
6 vehicle itself that would cause the accident, it's
7 the driver.
8 And that's something that we could
9 do more about and, of course, to a degree we do take
10 that risk, it doesn't mean we accept it, but
11 sometimes we take it. You are forcing us to accept
12 the risk we may not choose to take, and that is
13 against the Constitution, too, because you're saying
14 it's allowable for so many people to die, and under
15 our Constitution, again, it says that murder is
16 unacceptable, that depriving someone of life. You
17 should be before a judge and jury for a certain
18 supposed crime and then they decide, but you're not
19 letting anybody -- you're being the judge and the
20 jury and not giving any choices, and that's not
21 right. It's not right that all of you should be --
22 UNIDENTIFIED SPEAKER: Excuse me,'
23 I represent Senator Clyde Hopelin. I appreciate
24 what you're saying, but I think we're here to go on
25 with some of the specifics they have. I think
AR500065
36
11 l there's only a limited amount of time and I think
2 maybe perhaps you should have this debate with these
3 people who would be glad to set this up at a prior
4 date. I'm not. But they are here to give a
5 presentation based on the facts that they have,
6 based on the knowledge they have, and I'd like to
7 hear some more and there are some people I believe
8 who do have questions.
9 One question I do have is you
10 mentioned ground water, low-level ground water and
11 the deep ground water. What degree and how far down
12 are we as far as relative to ground water in
13 contamination?
14 MS. CHULIK: Trichloroethylene,
15 which is a probable carcinogen, was found at one
16 hundred parts per billion, approximately, and the
17 maximum contaminant level which EPA has now is five
18 parts per billion. That may sound like a lot, but
19 really it is above being what we call the MCL,
20 maximum contaminant level.
21 From previous studies that we have
22 done — we've done a lot of pump and treat
23 remediation at different sites, we have found that
24 it's very difficult to recover the contaminatedIT
25 water, especially when you're in a hydrologically
.
AR500066
37
12 1 complex area like we are, it's very difficult to
2 recover it and then if we did recover it, it would
3 probably be so diluted by that time that it would be
4 below five parts per billion anyway.
5 Now, that's not absolutely true,
6 we need to do more studies to find out -- to better
7 predict, some modeling, what the levels would be if
8 we recovered it, if we could even recover it. And
9 as I said, there are currently no downgrading of
10 receptors at all, it's all State Game Lands and it
11 probably will remain State Game Lands. There
12 probably won't ever be any wells there.
13 MS. BARNETT: Did we have somebody
14 else in the back?
15 MR. D. PINKEY: Dan Pinkey from
16 the Rush Township Planning Commission. I'd like to
17 speak a little more directly to the conditions of
18 the site. I waited a long time for this meeting. I
19 was the closest neighbor of the Diversified Metals
20 when they started up. My brother and I were the
21 first ones to bring it to the attention of our local
22 authorities, and I have a letter in my file from
23 1968 when -- in my naivete I thought it would be
24 enough to tell the responsible regulatory agency
25 that there's something lousy going on here and you
38
12 1 better look into it, then it was the Department of
2 Health down in West Reading. Letters went back and
3 forth, not much acknowledgment, not much happened.
4 The thing that really triggered my
5 concern, and you'll have to correct -- I don't know
6 how you are going to authenticate it, the fires were
7 not in late 1977, that would be showing things
8 differently, the fires were in late '67 while this
9 firm was in operation. And your worst case scenario
10 absolutely must consider the possibility of
11 additional fires at this site. I don't know if
12 anybody has burned this stuff and said what comes
13 off it. Have you in your studies -- has anybody
14 done that?
15 MS. CHULIK: We know —
16 MR. D. PINKEY: Is ignitability
17 one of the criteria for determining the hazards of
18 the waste?
19 MS. CHULIK: Yes, it is.
20 MR. D. PINKEY: Believe me, this
21 stuff burns bad, real bad. This is the spring of
22 1968 — yeah, '67, fires burned and had to be pulled
23 apart by bulldozers, chunks of fuse material big as
24 pool tables. The local fire company left their
25 equipment on the ground there for days and days. W
AR500068
39
12 1 And it was started apparently carelessly. It looked
2 like they were burning some pallets and it got away
3 from them right in the vicinity of the plant.
4 The point that I'm trying to make
5 is that from the beginning this was a lousy setup
6 and the people that were responsible at that time
7 did not respond. I have a letter here where I raise
8 the issue of the possibility of PCBs. They used to
9 be in insulation. You're not going to be a genius
10 chemist to know that reactions take place there in
11 the mass, that don't happen.
12 As this material accumulated
13 nobody seemed to be worried about it. I mean I rang
14 all the alarms, again, naively believing that
15 somebody would care, the Fish Commission, yeah, it's
16 a tough setup, but yeah, too bad. The Game
17 Commission, Game Lands 227 surrounds that place,
18 yeah, we sent the guy in, yeah, gee, we don't know
19 why they allowed a dump there. It's in this file
20 here if anybody wants to look. That's it.
21 Have you ever heard from the Game
22 Commission or the Fish Commission, have they ever
23 had any investigation, any input into this
24 investigation, no.
25 I thought maybe the people of the
HR500069
40
12 1 mineral mines industry were going to restore it from
2 a cold water fishery. I wrote to Secretary
3 Charmberry about the Little Schuylkill, gee, you
4 guys are going to be trying to clean it up, these13
5 guys are killing it, that's not our job, We'll pass
6 it on to the Department of Health. And eventually
7 the stationery started appearing with the DER typed
8 in or the Department of Health scratched out or the
9 Department of Interior was scratched out and EPA
10 appeared, and it took a long time. The company had
11 to fold up. And it's just not right to leave it
12 like that.
13 You know, for years people
14 preached the balance of youth, watch the
15 environment, but remember, we have jobs. Well, they
16 had a couple of hundred jobs there. The jobs are
17 gone, that 25 acres is gone for the foreseeable
18 future. Who knows what's going to happen if the
19 Diversified Metals pile -- a massive fire, a release
20 of all kinds of crap that we don't really know,
21 apparently? What could that do? How about a fire
22 in the game lands, drought conditions, prevailing
23 winds would bring it towards that dump. I think
24 that you have to go back and rethink this thing.
25 First, that stuff has got to go.
.
AR500070
41
13 l.I don't think that it's really safe to leave it
2 there. The first thing you've got to do is burn
3 this and see what we get out of there, the dioxins,
4 I'm sure there are a few other goodies. Nobody ever
5 told us, maybe we didn't ask hard enough, beg hard
6 enough or demand, but you people are our last hope,
7 really.
8 This is our last shot, and I think
9 that in conscience you owe it to us to get that out
10 of there, and I'll tell you what my bench mark is
11 going to be. There's a little stream there over
12 toward the railroad track, which used to be -- we
13 used to have a little camp for the Boy Scouts there
14 the last week of the summer before they returned to
15 school.
16 Part of our tour was to go over
17 there and follow the raccoon tracks along that
18 little stream, and periodically you'd see a pile of
19 crayfish shells and you'd turn the rocks over and it
20 was twitching with life, a little intermittent
21 stream without even a name. And then the day came
22 there were no raccoon tracks, there were no
23 crayfish. You -turned the rocks over and you saw
24 Diversified confetti, all that beautiful colored
25 insulation, and that was it.
RR50007I
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13 1 , The leachate plant, whoever
2 allowed that leachate -- where did they send the
3 material that they recovered from the leachate
4 plant? They used to pump it out and put it back on
5 the pile. DER calls that a permissible disposal
6 method. Don't do anything like that to us again.
7 As I said, it's being
8 accomplished. It was done before the regulatory
9 agencies were tuned up. We're stuck with it.
10 You've got to do right by us. And if twelve and a
11 half million dollars is what it's going to take for,
12 you know, a halfway hotspot elimination, plus, you
13 know — somebody has got to pay more. That stuff
14 has got to be made so it can never make trouble for
15 anyone, and we've got to shoot to return that to
16 productive use, that's the only thing that's really
17 going to satisfy me.
