protect our woods, inc. appraisal of u.s. epa's ...makes a mockery of environmental justice and...
TRANSCRIPT
EPA Region 5 Records Ctr.
259512
PROTECT OUR WOODS, Inc. APPRAISAL OF U.S. EPA's (EPA) PROPOSED PLAN(PP) FOR THE RECORD OF DECISION AMENDMENT OPERABLE UNITS TWOAND THREE, LEMON LANE LANDFILL SUPERFUND SITE
BACKGROUND
LEMON LANE LANDFILL (LLL) WAS A COMMON DUMP THAT BECAME ATOXIC AND HAZARDOUS WASTE DUMP WHEN WESTINGHOUSE DUMPEDMANY THOUSANDS OF ELECTRICAL CAPACITORS FILLED WITH PCBs AT THESITE FROM 1958 UNTIL LATE 1964
EPA called Lemon Lane Landfill a "sanitary landfill" in their Five-Year ReviewReport for the Lemon Lane Landfill, June 2005 when they noted, page 8,
"The Lemon Lane Landfill was operated as a sanitary landfill from the late1930s to 1964."
When EPA called Lemon Lane Landfill again a "Sanitary Landfill" in theirproposed plan for final cleanup, it supported the idea to those who knew nothing of itshistory that it might really have been a sanitary landfill.
The question is, why did EPA call it a "sanitary landfill", a label that deliberatelymisleads the public and the present generation of Monroe County / City of Bloomington(MC / CB) citizens who have little knowledge or understanding of the history ofPCB-contamination of their environment?
None of the common dumps established at the time of LLL, (and made highly toxicby PCB-dumping) had liners when they became common dumps in those days, even thosesituated over KARST, and it must be remembered above all it is the SITUATION OF THEPCB SUPERFUND NATIONAL PRIORITY LIST (NPL) SITES OVER KARST THATMAKES THEIR TOXIC CONTENTS SO EASILY AVAILABLE TO OURENVIRONMENT, with leaching out of PCBs, etc. into the groundwater during storms andtheir discharge into the environment by many large and small springs.
The State of Indiana had Rules, and Regulations in effect for construction ofsanitary landfills by 1968 when Monroe County had to have a new landfill, and knew itmust conform to state standards, selecting a site on Anderson Road out of the karst region.The County learned that constructing a sanitary landfill was not easy, and it was not just amatter of a bottom liner, but the design of the landfill was important to keep leachate fromfouling Bean Blossom Creek.
No one ever thought it might become a PCB-Superfund Site, but it did andWestinghouse was again the culprit. It is listed in the annals that PCBs were dumped therefrom 1968 until 1972. The contamination was not on the scale of the other dumpings in
Karst, with an estimate of 21 tons excavated (Valentin, 1997) as soon as the Consent Decreewent into effect, but it was still shocking to the public.
In the literature, we have found both "sanitary landfill" and "municipal landfill" asmisnomers for the PCB superfund NPL Sites. We would like to request EPAs erroneousreferences to Lemon Lane Landfill as a "sanitary landfill" be retracted in The Herald -Times so the public knows that the PCB-Superfund National Priority List Sites that are inreality Dumps in KARST in Monroe County, were ever "sanitary landfills" but commondumps turned into Hazardous Waste Dumps by Westinghouse Electric Corporation whowantonly dumped in them many thousands of capacitors etc., and even dumped PCBs intothe Bloomington sewerage system ruining Bloomington's Winston-Thomas SewageTreatment Plant.
SIGNIFICANCE OF CITY OF BLOOMINGTON'S OWNERSHIP OF LEMON LANELANDFILL, AND THE FACT THE CITY OF BLOOMINGTON, MONROE COUNTY,INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT (IDEM) AND EPAARE CONSTITUTED BY EPA TO BE "THE GOVERNMENT PARTIES".
The City of Bloomington owns Lemon Lane Landfill and it is recognized by EPA tobe the most heavily contaminated of all the PCB Superfund Sites and Westinghouse wasrecognized as the Principal Responsible Party (PRP) not only for the six designated PCB-Superfund Sites but also for the Westinghouse Plant and Fell Iron and Metal Site.
CBS, Inc. bought out Westinghouse around 1991 and became the PRP until late2000 when Viacom bought out CBS and assumed being PRP. Viacom recently was grantedby the Court to change its name to CBS so CBS emerges again on the scene as a PrincipalConglomerate Entity for the cleanups?
EPA periodically and publicly has let the City of Bloomington and its citizens knowas the owner of LLL they are in a precarious position, intimating if there is an impassewith CBS the City could be held responsible. EPA has been suspending legal liability overthe head of the City of Bloomington like the Sword of Damocles, and the City does not havethe money to pay for it, nor do we believe they should.
At any rate the City of Bloomington is considered along with Monroe County andthe Indiana Department of Environmental Management (IDEM) and EPA as the"Government Parties" who seem to have approved in the past whatever EPA wants or iscurrently promoting. EPA is now promoting water treatment and sediment removal. Thepublic has always wanted COMPLETE REMOVAL, unanimously recommended by EPAsscientific consultants as the only viable solution in Karst and included in the ConsentDecree, yet we have heard some city officials are now supporting Water Removal.
There is a Memo from Monsanto to Westinghouse in the Westinghouse recordsinforming them of PCB toxicity and of the need to dispose of capacitors and PCBsseparately from ordinary municipal wastes, but Westinghouse did not "heed the information
or warning, which is ample basis for making the PRPs pay for it by an installment plan orwhatever can be negotiated, even perhaps some assistance hopefully from Superfund'srevival after the Bush Administration is a thing of the past.
AFTER 8 YEARS OF GLOBAL NEGOTIATIONS EPA AND CBS HAVE REACHED ANIMPASSE ON EPAs OPERABLE UNITS 2 AND 3 AND WATER TREATMENT AS AFINAL REMEDY FOR THE PCB-SUPERFUND NATIONAL PRIORITY LIST SITES
CBS recently initiated an appeal to the Federal Southern District Court of Indianafor a Magistrate Judge to help with decision-making, so EPA is back in Court with CBS.There is a long history of CBS opposition to EPAs equally long history of wanting to makeWater Treatment the final remedy for the PCB-Superfund National Priority List Sites.
EPA addressed Bennett's Dump first in an attempt to establish water treatment asa remedy at that site. It soon became clear that they have to know more about thehydrology and scope of contamination of Bennett's Dump. Three additional quarry pitswith capacitor parts and PCB-contaminated soil were discovered at Bennett's Dump butwere not excavated because of water in the pits.
John Foster, who capped Bennett's Dump Area, believes that EPA has still notidentified all of the old quarry pits that had been used for dumping capacitors andcapacitor parts (along with a mixed assortment of wastes) prior to Mr. Bennett's pouringrubble and fill over them to disguise them from authoritie that might make him responsiblefor cleaning up the hazardous waste dumping on his property.
EPA HAS NOT COMPLIED WITH THE PRINCIPAL MANDATE OF CERCLA TOPROTECT PUBLIC HEALTH AND THE ENVIRONMENT AND OTHERGOVERNMENT PARTIES APPROVED OF THE DECISIONS NEGOTIATED BY EPA
On March 16,2003, the public was notified by EPA that Operable Unit 1, theexcavation of the three National Priority list sites had failed since PCBs were still beingemitted into the environment from all three sites at the same high level as before theexcavation. . - - . . • t o , . . . . . .
EPA has not complied with the principal objective of CERCLA: TO PROTECTHUMAN HEALTH AND THE ENVIRONMENT since it assumed responsibility forsupervising the cleanup of MC / CB Community at the beginning of the early 1980s. All ofthe remedies negotiated thus far have been based on COST-EFFECTIVENESS and costeffectiveness should not take precedence over long-term Protection of Public Health andthe Environment.
1. The Consent Decree authorized complete removal of the PCB-contaminatedsoils and other materials from all of the PCB-Superfund Sites and a Westinghouse /O'Connor Rotary Kiln Incinerator fueled by City of Bloomington/s Municipal Solid Waste
(MSW) to incinerate the PCB toxic and hazardous wastes, with the City of Bloomingtonpaying tipping fees for disposal of the MSW that would help Westinghouse pay off the costof constructing and operating the incinerator. The public called this a "sweetheart deal."and rejected it because it was totally experimental.
The Administrative Record shows that the City of Bloomington had anunderstanding or "promise" that Westinghouse would construct a Pilot Project to showthat the burning of highly PCB-contaminated soils with MSW as fuel would actually workbut Westinghouse never built a Pilot Project.
The public also found by simply researching operation of incinerators at that timethat they had a history of malfunction and this was admitted by U.S. EPA in theirevaluation of Hazardous Waste Incineration as part of its filing of Rules and Regulationsfor Hazardous Waste Incineration in the Federal Register of 1990.
The public was slow to learn about the monumental size of the Hazardous WasteLandfill that would have resulted from incineration of an estimated 650,000 to 1,000,000cubic yards of highly PCB-contaminated soils, but when they did, a storm of oppositionstrengthened the public's opposition to incineration as a remedy.
The experimental nature of incineration per se has been shown in U.S. EPA-conducted research for DEVELOPMENT OF A HAZARDOUS WASTE INCINERATORTARGET ANALYTE LIST OF PRODUCTS OF INCOMPLETE COMBUSTION at theirNational Risk Management Research Laboratory, Research Triangle Park, NC 27711.
The tests performed under varied combustion conditions feeding a mixed surrogatewaste, resulted in the generation of numerous PICs. While many of these PICs wereidentified as target analytes using standard sampling and analytical methods, the majorityof PICs present in the incinerator emissions were not target analytes. Although asubstantial number of PICs have been tentatively identified, a considerably larger numberhad not been identified at the time the report was issued. The conclusion of the report was:
"the current sampling and analytical schemes for characterizing HWCemissions provide an incomplete picture of the emissions profile."
We believe we are vindicated by these pilot scale incineration experiments forBloomington public's rejection of incineration. The public had no say whatsoever in theformulation of the Consent Decree with incineration as the remedy, and EPA deb'beratelyrefused the public an RI / FS, a requirement of CERCLA, to enable the public to beincluded in the decision-making process BEFORE the final decision was made on theselection of incineration as a remedy. Region V EPA and their Program Managercontinually remind us of our rejection and say on page 2 of the PP for LLL:
Public opposition to the incinerator arose before and after entry of theConsent Decree, and notes further "The Indiana State Legislature, however,passed several laws that prevented any immediate consideration of CBS
application for the necessary permits to design and build the incinerator in1991"
No mention is made by EPA of their reasons for denying the public an RI /FS onthe Consent Decree nor any of their "Proposed Plans" to date. EPAs refusal of an RI/FShas excluded the public from a voice in decision-making at an appropriate time for over 20years. The Hearings on the "Proposed Plans" where the public is allowed to "comment"makes a mockery of environmental justice and EPAs preparation of a ResponsivenessSummary is in no way a substitute for an RI/FS.
The record of incineration speaks for itself and it is long past the time when EPAand Congress should have outlawed all incineration as a remedy for disposal of MSW andhazardous and toxic wastes et al, as air emissions of incinerators are significantcontributors to global warming, contributing an estimated 15 % of the toxic air emissionsthat have contributed to global warning and to what is considered a threat to survival oflife on earth as we know it.
EPA TELLS PUBLIC AT CIC MEETING NO ALTERNATIVES WOULD BECONSIDERED TO HOT SPOT CLEANUP
EPA informed the citizens attending a CIC meeting in 1998 that a "HOTSPOTCLEANUP" would be the remedy for excavation of PCBs at Lemon Lane Landfill NationalPriority List Sites and there would be NO ALTERNATIVES.
We learned at the Hearing of January 20,2000 on Lemon Lane Landfill that onlycomments on Operable Unit 1, excavation of "hot spots" cleanup at LLL, would be heardthat evening, and that Operable Units 2 and 3, would be on Water Treatment andSediment Removal, and we would have a separate hearing on those at a later time.
These were arbitrary and capricious acts, giving us no RI/FS on what they were"proposing" but telling us what we were going to get: 1. A Hot Spot only excavation as a"Cleanup", followed at a later date by 2. Water Treatment and Sediment Removal,eliminating us completely and effectively from the decision-making process as there were tobe NO ALTERNATIVES.
Actually in the PP for LLL of January 20000 one of the alternatives wasCOMPLETE REMOVAL. The only way we can look at it now is that it was included assop to citizens, and a treacherous bit of sop, for a long time later when we saw a copy ofthe Report and Recommendations of the Magistrate Judge, signed by Judge Dillin as anORDER on February 1,2000 it mentioned that EPA had "abandoned it" duringnegotiations with CBS probably as early as 1998 but had not notified the public in a newsrelease, nor followed procedures in the Organizing Principles of 1994 for making such adecision.
Cizens believe that EPA should have prepared an amendment to the ConsentDecree for such action knowing citizens had long wanted Complete Removal of PCBs from
the three NPL Sites, and believed COMPLETE REMOVAL was the heart and soul of theConsent Decree. We felt betrayed by an Agency that was supposed above all to ProtectPublic Health and the Environment.
We knew EPA was building a Water Treatment Plant (1000 gpm) with public fundsbecause it was something of a cause celebre, as CBS would have none of it. We also knewthat the first water storage tanks received for the project were defective (leaked) andpurchasing and installing 2 new 1.2 million gallon water tanks, an integral part of thedesign (capability) of the plant would delay its completion and it would not be operable intime for the "hot spot" excavation of LLL as supposedly planned for initially.
The ICSWTP was supposed to capture and treat ground water-bearing PCBsreleased into the environment at Illinois Central Spring up to and including a 25-yearstorm. EPA made it quite clear in their applications for money to build the plant that itschief raison d'etre was to capture and treat STORM WATER as storms were the time ofgreatest release of PCBs into the environment via groundwater. EPA called it a Time-Critical Removal Action when they applied for initial funding in 1998, and when itofficially went on line on August 1,2001 it was called a Pilot Project.
Earth Tech operated the Illinois Central Spring Water Treatment Plant during itsfirst three years of operation and prepared the monthly Reports on its operation withIDEM overseeing the plant's operation and issuing the Monthly Reports. Earth Tech andIDEM completed their 3-year period of operation and management of Illinois CentralSpring Water Treatment Plant on July 31,2001. EPA had expected that CBS would acceptmanagement of the ICSWTP at that time but they refused.
It appears to the public at this time Environmental Field Services (EPS) had beencontracted by the Government parties to operate the Plant, although in the EFS MonthlyReports they mention they are under contract with the City of Bloomington while sendingthe Reports to Jessica Fliss IDEM who is continuing as Project Manager.
This is somewhat confusing as we have also seen a reference to the fact all the Govt.Parties are involved in its operation. At the same time the public learned in the press thatWater Treatment would be changed from a removal action to a remedial action because ofCBS's rejection of operating the plant without an analysis and critique of its first threeyears of operation and why it qualified to become a final remedial action after its firstthree years of operation without a Report on it as an act of public accountability.
EPA GUARANTEES WATER TREATMENT WILL BE THE FINAL REMEDIALACTION FOR "CLEANUP" OF LEMON LANE LANDFILL BY STACKING THEDECK WITH FOUR ALTERNATIVES, ALL CONCERNED WITH SOME FORM OFWATER TREATMENT
As it has turned out, we have never had a Hearing on water treatment Proposed as aRemedial Action nor a Report on its performance in the past SIX YEARS of its failings
and problems as well as its capabilities and benefits. We have read the Monthly Reportsand know the ICSWTP has had a checkered history and raised questions without answersbeing an abbreviated type of reporting, although Earth Tech has to be commended for itsgraphic description of the January 4,2005 storm and the power of exceedingly highquantities of erosive sediment produced during a cloudburst-type storm, wrecking havocwith the complex processing system embodied in the ICSWTP. even to changing site ofemergence of ICS into the environment.
The four alternatives presented in this Proposed Plan are all concerned with someform of water removal and simply recognize that EPA has accepted WATER REMOVALAS A FAIT ACCOMPLI. AND ANNOUNCED IT AS SUCH ON PAGE 15 of the PP:
"The actions described in the Proposed Plan are intended to be the finalaction for the Lemon Lane Landfill and address both contaminatedgroundwater and sediment, known respectively as operable units 2 and 3.The source control operable unit 1 was completed in 2000 and addressed theprincipal threat waste."
