for Bloomington PCB Sites
Bloomington, Monroe County, Indiana
Spencer, Owen County, Indiana
IV. Responses to Public Comments on Volume II of the Public Health Assessment for Bloomington PCB Sites
Volume II of the Public Health Assessment for Bloomington PCB Sites (PHA) was written by Agency for Toxic Substances and Disease Registry (ATSDR) staff members and was released for public comment in September 1994. The development of the document was based extensively on the findings of the expert panels that met in Bloomington, Indiana, in September 1993. Those findings are in a separate report, Proceedings of the Expert Panel Workshop To Evaluate the Public Health Implications for the Treatment and Disposal of Polychlorinated Biphenyls-Contaminated Waste, which was released in September 1995.
ATSDR held a public availability session in Bloomington in November 1994 to discuss issues related to Volume II and any other comments that citizens had regarding the overall project. Only a few general comments pertaining to Volume II came from the meeting or through the mail. Comments on Volume II of the PHA are addressed below.
This report divides the comments and responses to comments to Volume II between two sections: those that address issues regarding non-incineration remedial technologies (NIRT) (IV.A.) and those that focus on incineration (IV.B.). Because ATSDR is a public health agency, our primary focus is and was on factors that influence exposure potential and public health rather than on technology issues per se.
IV.A. Responses to Public Comments on the NIRT Sections of the Public Health Assessment for Bloomington PCB Sites, Volume II
##1. Regarding the potential health risk associated with NIRTs, The potential risks associated with implementing NIRTs were mentioned in general terms as data gaps, but the ATSDR report fails to review and report published data addressing this topic. For example, an EPA (Environmental Protection Agency) document (EPA/540/S5-90/002) that highlights innovative technologies developed under the Superfund Innovative Technology Evaluate (SITE) programs document reports the following for CF Systems' solvent extraction of PCB (polychlorinated biphenyls)-bearing sediments at New Bedford Harbor:
Similar assessments are available for other NIRTs from EPA and technology vendors, and this data should be included in ATSDR's report.
##2. NIRTs for water are entirely different from NIRTs for soil, sludge and landfill material. Since the large volume of water at the Winston-Thomas lagoon will be drained and treated, the surface water treatment system at Neal's Landfill is generally acknowledged to be inadequate, and springs and seeps at other sites may require treatment, NIRTs for water must be added to this report. At a minimum, the implementation risks of the following candidate NIRTs should be addressed: carbon, UV (ultraviolet) radiation and oxidation, membrane filtration, bioremediation, gas-phase chemical reduction, and evaporation with catalytic oxidation.
##3. Vitrification is a high-temperature destructive NIRT that produces a glass-like residual material. It is commercially available by more than one vendor, has been demonstrated to effectively treat PCBs and a variety of other wastes, and can be implemented in situ (i.e., without excavation). Vitrification was addressed in the NIRT expert panel discussion, but was omitted from this report under the incorrect assumption that it was represented by solidification. Since it is a viable alternative but has potentially significant implementation risks, it should be addressed by ATSDR in the Bloomington report. Data on performance in the field and chemical analyses of off-gases are available from Geosafe Corporation and EPA, so a detailed analysis of implementation risk should be possible.
##4. Capping, the interim remedial measure implemented at the landfill sites, and the remedial measure currently advocated for the long-term by at least one of the consent decree parties, was also omitted from the discussion of NIRTs. This remedial option is not the same as land filling since it offers protection only on the upper exposed surface, and should therefore be assessed separately in the report.
##5. All assessments of current or potential risk should be qualified to reflect that they are based on incomplete site characterization data. There is substantial value in performing preliminary risk assessments based on available data, but greater emphasis should be placed on the likelihood that some of the available data is of questionable validity, and that there are other chemicals of potential concern in water, soil/sediment, and air associated with the sites that have not yet been addressed.
##6. There are obvious sampling deficiencies at all of the sites. ATSDR should make specific recommendations regarding additional environmental sampling to identify the chemicals of concern at each site.
##7. Since there are a number of gaps in our full understanding of the impacts on public health of any remediation technology, including incineration, some would argue that we should not employ these technologies, the wastes should be stored in concrete bunkers until a safe technology that won't affect public health is developed. Vaulting of the wastes is admittedly only a temporary solution. The goal is detoxification of the chlorinated hydrocarbons and recovery and isolation of the toxic metals associated with them. Vaulting of wastes of the lower priority sites and more stringent remediation of the highest priority Sites until they can be cleaned up should be considered. PREVENTION of further contamination of the public and the environment should be the guiding principle of decision-making.