18 And I think anybody who works the
19 art of the possible and then politics enters in, it
20 enters into all these things, but please, don't let
21 us down, because I learned a little in the last 23
22 years, not as much as I should, but it doesn't pay
23 to be naive and think it's just enough to tell the
24 people about the problem, you've got to remind them
25 regularly, by whatever means you can, and we'll see
AR500072
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43
13 1 that the full — in fact, I would say this would be
^^ 2 a prototype situation where a legislative
3 investigation would make your job a lot easier
4 because I think it would show that it was a very
5 halfhearted effort on the people who had been
6 charged with enforcement. And long before you guys
7 got involved this pile of crap was foreordained to14
8 be dumped on.
9 Don't let us down. Get rid of it
10 completely. And as I said, I want to see -- before
11 I croak I want to see raccoon tracks and I want to
12 see crayfish in that stream and I intend to work
13 accordingly. Thank you.
14 MS. CHULIK: Thank you for your
15 comments. One thing that I want to say is this did
16 not get there overnight and it takes time to
17 investigate the best alternatives to clean up the
18 pile. The mess is out there. We are not forgetting
19 about the rest of the pile. As I said during the
20 presentation, we are going to issue another proposed
21 plan later on this year which will address the rest
22 of the pile.
23 We're considering a lot of
24 promising alternatives for the remainder of the
25 pile, so believe me, we're not forgetting it. It
SR500073
44
14 1 will be taken care of, but it does take a little bit
2 of time.
3 To address another issue that you
4 raised about the fires, if you read the remedial
5 investigation report, soil samples were taken in the
6 direction of the wind the day of — at least the
7 fires as we know, there were some fires in 1979,
8 there were some soil samples taken then, and I mean
9 taken to — I'm going to start again. We know which
10 way the wind direction was blowing in 1979 on that
11 day and we took soil samples in that direction. We
12 did find low level contamination on-site in those
13 areas. Off-site we didn't find anything. So it was
14 looked into.
15 MR. D. PINKEY: But do you know --
16 I mean could you get an analysis of what happened to
17 be burned, a representative sample of that pile,
18 what are the materials that are in that -- were in
19 that black cloud? Nobody has done that, have you?
20 MR. SMITH: This happens fairly
21 often in Superfund sites where there was some kind
22 of release like that, like a huge pile of burning
23 gases and things like that. We can't tell you what
24 could have been in that cloud, all we can say is
25 that we looked for residue in the soils that were
4
4
45
14 1 downwind and did not find it. We can't do anything
2 about that kind of exposure, but what we're trying
3 to do is prevent it from happening again, and we
4 cannot find any residual soil contamination that we
5 can measure, much less that can be cleaned up.
6 MR. D. PINKEY: I'm asking again,
7 cannot ignitability be added to the criteria to add
8 to the hazardous nature of the material, because I
9 think that -- I think it adds an element of urgency,
10 the fact that you are in a wooded area, the fact
11 that a forest fire scenario is very plausible, that
12 area has burned many times down along the river.
13 Tell us what could happen if it burns again.
14 MR. SMITH: I'll tell you what
15 we've looked for. The specific compounds we've
16 looked for were dioxin, that's polychlorinated
17 biphenyl dioxins, which were by far the most toxic
18 contaminants that would be released by a fire like
19 that. If you don't find them then it's safe to
20 presume there is no significant residual
21 contaminants.
22 MR. D. PINKEY: How about the HCL
23 that comes and burns the PCBs, what happens when you
24 break down the polyethylene and some of the other
25 rubbers that are used?
HR500075
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14 1 MR. SMITH: There's no doubt HCL
2 is hazardous, but it's hazardous in much greater
3 amounts, one millionth the amount of hazardous
4 amounts of dioxin.
5 MR- D. PINKEY: You've got a hell
6 of a lot to cook off. I mean I saw that fire 25
7 miles away, that smoke — what I'm getting at is I
8 think you should burn a sample and know what comes
9 off. This is a hell of a mix here and it would --
10 you know, not even the residuals of the dioxin, but
11 what happens if it goes up? I mean should we have
12 in our emergency management plan in this community
13 the contingency of that cloud catching on fire?
14 MS. CHULIK: Well, since the
15 1970's — maybe it was 1970, I'm not sure of the
16 exact date, the site owner, who is Theodore Sail,15
17 Incorporated, installed temperature sensors in the
18 pile and they monitor those sensors daily to make
19 sure that there could be no spontaneous combustion.
20 They actually haven't found temperatures that even
21 came close to being spontaneously combustible.
22 We think that previous fires that
23 occurred there were either set by -- were camp fires
24 that were set maybe by kids that used to ride around
25 on motor bikes on the pile. 4AR500076
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15 1 MR. D. PINKEY: A bunch of
2 pallets, I'll show you after the meeting. So what
3 I'm saying is it does burn easily and I think you
4 should in your worst case scenario crank that in and
5 let us know if we should be worried about it.
6 Believe me, please do it.
7 MS. CHULIK: My point is if the
8 company does this -- I don't know this, but if the
9 company did somehow cause the fire, the company is
10 not there anymore because --
11 MR. D. PINKEY: We know that.
12 MS. CHULIK: So it's not going to
13 happen by that method. Kids can't get on the site
14 to cause -- to set camp fires and cause a fire.
15 Since the temperature sensors have been on-site,
16 which is at least ten years now, there has not been
17 a fire.
18 MR. D. PINKEY: You say that
19 there's no chance of an external kind of a fire.
20 Please, rural area, unattended, that is not granted
21 immunity. I think in conscience you.should prepare
22 for that, I really do, the spontaneous aspect to
23 weigh that down. But you could have the fire lit by
24 a forest fire. You must do it. In conscience. How
25 hard is it to light off a sample and run it through
AR500077
48
15 1 the chromatograph?
2 MR. SMITH: You are making a very
3 good point, actually, that we have assumed that the
4 fire would not burn.
5 MR. D. PINKEY: Don't do that.
6 MR- SMITH: However, we have also
7 found as part of the risk assessment that there
8 is,nevertheless, risk from contact with the metals
9 and organics of the pile to make it worth cleaning
10 up, anyway. So that including a fire scenario does
• 11 not necessarily chance what will be done, and as
12 Christine said, we are exploring alternatives for
13 the pile. Believe me, we haven't forgotten about
14 the rest of the pile.
15 MR. D. PINKEY: Okay.
16 MS. BARNETT: Do we have other
17 questions, comments?
18 MR. WILLIAMS: My name is Evan
19 Williams, and I used to work at Bundy, who is across
20 the street from Eastern Diversified, and many times
21 there was fires behind that building. We never
22 realized it was such a big pile, you know, but
23 something would burn and the firemen would go there
24 and it was always concern of what was burning, you
25 know, smoke inhalation could kill you, regardless of
4
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what was in that pile.
Also, Eastern Diversified would,
during the night shift, open up their stacks, let
that go out. It looked like it was snowing in July.
And, in fact, it came down on the third shift -- the
cars that were on third shift were all ruined and
the roofs had to be all done over and Eastern
Diversified paid for that, but it looked like piles
of snow around there. That was not very healthy.
But I think -- the lady wants to put it in a shed.
I don't think you can put that pile in a shed
because you need to take that whole pile, not just
part of it, fluff or whatever, that whole pile
should go. I don't know where it can go.
MRS. FRACKE: I mean you're saying
take it away from my area, put it in somebody else's
area.
MR. WILLIAMS: No, I'm not saying
that, but it should go. You can't wait 15 years to
do something about it --
MRS. FRACKE: I'm not saying a
shed, either.
MR. WILLIAMS: — or we'll die a
long time before that. Just one fire could do that.
MS. CHULIK: I can see that
RR50QG79
50
15 1 there's a lot of concern for some kind of
2 spontaneous combustion of other material and the
3 kind of by-products that would be given off. We
4 can -- certainly we're not done with our
5 investigation of the pile. As I said, we can
6 certainly look into that, and even if that did
7 happen, which I think is very unlikely, but if it16
8 did happen, what could be done.