It was disturbing to have Unit 1 described as a principal threat waste removal mustfor the word principal gives the impression it was at least an adequate removal which itwas not, so we address Unit 1 first.
How does U.S. EPA define "what is a principal threat" ? In the Lemon LaneLandfill Proposed Plan of January 2000 it states:
"Principal threat wastes" are those source materials considered to be highlytoxic or highly mobile that generally cannot be reliably contained or wouldpresent a significant risk to human health and the environment shouldexposure occur." and defines
"source material" as material that includes or contains hazardoussubstances, pollutants, or contaminants that act as a reservoir for migrationof contamination to groundwater, surface water, or air or acts as a source fordirect exposure."
These definitions define and characterize Monroe County / City of Bloomington'scontinuous and continuing contamination with PCBs (now 48 years and counting), andare particularly apropos since the PCBs are in landfills over KARST and "cannot bereliably contained."
We believe the way EPA used the words "addressed the principal threat waste" inthe Proposed Plan of January 2000 for excavation of Lemon Lane Landfill, was misleadingfor they estimated only 38,000 cubic yards of "hot spots" were to be removed, and (actuallyremoved a little over 80,000 tons because EPA required CBS to pursue "hot spots" thatwere very hot until they were below 100 ppm), but that left around 120,000 cubic yardsthat were not sampled nor excavated, of the estimated 200,000 cubic yards at LLL.
March 16,2003 an EPA news release was given to The Herald-Times sayingofficials were frustrated by the failure of excavations in 1999 of Bennett's Dump and Neal'sLandfill, and in 2000 at Lemon Lane Landfill, and were so quoted:
"We expected when we did the Bennett's Dump remedy that the water wouldclean up, or at least the levels would be reduced," but," We have not seenthat."
EPA removed 36,172 tons of PCB-contaminated material and 1,756 capacitorsfrom Bennett;'s Dump (from an estimated removal of 55,000 cubic yards). The less thanestimated amount may be partly due to the fact that they discovered three deep quarry pitswith capacitor parts and PCB-contaminated soils but were not equipped to pump-out thewater and clean up the PCB-contaminated pits at that time.
Many abandoned quarry pits at Bennetts were filled with a mish-mash of materials,large and small, in addition to contamination with capacitors etc. so they are a poisonousmess. It is widely believed that the contamination of Bennett's is more widespread thanrecognized, accounting for the fact that contamination of Stout's Creek continues at a highlevel. The geology and hydrology is complex, PCB- dumping and scavenging of capacitorswidespread, and the length of time before excavation occurred has given the PCBs plentyof time to infiltrate deeply into limestone bedrock.
John Foster who capped Bennett's believes EPA has not located some of theabandoned quarry pits that had been used for PCB-dumping as well as non-toxicmaterials. Bennett filled many of the Quarry Pits with rubble and covered them with soilas a disguise so he would not be held liable for toxic dumping.
Tom Alcamo, Project Manager, PCB Superfund Sites, Monroe County, in theMarch 16,2003 news release said that there were probably still greater issues than those atBennett's to deal with at Lemon Lane Landfill and Neal's Landfill for:
"After heavy rains, water carrying high levels of PCBs flushes from springsnear the dumps."
Citizens had protested the proposed cleanups at Neal's Landfill and Lemon LaneLandfill as absolutely insufficient, and that at NeaL's Landfill a:
c~s\ !
omplete travesty of a cleanup for a Landfill with 320,000 cubic yards ofPCB-contaminated soils and other PCB contaminated materials throughoutthe entire landfill and as far as we know 7,000 to 41,000 excavated(?) bed by
Tetra Tech that did the excavation for EPA, actually recommended that another morecomplete study be done during the excavation of Neal's Landfill but was turned down bythe "Government parties."
The Hot Spot Investigation, March 1998, in which CBS did 13 borings in onesection of Neal's Landfill, and Tetra Tech did the other 78 for a total of 91 samples, and
believed by EPA would determine the location of principal threat material (hot spots) wasdescribed as follows in a Soil Delineation Sampling and Analysis Plan by PSARATechnologies, Inc. for CBS, March 5,1999:
In March 1998, Tetra Tech and CBS performed a boring sample andanalysis program to determine hot spot areas (i.e., greater than 500 ppmPCBs) in Neal's Landfill. About 90 (actually 91) soil borings were drilledover a 100-ft grid system across the site. The volume of material defined toexhibit PCBs above 500 ppm, which will require excavation and offsitedisposal, was estimated at 7,000 cu yd. It was determined that approximately41,000 cu yd of additional landfill material will need to be excavated. Thisadditional material must be stockpiled and sampled to determine if any of itcontains PCBs exceeding 500. Also during this investigation, about 57,000 cuyd of soil and waste were found to contain PCBs less than 50 ppm. Thismaterial will be directly consolidated under a RCRA Subtitle C cap.
To have Neal's Landfill, an NPL Site "excavation" be based on hot spots greaterthan 500 ppm, is outrageous in itself, and to the public a miscarriage of justice.
To top that off, EPA had approved that CBS could reduce Neal's Landfill from 18to 10 acres which resulted in the mixing of PCB-contammated soils up to 500 ppm, withuntested PCB-contaminated soils in a high area of the landfill which CBS believed was outof reach of the groundwater rising up during storms that would leach out the PCBs.
This massive Consolidation Pile resulted in a great change in loading over karst.The cap represented a further increase in loading above the KARST, and while the publicdoes not know the full extent of what happened at Neal's Landfill as the result of thedrastic and significant movement of land to condense the size of the landfill, we havelearned from documents in the Administrative Record that the extensive southwest seepsdried up, there were changes in the flow of major springs in the Neal's Landfill Area, andthree new springs (or perhaps more were recorded in Conard's Branch.)
We believe that EPA should have investigated the extent of the changes caused bycondensing 18 acres to 10 acres over KARST at Neal's Landfill, and issued a Reportinforming the public of the significance of the resulting hydrological changes.
The Recommendations of the Magistrate Judge and Special Master Kennard P. Foster,whom Judge Hugh Dillin had appointed in 1997 to see that the aims of the Consent Decree,as modified by the orders of the Court, were carried out expeditiously. came somewhatbelatedly to public attention. The Report is signed by Judge Kennard Foster on January20,1999 and Judge Hugh Dillin signed it as an ORDER on February 1,1999.
Pages 4 and 5 of Kennard's Report, under the title of D. Outstanding Issues were ofgreat interest to us, noting:0 7 ° • . • • ( > < < « » f%> ft :• • • I I '• •,'•, . i • . , • •
"These unresolved issues chiefly concern treatment of water at Lemon Lane
Landfill, additional water treatment at Neal's Landfill, removal of sedimentfrom certain stream beds, and the governments potential claim for naturalresource damages and cost recovery. CBS contends that these claims arebarred by the Covenant Not to Sue in the Consent Decree and are notincluded within the parties' current agreements. The governments contendthat the parties agreed or understood that the consideration of watertreatment and sediment removal were integral to the targeted excavationscheme planned for Lemon Lane Landfill and Neal's Landfill as analternative to the now-abandoned complete excavation required in theConsent Decree. The governments want the issues of water treatment andsediment removal to be discussed on the scientific and technical merit ofwhat will protect public health and the environment; otherwise, the extent ofthe current targeted excavation scheme must be examined and possiblyreopened if significant public and environmental health risks remain aftertargeted excavation., followed by the notice,
CBS agrees to negotiate about additional water treatment and sediment removaland, if consensus is reached, willing to undertake water treatment and sediment removalbeyond the requirements of the Consent Decree, but CBS does not want to relinquishdefenses under the Consent Decree in advance of a consensus and does not want to face therisk of demands for additional excavations after having negotiated and completedexpensive targeted excavations.
Judge Foster concluded the Section on Outstanding issues with the notice that "Theparties will continue negotiations about water treatment and sediment removal, naturalresource damages, and cost recovery both during and after the excavation work.
It came as a shock to learn that water treatment and sediment removal wereintegral to the targeted excavation scheme planned for LLL and Neal's Landfill as analternative to the NOW-ABANDONED COMPLETE EXCAVATION REQUIRED INTHE CONSENT DECREE, for COMPLETE EXCAVATION is what we were working forthen, as now. and will be doing so in the future.
After the March 16,2003 news release to The Herald-Times informing the publicthat the excavations of all three PCB-SUPERFUND NPL SITES HAD FAILED, (from ourpoint of view,) ands since PCBs were still being released at the same high levels duringstorms as before the excavations, we began to wonder why EPA hadn't mentioned at aCIC meeting or wherever, that EPA was considering additional excavations at the NPLSites since significant public health and environmental public health risks remained aftertargeted excavation?
The answer undoubtedly is because EPA had a position firmly behind waterremoval as the final remedial action for the NPL Sites dating back at least to 1998 whenthey began seeking funding for ICSWTP as a solution for LLL, and improvement of the so-called Treatment Plant at Neal's Landfill which Tom Alcamo has even called a joke as it isonly capable of low level flows. Alcamo told us at a CIC meeting a year ago, after telling us
that there had been no progress in global negotiations with CBS, that they believed theywould have a good case against CBS in Court, but noting since you couldn't predict whatthe Court might do, taking CBS to Court had the lowest priority. So protection of PublicHealth and the Environment seems to have relatively NO priority after forty eight years ofunremitting exposure to PCBs released into our environment every time it rains or pours.
We are asking EPA to consider again COMPLETE REMOVAL as recommendedby their scientific consultants over 20 years ago who knew KARST as an unpredictableentity that cannot be controlled. We would add there are too many scientific uncertaintiesand too many questionable assumptions associated with water removal to make it adependable remedy in a KARST situation.
how KARST will react as a watershed in terms of more January 2004storms , and othertype Storms, which the ICSWTP could not cope with during the first 6 years of itsoperation not only because of inadequacies of the Treatment Plant, but because of theinadequate and wholly unacceptable excavations at the sites.
SUPERFUND REQUIRES LONG-TERM REMEDIAL ACTIONS FOR NATIONALPRIORITY LIST SITES
The four alternatives presented to the public in the PP for final cleanup of PCBsand semi-volatile and volatile organic compounds at LLL do not constitute for any of thesites what would be considered a LONG-TERM REMEDY. Doubts must be raised s totheir cost-effectiveness in terms of implementation over-time for storms during globalwarming are being predicted as not only likely to increase in strength and potentialdamages to lives and property but in frequency. We need complete removal of theremaining PCB-contaminated soils and other materials in the NPL Sites as soon aspossible and isolated or treated successfully to remove them completely from theenvironment.
What we need is another financial appraisal of costs with not only EPA and CBSinvolved but the PUBLIC represented in negotiations by a person who knows not only thenature of KARST but has a broad perspective, examines all the angles as to how it can besolved, with protection of public health and the environment a pivotal part of the decision.
We are opposed to water treatment as a final remedy for a number of reasons, but firstand foremost THE PCBs SHOULD BE CLEANED UP AT THE SOURCE. The excavationat Neal's was a farce, and while far better at LLL was not a solution by any means.LETTING THE PCBs LEACH OUT OF THE SOURCE FIRST INTO THE EPIKARSTAND THEN TRYING TO CAPTURE THEM IN THE GROUNDWATER ERUPTINGFROM A BIG SPRING DURING A STORM, IS A SOMETIME THING. The fact thatKarst may have a certain conduit under extreme conditions, and another one at less flowand so on is a likely possibility and since KARST is always evolving and changing you aregambling at what the future may bring. You can't depend on KARST and that is a truism.
.. v-iti t k.
Certainly ICSWTP may be useful as a removal action but not as a final remedy.
The public has been given no alternative to speak to or for in the Proposed Plan andsince we believe COMPLETE REMOVAL of the PCBs and other heavily-contaminatedmaterials at the three PCB Superfund NPL Sites is the only remedy that will give us long-term protection of public health and the environment in a KARST environment, we askEPA to recognize COMPLETE REMOVAL as the most important FIRST STEP. Acomplete or satisfactory cleanup of our entire community will take much longer after 48years of contamination by air and water.
ILLINOIS CENTRAL SPRING WATER TREATMENT PLANT AN OPEN-TO-THE-AIR REMEDIAL ACTION
We learned on January 8,2002 during a visit to the ILLINOIS CENTRAL SPRINGWATER TREATMENT PLANT (ICSWTP) that it was open to the air from start to finish.
From the time the Bloomington public learned that the stencb they were smelling atIllinois Central Spring especially during and after rains was PCB Arochlors, and that theywere toxic, the public wanted something done to eliminate the situation, knowing it wasnot a simple thing as other springs on the west side emitted the same smell, only not asoverwhelming.
In January 25,1994, the Fish and Wildlife Service, (F&WS) Bloomington FieldOffice, sent a letter to Dr. Greg Steele, Indiana State Department of Health (ISDH),Environmental Epidemiology Section, commenting on the ISDH 1993 Draft Report entitled"Preliminary Data and Pathway Analyses Report Evaluation for Consent Decree PCBSites. Under the Heading "Limitations of this Study" F&WS noted
"In several instances throughout the site-specific review and risk assessment,pathways remain unidentified largely because sampling efforts wereincomplete or absent. Much of the data cited in this report is of questionablevalue due to the superficial nature of the sampling efforts, lack of adequatesampling design to ensure representativeness, and undocumented qualityassurance information." concluding:
We believe that the data sets that have been collected for these sites in no wayrepresent a complete evaluation of what is necessary to adequately characterize the fate,extent and environmental risks associated with these sites.
Under Ambient Air Pathways F&WS noted: site-specific risk assessments should bedone utilizing Superfund's Public Health Evaluation (PHE) process to evaluate inhalationrisks., following this statement, noting:
"After major rainfall events, ambient air in the Stout's Creek corridor isnoticeably impaired and would appear to be a potentially significant risk to
residents of nearby homes. Similar ambient air situations occur aftermeasurable rainfall events in Conard's Branch, at the Illinois CentralRailroad Seeps (ICS), in the unnamed tributary to Clear Creek downstreamof the ICS, and Clear Creek. At Winston-Thomas, air quality near anddownwind of the sludge lagoon almost always is noticeably impaired.Calculated theoretical and laboratory volatilization rates for PCBs in waterare high (Mackay and Wolkoff, 1973, Uhlken et al 1973). The potentialpathway for ambient air should be listed as a present and a future risk forNeal's Landfill, Lemon Lane Landfill, ICS, and Winston-Thomas.
During the excavation of Lemon Lane Landfill in May through October 2000, theair emission rate became so high in July, with a high of 5630.6 ng/meter cubed on July17/2000, that Tom Alcamo, EPA's Program Manager, shut down excavation for nearly amonth and required CBS to make a Report on Probable Causes and steps to be taken toprevent future occurrence during the remaining period of excavation.
The public learned from CBS corporation's "Review of Probable Cause of ElevatedPCBs and Effectiveness of Mitigation Efforts (August 2000) that their mitigation effortshad been ineffective in suppressing release of PCBs into the atmosphere, and indeed mayhave promoted release from strength/rate of water application to suppress them.
After CBS presented a plan to EPA containing many ways they had adopted toprevent future high releases of PCBs, EPA granted CBS permission to resume excavationon August 16/2000, The Herald -Times had an article the next day noting that EPA haddistributed a flyer in the neighborhoods surrounding Lemon Lane Landfill that if releasesof PCBs climbed over EPAs action level (1000 ng/ m 3) that excavation would be stoppedimmediately..
However, on October 1,2000 PCB air emissions exceeded EPA's limit and therewere 25 releases and many near releases above EPAs action level until October 27 andvery high PCB cumulative mass releases at LLL recorded by the 8 monitors, butexcavation was not stopped. EPA had a news release to the H-Times on October 24,2000noting excavation was completed, but also noting for the first time that CBS had arecurrence of an old problem of elevated PCB air emissions and but that the situation wasOK and implying that they had the situation in hand, even though on the day of EPA'snews release the highest exceedance of EPAs action level (over 3400 ng/m cubed) wasrecorded and high exceedances were recorded through October 27 when the initialgeomembrane as part of the RCRA Cap had nearly covered the entire landfill.
