The PCB-contaminated materials that are mixed with municipal and industrial landfill wastes at the Bloomington Consent
Decree sites represent a wide range of heterogenous waste streams that are difficult to characterize fully in terms of
contaminants and concentrations to be treated, including PCBs. Therefore, on the basis of the available data, it is difficult, to
determine the public health implications of using non-incineration technologies for remediation of the Bloomington PCB
sites.
Fugitive emissions might pose a health threat to workers and nearby residents if the emissions are not properly monitored
and controlled. Significant fugitive emissions of contaminants can result from excavation and handling of contaminated
media, including such preprocessing as blending, sizing, separating, shredding, and transportation. Use of any of the ex situ
NIRTs for the Bloomington PCB landfill sites (except encapsulation technologies, such as landfilling, vaulting, and
solidification) would require significant pretreatment to meet the material sizing requirements (less than one-eighth of an
inch to a maximum of three-fourths of an inch, depending on the specific technology). This pretreatment would increase the
likelihood of fugitive emissions.
If soil washing, solvent extraction, thermal desorption, or landfilling is selected as a treatment technology, further
treatment of PCBs might be appropriate. These technologies do not destroy PCBs; except for landfilling, they concentrate
PCBs. Non-incineration technologies other than bioremediation and solidification/stabilization require treatment or disposal
of non-PCB byproducts and waste streams. Post-treatment waste streams and byproducts create additional hazardous
substance exposure potential for workers and the community.
It is not possible to evaluate the public health implications of a non-incineration remedial technology without engineering
design plans, operating plans, and results of site-specific treatability testing.
It is not possible to predict all public health implications of the emissions from the proposed Bloomington incinerators
because this combination of wastes has neither been sufficiently characterized nor previously treated in an incinerator.
Few data on specific interactions of the contaminants released from waste incinerators are documented in the scientific
literature. Almost all of our toxicologic data are from studies in which exposure levels greatly exceeded those typical of
incinerator releases. Scientific information on the human health impacts of incineration is not available because the relevant
studies haven't been conducted.
Information provided in the incinerator applications indicates that the estimated stack emission levels of contaminants
would not reach levels of public health concern. However, there are few data to support those estimates. Better evaluation
of the potential public health impacts of the stack emissions would require analysis of stack emissions from a full-scale or
pilot-scale incinerator--similar to the proposed incinerator--that is incinerating the proposed combinations of wastes.
On the basis of a selected case study and ATSDR's guidance on evaluating incinerators operating under the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, the Westinghouse permit applications
for the incineration facility proposed for Bloomington appear to address satisfactorily many--but not all--of the issues
identified as affecting public health considerations.
If the consent decree parties decide to proceed with incineration of the PCB-contaminated excavated landfill material,
preliminary projections of the potential stack emissions would, at a minimum, require additional analysis of the waste feeds.
The Waste Analysis Plan and Trial Burn Plan should then be revised to address additional constituents of public health
concern and to provide for burning the maximum feed rate of PCBs that will be allowed in the facility permit.
Protection of the off-site community, including first responder personnel and the public at large, is not addressed
adequately in the existing contingency plans for the incineration facility and the ash landfill. Contingency plans for
excavation and other activities at the individual PCB sites are not yet available.
Determine the potential public health implications if a non-incineration technology is selected for use at any of the
Bloomington PCB sites. ATSDR is available to conduct a comprehensive review of the remediation design and operating
plans and specifications of any non-incineration clean-up alternative proposed for implementation at the Bloomington sites.
The Agency will work with representatives of the Environmental Protection Agency, the state of Indiana, the city of
Bloomington, and the public to evaluate public health issues that might be associated with other specific remedial options.
Sample and monitor ambient air throughout the material handling and treatment processes to ensure that fugitive emission
controls are effective.
Before building the proposed incinerator, test the planned combination of excavated landfill material, municipal solid
wastes, and sewage sludge first in another similarly designed full-scale incinerator (if one exists) or at a pilot-scale facility to
determine whether stable operating conditions are possible, what the stack emissions will be, and the concentrations of
constituents of public health concern in the residuals.
Evaluate the preconstruction stack testing data for potential public health implications before construction of the facility.
ATSDR should conduct or fund health studies of potentially affected residents before and after remediation of the six
consent decree sites to evaluate the public health implications of the selected remedial technology or technologies.
Revise the Waste Analysis Plan and the Trial Burn Plan to address additional constituents of public health concern.
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.
Integrate on-site contingency plans more effectively with the local emergency contingency plans. Conduct preplanning
and hold meetings with the first responder community and emergency medical care providers--including firefighters,
hazardous materials teams, emergency medical technicians, and hospital emergency room physicians and nurses--to ensure
that both on- and off-site personnel fully understand each group's training, capabilities, and responsibilities. Make the
community aware of the possible site-related emergencies that would result in their notification and possible shelter-in-place
or temporary relocation.
Revise the facility Contingency Plan to address the six items listed in Volume II, Section V.E. of this PHA.
Joseph C. Carpenter, PE
Environmental Engineer
Division of Health Assessment and Consultation
Lynn C. Wilder, MS Industrial Hygiene
Environmental Health Scientist
Division of Health Assessment and Consultation
Betty C. Willis, MS Chemistry
Environmental Health Scientist
Division of Health Assessment and Consultation
Health Effects Assessors:
Lee M. Sanderson, PhD
Senior Epidemiologist
Division of Health Assessment and Consultation
Allan S. Susten, PhD, DABT
Assistant Director for Science
Division of Health Assessment and Consultation
Editor:
Ronald E. Hatcher, ABJ
Writer/Editor
Division of Health Assessment and Consultation
Regional Representative:
Louise A. Fabinski
Senior Regional Representative
ATSDR, Region V
REFERENCESAgency for Toxic Substances and Disease Registry. Public health overview of incineration as a means to destroy hazardous
wastes. Atlanta: US Department of Health and Human Services, Public Health Service; 1992 Feb.
Agency for Toxic Substances and Disease Registry. Draft report of expert panel workshop to evaluate the public health
implications of human exposure to polychlorinated biphenyls (PCBs). Atlanta: US Department of Health and Human
Services, Public Health Service; 1994 Aug.
Indiana State Department of Health. Final report: preliminary data evaluation and pathway analyses report for consent
decree PCB sites. Indianapolis: Indiana State Department of Health, 1994 Apr.
Johnson BL. Testimony before the Subcommittee on Human Resources and Intergovernmental Relations, Committee on
Government Operations, US House of Representatives. Washington: 1994a Jan.
Johnson BL. Testimony before the Subcommittee on Human Resources and Intergovernmental Relations, Committee on
Government Operations, US House of Representatives. Washington: 1994b July.
Singal M, Roper P. Health hazard evaluation report HETA 86-519-1874, Ensco. El Dorado, Arkansas. Cincinnati, OH:
National Institute for Occupational Safety and Health, Hazard Evaluations and Technical Assistance Branch, 1988.
Westinghouse Electric Corporation. Application for incinerator certificate of environmental compatibility, volume 1: part 1
through part 13. Pittsburgh: Westinghouse, 1991a July.
Westinghouse Electric Corporation. TSCA/RCRA incinerator permit application, volumes 1 and 2. Pittsburgh:
Westinghouse, 1991b July.
Westinghouse Electric Corporation. Application for an air quality permit. Pittsburgh: Westinghouse, 1991c July.
Westinghouse Electric Corporation. Application for landfill certificate of environmental compatibility, volume 1: part 1
through part 13. Pittsburgh: Westinghouse, 1991 Sep.