9 MR. G. PINKEY: George Pinkey.
10 I'm the chairman of the Township Supervisors, and
11 that pile is probably one of the reasons that I'm a
12 supervisor. I'm also the closest neighbor to that
13 pile. If I get started, somebody shut me down
14 because I've heard enough here tonight to kind of
15 just fill my brain with things.
16 First of all, let's address the
17 fire situation. Two years ago I had to call the
18 local police who called the bomb squad from Fort
19 Indiantown Gap and found a fused mortar in the
20 woods. A hundred yards from the extreme west end of
21 that pile is the Hometown viaduct, also known as the
22 High Bridge. It's a tremendous tourist trap,
23 curiosity site of many drinking parties. No doubt
24 there's probably pot parties there and everything
25 else.
AR500080
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51
16 1 At one time, maybe ten or twelve
2 years ago, if you check the fire company records,
3 some idiot tried to put that bridge on fire. They
4 did manage to set several of the cross ties on the
5 railroad on fire. There's a lot of people from all
6 over the United States that walk along that track,
7 look at that pile and ask what that pile is. And
8 the day will come, just like I'm standing here,
9 someone will put that pile on fire again.
10 So I think that a sample should be
11 taken and burned freely in air, capture the cloud,
12 let us know. Because in the emergency management of
13 the township, which you're required by law to have,
14 we have to address every possible worst scenario. A
15 worst scenario would be that pile catching on fire
16 and a cloud enveloping Hometown. What do we do?
17 Who do we call? What do we do?
18 If H.A. Welty, who ran a powder
19 mill in that valley from Tamaqua past the High
20 Bridge- in the latter part of the last century and
21 the early part of this century, was told that some
22 day that would be State Game Lands, I don't think he
23 would think that would happen. So who's to say that
24 there are no downgrading lands. Now, is there a
25 hydrologist here or any expert on hydrology?
HR500081
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16 1 MR. SMITH: I'm a toxicologist.
2 MR. G. PINKEY: I'm a little I
3 above-grade from the pile. There's a narrow pin on
4 my property, the previous property owners removed
5 fill. My well is 88 feet deep. In dry summers we
6 can't wash more than two loads of wash, three people
7 have to watch if the washing machine is going to
8 take a shower.
9 I should go down a few more feet
10 with that well. If I do that and get into the deep
11 ground water there's a possibility my well will
12 contaminate, so we'll leave the well stay the way it
13 is and hope that it doesn't get contaminated. The
14 area around my house is zoned density residential.
15 There is no existing water pipes in that
16 development. And start a developer poking wells
17 down in there, because the cone of the depression of
18 the deep ground water, makes a lot of trouble for
19 the ground.
20 MRS. FRACKE: Mr. Pinkey, how far
21 away do you live from there?
22 MR. G. PINKEY: 220 yards.
23 MRS. FRACKE: Have you tested your
24 water? Have you gotten it checked?
25 MR. G. PINKEY: Yes. My well has
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16 1 been checked, chemically it has been tested.
2 MRS. FRACKE: For metals?
3 MR. G. PINKEY: Again, I talked
4 about the -- we eat a lot of stuff off the ground.
5 When the wind is from the south we still get the
6 fumes from that thing which is like plastic toys.
7 Now, how noxious that is, how wide it is. I
8 wouldn't mind if you came and took a tissue sample,
9 there's enough here and I think that my children and
10 my wife or even from our animals, and what about
11 animals on the game land, just to see what they're
12 picking up, if they're any different from say a
13 rabbit or a groundhog a mile away from here.
14 And, you know, we say it may, it
15 may, it may, maybe the day will come somebody will
16 take it up and find out whether it is or whether it
17 isn't. And I think -- the last thing I want to say
18 is I don't think the people in this town will ever17
19 accept anything less than total removal of that
20 pile. And I don't think that that's farfetched, and
21 I don't think that a shed the size of a football
22 field and 220 yards high has to be built. It would
23 be bigger than that, possibly. That's a big pile.
24 Take a walk down and look at it. I think you could
25 probably fill Vet Stadium.
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17 1 There have been over the years
2 several people that have poked around that pile.
3 We've taken people back and looked at that pile, and
4 I'm sure the day will come when we'll be starved
5 enough for resources, but how much money you spend
6 in your studies and everything else and advertising
7 and all in the trade journals and stuff like that --
8 give them a chemical analysis and a physical
9 description of what the pile is and, you know,
10 someone's pile of crap could turn into a pile of
11 money for someone.
12 The first half of the pile you're
13 going to have trouble with -- because in the
14 beginning before these people got involved there,
15 everything went on the pile, steel wire, the plant
16 garbage, dead dogs, whatever. The second half of
17 the pile — or maybe it's more than the second half
18 because of the elevation, it's relatively straight
19 enough — and, again, I want to mention for the
20 record, and this is hearsay, we have people tell us
21 that they process asbestos.
22 Never in any of the tests that
23 were done did anybody find asbestos. That has to be
24 looked at. If you can find 500 yards with PCBs,
25 maybe it's possible to find where the asbestos was.
4
55
17 1 The people that work there tell us they're not
2 willing to testify, that they have — in fact, the
3 gentleman that watches the pile up there admitted
4 that they did process asbestos but he said they
5 hauled the fluff away with the asbestos. I would
6 like to know where they hauled it, and I can't see
7 how some of it didn't escape into the ground.
8 One last thing, I heard you say
9 that the thermocouples in the pile are monitored
10 daily. That's a lie on your part. But somebody is
11 filling that sheet from somewhere other than in the
12 pile because many, many times I've walked two or
13 three times after a snowstorm around that pile and
14 there's not a track- And it just amazes me what
15 that water treatment plant is doing other than
16 running and churning that stuff around, because the
17 stuff that comes out of it looks and smells worse
18 than what goes into it.
19 And I know that they don't look at
20 that water treatment because, as I said, I
21 deliberately walk -- I used to work middle shift,
22 I'd take a walk over there and see -- and sometimes
23 a week or better at a time there were no tracks with
24 vehicles or footprints through the snow to that
25 site. Now, that was before the thermocouples were
AR500085
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17 1 put in, but since the thermocouples are there, there
2 are periods and I'll have to start watching again.
3 They are not being monitored daily.
4 Now, they did generate some pretty
5 good temperatures in the pile, not enough to set the
6 thing off, but the primary concern is for fire.
7 There is nuttiness, kookies, vandals, whatever you
8 want to call it, you know, you find unspent order
9 and people try to burn down a 90 percent steel
10 trestle, there's a potential for anything. They
11 have set firecrackers off at 1:00, 2:00, 3:00 in the
12 morning, sometimes almost rolls us out of bed. So
13 the fact that that bridge is there, you know, a lot
14 of people see that pile and all the squirrels aren't
15 in the chute.
16 MS. CHULIK: Okay. Thank you for
17 your comment. You made a lot of good points, and I
18 would like to address them as much as I can here.
19 MRS. FRACKE: I have another
20 question.
21 MS. CHULIK: All right. Could you
22 hold on until I address Mr. Pinkey's comment?
23 MRS. FRACKE: I'm sorry.
24 MS. CHULIK: The fires — I canIf
25 understand with your being chairman of the board you 4AR500086
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18 1 need to have -- the township is concerned for an
2 emergency evacuation type of a plan, and we will
3 look into that. The possible contaminants that
4 could be given off if the pile caught fire, we'll
5 look into that the remainder of this year while
6 we're addressing the fluff pile. As far as the
7 temperature monitoring system, that was the claim
8 made by the current sit owner, that it is being
9 monitored daily. If it's not I'll have to check
10 into that.
11 The water from the wastewater
12 treatment plant, the Pennsylvania Department of
13 Environmental Resources samples that quarterly, and
14 so far the treatment plant has been meeting its
15 permit, it does meet the standards for that permit.
16 Asbestos, again, Pennsylvania DER did sample for
17 asbestos as well as other parties. No one has ever
18 found any.