EPA has ignored the lessons they should have learned from the monitoring of airemissions during the LLL and at a CIC meeting when Stuart Hill was reporting on theirRisk Assessment and only Dermal and Ingestien risks were mentioned and was asked howabout air emissions as a risk, said EPA did not think them significant.
This attitude of non-significance of airborne emissions ignores the fact thatPCBs are highly volatile and very much so during storms when there is
maximum turbulence.
Recognition that PCBs are highly volatile was not designed into the ICSWTP. Thefirst thing we learned when Joe Hailer and I visited the ICSWTP on January 8,2002 wasthere were no covers (lids) over the two 1.2 million gallon Storage Tanks even though theyknew the water directed from the Sump Room directly into the tanks during storms andlater directed from the storage tanks into the treatment plant for removal of PCBs wouldbe turbulent.
Those concerned with operation and management of ICSWTP made a plus out ofstorage in the tanks called "clarification", which recognized the fact that sediment carryingPCBs settled out in the tanks, but did not recognize that PCBs were capable of volatilizinginto the air when storm waters were over flowing the tanks and moving down Clear Creekto Salt Creek, or when at a later time the full tanks were being drained and water beingshuttled to the treatment plant, etc. Later we saw photos of Earth Tech using a carbonfilter to remove PCBs from water overflowing the ICSWTP but that would not preventPCBs from volatilizing into the air at the same time.
The Sump Room is probably the place where PCBs are the highest as the receivingpoint of the turbulent waters carrying the PCBs into the plant and so we have wonderedhow the ISPWT is coping with the capture of airborne PCBs. Joe Hailer, a Biochemist whovisited the plant with me, did comment then to those in charge of the plant that theopenness of the plant to the air was a concern. After the visit he wrote to Jessica Fliss,Program Manager, ICSWTP, and again expressed his concerns. She replied that workerexposure was below NIOSH standards for an 8-hour work day that included regular visitsto the SRS. nevertheless noting that:
"All workers are required to follow confined space entry procedures andwear a respirator when entering the lower sump in the SRS, noting that "therespirator equipment may be discontinued if the engineering controls areeffective."
Engineering controls, however, may not be efficient enough to handle stormsituations when storm water is directed immediately to the treatment facility or to storagetanks open to the environment. Actually the whole process of collecting, transport, andtreatment is involved especially during storms. We have seen no data base on monitoringair emissions where Illinois Central Spring enters the environment during storms underturbulence and that is necessary as a reference point as well as at other points in theprocess of moving storm water where PCBs may be consequently emitted into the air.
I he design of the treatment plant is basically deficient with no consideration ofthe high volatility of PCBs under storm conditions. Monitoring sludge andeffluent to determine the efficiency of the plant in removing PCBs from the
storm waters is a snare and a delusion. Sufficient monitoring of air emissions effectively isnot easy for it would have to be effective at a number of key points in the present design,
T!
so we take a jaundiced view of water treatment at the present plant. In fact, removing theremaining PCB- contaminated soils down to bedrock at the NPL Sites seems relatively easyso that a new look at comparative costs in terms of eliminating PCB contamination seemsin order.
One thing required in further excavation is an effective cover of the part of thelandfill being excavated, movable or otherwise, so that air emissions can be captured andappropriately disposed of, so they don't ride the air currents and contaminate the publichither and yond as in all previous excavations when they contaminated the public and theenvironment without restraint.
EPA mentions on page 22 of the PP that their approach is to control PCBs from thelandfill by treating the discharge from ICS, the upstream point where it is feasible tocapture the PCBs emergent from the groundwater system. Again, they forget it is not onlythe PCBs in the groundwater but also the PCBs that volatilize into the air that they mustcapture. It is not only by water but by air that PCBs have contaminated seemingly ourentire earth!
ElPA emphasizes furthermore in the PP that their goal is to REDUCE theamount of PCBs released into Clear Creek. That may be their goal, but they
(follow that up by saying that spring water bypassing the 1,000 gpm watertreatment plant occurs infrequently and occurs mainly during storm events. This is evenmore disturbing since the principal purpose of the Water Treatment Plant was to treatstorm events when they release highly significant amounts of PCBs into our atmosphere,streams, lakes and oceans etc. The infrequency of storms seems to be the main point.Storms are often "infrequent" but droughts are also a fact of life so the point they aretrying to make seems inconsequential, nevertheless to EPA it seems the heart of the matterfor they conclude that:
Due to the frequent and episodic nature of the PCB releases at ICS the largequantities of dense nonaqueous phase liquids (DNAPL) deep in the rock near the landfill,and the volume of water requiring treatment (from the watershed), EPA is proposing aTechnical Impracticability (TI) waiver of National Discharge Elimination System (NPDES)requirements for spring water which is not treated within the 1,000 gpm treatment plant.On the surface of this request whose complications do not seem adequately addressed, weoppose granting of this request until the public has opportunity to know what it reallyentails.
Submitted by Protect Our Woods, Inc.
Saralf Elizabeth Frc^freprcscntaUveTjuK 30,2006
State warns: Don'teat the fish in Cleai**$&New report saysthere are high levels ofcontaminants in water
H-T Report
Citing high levels of conta-minants, state officials are warn-ing people not to eat fish caughtin Clear Creek in Monroe Comi-ty and Salt Creek in LawrenceCounty and downstream ofClear Creek in Monroe County.
;The state has labeled thecjfeeks "group 5 waterways,"meaning no fish caught in theirwaters should be eaten becauseof high levels of PCBs, mercuryand other contaminants.
Public health advocates saythe state's annual warningsagainst eating some fish caughtin Indiana's waterways aren'treaching enough Hoosiers, lead-ing some people to unknow-ingly eat catches tainted withindustrial contaminants.
LaNetta Alexander, an envi-ronmental epidemiologist at theState Department of Health,said the agency has been work-ing to reach out to more low-income residents and those whomight eat fish caught in thestate's waters.
The state recently releasedan annual fish consumptionadvisory listing the waterwayswhere fish are tainted with mer-cury and PCBs, and detailingspecies with highest concen-trations.
The state health departmentproduces the fish consumptionadvisory with assistance fromother state agencies. Last year,no copies of the guide wereprinted, although the informa-tion was available online.
This year, Alexander said thestate has printed about 4,000copies of the guide — and
'Get the guide
For a free copy of the 2006 Indian;Fish Consumption Advisory Guide,call the State Department of Healtlat 317-351-7190, ext. 262, or clickon Data and Statistics atwww.in.gov/isdh/.
Eating fish safelyTips to reduce exposure to chemi-cals found in fish taken from Indi-ana waterways include:
• Release larger fish and keepsmaller ones for dinner. Small fishtaste better and are less contami-nated than older, larger fish.
s.
• Cut away the skin and as muchof the fat as possible for a bone-less, skinless fillet. PCBs collect infatty tissue, so removing fat willreduce exposure.
• Broil, bake or grill fish, rather ,than fry them, so the fat dripsaway, reducing levels of PCBs anddioxins.
• Avoid eating bottom-feeding fishsuch as carp and catfish, becausethey have more PCBs than leaner,predatory fish.
• Avoid largemouth bass, whichoften have high levels of mercury intheir tissue.
mailed three-quarters of thoseto state agencies and individu-als who requested them.
Russ Grunden, a spokesmanfor the Indiana Department ofNatural Resources, said theDNR is working with the healthdepartment on a Spanish-language version of the fish con-sumption guide, and is pro-ducing its own handout to edu-cate anglers about toxins in thestate's fish.
-'- o.
flr,
• / * • • ' •
fa
February 17,2004 ^
Indiana Department of Environmental Management vUL U 0Ms. Jessica Fliss • •,100 North Senate Ave. MONROE COUNTY PUBLIC LIBRARYP.O. Box 6015Indianapolis, IN 46206-6015
RE: ICS Treatment Facility -January 2004 - Monthly Operation Report
Dear Ms. Fliss:
In accordance with the Supplement to the Master Agreement for Hazardous Substance OrPetroleum Response Services between the Indiana Department of Environmental Management(IDEM) and Earth Tech, Inc. (Earth Tech or ET), enclosed is the Monthly Report of Operationsof the Illinois Central Spring Treatment Plant (ICS) located in Bloomington, Indiana for thereporting period of January 2004. This report is based on the most accurate information given the H
^marginjv£f rrnr JUKmr.iatgfTwith the flow-T'ftflS"remft"f devises used at the plant. _ j
Operational Status
Operations were relatively normal fpr fhe period: however, heavy rainfall within a short periodtime exacerbated a situation that is described below.
Highlights of the Month Included
Precipitation recorded for the month was 4.17 inches. The National Weather Service records rj /•show that the historical average rainfallTor tne month is 2.66 inches. The maximum rainfall ..during a 24-hour period occurred on January 4th with 2.47inches recorded. Approximately11.904,249 gallons of spring water was taken into storage with 17,249,610 gallons drained andprocessed through the treatment facility during the month. Approximately 1,269,456 gallonswere processed from the SRS tank. Approximately 10,634.793-galkms were discharged as SRSstorage Tank Overflow {clarifiejdTa^terlDueJo the extraordinary rainfaljeyent| approximately31.267 gallons were j?ypassed.The assoclffecnm^pected incident and corrective measurefs)
iponse are explained in greater detail below at Unexpected Corrective Measures "d."
Corrective Measures Taken or Planned in the Month
a. It was noted that the compressor drain valve was left in the open position?upon determination the valve was closed and alarm reset - also reset the autoreset on the compressor unit;
b. Heflin (contractor) was on site to repair the SRS building heater;
c. Routine preventative check of eyewash and shower units;
d. Backwashed all 800 pumps.
NOTE: This reporting is filed electronically with Uie Project Manager of the State of Indiana, Department of EnvironmentalManagement (IDEM). The original reporting including signatory requirements are maintained at the ICS Water Treatment Facility at1550 West Third St., Bloomington, Indiana 47403. Copies of this reporting are available for review upon written authorization of theIDEM Project Manager. The original documents on file at the ICS Water Treatment Facility shall prevail over any other suchoutstanding copy or reproduction. Discrepancies, changes, or modifications to copies should be confirmed with the originaldocumentation
1
*>m i-iv i i- 11 1 r/ivsii_i i CVCNI MINMLTC5IO
LineHo.
314
315
316
317
318
319
320
321
Sample Date
12/9/2004
12/16/2004
12/21/2004
12/28/2004
1/6/2005
1/13/2005
1/20/2005
1/27/2005
Time (Mil)
7:35
7:50
8:30
7:05
8:30
9:00
9:00
8:35
Sample Type
Auto.Samp.Bottle
No.
Grab
x
x
X
X
X
X
X
X
EventType
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Sample Identification
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
SpringFlow (gpm)
379
152
97
67
4032
1964
319
120
PCB
(Mg/l)
ND
ND
ND
-ND"
0.35
ND-
,.. -ND •
-ND •
TSS-
(mg/0<5
<5-
-<5
...,<5-,.
<5
.. <&..
, -<&'. .
, -<5 •
,.,„., Effluent
PH
' 6.82
• 6.71
- 6.91
-6.81
6.73
6.73
6.94
6.86
SG(mS/cm)
0.557
0.619
0.644
0.680
0.363
0.554
0.460
0.564
H20 Temp(Deg C)
16.8
15.5
16.1
15.2
16.5
16.0
12.7
15.5
Turb.(NTU)
0.188
0.095
0.080
0.094
6.080
0.315
1.210
0.203
DO(mg/i)
5.00
5.21
5.02
5.07
5.50
5.57
6.96
5.58
~~7 m^ ^ HBB^ HH£3BB99 BHHBnF
l«l|||||^^ !
Comment
NOTATIONS:E
FGBQLND
Sample Broken during Shipment...No Sample CollectedSample Broken @ LabBelow Qualification LimitsNon-Detect
Spring FlowStorm Event Influent
Weekly Influent
EffluentEPA Sample
As recorded by ISCO Flow MeterISCO Automated Sampler located at entrancThrough 1/31/02 Grab sample @ sample poAfter 1/31/02 Manual Mode - ISCO Auto sarrGrab Sample collected at entrance to Parsh<Testing conducted by Severn Trent Laboratc;
January _2005_Report_Data 24 if 4
Unexpected Maintenance Requirements
a. Call out alarm occurred during week of ending t) 1-02 due to the low level in^SSCKSHlrTalEs 1 arid 2 - the alarm was reset - but a power surge issuspected since the thickeners had only moderate levels of sludge/water inthem;
b.
rc.
Call out alarm on 01-03 for elevated pressure in bag filter- bag filters"replaced;
Call outalarm on OM)4 for SRS high level - the pump output had beenreduced"due to silt kithelSRS-- changed to other pumps to restore the 1000gpm proceiii -"the i>AS storage tanks overflowed since flow to tanks wasmeasured at 5000 gpm due to high rainfall event;^____
d. Another call out alarm on 01-04 - this time due to high pressure in the MMF-A&C_resulted in ~ 6 to 8 inrhf'j pf stanHing water in thp p^rrf (pressure_ _ _ _relieZyalves on MMF we™ HUr.hargjng watm- ontr. the floor of the plant) -corrective measure was to shut Hnwn all pumps except the SRS storagepumps allowing the plant floor to drain back to the SRS sump which allowed
"resetting ot the pressure relief valvesonjhe MMF fillers, which were thenprior"t6 Chanfee out orDieT)qg$ which were not operating.
prpperly due fo heavy silt loading. The facility was then placed on-line at1:30 am on 01-05 at a reduced rate of processing (800 gpm) due to theinability to run P-106 in auto mode (P-105 was still being repaired).Several calls were placed to BBC pump in reference to the status of P-106 -which has been repaired - PI06 was placed in service on 01-05 withrestoration of normal production rate.
A review of the records and inspections indicates that the air qnmpp"^"1'failed to automati^'ly ctart "n 01 -<u at 5:30 am- however/t^p p.ranfi^f.sludge niimns turner! nn and off and appeared to he fiinr.tinninp when, in fact.
there wqs no airflow to them, The a hnild up of sediment,which passed through the MMF and bag filters. Additionally, inspectionthe^spring area indicated thatthe spring opening had collapsed into the^ __hjjFside approximately \ and Vi teet apparently^due to the heavy rains. Also-evident during the inspection was that the SRS intake had approximately 1foot of seoTment build up at the bar grate and^Lffiptof sediment collected
Bunder trie Viacoinplatform which is located over the spring. It is also'- miSpeCLed Ihal IheswaTTow^hglesup gradient of the spring mayhave __
'coltapseo'Tritroa'ucing a considerable slug of sediment tnto the systernTPIansare Being developed to move the Viacom platform and clean out the sedimentpiles in the spring. The entire floor of the plant was pressure washed between01-05 and 01-06. Also the WIN system will be carefully reviewed tn_
jdetermine the reasonjpr the failure of the air compressor; a redundant or fail-safe system will be installed pending results of the investigation. Until _
,^CQiru2letion ofthejnvgstigation, the compressor is inspected on a daily basis^_
NOTE: This reporting is filed electronically with the Project Manager of the State of Indiana. Department of EnvironmentalManagement (IDEM). The original reporting including signatory requirements are maintained at the ICS Water Treatment Facility at1 550 West Third St., Bloomington, Indiana 47403. Copies of this reporting are available for review upon written authorization of theIDEM Project Manager. The original documents on file at the ICS Water Treatment Facility shall prevail over any other suchoutstanding copy or reproduction. Discrepancies, changes, or modifications to copies should be confirmed with the originaldocumentation.