IV.B. Public Comments on Incineration Sections of the Public Health Assessment for Bloomington PCB Sites, Volume II
Citizens' concerns regarding the selection in 1985 of incineration as the primary remedial option for the destruction and disposal of polychlorinated biphenyl (PCB) contamination in wastes from the Bloomington area was in fact the driving force behind the Congressional request to ATSDR to initiate the current project. A number of the incineration-related comments ATSDR received on Volume II were similar to comments the agency received on the Proceedings of the Expert Panel Workshop To Evaluate the Public Health Implications of the Treatment and Disposal of Polychlorinated Biphenyls-Contaminated Waste. Those proceedings were general in nature and did not address site-specific questions or concerns. However, because of their general nature and because of the interest in incineration, the first four responses below (##8-##11) are the same as those presented in the proceedings. The remainder of the responses are to questions that were more specific to the six consent decree Bloomington PCB sites.
##8. Does ATSDR believe that we should try to prevent and not add to the high levels of persistent toxic chemicals and heavy metals in background pollution?
##9. The best way to prevent dioxins from entering the environment would be to prevent incinerators from being built. For those in operation, the best available pollution control technology should be required for storage of incinerator ash, particularly fly ash, but also bottom ash if it contains significant amounts of dioxins.
##10. ATSDR appears to be pro-incineration based on certain statements in the ATSDR document Public Health Overview of Incineration as a Means to Destroy Hazardous Wastes and testimony by Dr. Barry L. Johnson, assistant administrator of ATSDR, on January 24, 1994, before the Subcommittee on Human Resources and Intergovernmental Relations, on the health impacts of incineration. Dr. Johnson's testimony on the lack of knowledge of health effects from incineration is sufficient grounds for outlawing incineration of hazardous wastes until the data gaps are filled and the results evaluated.
##11. One of the Incineration Panel's recommendations listed in the Executive Summary and Chapter 3 of the Proceedings of the Expert Panel Workshop To Evaluate the Public Health Implications of the Treatment and Disposal of Polychlorinated Biphenyls-Contaminated Waste states that pilot or full-scale tests should be run before incineration of "unique" waste feeds. PCB wastes from 100% to dilute aqueous stream and low PCB concentration soils have all been burned at full scale. What other PCB wastes exist that do not fall within the wide ranges of PCB concentration, ash content, chlorine content, and heat value that have already been incinerated?
##12. The use of MSW (municipal solid waste) to fuel the incinerator is a moot point as MC/CB (Monroe County/City of Bloomington) citizens have made RECYCLING of their wastes a resounding success, with Bloomington recently receiving a Governor's Award for its recycling program. In fact, MC/CB citizens believe that ATSDR should consider INCINERATION A MOOT POINT. Consent Decree parties are now considering alternatives to incineration.
##13. The importance of "cumulative loadings" cannot be underestimated by ATSDR because of high concentrations of PCBs and other chlorinated materials and trace catalytic metals such as copper in the soils of the Superfund Sites. The sheer bulk of the contaminated soils which remain grossly underestimated is another dimension to be considered in "cumulative loadings". The outside estimate in the Consent Decree for burning the contaminated soils of the 6 Superfund Sites was 15 years. What is it now when Lemon Lane is estimated at 670,000 cubic yards? What will it be when Neal's Landfill is re-estimated? EPA and Westinghouse also want to burn the excavated soil from Fell's and Westinghouse, even though they refused to have them listed as Superfund Sites under the Consent Decree. Long-term bioaccumulative effects of cumulative loadings of PICs (products of incomplete combustion) and POHCs (principal organic hazardous chemicals) and heavy metals from incinerator emissions into the atmosphere and/or accumulation in the ash, on public health and the environment, is a primary concern of the Monroe County/City of Bloomington community.
2. Evaluate the preconstruction stack testing data for potential public health implications before construction of the facility.
--------
5. If the decision is made to dispose of the residuals in the proposed landfill in the Bloomington area, evaluate the landfill operating procedures for potential public health impacts from the management of ash and residuals.
##14. ATSDR must evaluate all aspects of incineration applying to MC/CB Superfund Sites including hazardous ash landfills. ATSDR never mentions ash disposal but this is exceedingly important to the MC/CB situation because the burning of soils contaminated with diverse types of toxic pollutants will result in need for hazardous waste landfills of monumental proportions equal in size to the number of cubic yards of soil burned. Only ash promotes leaching-out of toxic substances faster than soil.
The use of the best possible pollution controls is the Catch 22 of incineration since, if the pollution controls are well maintained and effective, toxic pollutants will be concentrated in the ash, which would include not only heavy metals but dioxins, etc.
Dilution, too, is no solution, since it is the sum total of toxic substances that are contained in the ash landfill that will be released over time into the environment that is significant. Since batches of waste feed may vary considerably in toxicity from batch to batch and effective routine sampling of ash is next to impossible, a community will never know the full extent of the toxic burden in the hazardous ash landfill. Prevention of such a legacy to succeeding generations is a strong reason for prevention of incineration.