19 Recycling -- you mentioned that
20 there's a lot of good plastic there, it's one of the
21 alternatives that we are looking into. It could be
22 a very promising alternative for the remainder of
23 the fluff pile. The records center for recycling is
24 currently doing treatability studies for us to see,
25 in fact, what the possible use for the pile, that
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18 1 would be a really good remedy because it would
2 provide a beneficial use for something that is now
3 considered to be a waste.
4 And as far as your well, the data
5 that we have so far shows that certainly what you're
6 drinking now is fine, your well is being recharged
7 from an area which is upgrading of the site, so your
8 water is clean. If you deepen your well, we think
9 that the situation would still be the same.
10 However, we will certainly address, when we continue
11 our ground water studies, just that issue -- or not
12 just that issue, that issue along with other issues
13 to see how deep you would need to go and whether the
14 well would remain clean.
15 MS. BARNETT: You had a question
16 right there?
17 MRS. FRACKE: Have you done any
18 test on the site surrounding of the people's
19 property of the different wells?
20 MS. CHULIK: There were several
21 test wells on-site and that's how we found that
22 there were TCE and manganese contamination on the
23 ground water. No off-site wells were sampled
24 because they are all upgrade of the site.
25 MRS. FRACKE: Because I know over
.
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18 1 in Foster Township there has been lead contamination
2 in the wells off the site as well. Of course, the
3 EPA and DER are saying that it doesn't even come
4 from the site, but there's nothing else around that
5 would cause that and it doesn't always show up.
6 There's different kinds of tests that have to be
7 taken for the lead in water. One time it may prove
8 perfectly okay and then maybe a couple days later it
9 may not, and that was found over there in Foster
10 Township.
11 I don't know if you people are
12 familiar with the Foster Township Superfund site.
13 Recycling is very similar to this only they do have
14 an incinerator there that they were burning off
15 the -- do they have an incinerator also at this site
16 that they've been burning off or stripping it? I
17 don't know what they've been doing at this site.
18 MS. CHULIK: At the Eastern
19 Diversified site?
20 MRS. FRACKE: Yes.
21 MS. CHULIK: No, they --
22 MRS. FRACKE: Well, they have that
23 over at Foster Township and then as they washed off
24 the stuff afterwards it just went all over the place
25 and it has contaminated wells off as well, of
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18 1 course. But again, Nassau is another responsible
2 party along with the people that own the site over
3 the years having done that, and it really needs to
4 be — the wells need to be monitored very frequently
5 to catch whether the lead is actually getting into
6 the water.
7 People there have lost babies.
8 One woman I know at six and a half months pregnant,
9 her child died in utero. Her sister also had a
10 miscarriage. Both properties are adjacent to the
11 C & D site. The animals had very unusual problems
12 as had other people in the area. You know, there
13 lead wasn't in the drinking water and it's a matter
14 of playing Russian roulette. Sometimes they say you
15 can drink the water. Well, nobody knows and no19
16 filtration system is 100 percent effective. It's
17 scary.
18 MS. BARNETT: Unfortunately, none
19 of us know about the C & D recycling site, but I can
20 give you the name of somebody to contact about that.
21
22 MS. CHULIK: Yes, I'm not familiar
23 with the C & D recycling site, however, I do note
24 that at this site there are no downgrading of wells
25 to sample, only the private home wells at this site
4
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19 1 . are upgrading, meaning that they are -- the water
2 flows to the wells upgrading it before it goes to
3 the site. That's what upgrading means, just to
4 clear that up.
5 MS. BARNETT: Do we have other
6 questions, comments?
7 MR. MILLER: Paul Miller. On this
8 contamination of wells, what's the possibility of
9 the people located along Route 54 here having their
10 wells being contaminated, which is south of that
11 site?
12 MS. CHULIK: There is no
13 possibility because you're upgrade of the site quite
14 a bit.
15 MR. MILLER: No, I'm below it.
16 MS. CHULIK: You'd have to show me
17 on the map. When we located all of the private home
18 wells that we could find they were all located
19 upgrade of the site. If you want to meet me after
20 the meeting and show me where your well is, I would
21 be glad to take a look at it.
22 MS. BARNETT: Is there somebody
23 else?
24 MRS. NOBEL: Beverly Nobel,
25 N-0-B-E-L. I'm concerned about the process of
UR50Q09
62
19 1 • incineration. Now, we're talking about the danger
2 if the pile catches on fire, but if we put something
3 on-site which will incinerate, when you incinerate
4 you don't really destroy, you only change form. In
5 Lehigh County solid waste people told us that when
6 you burn you change the form of something, you don't
7 really destroy, you change the form. If you could
8 comment on that for me.
9 MR. SMITH: From a chemical point
10 of view you're absolutely right, but the philosophy
11 is take an organic chemical and oxidize completely,
12 and the form that it takes then ideally is pure
13 water or pure carbon dioxide so that the atoms still
14 exist but they've been rearranged.
15 As you probably know, the trouble
16 with incinerators is that no matter how careful you
17 are there are still some traces of harmful chemical
18 form, even with 1800 degrees temperature from this
19 stack you will get dioxin molecules. The trick is
20 to keep that to a minimum and stop — keep the
21 operating parameters so that the number of molecules
22 are acceptable. But the number of molecules will
23 not be zero, they will just be very small and a bit
24 of hydrochloric acid, just a trace.
25 MRS. FRACKE: Are you familiar
4
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19 1 with the Bridgeport incinerator in Bridgeport, New
2 Jersey?
3 MS. CHULIK: No, I'm not.
4 MRS. FRACKE: So far that hasn't
5 been able to pass toxic emissions tests from what I
6 understand, unless it has recently, the EPA's own
7 standards. And I think that's a brand new
8 incinerator.
9 MS. CHULIK: I'm not familiar with
10 that site. All I can tell you is that EPA's
11 incinerator experts have looked at this site and
12 feel that it is achievable to meet the emissions
13 control standards for the fluff material.
14 MRS. FRACKE: Have you any kind of
15 technical data on the type of incinerator and the
16 filters you use and scrubbers and the whole thing?
17 MS. CHULIK: Yeah, there's quite a
18 bit of information in the remedial investigation
19 report or actually the feasibility report.
20 MRS. FRACKE: Where do you get
21 that?
22 MS. CHULIK: It's in the
23 repository in the Rush Township Municipal Building,
24 and that's what we have available now, what's in the
25 administrative record there. When we go to the
flR500093
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1 design phase we'll be doing more detailed
2 engineering studies on exactly what kind of
3 scrubbers and particular control devices that are
4 needed to achieve the safe levels.
5 MS. BARNETT: Are there other
6 questions, comments?
7 MR. HALDEMAN: Charles Haldeman.
8 I'm a member of the Rush Township Environmental
9 Advisory Council, and I'm also vice president of the
10 Little Schuylkill Conservation Club. The first
11 question I would like to ask is who made the
12 remedial investigation?
13 MS. BARNETT: You mean who
14 performed it?
15 MR. HALDEMAN: Yeah, who made it?
16 who actually got out there in the field and did this
17 study?
18 MS. CHULIK: The AT&T Nassau
19 Metals and Theodore Sail, Incorporated, conducted
20 the remedial investigation. They hired a
21 contractor, environmental resources management, to
22 do the study.
23 MR. HALDEMAN: Okay. So what
24 you're saying is the person who owns that pile hired
25 someone to do a study to tell him what is in that
4
65
20 1 pile. Am I correct in saying that?
2 MS. CHULIK: That's true. With a
3 lot of other sites --
4 MR- HALDEMAN: Okay. Let me make
5 a point. I own a site that's potentially dangerous
6 that has contaminants on it, I go out to hire
7 somebody -- say I hire you, George, Mr. Pinkey, I
8 hire you to do a study for me. What do I want to
9 hear, a favorable study. How can we go definitely
10 by that study when it was actually the person that
11 owns that pile that had that study conducted? I
12 know if I had somebody doing something for me, I
13 ain't going to tell him I want to hear bad stuff.
14 Do you think they are going to want to hear bad
15 stuff? Do you think this study was very thorough?
16 Do you, as the EPA, in general think that study was
17 very thorough?
18 MS. CHULIK: I think the study was
19 very thorough or else we would not be approving the
20 documents.