ICS Water Treatment Facility 5/18/2004
Monthly STank Overflow
[Clarified](gal)
MonthlyTank Drained[Processed]
(gal)
Monthly-Bypass
Untreated(gal)
Total MonthlyWater Processed
(gal)
Monthly SRSTank Storage
(gal)
MonthlyRainfall(inches)
Water remaining In Tanks:291,635 gal
Jan-04 0.36' 392,311 Rainfall In evening
Jan-04 0.17 668 915.395 Rainfall early morning and occasional in evening
Jan-04 0.71 >.7xJ225 1,076.977 781,547 Rainfall in morning and afternoon
Jan-04 2.47 1938 1,024,751 3,126,190 2,666,025 31,267 Rainfall all day
Jan-04 0.01 3461 852,061 3,907,738 3,907,738Jan-04 0.00 2604 1,090,606 2,402,431 2,402,431Jan-04 0.00 1808 1.081.417 1,249,338 1,249,338Jan-04 0.00 1079 1,299,584 379,503 379,503Jan-04 0.00 786 1,140,591 29,758 29,758
10 Jan-04 0.00 566 982,442 35 152,91511 Jan-04 0.00 480 879,027 267,60212 Jan-04 0.00 403 723,907 344,06113 Jan-04 0.00 305 914,902 23,694 458,67814 Jan-04 0.01 238 308,234 4,015
15
18
Jan-04
Jan-04
Water remaining in tanks
0.03
19 Jan-04 0.00 317 393,365
20 Jan-04 0.00 247 370,456
21 Jan-04 0.00 232 349,146
22 Jan-04 0.00 204 294,798
23 Jan-04 0.00 186 283.090
24 Jan-04 0.00 167 240,079
25 Jan-04 0.00 156 224,372 5 inch snowfall
26 Jan-04 0.00 145 208,666
27 Jan-04 0.00 131 182,322 3 inch snowfall
28 Jan-04 0.00 113 179,266
29 Jan-04 0.00 108 120,271
30 Jan-0 0.00 104 177.189
31 Jan-0. 0.02 94 128.524
MonthlyAveFlow
(gpm)
Monthly SRSTank Drained[Processed]
(gal)
Monthly SRSBypass
[Untreated](gal)
Total MonthlyWater Processed
(gal)
MonthlyRainfall(Inches)
Monthly SRSTank Storage
(gal)
Monthly SRSTank Overflow
[Clarified] (gal
MonthUS 1 of 2
DEAL NG WITH PCBS
Excavation work doneat Lemon Lane LandfillCBS hopes to have sitecapped by end of year
By Steve Hinnefeld ^H;-T Staff Writer
CBS Corp. has finished digging upPCB-contaminated dirt and capacitors atdie; Lemon Lane Landfill and is racing thedock to complete the cleanup by Jan. I.
It's also battling an old problem thatresurfaced recently — higher-than-alknved PCB levels in the air around thelandfill
"We've still got a lot to do. We needgood weather to get done," said TomAlcamo, remedial project manager withihe US. Environmental ProtectionAgtsicy, which supervises the cleanup.
CBS inherited respohs^Mly for the
Lemon Lane Landfill cleanup
Workers havecompleted removalof PCB-contaira'natedmaterial at LemonLane Landfill and aretrying to finish thecleanup by Jan. 1.
STAFF MAP BY STEWART MOON
ExcavationT Excavation / from A1
Corp. It has removed 79,000 tons ofcontaminated soil and waste fromLnu wesibiue Bioomingron landfill.That's about twice as much as offi-cials estimated would be excavated.
H '.ilso removed more thsn 4 400Qprnn cH^cicitors, the source of thePCBs, or polychJorinated biphenyls.The capacitors were taken to a Texasincinerator for disposal. Soil andwaste went to a hazardous wastelandfill in Michigan, with the lasttruckJoad leaving BloomingtonTuesday.
Now CBS contractors are gradingthe landfill surface and starting toinstall a synthetic liner that's sup-posed to repel water and preventremaining PCBs from washing into
egrading and earth-movingwork apparently caused a rise inPCBs detected last week by air moni-tors near the landfill, Alcamo said."The risks are OK but we're keepingour eyeson it," he saioV
nvolved removinghighly contaminated "hot spots"from the landfill but leaving somePCB-contaminated material at thesite. Generally speaking, areas withPCBs at concentrations above 50parts per million were removed.
Lemon Lane, a former Bloom-ington city dump, is one of several^rpa sites where CBS has bsenremoving PCB-laced material inrecent years. The chemicals, l inkwi
unvu on-mental problems, were used byWestinghouse in making electricalcapacitors at a Bloomington factory.
Work "started at Lerriotv l^anfrLandfill in Thp spring But the EPAshut it down in July because PCB lev-eis in the air were threatening toexceed agency safety limits.
The EPA says public health will
done at LaneL
< , - « , - * .—™~™ dahlpandj-edti^iaaslJiJi« ^ <£• ;£1 &iw tasfcifceAS *.w \sLAffi
an effort to reduce the PCB levels intheair.
J6hn Langley, environmentalprojects coordinator for the city ofBloormngton, said, the • dfeanupseemis to havegone well stffer"1
the grbundwater around that1 siteJand iriake sure the^tejped^ we've, implemented is t "
, Alcanto said thedutto bie ipwry bit tis^coritanliliated
r as OfficiaiSreXpeBted. 'Whde the PCBs were durfaped
thereon fhe late 1930s and496Gfe, the* 'ChBrinfeafe don't break dowra-Hte the: environment The:heatviest cdritami-r
nation, was on the south and westsidesT of the landfill. At one ppint>Aicamo said, GBS d^30 feetdeep inlayers:(Jf liraesttoe flWerrwredsEl^K'
,,*GSfrfH&ui&&- —>"' •'^ **r*r-. ^;\S' '•• •,,.:?
workirtg under a deadlirieinipo^ed;by,U.S.,^District^^Jadgfe S:
Workers exeaVate down to about 29 feet, below the rock surface
ed materials at the site. Excavation at the ails, is now? cornpieteaand officials hope the cleanup project will be finished by Jan. 1.COURTESY PHOTO - •
- wJli^eoyer -die isntlietic linsr: -inciu
and top tfeMer,; The material worteweW
; piaee, wJheHftfiebe protected if average PCB levels while the"pro'ject wasdon't exceed 1,000 nanograms per The fernilies'Tet'arned home "lastcubic meterofaa. Ahanogfcim is one
Uies^ftom homes rteat die landfill
^ *»!?•<
feW|&;mostofiheT. Contractors [email protected].
6.1J46 Federal Register./ VoL 65^ No, 46 / Thursday, March S, 1990 / Ruted ami Regulations
{d) Ml appropriate Fund-financedM;spo;wC Bfkdjsr CERGLA has beenimpleiti'SnledL end no further responseuctioaby resp<nis41)l<5 pai:lios is.•appropriate; &r
(iii; 'Ilie.rcme.duil Investigation hasshown that the release posas nofiigni.kant threat to public health or'-tjiecnvii •on.'Tient ar.d, therefore-, taking ofrerm d ie l mcaniires is not appropriate.
[2j. KeJeasca i.'hall rot be deleted fromthe HFl. until the stale hi which thereleuse was located has concurred onthe proposed deletion.- EPA shallprovider the jiiate 3C 'rvprkuag days forreview of the deletion notice prior to itspublication in the Federal Register.
(.' J AH nrfiMse-j defend from the NPI,ere eligible for fiirilTjr Fund-financedretrietfial actions should" futurecor ditlons •warrant .-such action.Wl leii'jver there iee. significant releasefrom e sftedeFeled from the- NFL, thesiti! shall be restored to the NPL withoutap dk/alion af tlie HR8.
1 4) To ensure pul-lic Involvementduring (he proposal.' to delete a releasefn-.rn foe- NPL, EPA shall:
. (i) Publisih a 'notice of intent (o defefein the Federal Rcjpstcrand solicitctamdent through 11 public- commentpuriod of H Efriiurrrtim of SO calendard iys:
(i i j In a ncijor local newspaper ofgeneral ctk-c-ulalioiLaJt ox near the releasetliat i» projwsed for deletion, publish a
.notice of avai'liibi ily of the notice ofi iliyit to delete:
(i i i) Place copies of informationi: uppartiii^; (ltd proposed deletion in themfonaaticiii repository. described ia•j .-(()0.43&(c)(ZJ(iii|, at or near the releaseproposed far deletion. Tliese items shallbe; a\;ailii'aljc. fw puWic inspection andcopying; ami
[i\\ Rwijicind t'j each significantcoirunen.t uriiany significant new datasubiniUttl durinj; the comment periodand fncltide: this response document inthe final deletion package.
(5) EI'A shall place the final deletionptickaga In 'tlie lociil Informationrcposllor,' once the notice of finnldolct ion has been published in theFederal Kejjisi.cr.
Heri>?dJat Investlgatkjn/.)' study and telectlon of remedy.
(a) Gztierui'— -(1J Introduction. Thepurponi: of the remedy selection processis to iinplctnen.t remedies that eliminate,i educe -or control risks to human healthnnd tin: envinmnicnt. Remedial actionsare to 'ao implemented ag soon as sitedate and Infoi-mation make it possible todo so. Accordingly, EPA has establishedthe followin.? program goal,expeztntloai, arid program managementprinciple.1! to asj:ist in the identification
end implementation of approprialeremedial actions.
') Program goal The national goul ofthe remedy sdectron process Is to selectj|remedies thai are protective of humnnhealth and the environment, thatmaintain- protection over time, and that/minimize untreated waste!
. cqnsidfijr thefollowing gene/al pfiacipIes'bT programmanagement during the remedialprocess;
(A) Sites should generally beremediated to. operable units when earlyactions aw*necessary or appropriale toachieve significant risk reductionquickly, when.phased analysis andresponse ia necessary or appropriategiven the size or complexity of the site,oc to expedite tbe completion of totalsite cleanup.
(B) Operable units, including interimaction operable units, should not beinconsistent with nor precludeimplementation of the expected finalremedy.
(C) Site-specific data needs, theevaluation, of alternatives, and thedocumentation of. the selected remedyshould reflect, the scope and complexityof the site problems being addressed.
(iif) Expectations. EPA generally shallconsider the following expectations indeveloping appropriate remedialalternatives:
(AJ EPA expects to use treatment toaddress the principal threats posed by aaite, wherever practicable. Principalthreats for which treatment is mostlikely to be appropriate include Liquids,areas contaminated with highconcentrations of toxic compounds, andhighly mobile materials.
ffl) EPA expects to use engineeringcontrols, such as containment, for wastethat poses a relatively low long-termthreat or where treatment tsimpracticable.
(C) EPA expects to use a combinalionof methods, as appropriate, to achieveprotection of human health and theenvironment. In appropriate sitesituations, treatment of the principalthreats posed by a site, with priorityplaced on treating waste thai is l iquid,highly toxic or highly mobile, will becombined with engineering controls(such as containment) and insti tut ionalcontrols, as appropriate, for treatmentresiduals and untreated waste.
(DJ F.PA expects to use institutionalcontrols such as water use and deedrestrictions to supplement engineeringcontrols as appropriate for short- andlong-term management to prevent orlimit exposure to hazardous substances,pollutants, or contaminants. Institutionalcontrols may be used during the conduct
of the remedialinvestigation/fetfsibilitystudy (Rl/FSf and implementation «f theremedial action and. whore necossirry,as a component of the completedremedy. The use of institutional coatrolssh,all not subs t i tu te far active respcmsanjesaures (e.g., treatment and/orcontainment of source material.
' restorah'on of ground waters to theirbeneficial uses] as tie sole remedyunless such active measures aredetermined not to be practicable, bonedon the balancing of trade-offs amongalternatives that is conducted during: thi;selection of remedy.
Pi) ETA expects '.o consider usinginnovative; technology when suchtechnology offers the potential forcoflaparabie o* superior treatmentperformance oc iin;plen%eatabilily, feweror lesser adverseimpact* than oihera\-ailable approadies. c« lower costs forsimilar bveb of rxyionnance tliondemonstiated teclinotogies.
(F) EPA expects to return usabfeground waters to- 'their benefrcial u;w?swherever practictible, within atimefrsme that 19 reascfnable given th<particrfarcircmnMtant;es of the site.When restoration of ground water tobeneficial uses is not practicable, EPAexfKrtIs to prevent further migration ofthe plume, prevent exposure to thecontemplated ground water, andeva lua te further risk reduction
(2) Remedial investigatlon/fnaf.ibi.'ityA'furfy.The purpose of the remedialinvestigation/feasibility study (RI/FS) isto assess site conditions and evaluatealternatives to the extent necessary toselect a remedy. Developing a.ndconducting an Fll/FS generally includestin; following activities: project scoj'ing,data collection., risk assessnionl,trea.tability/ stttiies; and analysis ofalternatives. Tlie scope and tiriung of
e _anil the response ijlterna'tFvesDeGiR-- T --- ----- . ''
(b] Scaping. In implementing lhi«;sei^ion, the lead agency should conside-tin; program goal program managementprintHpUjs. and expectations containedin this rule. Trie investigative andanalytical studies should be tailored tosile cireomstiinces so that tl'ie scope andirfai! of the analysis I5"Spipfgjf»riaie_lo_.
__uririg scoping, the lead ar
'support agencies shall coiil'er to identi.tlie optimal eel and sefjuence of actionnecessary to adifrcss site probleiiis.S'ipccificalry, the lead ageri'i.'y uha'fb
(i) Assemble and evaluate existingda ta on the site, including the resultsany removal actions, remi.'dinl
EFA - 560/7-76-001
. REVIEW OF FCB LEVELS Iff THE" ENVIRONMENT ;. ;.: ;';: \:...;
• -%.-(;:••:?£••;:>•.rvi:s • *s ;'.:'L%'•:'•''-.'••• ••-','V:,'-.-':/.':> '•' -,- ;•>"•-f :':•&"''-•i-Ji\-'\*::':•• •••:--;" • • -;' :
e£fluenc reflected the di f ferent water solubility and adsorption prop«rti,?harieterlsclc of the Arsclor 1016 iaoners. Th« l«si chlorinated t«o»trsere core readily leached. Results froa th«s« txpcriaencs art ihovn inlgv;ri 3-1, •-•hiri >u Atotlor 1016 and 1221 standard solution ii coapartdith the leached mixture. A .32mm id x 50m flai* capillary coltnmoated wich OV-101 vas used for these separation*. The flov r»ti vas
nil/tQin heliua and the column temperature vas protrasned froa 150* to230"C at 2*C/mln. The resulting iion<r dlitribucior. is lijtvtficir,:ljcnanged from tha itartlng Aroclor 1016 and hat a closer res«mbl«rn-«:; ;.'i« immmt pat tern o: Aroclor 1221. In the worse case, less than 0.03"of the total Aroclor 1016 available vas leached under conditions equivaltrto forty years of annual rainfall.
Adsorption and evaporation studies' wich Aroclor 1254 on differentsoils show chat due to the few adsorption sites In (and, sand surfacesadsorb relatively small amounts when coapared Co the other types of soils.Consequently cha vaporization loss froa a sand surface will b« signifi-cantly higher than soil surfaces where it is more tightly bound. Theless chlorinated isoaers show a greater loss than those laooers of highChlorine content.
3.4 Evaporation of PCB's from Water - ^*
The transfer of PCB's fron water to the air environment may besignificantly faster than expected when considering that these compoundshava a high nolecular weight, low solubilities end low vapor pressures'•'.On exa&inatloa, these compounds exhibit very high ectlvity coefficientsin aquecuj solution resulting in high equilibrium vapor partial pressuresand consequently hirhev^gcjajion ratjf. The rates ere relatively Insen-sitWe^^^^^apWTTiTm^^^TWr^dlffirent Aroclor products, the evaporationproctss is complex depending on the chloroblphenyl isooers present, jleading to different isomer concentrations In each phase with time. Thecalculated half-^ives for Aroclor 1242 and 1254 for a water depth of onenecer are 12.1 and 10T3Jiours respectively. Dsing the half-life values.^if a aonltorlng station is located one hour downstream froa e source ofAroclor 1242, by che time the water reaches the station, approximatelyone twentieth of the initial levels may have been evaporated. Wh-tre the""er body is turbulent^ the evaporation rate will he i^ere||ejl'sltnltl-
a—BST-3.5 Environmental Sampling Guidelines
lased on these limited studies, the following guidelines endpreciucions are suggested:
(1) laboratory measurements of field samples should be ate4e asGOCTi as puaa iu le ;
(2) concentration level* nf fl^ld s plc:: w^«wr«il In Cnm i«borvill be IO-CL tn«u nccuai concentrations;
'.3} concentration level i in vacsr niy bs auch lower in «oftM» »r*depending on rhe ty^e af surrpp-^e-d ^---ic-lita skitt i. ,
samples;
JAN "< 2 2005
EST STATE ROAD 32WESTFIELD, INDIANA 46074TELEPHONE: (317) 896-1116
FAX: (317) 896-1118
ENVIRONMENTAL FIELD SERVICES, INC.
