Risk Assessments at Lemon
Lane and Winston-Thomas

by Mitch Rice
from the Bloomington Voice
April 17,1997

As you may know, the 7th Circuit Court last year demanded that the parties to the Consent Decree develop an aggressive schedule for cleanup of Bloomington's Superfund sites. (Note that only the Westinghouse Plant and Fell Iron and Metal sites have been cleaned up, and they were not part of the Consent Decree, which governs the cleanup process).

Unfortunately the parties have spent so much time debating the issues involved in developing risk assessments for Lemon Lane and Winston-Thomas, that the schedules for the other sites, most significantly, Neal's Landfill, which releases large amounts of PCBs every time it rains, have been delayed. (Sound familiar? This is the same scenario as at Lemon Lane: when it rains, PCBs are released into our local creeks and rivers.)

As the Winston-Thomas facility is arguably the easiest site to deal with, and as there have been repeated accidental releases from the site, the City and EPA have been pressuring Westinghouse to begin work at Winston-Thomas this year, with the cleanup being completed in 1998. But this site is in the risk assessment phase, and if it follows the pattern that has been established at Lemon Lane, we are in for a long wait! There are many contentious issues involved, though not so many as at Lemon Lane.

Lemon Lane

The City recently released a large number of the documents related to sampling at Lemon Lane. Results of the borings done last November showed PCBs everywhere, but some especially high numbers at various depths all along the south end, including the southeast corner, and numerous water samples were taken at the various sampling wells around the site, and at the ICC Springs. Those of us who get our jollies from reading such exciting documents have been asking to see this material for over a year. The EPA told us time and again that these documents were located at the PCB Repostitory at the MCPL, but we could never find them when we tried. So it was not much of a surprise to find out the truth of the matter at the last CIC meeting: the sampling plans and results were not being placed in the Repository, Westinghouse had failed to place them as agreed with the EPA! So this package of materials, plus the summary of all the various studies prepared by Earth Tech, an EPA subcontractor, were given to us at COPA, and we can make them available to anyone who wants to see them by calling 333-8888. There is not much one can do about the sampling plan, the work was done last November, but the all important question of how the data is to be interpreted is still to be determined.

Ecological sampling was done last fall as well, and the results, though not officially released, do show high levels of PCBs in the fish in Clear Creek south of the ICC Springs, This is no surprise of course, but it does reaffirm the necessity of constructing a water/sludge treatment plant at the ICC/Quarry Springs complex to stop the PCBs from entering the environment. As Westinghouse's plan is to cap Lemon Lane with as little excavation of PCB contaminated material as possible, this treatment plant is vital: PCBs are expected to leak from the site in perpetuity.

Estimates of the total tonnage of PCBs dumped at Lemon Lane range from 40 to 400 tons, depending on who you ask. This is a lot of PCBs, and Westinghouse's "cap and run" plan leaves them right here, unremediated, and not very well contained. If one compares this with the clean-up specified in the Consent Decree, (removal of all material down to the 1958 level), you can see the approach to clean-up has changed considerably since Westinghouse will no longer make money from this venture, as was the case when the incinerator was the remedy of choice.

When we ask why a remedy other than capping in place can not be implemented, the answer we get is that under the Consent Decree, only Westinghouse can propose new technologies. But when we point out that the Consent Decree requires cleanup to the 1958 level and beyond, it no longer has the force that it does when it works in Westinghouse's favor. So what is going on? The City has taken a hard line on this, thanks to the Mayor's new attitude towards Westinghouse and the EPA. Apparently this use of the Consent Decree to protect Westinghouse while excluding meaningful input into the process does not pass muster with the Mayor, and this is one of the main points that has been in contention over the past year. All the forces are at play that could give us a final choice of remedy at Lemon Lane this year, but the disparity between the Westinghouse plan and the reality of what is needed is so great that I must doubt that an adequate plan will be agreed upon this year. For more information on the sampling plans and results at Lemon Lane, stop by the COPA PCB Clearinghouse.

Winston-Thomas

Due to pressure from the City and the EPA, plans to begin remediation at Winston-Thomas are being formulated and debated. This site is the most straightforward to clean-up and has had several releases into Clear Creek in the last couple of years, though the amount of contamination released is small compared to the ongoing releases from ICC Springs. Westinghouse has proposed a "Health Based Cleanup Goals Plan" (Dec. 23, 1996), and the City, County, and State have commented on this plan. These documents are available on the COPA site at http://copa.org.

Also recently released was the EPA's "Determination of Clean-up Criteria for the Winston-Thomas Site." (March 6, 1997). In this document, the EPA has set a goal of 15 ppm for most of the site as being protective of human health. The criteria to protect the environment was set at 1 ppm (part per million), and this level of clean-up is to apply to the abandoned lagoons and the West Side of Clear Creek, where a new area of contamination was recently discovered, and where flooding occurs each spring and fall. The City has been working on fencing this area, but has been unable to do so due to the high water. Why is the level for human health protection so much higher than that required to protect the environment? Is it that the effects of bioaccumulation that are the most pressing? If so, why don't we attempt to stop the ongoing releases at ICC Springs, Neal's Landfill and Winston-Thomas, by emergency order (of the EPA) if necessary.

The urgency of stopping these releases into the environment is highlighted by the two cleanup standards, 1ppm for the Environment vs.15 ppm for human health. This is because of the effect of the rising background levels of PCBs, having such an effect on the reproductive systems mammals and birds, is more of a danger than that of anyone having to be around dirt that contains 15 ppm. About 50% of all the PCBs manufactured are still out there, we must stop these releases now before this insidious poison compromises our reproductive futures.

For more information about the health effects of PCBs stop by COPA Website at http://copa.org/. If you do not have access to a computer at home, then simply stop by the Monroe County Public Library and on the second floor is the public computer room, you can access the COPA Website from there, and print up to 25 pages for free.