21 MR. HALDEMAN: If you think the
22 study was very thorough, why was none of the fluff
23 stated anywhere found in the stream all the way down
24 to as low as Port Clinton?
25 MS. CHULIK: The remedial
flR500095
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20 1 , investigation report does say there was fluff found
2 down to Port Clinton.
3 MR. HALDEMAN: Well, why is there
4 no mention of it in the cleanup in there?
5 MS. CHULIK: There's a lot of
6 media to address at this site, a lot of different
7 kinds, and there were many different cleanup
8 alternatives proposed for a lot of the different
9 media. That particular area is one area that I
10 think we should look into a little bit more. We
11 talked about this, a couple of weeks ago you
12 mentioned that to me.
13 When these reports are submitted,
14 and I must say that I think this is a very good way
15 this whole process is done, getting the companies
16 that are responsible for the contamination at a site
17 to pay for these studies and to pay for -- hopefully
18 to pay for the cleanup, and so I think it's good
19 that it's done that way. When these reports come
20 into EPA we give them a very thorough review, and if
21 you open the administrative record you will see that
22 we submit a lot of comments back to them and ask
23 them — them being the responsible parties and their
24 contractor, to revise the reports where we think
25 it's necessary until we get the study to -- the
4
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20 1 reports to what we think is an acceptable format.
2 And the whole time that the field
3 work is going on there's EPA oversight out there.
4 We make sure that it's done correctly and we also
5 take split -- what we call split samples. When the
6 responsible company's contractor takes a sample, we
7 take half of that sample and we have them analyze it
8 at separate laboratories, and when we check that we
9 make sure that the answers come out the same so then
10 we know that everything is fine and --
11 MR. SMITH: I'd like to envelope
12 that point. We have a staff of 18 scientists, 6
13 toxicologists like me and 12 hydrogeologists who do
14 nothing but review these studies. We review the
15 preliminary data with the contractor to make sure
16 that the plan is planned right. There are people
17 that go out in the field who observe, we take split
18 samples, we review all the reports.
19 Everything we do is subject to EPA
20 scrutiny. I don't want you to think that this is
21 the fox watching the chickens or at least there's a
22 guy with the club watching the fox watching the
23 chickens, if you will. We are very careful with
24 these studies that they are done correctly. We are
25 extremely aggressive in our oversight.
flR500097
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1 MR. HALDEMAN: Okay. Another
2 thing that I didn't see on any of them was seepage
3 west of the site down close in proximity to the
4 Little Schuylkill River. It was tried to be passed
5 off as a mine acid discharge. There is no mines in
6 the area. It is seepage from that site.
7 MS. CHULIK: We know that there's
8 several seeps that empty into that stream which runs
9 along the southern boundary of the pile down to the
10 Little Schuylkill River. Four of these seeps were
11 sampled during the investigation. Now, the one
12 that's closest to the Little Schuylkill River, I
13 don't know if that one was sampled, but I know that
14 four were along that stream, so they were -- and as
15 I said during the presentation, we do believe that a
16 lot of that -- a lot of the seeps are coming from
17 the shallow ground water which currently underflows
18 the existing trench system, and that's why we want
19 to deepen the trench system to collect that
20 additional ground water and so we won't have any
21 more seeps.
22 (A brief recess was taken.)
23 MR. HALDEMAN: Going back to the
24 collection plan that is there. Your handout that
25 you had here, the second page, the third paragraph
4
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1 down it has that in 1974 the Pennsylvania Department
2 of Environmental Resources told them they had to put
3 that leachate plant there. Then down further on it
4 it has on it, the treatment plant is still operating
5 and is part of a leachate management system which
6 also includes erosion control measures.
7 Why is all that fluff in the river
8 down as far as Port Clinton if that plant is
9 working?
10 MS. CHULIK: Well --
11 MR. HALDEMAN: And you just said
12 just before that the plant has passed quarterly
13 inspections from DER.
14 MS. CHULIK: The surface water
15 diversion system that's there now needs improvement,
16 and that's what I -- it's what EPA has proposed in
17 the preferred plan. Certainly there's runoff on the
18 pile that's not all captured by those diversion
19 ditches because they needed to be upgraded, and some
20 of it -- since it isn't captured by the diversion
21 ditches, some of the fluff probably goes into the
22 stream and it is therefore washed down into the
23 stream.
24 MR. HALDEMAN: Okay. In 1976 when
25 the Little Schuylkill Conservation Club was first
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1 started and formed, we had Fish Commission personnel
2 up here for a tour of the river looking at it to see
3 what could possibly be done and how it looks. The
4 bottom hill right where Pine Creek flows into it
5 they saw the fluff and they said, what's this. We
6 told them what it was. They went to the plant and
7 they were fined right then and there.
8 Now that's the first and only time
9 that I know of that the Fish Commission did fine
10 them. Dick Marshall was the guy with the Fish
11 Commission that did the fining right on-site there.
12 Why since then -- and that was in '76 -- it was in
13 1974, why haven't they ever been -- this site is
14 still owned by that company, why -- and you just
15 said that they're passing inspections from the DER,
16 so why aren't they being fined or being mandated to
17 upgrade that collection system so that the fluff is
18 not allowed to go into the river?
19 MS. CHULIK: As I said, I have
20 checked with DER on several occasions, and just
21 recently, as a matter of fact, to make sure that
22 they were meeting their permit, and they are. And
23 Mr. Ziemba, if you would like to elaborate on that.
24 MR. ZIEMBA: First of all, you're
25 talking about fluff escaping into the Little
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1 Schuylkill and DER monitoring. What Christine is
2 talking about is the effluent discharge from the
3 wastewater treatment plant. As far as physical
4 particles of fluff getting past the barriers, that's
5 a different point, that's not something that the
6 Bureau of Water Quality and DER checks what --
7 MR. HALDEMAN: Doesn't that fall
8 under the Clean Stream Acts?
9 MR. ZIEMBA: It would if they knew
10 about it, but I haven't --
11 MR. HALDEMAN: Are you saying that
12 nobody has ever notified the DER?
13 MR. ZIEMBA: When is this fluff in
14 this river? Is it still continuing?
15 MR. HALDEMAN: Is it what?
16 MR. ZIEMBA: What period of time
17 are you talking about?
18 MR. HALDEMAN: Mostly periods of
19 high rains is when it flows into it, but it's there.
20 It's there from past years. Ever since the pile has
21 been there it's run off that -- it's flowed from the
22 pile down and into the river.
23 MR. ZIEMBA: All right. I'll look
24 into this and after the meeting is over I'll get
25 back to you.
f t R S O O I O l
72
1 MR. HALDEMAN: Another question I
2 have, if the hotspots are incinerated what's to say
3 that all the areas where potentially dangerous
4 contaminants were taken out?
5 MS. CHULIK: What we'll do as
6 we're excavating the material for incineration is to
7 sample the media as we're excavating it to make sure
8 that we get all the contaminated areas, at least in
9 that general localized area, and then when we
10 address -- when we address the remainder of the
11 fluff pile, depending on what the remedy is for
12 that, it involves excavating the pile in some way,
13 we would again sample as we were excavating it to
14 see if there were any areas that we missed.
15 MR. HALDEMAN: How is that pile
16 going to be excavated? You have a room here, fill
17 this room with the pile. It's surrounded by the
18 fence, that pile. Where are you going to excavate
19 it to?
20 MS. CHULIK: One of the remedies
21 that we're looking at, as I discussed before, is
22 recycling, and if --
23 MR. HALDEMAN: But I'm talking
24 about -- okay. That gets into OU4, that completely
25 gets rid of the pile is what I would like to see,
4
SR500IQ2
73
1 yes, I think what everybody -- but I'm saying with
2 your back onto your OU2's and 3's, you're saying
3 about limiting the hotspots. What if there's a
4 hotspot at the complete bottom down in the end of
5 that pile, where are you going to move the rest of
6 that pile to get to that hotspot?