September 15,2005
Ms. Jessica FlissProject ManagerIndiana Department of Environmental Management100 North Senate Ave.P.O. Box 6015Indianapolis, IN 46206-6015
Re: Illinois Central Spring Treatment PlantBloomington, IndianaMonthly Operation ReportAugust 2005
Dear Ms. Fliss:
In accordance with the current contract with the City of Bloomington, EnvironmentalField Services, Inc. (EPS) is pleased to provide you with this Monthly Report ofOperations of the Illinois Central Spring Treatment Plant (ICSTP) located inBloomington, Indiana for the reporting month of August 2005.
Highlights of the Month
Precipitation recorded for the month was 6.63 inches. The National Weather Servicerecords show that the historical average rainfall for the month is 3.99 inches. Themaximum rainfalls during a 24-hour period occurred on August 30th with 2.58 inchesbeing recorded. Complete precipitation data for the month is included in Attachment A.
All water coming into the plant was processed for a total of approximately 5,407,755gallons during the month. The average flow for the month was 180.1 gpm. Completeflow data is included in Attachment B. This flow data is based on the most accurateinformation available given the margin of error and tolerance of flow measuremeTTF
"associated with the instrumentation utilized at the plant. ^
)FALiNG WITH PCB8
PCBs still
3ff iciais 1 r ustraix'd>v fai lure o f cleanup o .
3y Stove Hinn e'teld -- •••;H-T Staff Writer \ '
It has bet-n 2W: years jitijis Viacom
wasM! from. Ben-lett's Di.nr.jD n( rthwest of Blooming-o n . ' • • • •
But low levels of tine chemicalsremajn in springs diat flow from underthe site, confo .inding the hopes ofcleanup off idals ./•
"We expected iliat when v/e (id iheBennett's Dump remedy, {hut the.yajer.would d«:an up^jj^atjejyiLJllfiLle^sj woal<i_b« jwiyceji:. |aicl Tt)tnM'camo, reiiiedi ;i| piroject nviriager forthe U.S. Iirivii urimental Protection '
."We have net 5;t«n_that. IhejiJiid,So trie EVA 1 5 -undertiild^i; a njview
af the Bennett's Dump cleanup. Underfederal Superfurul regtLitions. the
h>See PCBEf / Eaok
-.«^ci,uauinu resources""'** " '
STAFF MAP BY STEVE SNYtfERi , - ;r"
- • • « ! "In the know
Detailed information about PCBsites in the Bloomington area is avail-able from the Web JMteof the CoaHJioROpposed to PCB Ash'JOMonroe *'••'County. The site is at www.copa.offl.
. ,f. i,(--if^:,-<:-i.J ,-' 5*l"£{'it j3issues jgatjoernam ami weto'' t * '• •?T-B-"--. ^ <,' i' *' '• i»"-'- l!i
the issujBisflistead ofpnt''
But the idea of .mjgqti^ti^qs ifiwhichf prpgi-ess on one issue^cpUjy; txj'
troubleS^iike Bakier of |h^?^^^JrfOpposecJ: tg PCB;. Ash ''in''MoinnM:County.
"WeVe l3a;n...makes ;' me.said., .'•"
He said dcsed-doojrnejgptiatipnjiled to a aintroversial pkin iri'.the1980s tp incinerate the ai^a's PCBwastes^ His| group >vvas fROped tooppose trie incinerator and.coiitin-ued to monitor the cleanup) after" theidea vyas^crapped.: \ '
BaSer ia'dr ,
some pe«ple would llii'ip ijuerwise/- ."I believe thepretty yyeD v/ashed thejiriiarids of it,"he said,': "thinking tfi5s]|r've"done"'"<illthis excavation and jreniediauoo,therefcaek's over.
Reporl&t Sieve Hinnvfetd cart toereached at 331-4374 or by o-maS athinnefBfd9hi3raidt.com.
til
V \/ J i)
PHL4-
M E M O R A N D U M cc: Barbara Magej, JEPA
)TO: For The Record
FROM: Philip E. LaMoreaux, Sr. (. .
SUBJECT: EPA/Bloomington Sites - Remedial Alternative
(PELA File No. 451000) ' VV^.r
DATE: August 1, 1984
On the basis of data obtained to date on the geology and hydro-
logy of Meal's Landfill, Lemon Lane Landfill, Bennett's Dump and the
Winston-Thomas Treatment Plant, it is concluded that pumping and
purging of groundwater and leachate is not an economically feasible
remedial action at those sites. Neal's Landfill and Lemon Lane Landfill
are in a karst region typified by sinkholes, solution channels, fractures
and cavernous limestone. Although these karstic features are not
readily apparent on the surface near Bennett's Dump and the Winston-
Thomas Treatment Plant, it is probable that solution channels, fractures
and cavernous limestone underlie the sites (literature references indi-
cate that the geologic formation underlying the sites are karstified in
other areas in the vicinity.)
Pumping and purging of groundwater and leachate is a complex
problem in a karst area due to the groundwater flow~$ystem. Ground-
water flow is via numerous discrete, solution channels oriented along
joint/fracture and bedding planes. Also, the location of the discharge
points of groundwater in karst regions may vary with changes of stor-
age of groundwater in the system. For example, as water levels rise or
decline, the direction and rate of groundwater movement may change as
the zone of saturation with'in the solution channels may be increased* or
decreased in the groundwater flow system network. Placement of wells
and pumps at appropriate locations in a karst system is therefore 'very
difficult due to: /
rtc I ^ 0 A r-v^^vy^j"
*t> s ,-trhMEMO: For The RecordAugust 1, 1984Page 2
1. _ Problems In identifying exact locations of subsurface water
bearing solution channels.
2. Variability of flow regime with changes in hydrologic condi-
tions. / ;.
reaux, Sr.
President
Certified Professional Geologist:
American Institute of Professional Geologists #880
Certified Professional Hydrogeologist:
American Institute of Hydrology #170
Certified Professional Geologist:
State of Indiana #366
PEL,Sr./ral5/01
P. ELaMoreaux & Associates
ATTA Report On Some Problems Associated With Removal
Of Groundwater From Karst Terrains At Bloomington, Indiana
by•\
Richard L. Powell, Ph.D,Senior Geologist
Geosciences Research Associates, Inc.
The feasibility of cleaning up groundwater beneath a capped hazardouswaste 1s diminished by several variable factors common to karst terrainsdeveloped on limestone bedrock. The Neals Landfill and Lemon Lane sitesare on karst terrain on soil mantled limestone bedrock, the dump at Bennett :Quarry 1s on limestone and Into a quarry, and the Winston-Thomas site is onalluvial materials "on limestone. A .groundwater purge system, in my opinion,would not be a feasible or reliable method to control the migration ofcontaminants into the groundwater or controlling groundwater migration fromthese sites, owing to their geologic settings.
The limestone bedrock units of the sites in the Bloomington area do nothave .a uniform permeability or transmissivity. They do not constitute ahomogeneous medium. Some strata are more porous, more broken by joints andfractures, or more soluble than others. Similarly, an individual lithologicunit may have lateral variations in transmissivity, especially where someopen joints have been enlarged by solution along particular subterranean route
Cavernous voids, solution conduits, and open joints that transmit largevolumes of groundwater constitute a small volume within the limestonebedrock. The solution enlarged zones are commonly along sinuous routes andusually not detectable from the surface. Consequently, they are difficultto locate by boring.
Groundwater levels in limestone bedrock, particularly along cavernousroutes, commonly fluctuate highly following heavy precipitation in the area.Some sinkholes temporarily flood until the conduits can drain the watersafter the storm abates. Temporary high water levels 1n caverns mav rise_into-sinkholes_and soils contaminategLMith refill, thim thg water would becomecontaminated. A Cap OV6r a filled Sinkhole would not prevent a temporary
level from flooding a sinkhole or saturating
s.
theL_ad1acent soils. sTmiTarly, any unconsolldated sediments-with in thpsolution conduits wouldT>e temporarily saturated.
Purge wehs completed in bedrock with a low transmissivity probably wouldnot effectively drain adjacent cavernous voids. Wells completed in cavernousopenings at one elevation may not effectively drain similar openings and smallervoids more remote from the boring, and would not affect such openings at lowerelevations. Some wells 1n cavernous voids might be replenished with such alarge volume of transient groundwater that an effective drawdown would not beaccomplished without Installation of a grout curtain around the site.
The Installation of p grout curtain 1n fractures and solution voidsarouriirand-under a SU.P jn cavernous beorocK is not teasTDTe tor several
JTSasons. ror jex&mple, 1jTTs difficult to estabmn the certainty of boring Into^ all open vojdsll adequate-seal ing of targe open passages or solution conduitsU not assured",and replacement of sediments with grout 1n those voids that
r contain sediment 1s uncertain.
30 July 1984
"V
C2 • The Herald-Times, Friday, April 28, 2000
DEALING WITH PCBS
Research shows PCBs sgoing into Lake Michigan
F
Federal study wasa surprise to many whothought contaminationof lake was decreasing
Associated Press
CHICAGO — More than 20years after the manufacture ofPCBs was banned, the cancer-causing toxins are still enteringLake Michigan from sources onland, according to a federal studythat challenges longheld beliefsabout the toxin.
Air tests indicate that theChicago and Gary areas are majorsources of PCBs going into the lake,
,said Glenn Warren of the U.S.Environmental ProtectionAgency's Great Lakes NationaTProgram Office in_Chjcago.
The findings came as a surpriseto scientists who had long believedthe lake's PCB load was decreas-ing, and suggest the same thing ishappening in industrial areasthroughout the world, researcherssaid.
PCBs — polychlorinatedbiphfnyis — have been linked tocancer and birth defects. Thechemicals were widely used as acoolant in electrical transformersduring the 1960s and 70s, to con-trol dust on roads, as a woodpreservative and in paint.
PCB pollution of lakes andrivers is a particular concern be-cause contaminated sedimentexposes fish to the toxin andspeeds its movement up the foodchain. Because PCBs don't breakdown easily, the chemical buildsup in fatty tissue, with each expo-sure putting a person at greaterrye.
Salimol Thomas, a graduate student at the Illinois Institute ofTechnology, looks up at the equipment she uses to check airquality at a testing station on the roof of a campus buildingTuesday in Chicago. Air tests indicate that the Chicago andGary areas are major sources of PCBs going into Lake Michi-gan, according to a federal study. AP PHOTO
That has prompted the gov-ernment to warn people, especiallypregnant women, against eatingtoo much Great Lakes fish.
It was widely believed thatmost PCBs in the environment hadbeen there for years and wereredrculating by evaporating andre-entering the lake from theatmosphere — not necessarilycoming from new sources.
"Conventional wisdom was ...that Lake Michigan overall was los-ing PCBs to the atmosphere," War-ren said. "But because of the urbaninput, Lake Michigan is still takingin PCBs."
^Researchers suspect the toxinis cominR from old electrical trans-formers, dumps that were notcapped properly, sludge beds anddisposal sites for PCB-laced sedi-ment dredged from rivers andshipping canals, as well as a host ofsmaller sites, said Tom Holsen, anenvironmental engineering pro-fessor at Clarkson University inNew York, who is leading the PCBstudy in Chicago.
PCBs evaporate from thosesources and are deposited in dielake from the atmosphere, Holsen
/said, __" He said more extensive analy-
ses of air data must be completedbefore researchers identify sourcesof new emissions. A report isexpected by the end of the year, hesaid.
But the extent of the problem isprobably not yet known because
_PCBs are probably being releasedby industrial areas throughout theworldi Holsen said'
Since 1995, tests also havefound high levels of the toxin in the
**Conventionalwisdom was ...that LakeMichiganoverall waslosing PCBs tothe atmosphere.But because ofthe urban input,Lake Michiganis still taking inPCBs. "Glenn Warren of the U.S.Environmental ProtectionAgency's Great LakesNational Program Officein Chicago
atmosphere near Baltimore andDetroit, and in England, he said.
Technology to allow routinetesting of industrial areas becameavailable only recently, lie said.That means scientists and jpolicy-tnakers will have to revisit the PCBissue on an imern^tionajjrale, he ' washed into waterways — presen
Lake Michigan! JQjAt findingI prompted the EPA tpfnid a sepa-rate study to piripbin|,jhe toxin's Isources. , "
Holsen said Jewels, in Jhe air1
around Chicago ahcthigher than front hdmifuf areas— 10 times higher in Chicago \in Kankakee, about 50 milefe 1south, for example.
"It was clear that urban In-dustrial areas were the sou|te,"Holsen said. f 's^i
The new information couldhelp government agencies decidewhat steps to clean up P^Bsshould get top priority, said War-ren and Cameron Davis, executivedirector of the Lake Michigan Fed-eration, a citizens environmentgroup-
Many government officialsand advocacy groups supportdredging contaminated sedimentfrom lakes and rivers.
Industry has resisted that astoo expensive and has favored pov-.ering polluted sediment with cleanfill such as clay to limit exposure,
_ Warren said.The land-based sources^—
from which PCBs evaporate'br are
saic"These pollutants don't
spect state or national boundaries;they go everywhere," he said. "Jf_you just clean up (he Great kikes, itwon't solve the problem."
The liigh levels of PCBs in theair near Gary and Cliicago werefound during testing for a different
a. new concern, but cleanup of aL.sources of the toxMlsTmponant toreduce" fish 'contamination
"It is my belief we will have to_go after all sources if wf want ron-
lfVpk lnw pnnugh so_(fish are]__consumablg^ by eve-
'ryone/' Warren _s_aid___
TABLE A-lAIR MONITORING RESULTS
LEMON LANE LANDFILL SITEBLOOMINGTON, INDIANA
Notes:A == 48 iour samplesBDL = Etelow Detection LimitND = No data
ng/m = Nlanogram per cubic meter, or part per trill ion
PCB = Polychlorinated biphenyl
A-4
Draft 6/15/00
AIR SAMPLING RESULTSPerimeter Sample Remits for PCBi
LEMON LANE LANDFILL REMEDIATION PROJECT
tiMht-vi-W9/TCI/L&3
T^T, j\^>&>nv>U-4k
Primary WindDirection DuringEiovtitton (0«
Chit* S«.,l»D.tt>
Apr. 19,2000Apr. 19.2000Apr. 19.2000Apr. 19.2000
Apt. 10, 2000Apr. 20, 2000Apr. 20, 2000Apr. 20, 2000Apr. Z0.2000
May. 17.2000May. 17. 2000
May. 18,2000May. 18.2000May. 18,2000
May. 19,2000May. 19,2000
May. 20,2000May. W, 2000
May. :n, 2000May. :i2, 2000May. :.S. 2000
Msy 23. 2000May. ;'.3r 2000
May. 24, 2000May. 24, 2000May 14,2000
May. 25,2000May. : J, 2000
May. 26, 2000May. 26, 2000
May. 30.2000May. 30.2000May. 30,2000
Mt)-. 31,2000May. 31.2000
Jun. 0 .2000Jim. 0 ,2000
Am. 07, 2000Jwtt.lOOO
Jun. 0;. 2000Jun OJ, 2000Jun. 03, 2000
M/AN/AN/AN/A
N/AN/AN/AN/AN/A
North
N«th
&6t
Eist
North
North
East
South
North
North
East
Nonih
East
South
Avg WindSpeed
(Ok&npfc
D-.)
N/AN/AN/AN/A
N/AN/AN/AN/AN/A
4.4
8.8
4 5
3.0
6.9
S.6
7.8
3.9
3.7____
5.0
6.7
5.5
6.)