7 MS. CHULIK: Well, this is what I
8 am trying to address, if you let me finish. One of
9 our alternatives is recycling. If we recycle the
10 material it would be excavated, okay, and as we were
11 excavating it we would sample it, because anything
12 that was too contaminated we couldn't recycle it
13 anyway, so we would eventually get to that corner of
14 the pile and we would treat that.
15 Another alternative is
16 incineration of the pile. That would involve
17 excavation of the entire pile. Some other
18 alternatives are capping the landfill and -- and
19 these are all discussed in the feasibility study,
20 and they don't -- they wouldn't address excavation
21 at all and they -- they wouldn't include excavation,
22 I should say. So that's basically how we would get
23 to any other contaminated areas of the pile.
24 MR. HALDEMAN: Under your
25 operative main units it has about the enhanced water
flR500103
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1 collection. Would that take care of fluff runoff
2 into the stream?
3 MS. CHULIK: Yeah, because we are
4 upgrading the surface water diversion ditches, so
5 that would capture any of the runoff fluff material.
6 MR. HALDEMAN: One other thing.
7 To me — and this really grated on my head, it
8 turned my stomach to hear you saying it on several
9 occasions, no receptors because it's State Game
10 Lands. That killed me. That kills me right here.
11 Who is to say that there is no receptor downstream?
12 Did you check any fish downstream? Were any fish
13 checked by your toxicologist? Were any of them
14 checked?
15 MS. CHULIK: The river was sampled
16 both upstream and downstream of the site and we
17 couldn't find any difference in the level of
18 contamination upstream or downstream because the
19 river is so impacted by acid mine rain. In other
20 words, there's a lot of contaminants in it now.
21 MR. HALDEMAN: But is there
22 contaminants downstream? Were the fish checked?
23 MS. CHULIK: No, there wasn't any.
24 MR. HALDEMAN: I catch fish in
25 that stream, one a mile --
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1 MR. SMITH: We typically did not
2 sample fish unless we have some evidence, a sediment
3 sample or water sample, that there's a pollutant
4 released by the site that is in the river. We did
5 not find significant levels of PCBs in either
6 sediments or water nor levels of dioxins
7 accumulated, so that if in fact you were to eat fish
8 from the river it might not be safe but it wouldn't
9 be unsafe because of the site.
10 MR. HALDEMAN: Okay. You do have
11 evidence of it downstream. If it would have been
12 mentioned or shown in your investigation of the
13 fluff, if the fluff is downstream, what's to say
14 that there is no contaminants downstream?
15 MR. SMITH: The problem of the
16 fluff,is it is highly visible stuff, colored wire
17 fragments, which you could easily see at the bottom.
18 That doesn't necessarily constitute toxic threat.
19 Obviously those pieces of fluff came from the site,
20 but their presence -- the presence of a few of these
21 pieces in the sediment does not necessarily
22 constitute toxic threat.
23 The material that has leaked from
24 the fluff, or a considerable amount of fluff, would
25 constitute a threat. Basically we could not find
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1 anything in the Little Schuylkill which suggested
2 that the site has any impact either on wildlife or
3 on people consuming the fish.
4 MR. HALDEMAN: You don't think —
5 or you're saying for sure that it will not have any
6 affect on wildlife as deer, rabbits, pheasants,
7 grouse, based -- okay, being shown on the map there
8 before ever wetlands area. Wetlands area has lots
9 of different flora in it. Now, what's to say
10 that —
11 MR. SMITH: This is totally
12 unassociated. We did include hunters and fishermen
13 in the risk assessment and made worst case
14 assumptions about what game animals and what fish
15 may have been contaminated and found the risks to be
16 not significant, but we did not sample the fish, we
17 did not feel that the particular parameters of the
18 site warranted that.
19 MR. HALDEMAN: But then there
20 still is a risk that somebody could shoot a pheasant
21 or shoot a deer that's been living down there in
22 these wetland areas and has eaten flora from down
23 there and has become contaminated from these
24 contaminants and that person could become
25 contaminated themselves.
4
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1 MR. SMITH: All we can say is that
2 based on our sample data we would find that to be
3 extremely unlikely.
4 MR. HALDEMAN: But then what yous
5 were saying there, what Christine said about four or
6 five times, about no receptors because it's State
7 Game Lands, I don't think that statement should be
8 said anymore.
9 MR. SMITH: But as I said, we did
10 assume that people would hunt and fish in the area
11 and we made worst case assumptions about what the
12 game and fish would contain, that risk was still not
13 significant.
14 MR. HALDEMAN: Okay. But there's
15 a possibility of a receptor --
16 MR. SMITH: Oh, absolutely.
17 MR. HALDEMAN: Well, then I say
18 that we shouldn't hear that statement no more that
19 there is no receptor downstream because it's State
20 Game Lands.
21 MR. SMITH: In fact, those were
22 included in the statement that there was no receptor
23 downgrading, and that's talking strictly ground
24 water. All were considered. All I can say is check
25 the risk assessment, it's in there. In fact, I can
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1 show you the tables, I have it right here. After
2 the meeting I'll be happy to show you the tables and
3 show you where those risks were considered.
4 MS. BARNETT: Do you have a
5 question?
6 MR. WESTON: My name is Walter
7 Weston, I'm presently the chairman of the Rush
8 Township Environmental Commission. I have a
9 question and a statement. At our preliminary
10 meeting several weeks ago I asked Christine a
11 question, and I must say that she returned my call
12 the next day, most of my questions were given by
13 Charlie, so my only question right now is when I
14 look at the hotspots in the pile, which is actually
15 two and a half percent of the total pile, I would
16 like to take a look at a pattern or statistically
17 look at how these samples were taken.
18 The statement that I received was
19 that it was in a certain section. I've looked
20 through the books up there for hours and hours,
21 okay. Could I get a number? All the pages and all
22 the manuals are listed as an AR number with six
23 digits after that. Could you give me some kind of
24 number where I could actually find the grid pattern
25 that was used to take these samples? You gave me a
4
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1 number of --
2 MS. CHULIK: Yeah, that's in the
3 remedial investigation report and there's a figure
4 which shows the grid pattern in that report. You
5 didn't find it -in there?
6 MR. WESTON: I'm sorry, I looked,
7 but all the -- there's approximately -- I'm not sure
8 if there's 11 or 12 black manuals up there in the
9 Township building, and every page is listed with an
10 AR number with six digits after that.
11 MS. CHULIK: Yeah, there's
12 separate reports that I dropped off the day that I
13 was up there.
14 MS. OPET: Carol Opet. There's
15 several, they're not in those black binders, but
16 they're in the file and that is the remedial
17 investigation report and the feasibility study
18 report and the risk assessments, they would be in
19 there. If you still can't find it, you_may call me.
20 MR. WESTON: Thank you.
21 MS. BARNETT: Other questions?
22 MRS. FRACKE: Mine is not a
23 question. I would like to address some of the
24 things that Charlie was asking. I think if you want
25 to find out more about how AT&T and the EPA have
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1 been doing studies on the Superfund sites that you
2 ought to call the concerned citizens of Foster
3 Township. I think they'll give you a real good
4 idea. They have not been very satisfied at all.
5 It's been going on a couple years
6 over there, and they don't think the EPA and AT&T
7 have been cooperative with always giving them the
8 information that they feel they are entitled to.
9 Also, there's something called the TAG grant that
10 maybe -- I don't know if you're familiar with that,
11 but you can apply for it. It's hell and high water
12 to get it and everything that's involved with it.
13 It's a lot of work.
14 The EPA will do everything to
15 support you even though it's by the EPA. It gives
16 the township people $50,000 to get your own experts
17 in — I believe that's how it works, to get your own
18 experts in to check and see that the EPA and AT & T
19 are doing things correctly and what not. Because,
20 again, EPA and industry are so close, they make
21 standards that only the industry can meet, and if
22 the industry can't meet them they lower standards so
23 they can meet them. This has been going on, I'm
24 afraid, too long and so you need somebody to watch
25 over both of them.
4
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81
1 MS. BARNETT: I can say a little
2 bit more about technical assistance grants. So far
3 we have a very good record at awarding technical
4 assistance grants. I don't know of anybody in
5 region 3, which is five states and the District of
6 Columbia, that has applied for this that has been
7 denied a grant.
8 MRS. FRACKE: I don't doubt they
9 have been denied, but it's the process of acquiring
10 it. It takes a lot of your time.
11 MS. BARNETT: There is a lot
12 involved in getting it.
13 MRS. FRACKE: I don't know any
14 Superfund cleanup that anybody has been actually --
15 any actual fulfilled cleanups that have ever been
16 totally accomplished yet, and it depends on what you
17 call clean. The EPA assessment clean might be
18 different from what you consider to be clean.
19 MS. BARNETT: Just to say a little
20 more about technical assistance grants, if anyone
21 wants to know more about it I would be happy to give
22 them lots of information. But the problem with all
23 the paperwork -- and I agree there's a lot of work
24 and there are people that are unhappy about the
25 amount of work, but this process where the citizens
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1 get the money, they have to adhere to all the
2 regulations using government money that we ourselves
3 have to adhere to and there's just no way to get
4 around it, so that is the unfortunate part of it.
5 But communities can get independent consultants to
6 tell them exactly how it's going, how's EPA doing on
7 this.
8 MRS. FRACKE: I think it's a good
9 idea. I think we should get to go and try to share
10 the load, not just a couple of people to do it, we
11 could share it with each other, I think, you know,
12 you'll get yourselves .real informed. You might not
13 enjoy it, I guarantee you won't, but it's something
14 you really should, you know, you have some real
15 valid concerns. I mean our government has not been
16 doing such a great job all these times or else we
17 won't have the Superfund sites and all the other
18 problems and they're creating more problems with
19 their cleanups, so called.
20 MS. BARNETT: Do we have other
21 questions or comments?
22 MRS. NOBEL: I have a question. I
23 think it's probably related to my question on
24 incineration, it's on page four and it's in
25 paragraph three and it says treating and removing
12
83
1 the hotspot fluff and soil areas will prevent any
2 future exposure, eliminate the toxicity of the
3 dioxin and PCBs by way of thermal destruction.
4 What's thermal destruction?
5 MS. CHULIK: Thermal is the
6 incineration process.
7 MRS. NOBEL: Because then it
8 continues, but it really is the same thing.
9 MS. BARNETT: Other questions or
10 comments?
11 MR. G. PINKEY: George Pinkey.
12 How bad would that have to be before it would be a
13 concern for people from Philadelphia and Pottstown
14 to drink water from the Schuylkill River? How many
15 parts per million or billion? That's not even
16 considered as a threat to Pottstown or the
17 Philadelphia drinking water, am I right or am I
18 wrong?
19 MR. SMITH: Actually, we studied
20 surface drinking water supplies extensively about
21 six years ago, and I had a half hour speech that I
22 used to give on this, but in essence what we found
23 was that there was very little chemical risk in the
24 raw water, that, in fact, when we chlorinated the
25 water we produced chloramines, we produced things
ftRSOQl 13
84
1 like chloroform and bromoform, basically
2 trichloroethylene compounds which increased the
3 carcinogenic risks about a hundred fold.
4 But the raw water has very little
5 chemical risk at all. And we sampled the water and
6 it was pretty good until we chlorinated it.
7 However, obviously chlorination destroys pathogens
8 and is a very destroyable thing to do, but from a
9 chemical point of view it makes the water more
10 interesting to drink, all the way up to about a 1 of
11 10,000 lifetime cancer risk if we're consuming two
12 liters of water per day. But, in fact, it's the
13 chlorination that does it, not necessarily the
14 quality of the raw water.
15 MR. G. PINKEY: Well, in 1962 at
16 the University of Maine I took probably what was one
17 of the first ecology courses offered at a
18 university, Dr. Holter was the professor, and I can
19 never forget the first class, he made the
20 statement -- and he didn't claim it as his own
21 statement, I think he might have said Albo Leopold,
22 but the solution to pollution was dilution, more or
23 less. Do you subscribe to that tenet as a
24 toxicologist?
25 MR. SMITH: From a toxicological
85
l point of view it's true. However, most of the laws
2 the EPA enforces specifically forbid that as a
3 solution. The point is destruction of the
4 pollutants or reduction in mobility or anything but
5 dilution.
6 MR. G. PINKEY: I don't want to
7 seem like I'm cross-examining, but I'm going to
8 anyway. If you were a resident of Pottstown that
9 derived their drinking water from the Schuylkill
10 River would what happens at the Diversified site be
11 of concern to you as a toxicologist?
12 MR. SMITH: You mean as a consumer
13 of drinking water in Philadelphia or —
14 MR. G. PINKEY: Well, again, I
15 think Pottstown is the first place down the way that
16 gets its drinking water from the Little Schuylkill
17 River. If you were a resident of Pottstown would
18 you be concerned with what happened at the
19 Diversified site as far as drinking that water?
20 MR. SMITH: From the point of view
21 of a resident down the river, no. I believe there
22 is very little concern related to the site. The
23 releases to the Little Schuylkill have been minimal.
24 MR. G. PINKEY: Now, earlier in
25 the evening when you people drew your water to wet
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1 , your throats, if someone put a pitcher from that
2 treatment plant on that table would you partake of
3 that water?
4 MR. SMITH: Yes, and if I lived in
5 Pottstown I assure you I would do the same thing.
6 MR. G. PINKEY: But I think that
7 the statement that there's no receptors downstream
8 should be struck from the record. I mean that's the
9 kind of scientific stuff that makes scientists look
10 bad. We have been told --
11 MR. SMITH: We simply said
12 downgrade, didn't we?
13 MS. CHULIK: Exactly, it was in
14 reference to ground water, downgrading from the
15 site.
16 MR. SMITH: What we were talking
17 about with that reference is the space between the
18 site where we know there is ground water
19 contamination and the Little Schuylkill River, that
20 little piece of land is the downgrading operative.
21 We believe that the Little Schuylkill intercepts all
22 that ground water and that, in fact, you have to
23 understand that levels of trichloroethylene in
24 ground water at a hundred parts per billion may be
25 only a gallon of trichloroethylene in that entire --
4
87
1 I mean we're talking about very, very small
2 quantities.
3 If you spilled a gallon of this
4 stuff you could very easily recreate that kind of
5 ground water contamination, so that this is seeping
6 into the river over a period of years is of
7 virtually no concern at all. And what does leach
8 into the river is volatile so it immediately goes
9 into the atmosphere, there's no concern downstream
10 as far as water quality when that downgrading
11 statement applies only to ground water.
12 We are evaluating the possibility
13 that someone will sink a well in that -- maybe what
14 is it, 200 yards or so between the pile and the
15 river, that is the only ground water we're worried
16 about.
17 MR. G. PINKEY: You're not worried
18 about the surface water. We addressed the surface
19 water, the fact that the fluff is as far as Port
20 Clinton, probably as far as the Delaware River Bay,
21 but the surface water and the ground water
22 eventually make their way into the Little Schuylkill
23 River and they work their way down, however slight
24 they are, I don't know. And I just can't -- you
25 know, if it's a whiskey glass of trichloroethylene,
flRSOOi 11
88
1 if I got caught in the reservoir I would be in big
2 trouble, big trouble. And I think that it has to be
3 addressed, the shallow ground water as well as the
4 deep ground water. And when that is cleaned up,
5 only then will that site be finally cleaned up.
6 MR- SMITH: Well, that's part of
7 the proposed plan, to further study the ground water
8 contamination, to figure out what to do about it.
9 That's still an open question and we have decided we
10 need to know more about the extent and depth of the
11 contamination in order to decide what has to be
12 done. So that's not being forgotten either. And as
13 for the downstream receptors, they're in the risk
14 assessment, they have been considered.
15 MRS. NOBEL: I have a question
16 about figure one, this regional topographic map, and
17 I'm wondering, when you show all these contours on
18 the map as far as topographical lines, is this
19 showing us the way this ground water flows from the
20 site? Is that what it's showing there?
21 MS. CHULIK: No. Those are
22 contours of land elevation.