5.1
Simple Number
30400.11-PUF-OOl
30400. ll-PUF-00230400.U-PUF-00330400. n-PUF-004
30400. 11-PUF -00530400 1 1-PUF-Q0630400. II-PUF-00730400. ll-PUF-00830400. ll-PUF-009
30400. 1 1-PUF.OIO30400 ll-PUF-011
30400. U-PUF-01230400.11-PUF-OI330400. ll-PUF-014
30400.11-PUF-01530400. ll.PUF-0 16
30400.11-PUF-01730400. ll-PUF-018
30400.11-PUF-01930400.1 1 -PUF-02030400. ll.PUF-021
30400. ll-PUF-02230400. ll-PUF-023
30400. n-PUF-02430400. ll-PUF-02530400.11 -PUF-016
30400, ll-PUF-02730400. ll^UF-028
30400 ll-PUF-02930400 ll-PW-030
30400. 11-PUF43I30400. 11 -PUF^)3230400.1 l-PUF-033
30400.11JW )3530400. ll-PUF-034
30400.1 1 -PUF-03630400 ll.PUF-037
30400. 11-PUFX)3830400. ll-PUF-039
30400. 1I-PUF4MO
SimpleLocatioa
»7NorthISEast
IU South» 1 West
»7North* 8 East
* 12 Southm i WestBlank.
* 4 Southeast17 North
17 North#4 Southeast
Blank
14 SoutheastIS East
ISEajt14 Soothe**
17 NorthMSortheart
Blank
*7North« 4 Southeast
I8£ast14 Southeast
Blank
112 South14 Southeast
1 7 NorthMSoutheatt
17 Northf4Soatbewt
Blank
fSEatt14 Southeast
17 North14 Southeast
ISEasT*14 Southeast
I 12 South30400 I I-PUF-W1 1 * 4 Southeast30400. ll-PUF-042 Blank
SampleVolume
324319329334
324323319335NA
317316
310314NA
295313
277265
288264NA
295279
307288NA
719302
300285
308291NA
306393
304292
294279
272262NA
L«b Retail
(««)
10.012.019.06.0
5.07.02.03.0
BDL
8.04.0
13.06.0
BDL
2238
2011
22010
BDL
290.010.0
13S>45.0BDL
49.0150.0
150.026.0
55.013.0BDL
19.024.0
120.016,0
290.0450.0
250.0230.0BDL
CoaceatnttoDIn Air
(og/m1)
30937657.818.0
15.421.7639.0NA
25.212.6
41.9191NA
74.7121.4
72.241.5
- vai&^nsNA
J«u i35.8
434.0 _156.2NA
15JJS^496.7 ^
500.591.3
17J.844.6NA
63.081.9
gftrwt
SSE&-~-^VA
NumberofDtyi
1111
2222
13
42
33
44
S5
6S
57
39
r9
810
011
a12
713
414
CumulativeAverage
30.937.657818.0
23.129832.013.5
25219.6
25.222.2
39.760.2
63.240.1
173.039.7
306.039.0
135.455.8
72.5110.9
335.5100.7
315.9102.3
123.2100.4
324.796.6
246.4213.1
284.12605
Draft 7Y24/00
AIR SAMPLING RESULTSPerimeter Sample RcMht for PCBt
LEMON LANE LANDFILL REMEDIATION PROJECT
D*te
>>3u»ie tJun. 05, 2000Jun. 05, 2000Jun. 05, 2000Jun. 05,2000Jun. 05, 2000
Jun. 06 2000Jun. 06 2000
Jun. 07, 2000Jun. 07, 2000Jun. 07, 2000
Jun. 08. 2000Jun. 08, 2000Jun. 08, 2000
Jun. 09, 2000Jun.09,2000Jim. 09. 2000Jun. 09, 2000
Jun. 10, 2000Jun. 10. WOOJan. 10. 2000
Jun. 11,2000Jun. 11.2000Jun. 11. UOOO
Jim. 12, 2000Jun. 12. 2000Jun. 12. 2000Jun. 12, 7000
Jun. 13, 2000Jun. 13. 2000Jun. 13,2000
Jun. 14, 2000Jun. 14. 2000Jun. 14. 2000
Jun. 15.2000Jun. 15. 2000Jun. 15. 2000JUD. 15,2000
Jun. 16,2000Jvn. 16.2000Jun. 16,21)00
Jun. 17,2IX)0Jun 17.2000Jun. 17,2(00
.Jun 17. 2WO
> ft«.. 10Jf*«Najy"" JmW.lM»
Jun. 19.2000Jun. 19. 2000Jun. 19. 2000
Primary WindDirection During
CicavatioR (OfSMpkCtaU)
East
Soutti
North
East
East
North
East
North
North
North
East
North
South
We*
AvgWtadSpeed
(feSM*
M»
6.5
5.2
4.3
9.2
7.5
5.2
7.8
6.2
5.5
*
7.3
6.8
7.2
3.8
\6
Sample Niuabe
30400. ll-PUF-0430400. ll-PUF-04430400. 11 -PUF-05030400 11 -PUF-0530400. 11 -PUF-05
30400. 11 -PUF-0430400. ll-PUF-046
30400. 11 -PUF-0430400. 11 -PUF-0430400.1 l-PUF-04
30400. ll-PUF-5330400.1 1-PUF-S430400.U-PUF-55
30400. ll-PUF-05630400. ll-PUF-03730400.1 I-PUF-05S30400. U-PUF-OJ9
30400. ll-PUF-06030400.1 l-PUF-06130400.1 1-PUF-062
30400. ll-PUF-06330400.1 l-PUF-06430400.1 1-PUF-06J
30400.1I-PUF-066J0400.M-PUF.06730400.1 1-PUF-06J30400.U-PUF.fl69
30400.1 l-PUF-07030400.II-PUF-07I30400. ll-PUF-072
30400. H-PUF47330400. 11-PUFXJ7430400.1 1-PUF.01S
30400.1 1-PUF-07630400.1 iJUFJtn304M.ll.PUF.07S30400.1 l-PUF-079
30400 ll-PUF-08030400.1 1-PUKOtl30400.1 1-PUF.OI2
30400. H-FUF-OS330400.1 1-PUF-OS430400.1 1-PUF4I530400.1 1-PUF-O6
WttO.U-VUF-Otn30400. 11-PUF-OMM400.ll.pUF4t930400.1 1-PUF-OW
SampleLocation
* 8 East14 Southeast
07North112 South01 West
112 South1 4 Southeast
!7NorthtSEast
«4Southeast
17 NorthISEut
14 Southeast
17 North18 East
14 SoutheastBlank
* 7 North* 3 East
14 Southeast
17 North« 3 East
14 Southeast
* 7 North03 East
04 SoutheastBlank
07 North03 East
04 Southeast
07 North03 East
4 Southeast
07 North03 East
4 SoutheastBlank
07 North03 East
4 Southeast
07 North03 East
« 12 South4 Southeast
fJNoruj03Ea»t
110 West4 Southeast
SampleVolume
283276288289279
318304
298303281
285284253
285287277NA
302293280
410399380
292290273NA
335310304
327326311
315314304NA
313 ;
305 /293 U
309>o306
301292
•m322275318
LabRctu
(«K)
280.0570.050.0140024.0
220.0200.0
200.0110.0260.0
290.0140.054.0
150.0200.080.0BDL
100.0140.045.0
130.080.0120.0
130.060.060.0BDL
91.088.048.0
98.070.030.0
240.0110.088.0BDL
/fto.oy 46.0
1 M-°-l
1 100.048.038.060.0
tt.t>10.038.036.0
ConcenlratloitaAIr
(a*/"*)
$<.<.ndff.ytin p&r-si988.1
2066.5173.6 •484.4
~sro '
691.8;657T
671.13630925.3_
1018.6~-*9ZS~"2T1T1
J2M-_^L!JSJO-' NA
331.2*J7|-^mr_
317.4' 29A-6~^jiis—44J5,5
^7^miuNA
^J2M-2m158.0
299:9•^JI4J^' 96T~"
7fthr^3M_1i>n•TJA—
1
-aatljM"TwlJJ^
32410157.1126.2205.2
Yll/iH1 144<rAoB
5.&P
Numberof Dtj1*
8151053
616
11917
121018
131119
NA
141220
151321
161422
171523
181624
191725 jNA I
i201826
2119727
Cumulative| Avenge
34123798309.6324836.7
3859397.2
342.5343.64282
3988358.54163
408.7389.1 14096 1
NA 1
403.1396.5397.2
397.4381.5393.3
4004369.0385.4
392.8363.33755
387.7354.0363.9
4073353.8360.9
NA
407.73425351.5
403.73328348.8346.1
\
22 i WM20 ; 317.74 I 62.0
28 ;' 337.8
AIR SAMPLING RESULTS
Perimeter Sample Rente for PCBs
LEMON LANE LANDFILL REMEDIATION PROJECT
Dale
June 19, 2000
June 19, 2000
June 19,2000
June 19,2000
June 20, 2300June 20, 2<300June 20, 2'300
June 2 1,2000
June 2 1,2000June 2 1,2000
June 21. 2000
June 22. 2000June 22. 2000.'une 22. 2000
, une 23, 2000
.une 23. 2000
June 23. 2(00
June 24, 2(00
June 24, 2COOJune 24, 2000
June 25. 2COO
June 25. 2000June 25, 2000
June 25, 2000
June 26, 2000June 26. 2000
June 26. 2000June 26. 2030
June 26, 2030June 26. 2030
June 27, 20)0
June 27, 20)0June 27. 2000June 27, 2000
June 28, 2000
June 28, 2000Jioe 28, 2000
June 28, 2000
June 28, 20W
June 29, 20CO
June 29. 2000
June 29. 2000
June 29, 20CO
June 30. 2000
June 30, 2000
June 30, 2000
June 30, 2000
Primary Wind
Direction During
Excavation (On SamplD»te)
West
North
East
East
East
North
South
East
South
South
South
South
AvgWtod
Speed(OQ Supfe D«c
3.6
5.6
8.3
10.6
4.4
5.7
3.1
6.6
3.5
2.7
4.6
2.4
Sample Number
30400 11 -PUF-087
30400 11 -PUF-088
30400. ll-PUF-089
30400. ll-PUF-090
30400. ll-PUF-091
30400. ll-PUF-09230400.1 1 -PUF-093
30400. ll-PUF-094
30400. ll-PUF-095
30400. ll-PUF-09630400.U-PUF-097
30400. ll-PUF-09830400. ll-PUF-09930400. ll-PUF-100
30400. 11-PUF-l 01
30400.1 l-PUF-102
30400. ll-PUF-103
30400.1 l-PUF-10430400.1 l-PUF-105
30400. 11-PUF-l 06
30400.1 l-PUF-107
30400.1I-PUF-10830400.11-PUF-109
30400. 11-PUF-1 10
30400. 11-PUF-l 11
30400.1 1-PUF-l 1230400. 11-PUF-l 13
30400.11-PUF-114
30400.11-PUF-115
30400. 11-PUF-l 16
30400. 11-PUF-l 17
30400.11-PUF-11830400.11-PUF-11930400.1 l-PUF-120
30400. ll-PUF-121
30400. 1I-PUF-I2230400.11-PUF-123
30400. ll-PUF-124
30400. 1I-PUF-123
30400.1 l-PUF-12630400. ll-PUF-127
30400. 11-PUF-l 28
30400. ll-PUF-129
30400.11-PUF-130
30400. 11-PUF-I3130400. ll-PUF-132
30400.1 l-PUF-133
SampleLocation
#7 North
MEast
# 10 West
#4 Southeast
#7 North
#3East
#4 Southeast
#7 North#3East
#4 Southeast
d533#7 North#3 East
#4 Southeast
* 7 North#3 East
#4 Southeast
#7 North#3E«st
#4 Southeast
#7 North#3 East
# 12 South
M Southeast
#7 North#3 East
# 12 South
» lOWest
# 4 Southeast
JTJSS)
#7 North
#3East# 1 South
M Southeast
L #7 North
#3 East
# 1 South
jBlantJM Southeast
#7 North#3 East
# (South
*4 Southeast
#7 North* 3 East
* 1 South
I* 4 Southeast
ConcentrationtaAlr
37.531.1138.0113.2
113.937.437.7
25S.6_
TJT187.1NA
^3g5.3CT
' 7*283.3
J"-8 .,
<-ay~291.2 _
JJiLT247 J_
_J32J-^J5CV7__
108.079^
268.1 _
183.0...
. «?,6 I147J61.6543147.7
"BDiT"
47.5152.0180.4
.."in-/18.430.7
BDL206.4
1
161.02grJ>"
jSjpf-^^4-
Cumulative
Average
(ag/m1)
387.1317.762.0337.8
375.2
247.8293.7
277.6237.8290.1
NA
281.9239.7292.1
291.4241.9292.8
289.8237.7
288.5
283.3
231.6323.0285.4
281.4228.5293.9
32.9281.5
273.6
225.8282.6262.4
265.4
219.0280.2
NA280.3
264.6
220.2280.3
284.3
261.5221.3274.6
290.1
fy
3
3
y
4
J*
t/y
,_-*"
/,,'
¥
4^
^
The Concentration in ,Mr is deter mined from the PCB result and the volume of air for the sample period.
The Cumulative Average is an arithmatic average of all results recieved at that location to that point.
AIR SAMPLING RESULTSPerimeter Simple Results for PCB»
LEMON LANE LANDFILL REMEDIATION PROJECT
Date
July 1&2, 2000
July lft.2,2000
July 1&2, 2000
July 1&2, 2000
July 1&2, 2000
July 3&4, 2000
July 3&4, 2000July 3&4, 2000
July 3&4, 2000
July 3&4, 2000
July 5. 2'XX)
July 5. 2'XX)
Jury 5. 2'XX)July 5, 2'XX)July 5. 2iXX)
July 6, 2000
Jury 6, 2000July 6, 2IXK)July 6, 2000
July 7, 2000July 7, 2000
Jury 7, 2(100July 7, 2000Jury 7, 2(KX)
July 8, 2000
July 8. 2000July 8. 2000Jury 8, 2000
July 8, 2COO
Jury 9. 2000^V July 9. 2COO
July9.2COO
Jury 9, 2COO
Jury 10. 2IXX)
July 10, 2000July 10. 2000
Jury 10, 2000
July 1 1. 2000
July 12, 2000
July 12, 2000Jury 12. 2000
July 12. 2000
July 12, 2000
July 13, 2000July 13, 2000
July 13.2000
July 13,2000
July 13,2000
Primary WindDirection During
Excavation (On Sampk
North
North
East
East
West
North/West
East
East
South
West
South
AvgWindSpeed
(On Simple D*U
2.8
55
2.9
3.4
5.7
3.5
7.1
6.0
3.3
3.3
3.1
Sample Number
30400. 11 -PUF- 13430400.1 l-PUF-135
30400. 11-PUF- 13630400. 11-PUF-I37
30400.1 l-PUF-138
30400. 11 -PUF- 144
30400. 11 -PUF- 145
30400. 11 -PUF- 14630400.11-PUF-I47
30400.1 l-PUF-148
30400. 11 -PUF- 149
30400.1 l-PUF-15030400.1 l-PUF-151
30400. 11 -PUF- 15230400.I1-PUF-154
30400.1 l-PUF-139
30400. 11 -PUF- 14030400. ll-PUF-141
30400.1 l-PUF-143
30400.1 l-PUF-15530400. 11 -PUF- 15630400. 11 -PUF- 157
30400.1 l-PUF-15830400. ll-PUF-159
30400. 11 -PUF- 160
30400. 11 -PUF- 161
30400. 11 -PUF- 162
30400. 11 -PUF- 16330400.1 l-PUF-164
30400.H-PUF-16530400.1 l-PUF-16630400. ll-PUF-167
30400.1 l-PUF-168
30400.1 l-PUF-169
30400. 11 -PUF- 17030400. 11-PUF-l 7130400. 11 -PUF- 172
All samples void this date
30400.1 l-PUF-179
30400.U-PUF-18030400.1 1-PUF-I81
30400.1 l-PUF-182
30400. 11 -PUT- 183
30400.1 l-PUF-18530400. 11 -PUF- 18630400.11-PUF-187
30400. 11 -PUF- 188
30400. ll-PUF-190
SampleLocation
» 7 North03East
0 1 South0 lOWest
#4 Southeast
07 North
*3East
0 1 South
0 IQWcst
0 4 Southeast
* 7 North
03East0 1 South
04 Southeast
Blank
#7 North03East
0 1 South#4 Southeast
0 7 North*3East
01 SouthjCSTWesT)
04 Southeast
07 North03East
0 1 South0 10 West
04 Southeast
#7 North
03East
0 1 South
04 Southeast
07 North
03 East# 1 South
04 Southeast
due to Laborito
07 North03 East
MSouth
s^HlO West"
If 4 5uuiHcO5l
07 North03 East
tt 1 South
04 Southeast
Blank
Concefltrition
In Air
(ng/m*)
217.168333.3422112.7
_iii40.07.811.7
107.3
28^8.nrj.i ~70.6110.0BDL
254.3 _-_2J2JL^
_244.2267.7-
15.327.4163.8*4J* T
162.2
67.222.2113.280.4
354A
^iit—68.712.083.7
,g523^).374.0
189.950.1
ry error -(hiviU
58.831.6
/•p. 122.5-^Oso^jg)
•464'4
67.5247.7
- J487.4/JJy 772.6 f^.-ror^^
CumulativeAvenge
(ng/m5)
260.2216.5257.4344
285.7
264.6216.5240.731.2
281.3
265.2213.3230.1277.3
264.9213.42309277.0
2583208.1227.282.6
274.4
2534202.9221.282.4
276.2
260.3199.3210.7272.0
299.1203.9209.7267.3
d extraction)
293.4199.5205.8150.1271.4
288.1200.7261.5281.6
NA
/'3
**6
y~
y7
&i</
5~ •
„'
7
t*-.