23 MRS. NOBEL: Just land elevation,
24 it has nothing to do with the way the water is
25 flowing?
4
A R 5 0 0 I 1 8
89
1 MS. CHULIK: Well, not exactly. I
2 mean someone who knows how to read them would be
3 able to tell which way ground water was flowing from
4 the contours, however, this — to tell you ground
5 water is flowing towards the discharge areas which
6 were the — the stream — the shallow ground water,
7 the stream which is on the southern boundary of the
8 pile, and the deeper flowing towards the Little
9 Schuylkill River, so it's flowing in a southwest
10 direction.
11 MS. BARNETT: Any other questions
12 or comments?
13 MRS. MILLER: Helen Miller. When
14 are they going to clean it up or aren't they going
15 to clean it up? I mean you could study this for the
16 next 15, 20 years. It's been there how long? But
17 when are they going to do something about it?
18 MS. CHULIK: Well, the
19 consideration for the hotspot areas and the deepened
20 trench systems that collect the shallow ground water
21 will probably begin in 1993.
22 MRS. MILLER: Until that time we
23 have to live with the rest of it?
24 MS. CHULIK: As I said before,
25 these piles took a long time, the whole site took a
f l R S O O l 1 9
90
1 long time to create, you can't get -rid of it
2 overnight.
3 MRS. MILLER: What do you do when
4 you start out with those hotspots and they got put
5 into the plans?
6 MS. CHULIK: Well, that's not
7 going to happen in our --
8 MRS. MILLER: What are you —
9 MS. BARNETT: Hot doesn't mean hot
10 as in temperature. We're calling them hotspots
11 because there's contamination of a certain type.
12 MRS. MILLER: But you have heat
13 there.
14 MS. CHULIK: In the incinerator,
15 but very controlled temperatures.
16 MRS. MILLER: What about those
17 piles of insulation?
18 MS. BARNETT: We don't have any
19 significant heat there now that would start a fire
20 there, no.
21 MRS. MILLER: What happens if
22 there is underneath, and it's already down in the
23 coal mines, all right, the coal that's underneath
24 there?
25 MS. CHULIK: We don't have any
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1 . evidence of any significant amounts underneath the
2 pile for that.
3 MS- BARNETT: Do we have other
4 questions or comments?
5 MRS. HEITZLER: Virginia Heitzler.
6 Just how long are you working on this? How many
7 years are you looking into this? I heard you
8 mentioned 1972 or something like this. You had
9 records from so many years ago. Are you people
10 looking into this all this time?
11 MS. CHULIK: No. The various
12 parties have looked into this site over a period of
13 many years. As Daniel Pinkey said, first the
14 Pennsylvania Department of Health got involved then
15 the Pennsylvania Department of Environmental
16 Resources. EPA has been involved with the site
17 since 1985 when we first did our site investigations
18 and then we signed a consent order with AT&T Nassau
19 Metals and Theodore Sail, Incorporated to conduct a
20 remedial investigation, and that's been going on
21 until this time.
22 MRS, MILLER: Well, that's six
23 years and now you want two or three more years
24 before anything is done? I don't understand. I
25 really don't.
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1 MS. CHULIK: It's a very — it's a
2 very complex process, it just takes time.
3 MRS. MILLER: I can't see that
4 it's complex. Get rid of it.
5 MR. ANDERSON: Maybe it would be
6 useful just to talk about the steps. Remember on
7 the first chart where you talked about the record of
8 decision, then there was a remedial design and then
9 there's remedial action. Basically we're just short
10 of the record of decision which is a major step, and
11 I guess the most important step in this process, to
12 try to get a remedial action plan and to have it
13 actually begin.
14 Now, understand -- and I think
15 there might have been some misunderstanding, that
16 we're looking at this in three different pieces,
17 that the first piece is going to be this one
18 relatively small area, and I think we've been
19 through that. The other is to do further ground
20 water work, which I've heard a lot of comments
21 tonight indicating that that sounds like it might
22 still be necessary, that you're agreeing with that
23 to find out exactly how and to what extent and to
24 what depth, those kinds of things.
25 And then lastly, certainly by no
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1 means the smallest part of this but the largest part
2 of it, is the pile itself. What in the world do you
3 do with this, you know, small mountain of material.
4 I mean, someone said we'll put it in the room here.
5 Well, if you've seen it you probably know that it
6 would take probably a hundred rooms this size to
7 hold that volume of waste. And to just take it away
8 somewhere, we don't care where it goes, just take it
9 somewhere, can't work.
10 So there's just nowhere to take
11 it, we have to find some alternative, and those are
12 the kinds of things that we're looking at now rather
13 than wait until we have all three of those operable
14 units. Rather than wait any longer, what we've
15 decided to do is step forward and deal with what
16 appears to be some of the more important areas right
17 now, to make sure that there's a holding action
18 that's formed so that it doesn't continue any longer
19 to migrate off-site or to present a problem there on
20 the site itself.
21 Okay. And we are looking at --
22 and believe me, there have been groups of people
23 within the agency who have sat down and just
24 brainstormed as to what in the world you can do with
25 it. Hopefully some of the ones that we're looking
94
1 at now, which include some of the recycling options,
2 will prove viable to be something that we can do.
3 Again, once there's a record of
4 decision that begins a negotiation phase -- I'm just
5 going to give you the straight story as to what's
6 going to happen, because we're talking about
7 something that might take up to two years before
8 something begins to happen, when you see action on
9 the site. Then there is a negotiation phase where
10 we will attempt to get all of the potentially
11 responsible parties involved in the remedial action
12 itself. In other words, if they would implement the
13 action then the agency is making the decision. They
14 don't make the decision, the agency makes the
15 decision with your input, that's why we're here
16 tonight. I think it's important to understand that.
17 That typically takes something on
18 the order from anywhere from one month, and that
19 hardly ever happens in a month, up through four to
20 six months, okay. So there's a half of a year
21 that's gone at that point in time. Then the
22 remedial action, the remedial design phase begins,
23 that in this particular site will take anywhere from
24 six months probably to a year. Okay. So there we
25 are at one year to one and a half years, okay.
95
1 To be able to get all of the
2 material, all of the people, the individuals, the
3 contractors and all of that on-site, mobilized, is
4 going to take an additional several months, so
5 there's your two-year time frame in kind of monthly
6 blocks.
7 We wish we could make it faster,
8 you know, we've got orders to try to make it happen
9 faster. We've got people telling us to do it
10 faster, the same as you're telling us to do it
11 faster. We're trying to do the best we can. Just
12 telling us to get it done faster doesn't help us get
13 it done faster. We can input alternative innovative
14 ways and that doesn't necessarily mean that it's
15 going to happen faster.
16 MR. FROCKY: My name is Fred
17 Frocky. If you do plan an incinerator, incinerating
18 this, where does the ash go? What are you going to
19 do with it, the ash?
20 MS. CHULIK: The ash, as I said
21 before, will undergo a leaching test to see how much
22 lead it leaches. If these cement-type matrix to
23 bind the contaminants make them immobile, then it
24 will be taken to an off-site municipal landfill most
25 likely. It also could be consolidated with other
ftR50Q!25
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media on-site.
2 MR. FROCKY: That would be the
3 same process by stabilization?
4 MS. CHULIK: Right. And if it
5 doesn't leach too much lead then we can take it
6 straight to the municipal landfill or consolidate it
7 without stabilizing it.
8 MS. BARNETT: Okay. Do we have
9 other questions or comments? Okay. Before you go,
10 please take a moment to fill out that survey form so
11 we can try to make these documents more helpful.
12 Thank you very much for coming.
13 We really appreciate it.
14 (Meeting concluded at 10:00 p.m.)
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10 I hereby certify that the evidence
11 and proceedings are contained fully and accurately
12 in the notes taken by me of the testimony of the
13 within meeting, and that this is a correct
14 transcript of the same to the best of my ability.
15
16
17Mary EV Porter
18 Registered Professional ReporterNotary Public
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22The foregoing certification does not apply to any
23 reproduction of the same by any means unless underthe direct control and/or supervision of the
24 certifying reporter.
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