^
£
The Ccncentration ii Air is determined from the PCB result and the volume of air for the sample period.
The Cumulative Average is an arithmatic average of all results recieved at that location to that point
LEMON LANE LANDFILL REMEDIATION PROJECT J.
Itau
Jul. 14,2000Jul. 4.2000Jul. 4,2000Jul. ! 4, 2000
Jul. 15,2000Jul 15. 2000Jul 15,2000Jul. 15,2000Jul. 15,2000
Jul. 16,2000, Jul. 16,2000I Jul. 16,2000
Jul. 16,2000Jul. 16.2000
Jul. 17.2000Jul. 17.2000
17,200017.2000
Jul. 18,2000Jul. 18,2000Jul. 18,2000Jul. 18,2000
Jnl. 19.2000Jul. 14,2000jui. i1*, 20004ul. H.2000Jul. l'»,2000
Jul. 20,2000Jul. 20.2000Jul. 20.2000JuL 20.2000
Jul. 21.2000Jul. 21.2000Jul. 21.2000Jul. 21.2000
Jul. 23.2000Jul. 22.2000Jul 22.2000M. 22.2000Jnl 22,2000
Jul. 23.2000Jul. 23.2000| Jui 23.2000I Jul. 23.2000Jul. 23.2000Jul. 23,2000
Primary WindDirection Daring
Excavation <o«r)
South
SouHi
South/East
Easi
South
South
Atf WtaSpeed
D*> Sample Number
30400II-PUF-19I30400.1 l-PUF-1923<MOO.I1-KJF-I9330400.II-PUF-IM
30400.II-PUF-I9)J0400.I I-PUF-I9630400.II-PUF-19730400.II-PUF-IM
30400I1-PUF-199J0400.I1-PUF-20030400 I1-PUF-20I30400.II-PUF-20230400.1 l-PUF-203
30400.1 1 -FUF-20430400. 11-PUF-20J30400.11-PUF-JM30400.I1.PUF.207
30400.I1-PUF-2M30400.I1-WF-20930400.1 l-fUf-21030400.1I-PUF-21I
30400.1 l^UF-212
Sample
* 7 NorthI3E*S)
II South»4Southe«ut
17 NorthI 3 East
11 SouthI4Southe«t
17 North
II South1 4Southeut
I 7 NorthII East
30400.1I-PUF-2I430400. ll-PUF-2 IS30400.1 l-PUF-216
ISSoutbew?
I 7 NorthlIEattII South
1 4 Southeast
I 7 NorthIJEMt
II South1 4 Southeast
Blank
30400.1 l-PUF-217 17 North30400.1 l-PUF-218 13 East30400.1 l-PUF-219 11 South0400.1 l-POF-220 fSSoothcot
040011-POF-2210400.1 l-POF-222 13 Bast0400.1 l-PUF-223 11 South0400.11-PUF-224 14 Southeast
30400.ll-fUF.2250400.H-POF-226
30400.I14DF-227W400.11-PUF-2280400.II.PUF.229
XHOO.ll-PUF-230J0400.11-PUF-231KMOO.I1-PUF-232
30400 M4W-233MOO.II.PUF.234MOO.ll-PUF-235
17 North13 EastI (SouthI lOWest
14 Southeast
17 North13 EastII SouthIII West
14 SoutheastBlank
. 7 _ <5 o
Draft 8/4/00 PSARA Ttchnologi**. Inc.
AIR SAMPLING RESULTSPerimeter Sample Results for PCBs
LEMON LANE LANDFILL REMEDIATION PROJECT
Dite
July 24. 2000July 24, 2000July 24, 21)00July 24. 2000July 24, 2000
July 25, 2000July 25, 2000July 25, 2000July 25, 2000July 25, 2000
July 26, 2COOJuly 26. 2COOJuly 26, 2COOJuly 26, 2COOJuly 26, 2COO
luly 27. 2000July 27, 2COOluly 27, 2000July 27, 2000July 27, 2000
July 28, 2000July 28, 2000July 28, 2000July 28, 2000July 28, 2000July 28, 2000,'uly 28, 2000
My 29, 20DO.•uly 29, 20».uly29,2000.uly 29, 20)0.uly29,20jO
July 30. 20X>July 30,20)0July 30, 2000July 30, 2000July 30, 2000
July 3 1.2000July 3 1, 2000July 3 1,2000July 3 1,2000July 3 1,2000
Ajgust . 2000Aigust , 2000Ajgust . 2000August , 2000August ,2000
Ajgust 2, 2000Ajgust 2, 2000Ajgust 2, 2000August 2, 2000August 2, 2000August 2. 2000
Primary WindDirection During
Eicavation (On SimpDiU)
West *•
West/South
East
North
East
duplicate sample
North
North
North
East
East
AvgWindSpeed
(On S.mpk Difc
4.8
2.6
3.5
4.6
7.1
3.0
3.0
3.4
6.8
Sample Number
30400. ll-PUF-23630400. ll-PUF-23730400.11-PUF-23830400. ll-PUF-23930400. ll-PUT-240
30400. ll-PUF-24230400 II -PUF-24330400.1I-PUF-24430400. ll-PUF-24530400. ll-PUF-246
30400. ll-PUF-24730400.11-PUF-24830400. ll-PUF-24930400. ll-PUF-25030400. ll-PUF-251
30400.11-PUF-25330400.1 l-PUF-25430400.1 1 -PUF-25530400. ll-PUF-25630400.11-PUF-257
30400. ll-PUF-25830400. ll-PUF-25930400. ll-PUF-26030400. 11-PUF-26I30400. ll-PUF-26230400.11-PUF-26330400. ll-PUF-264
30400. ll-PUF-26530400. ll-PUF-26630400. ll-PUF-26730400. ll-PUF-26830400. ll-PUF-269
30400. ll-PUF-27030400. ll-PUF-27130400. ll-PUF-27230400.1I-PUF-27330400. ll-PUF-274
30400.1 1 -PUF-27530400. ll-PUF-27630400. ll-PUF-27730400.1 l-PUF-27830400. ll-PUF-279
30400. ll-PUF-28030400. ll-PUF-28130400. ll-PUF-28230400. ll-PUF-28330400. ll-PUF-284
30400. ll-PUF-28530400. ll-PUF-28630400. ll-PUF-28730400. ll-PUF-28830400. ll-PUF-28930400. ll-PUF-290
SampleLocation
#7 North#3 East
» 1 South# 10 West
ft 4 Southeast
#7 North« 3 East
# 1 Southft 10 West
* 4 Southeast
#7 North* 3 East
ft 1 SouthH 10 West
* 4 Southeast
* 7 NorthS3 East
H 1 Southft 10 West
* 4 Southeast
H 7 North#3 East
* 1 Southft 10 West
*4 SoutheastH 8 Southeast
JSiiO
#7 Northft 3 East
* 1 South* 10 West
ft 4 Southeast
ft 7 North#3East
ft } SouthX 10 West
#4 Southeast
ft 7 North#3 East
ft 1 SouthH 10 West
It 4 Southeast
ft 7 North» 3 East
ft 1 Southft 10 West
ft 4 Southeast
ft 7 Northft 3 East
ft 1 Southft 10 West
ft 4 Southeast1 Blank/
Concentrationin Air
(ng/m )
20.223.8441655! '139.1
84794.6
jiyj—139.0400.8
76.3104.25608_113.1
Jt§±°_
_[22£—113.293.193.6234.6
266.9169.6513150.31639163.6BDL
267.3"JiilQir
71.047.1
454J5-.
89.8
78.364.131889.8
142.0"72.4
52.641.8101.0
177.180.926.815.268.6
O58.672.326.572.781.7BDL.
Cumula tiveAverage
(ng/m1)
360.0314 1548.313045247
3549309.9551.4131.1522.7
3499306.0551.7129.9522 1
347.1302.4538.9127.6517.5
3457300.05257128.9512.0
NANA
344.4236.6513.8124.4506.5
340.1292.8502.2119.5500.2
336.8289.0491.0115.6494.2
334.1285.4479.7110.8488.0
331.3281.9468.9109.1482.1BDL
** winds to the south during overnight
The Concentration in Air is determined from the PC8 result and the volume of air for the sample period
Draft 11/2/2000I UO C <-t
PSARA Technologist Inc. ' 20
AIR SAMPLING RESULTSPerimeter Sample Remits for PCBi
LEMON LANE LANDFILL REMEDIATION PROJECT
Date
October 27 2000Friday
October 28 2000Saturday
October 29 2000Sunday
Cttober 30, 2000Monday
-
October 3 1,2000Tuesday
November 1,2000Wednesday
Primary WindDirection During
Eicavalion (On SutpkD»U)
East
South
West
West
West
West
AvgWindSpeed
(On Sampk D>U
3.2
4.0
4.7
4.4
3.6
4.6
Sample Number
30400. ll-PUF-96730400. ll-PUF-96830400.1I-PUF-96930400. ll-PUF-97030400. ll-PUF-97130400. ll-PUF-97230400. ll-PUF-97330400. ll-PUF-974
30400. ll-PUF-97530400. ll-PUF-97630400. ll-PUF-97730400. ll-PUF-97830400.11-PUF-97930400.11-PUF-98030400. ll-PUF-98130400.1I-PUF-982
30400. ll-PUF-98330400. 1 l-PUF-98430400. ll-PUF-98530400. ll-PUF-98630400. ll-PUF-98730400.I1-PUF-98830400. ll-PUF-98930400. ll-PUF-990
30400. ll-PUF-99130400. ll-PUF-99230400. 1 l-PUF-99330400. 1 l-PUF-99430400. ll-PUF-99530400. ll-PUF-99630400. ll-PUF-99730400. ll-PUF-99830400. ll-PUF-999
30400.I1-PUF-100030400. 11-PUF- 100 130400. 11-PUF- 100230400. 11-PUF- 100330400. ll-PUF-100430400. ll-PUF-100530400. 1I-PUF-I00630400. ll-PUF-1007
30400. ll-PUF-100830400. ll-PUF-100930400.1 1-PUF-10IO30400.1 1-PUF-lOll30400,1 l-PUF-101230400,1 l-PUF-101330400.1 l-PUF-101430400. 11-PUF- 10 15
SampleLocation
NorthEast
Valhalla EastWest
GriffinWoodsBender
Gray Si.
NorthEast
Valhalla EastWest
GriffinWoodsBender
Gray St.
NorthEast
Valhalla EastWest
GriffinWoodsBenderGray St.
NorthEast
Valhalla EastWest
GriffinWoodsBender
Gray St.Blank
NorthEast
Valhalla EastWest
GriffinWoodsBender
Gray St.
NorthEast
Valhalla EastWest
GriffinWoodsBender
Gray St.
Concentritionhi Air
(ng/m1)
2556
171.9
-j,«|.g ..W2713.6
370.4291 2 _86.7
^-tm_85.0
JOfift.
•. «!„?,„276.5_161.9^50,448.9582
16,4BDL17.1
126.317.938
BDL33
150147126
185.124.1693263
BDL
33214.795
474.1 ..22914.16.49.9
26.719.49.4
(»1 *25.810.49412.4
CumulativeAverage
(ng/m3)
2499216.2469 .5334.9388.4112973.268.5
248.8215.5474.2334 4387.0112.172.868.4
247.2214.0458.4332.5384.6110.771.967.6
2457212.6443.6331.1382.2109.571.066.8NA
244.2211.3429.6332.4379.9108.370.266.1
242.8210.0416,5336.9377.7107.169.565.5
The C ancentration in Air is determined from the PCS result and the volume of air for the sample period.
The C jmulative Average is Jin arithmatic average of all results recieved at that location to that point
urart 10/9/2000 16
AIR SAMPLING RESULTSPerimeter Sample Reodfci for PCBs
LEMON LANE LANDFILL REMEDIATION PROJECT
Date
October 1.2000Sunday
O-nober 2, 2000Monday
Primary WindDirection During
Eicavatioa (o« ScfnpfcD*«>
North
North
Motor quit on EJist and time lostEstimated loss ill 8 hrs and calculated as such.
October 3, 2300Tuesday
October 4. 2000Wednesday
October 5. 2000Thursday
&BK&SGK&&
October 6. 2COO
Friday
muaam
Ocwber 7, 2COOSaturday
North
Indeterminate-varied directionsthroughout day
Av(WmdSpeed
(O.S—PI.D-.
29
43
37
2.9
__,
^^^HHHHHHIBII '•*™mm~—a.
East 4.4
|
East 39
Sample Ntamber
30400. ll-PUF-75730400. ll-PUF-75830400. ll-PUF-75930400. ll-PUF-76030400. 11-PUF-76I30400. ll-PUF-76230400 ll-PUF-76330400. ll-PUF-764
30400. ll-PUF-76530400.11-PUF-76630400. ll-PUF-76730400. ll-PUF-76830400. ll-PUF-76930400. ll-PUF-77030400.H-PUF-77130400. ll-PUF-77230400. ll-PUF-773
30400. ll-PUF-77430400.11-PUF-77530400.H-PUF-77630400. ll-PUF-77730400. ll-PUF-7783O400.11-PUF-77930400. ll-PUT-78030400 \\-PUF-78l
30400.11-PUF-78230400. ll-PUF-78330400. ll-PUF-78430400. M-PUF-78530400.11-PUF-78630400.11-PUF-78730400.1 l-PUF-78830400. ll-PUF-789
30400. ll-PUF-79030400.11-PUF-79I30400. ll-PUF-792304OO.I1-PUF-79330400. ll-PUF-79430400. ll-PUF-79530400. ll-PUF-79630400. ll-PUF-797
30400. ll-PUF-79830400. ll-PUF-79930400. ll-PUF-80030400. ll-PUF-80130400. II-PUF-S0230400. ll-PUF-80330400. ll-PUF-80430400. ll-PUF-805
SampleLocation
NorthEast
Valhalla EastWest
GriffinWoodsBenderGray St.
NorthEast
Valhalla EastWest
GriffinWoodsBender
GraySLBlank
NorthEast
ValhalliEastWest
GriffinWoodsBenderGray St.
NorthEast
ValhalUEastWest
GriffinWoodsBender
Gray St.
NorthEast
Valhalla EastWest
GriffinWoodsBender
Gray Si
NorthEast
ConcentrationIn Air
(ng/mJ)
^J32.5
12.4
iLm&t.^T?T^131 8
TTT2 4 2
J8J 1 -.343.0
6.4297.4__.218.4 ._156.9 .135.563.1BDL
8354J28.7
33.3
^344.6 ..369 8
''148.6^H2
^24w-140.9193.8
I*T036.1~"_
182.781J33.1
125.3TOoT
IHID^.245.2 -
188.745.548.832.6
82.0I6KQ
ComulatrvrAverage
(ng/m')
2178176 3124
1457314051 638.7305
219217779.4
1476313253640531.1NA
224 3179017.4
150.2313.459444 531 9
225S178661.51609312761 745.131.9
225.1176.0
HBS9H161 9311.761.445231.9
224.0178.0
j$ ^(^jidati-Cjf.
/i't> .-. '/—
%
rtl-ttottftk.,lg ^fiC-£^*L& rtf- -c
£,'( ' * { a Jft^-fGi-U/&. r~ i ftC-i~^££l $4;'
O f& r .»-// l '/" _2.
ift&ftS >— v & i *'i&i ' *fb'i'V' £rf^j ST.
> ,'i /T L / ^_rj
f<Jd 37
/•^-A# l&'/l*WL. Cf t-^
fict-f^-e^->. "^^^^^£l
. - J. LValhalla East jBHSQHflHBQOHB 7 f' t/aSiieJ/et &3?
west l ^ i ^ T ^ j ^ i e o ^ n ' "* fo<*-Mu~-£ZL t
WoodsBender
Gray St.
9.654.5
//) d"
60.5454
1-7 **
/• '
no Jafo £ '1 $+
£l<£CLVu-<ke~uti<id%>«f-* of:
Trie Coo;enfration in ftir ts determined from the PCS result and the volume of air for the sample period
The Curr ulatve Average ts an arithmabc average of all results recieved at that location to that point
CommentariesDo Large-scale Remedial and Dredging Events Have the Potential to ReleaseSignificant Amounts of Semivolatile Compounds to the Atmosphere?Jeff Chiarenzelli,' Ronald Scrudato,1 Brian Bush,2 David Carpenter,2 and Sean Bushart2
'Environmental Research Center, SUNY at Oswego, Oswego, New York 13126 USA; ^School of Public Health. University at Albany,Albany, New York 121201 USA
Laboratory studies suggest that substantial amounts of polychlorinated biphenylsvoiaUjucdfroin wet contaminated solids during water evaporation. If significant losses
• during rield attivities. potential analytical, global, and health implications should be considered in~/he design and monjtoiing of remedial actions and the handling of contaminated solids..Key words-.
dredging, orr.fo-subsiituted congeners, polychlorinated biphenyls, semivolatile compounds,volatilization. Environ Health Ptnpect 106:47-49 (1998). [Online 21 January 1998)http://ihpnttl.niths.nih.gov/doa/1993/106p47-49chiarenzeUi/abstract.hml
Recent experiments monitoring the loss ofpolychlorinated biphenyls (PCBs) from wetsediment (1,2) and subaqueous sand (3)have shown that a strong correlation existsbe tween water evaporat ion and PCBvolatile loss, implying that PCBs can bereleased du r ing drying of contaminate,d
^solids. Similar relationships between thevolatile loss of dibenzofuran, phcnanthrene,and pyrene from dredged sediment and therelative humidity of air have also recentlybeen described (4). While these findings aresomewhat surprising if viewed from the per-spective of the perceived relative immobilityof hydrophobic semivolatile compoundslike PCBs, it has long been recognized thatthe volatile loss of chlorinated pesticidesfrom soil is considerably enhanced by mois-ture (.5). This phenomena, termed wickingin early studies, is related to competitionbetween water molecules and contaminantsfor abjorption sites on mineral surfaces (6).PCB volatilization is enhanced by environ-mental t ransformat ions of parent com-pounds yielding more soluble and volatilecongeners. In this commentary we brieflys u m m a r i z e the sa l i en t po in t s of th i sresearch, discuss PCB priysicochemistry andvolatilization, and speculate briefly on thesignificance of these findings in terms ofpotential analytical, remedial, global, andhealth mplications.
Volatile Loss of PCBs fromWet SedimentThe volatilization of PCBs from soils (7)and lar|;e contaminated v/ater bodies (8) hasbeen extensively investigated and is thoughtto be a major pathway by which PCBs andpesticides are losi from these reservoirs (9)and are globally distributed. However, therei s l i t t l e research a v a i l a b l e in the peer-reviewed l i terature on the volatile loss ofPCBs from sediment (10\, despite the find-ings of U.S. Army Corp of Engineers-spon-sored irvcstigations (11-13). A for tui tous
discovery in our laboratory of PCB volatilelosses of -75% (n = 4) during evaporationof water from small amounts of anaerobi-caJly dechlorinated St. Lawrence River sed-iment during a period of 1 week promptedadditional investigations of this phenome-non (1-3). Subsequent controlled replica-tions of this experiment yielded similarresults [73.4 ± 1.5% (mean ± standarddeviation); n = 3|. Experiments designed toinvestigate losses over shorter time periods(24 hr; 18.0 ± 3.2% loss; n = 9) and withvariable initial moisture content were sub-sequently conducted and were stronglycorrelated with water evaporation. Thevolatilized fractions recovered in all experi-ments were predominant ly lower ortho-chlorinated congeners (2, 2/2, 2/6, 26/2;IUPAC numbers 1 . 4 , 10, 19). In experi-ments of shorter duration (24 hr) and withlower initial moisture contents (35-50%),80-90% of the PCB volatile loss occurredwithin the first 8 hr and ended when thesediment dried. In experiments with vari-able mois ture con ten t , an e x p o n e n t i a lincrease in PCB volatilization was notedfor moisture contents above 26% relativehumidity, equivalent to a monolayer coat-ing of water molecules (6). Addi t iona lPCBs were volatilized when dried sedimentwas remoistcned.
Physicochemical Propertiesand Environmental Changes
^Significant progress in the understandingof how PCBs partition in the environment.and impact organisms has been made in,
'the last decade. Much of this can be attrib-uted to the development and use of analyt-
"Jcal techniques capable of measuring indi^vidual PCB compounds (congener-specificcapi l lary column gas chrpmatography) .Accurate informat ion on how PCBs andother s imi l a r organochlormc compoundspartit ion and degrade in the environment.
_is essential to determine their ultimate fate
_and ecosystem impact and, consequentially.to arrive at informed remedial decisions.Contrary to widely held notions of t h e i rchemical stability and immobility, PCBs arenow known to undergo a l tera t ion, pa r t i -tioning, and degradation in certain environ-mental systems. Although these conceptsare appreciated by PCB researchers, they areyet to be fully recognized by the scientificcommunity at large or integrated into recu-
Tarory policy considerationsThe degree of c h l o t i n a t i o n of PCBs
determines their physicochemical properties,such as solubility, octanol-water partitioningcoefficients, and Henry's Law constants, andthus their mobility (/•/). Anaerobic microbialdegradation, resulting in partial dechlorina-tion of PCB congeners, has now been reported from numerous localities i . /5) includingthe St. Lawrence ( /6) and Hudson i / ~)Rivers. Although dechlor ina t ion is widely
.inferred to be env i ronmen ta l l y beneficial. . ,^ these transformations result in the productionjat more mobile and bioavailable daughter t
products and increase the potential (or trans-port by water or air. Large concentrations ofmicrobial dechlorination daughter productswith one to three chlorines have been mea-sured in sediments from the St. Lawrence andHudson Rivers. Three of these (I. 2/2. 2/6)comprise over 65% of the PCBs transportedby waters of the upper Hudson River i 18). Incontrast to the more highly chlorinated PCBcongeners with solubilities below the pau-per-billion range, these congeners are solubleat the par t -per-mi l l ion level ;ind have thehighest Henry's Law constants ( \ 9 \ .
Possible ImplicationsThese measurements of PCB volaul iry frombiodegraded sediment, al though based onsmall-scale experiments, may have impl ica -tions for die handling of PCE-contaminatedmedia. From an analytical perspective, signifi-cant changes can be expected as environmen-tal media are allowed to air dry or evaporate.
Address correspondence to R. Scrudaio E n v i r o n -mental Research Center. J I ' J Pu-z Hal l > l 'NY atOswego. Oswego. New York 131 -6 I'SAThe authors wish 10 acknowledge f u n d i n g f r o m ihcNew York Sea grant I n s t i t u t e - i p r j m M i - ' M - i l M )and from the National I n s t i t u t e - tor I.n' . iriHirm-m.ilHealth Sciences Basic Research P rour jn i i i i r j n t IN 2ES04913). The authors also .ippri.-i.iatc ihi- l ie lp l 'u lcomments of the reviewersReceived ') J u n e 199': accepted 8 ( \ io rx t
tvcn tor short periods. Anticipated chancesncludc lowering "I totaj concentrations .ind.ilteration of relative congener abundances.
''These alterations can mask environmentaltransformations: result in erroneous assump-tions or aerobic hiodcgradation (e.g., disap-pearance of ^rr7>»-chlorinated PCB >.on-g'.-ners); impose bia:> on retrospective studiesor archived samples: confuse fingerprintingof Lontam mant sources: or. because ofreduced concentrations, reduce liability orresult in improper disposal.
Or grejter concern, however, is thepotential vo la t i le losses of semivolat i lesduring large-scale remedial, dredging, landfarming operations involving contaminatedsolids and the use of contaminated sedi-ments tor rl.l or landfill cover material. Inparticular. P(.'B mixtures with a high pro-portion lit more mobile congeners, includ-ini; those produced by microbial detirada-tion or originally present in less chlorinated'"Ar.itlorsie.". 1010. 1242. 1248). have thepotential to lose significant quantities ofI'CBs during handling and drying.
Within New York State, a number oflariie-scalc dredging projects involving cont-aminated sediments are under considera-t ion. In the St. Lawrence R iver , overI 00.000 yd' or sediment contaminatedwith I'CBs i Aroclor 1248) and polvcyclicaromatic hydrocarbons (PAHs) have beendredged, and add i t iona l dredging isrequired. Dredging of the upper HudsonRiver, which has been debated for twodecades in relation to industrial dischargesof .:.()00--4.: 00 metric tons of Aroclor1242 (2(J\. could occur in the future. ThePCB tractions of sediments from both theSt. i .awrcnee .ind Hudson rivers are domi-nated bv l o v e r ch lo r i na ted congeners( Id 21) der ived f rom both microbialdeclilorm.mon and the original Aroclorcomposition. A dredging project, promptedbv ravigationj needs and dwarfing eitherof these act ions, is planned for the NewVorL'-Mew lerscv Harbor area and will x
involve remov.il. transportation, and dispos-al lit approximately -+-S x 10" mVyear ofsedinem tor ^ years. A large portion or thissediment is contaminated with a wide vari-etv ( t senmol.mlc compounds includingI'CBs. P A H s . d iox ins . and pes t i c i des .\'olaiile losses of contaminants during stag-ing, 'lewaterms.:. drying, transportation, ornpl.ii d of or .it contained disposal facilit ies.ire l ikelv .nut i.annot be reliablv estimatedfrom the exist ing database < -/).
L.ind larmi'ig, .in .ncreasinclv populartreatnenr method for contaminated soil ursedi ivent. also has the potential to releaseNigmlkant c|uantiries of con taminan ts viavol . i t i l i / a t i o n . Tempora l c o n t a m i n a n trcduc:ions in nunv land farming operations
have been attr ibuted to bioremcdiationwith little or no evaluation of volatile losses.despite a Considerable body of literatureshowing positive relationships between pes-ticide loss and soil temperature, moisturecontent, or precipitation events (5). Inaddi t ion, many in situ biorcmediationefforts employ the injection of air or oxy-gen. or vapor stripping to enhance micro-bial activity. Little is known or the magni-tude of volatile losses during these activities.
The volati le loss of PCBs and othersemTvolatile organic pollutants from soil.sediment, and water is the primary pathwayresponsible lor their global redistribution.
JiloTS.il frac'rMlVUion theories propose that^the more mobile congeners of various contr.
^iminaiu~ctoses I e.g., I'CTIs. PAHs. polv-clilonnaied diben/odioxins and dibenzofu-rans. chloroben/enes, chlorinated pesti-cides) preferentially volatilize, migrate, con-
.jjen.se. and (ail out in polar regions (22.23),consistent with lIleirphysicocnemicaTprop-erties (/*). The flux, ultimate fate, andpotential impact of these contaminants inpolar regions is largely unknown.
Long documented to be carcinogenic,PCBs are now implicated in other humanhealth effects, including permanent reduc-tion in IQ and altered behavior in develop-ing fetuses and children exposed to themother 's contaminant body burden inutcro (24). There is significant evidencefrom animal studies implicating orrAo-sub-stitutcd, lower chlorinated congeners inthese neurotoxic effects (25-28). Given thepotential for volatile releases dominated pvflrfAo-substituted. lower chlorinated con^geners during sediment dredging or reme-dial operations. PCB exposure to local pop-ulations i J") warrants further investigation.
jarticularlv via inhalation, which has beenlargelv neglected since the initial studiescarried out by the Halowax Corporation in1 936 ' J 0) . Although lower chlorinatedPCB coni;eners arc generally considered tohe rapidlv metabolized and excreted, they,Jiave been found in subpopulations of fetalcord blood and mother's milk samplestrom upstate New York (31. 32), possiblv_implying continuous exposure through^i n h a l a t i o n . Studies are needed to evaluatecontaminant air concentrations and the sig-nificance of inhalation exposure to popula-tions residing near activities likely to leadto volatile releases.
SummaryC o n t a m i n a t e d so l ids ( so i l , sed imen t ,sludge) represent significant repositories ofI'CBs and tit l icr sennvolatile compoundsw i th s imi la r pin sicochcmical propertiesc i i r r e n t l v i s o l a t e d Irom c i r cu la t i on .Alterat ion ul these sediments by microbial
processes results in dechlormation and theproduction of more mobile and bioavail-able daughter products. Experimental datasuggest that lower chlorinated PCB con-geners are highly susceptible to volatile lossduring co-evaporation wi th water . Byextrapolation, similar findings are antici-pated for other classes of semivolatile com-pounds. Dredging, remedial, or land (arm-Ing operations targeting large isolated orburied contaminant repositories may havethe potential to release semivolatile com-pounds to the atmosphere. Studies <>f cont-aminant air concentrations associated withremedial activities and potential exposurevia volatilization to local inhabitants aresorely needed, as arc new guidelines toaddress sample analysis and handling. \X'eurge that the volatility of semivolatile i.oin-pounds be considered in decisions regard-ing possible remedial intervention, benefi-cial use. and in design and implementationof remedial activities.
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Tommerranes
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28. Kodavanti P. Ward T McKmnev J. Tilson H nn-bitionof microsomai and mnocnononai Ca; • seouestrationin rat cerebel lum oy poivchionnated Dipnenvi mix-tures and congeners, structure-activity reianonsniosArch TOXICOI 70.150-157 119961
29. Cullen A. Vornees D. Allsnul L Influence ot naiocr con-tamination on the levei ano composition ol ooivcnon-nated biphenyis m produce in greater New Bco 'o 'C.Massachusens Environ Sci Tecnnoi 30 1581 -588119961.
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32. Busn B. Snow J. Connor S. KoblmuR Polvcnlormateobiphenyl congeners, p-p -DOE ano hexach io rcoen-/ene in human milk m three areas ol upstate NewYork Arch Environ Contam TOXICOI 14 M3 450 ! 19851
NIEHS Excellence in basic research at theNational Institute of Environmental Health Sciences
NIEHS scientists and grantees perform basic studies of our susceptibility to environment-related disease:
Demonstrating that a carcinogen in cigarette smoke (benzo(o)pyrene) alters part of a gene to cause lung
cancer...showing the effects of fetal exposure to PCBs...developing a strain of mouse that lacks functional estrogen
receptors and that helps evaluate how some pesticides and other estrogen-like compounds might affect development
and reproduction—discovering the genes for breast, ovarian, and prostate cancers—finding womefTsjDptirnardays of
fertility,..seeking to reverse the damage from lead exposure...finding alternatives to tradit
pinpointing the functions of specific genes by eliminating them from specially bred mouse Ifrim
3; using ordinary yeast cells, to isolate and clone genes and other fragments of genetic materiar ' jf.Sb-iF^ * *•- "'
jth«lBiflfects of urban air on lung function...