Work Plan to Develop
Health-based PCB Cleanup Goals
for Winston-Thomas Facility
Rodger DeVincenzo
Westinghouse Electric Corp.
Dear Rodger:
I have completed a review of this work plan as requested by Westinghouse.
Please note that Monroe County has no formal review process for such a document,
but I will take this opportunity to comment.
The health based cleanup goals ( HBCGs) were not presented in this document.
The equations were presented but the calculations were not conducted. After
discussions with the other project managers, it appears that the calculated
HBCGs are higher than allowed by current Federal Law (50 ppm versus 68 to
176 ppm). This is totally unacceptable to Monroe County. The use of performance-based
and technology-based standards are more protective of human health and the
environment than the health-based standard as presented.
Westinghouse is proposing to do less cleanup than what is required by
the Consent Decree (50 ppm plus a two to three foot "buffer zone"
for the site removals and less than 1 ppm PCB treatment for incineration
and "nonhazardous" ash disposal). Westinghouse has outstanding
past performance records at the Fell Iron and Metal site and the ABB Plant
property (where site cleanup to less than 10 ppm was achieved and acceptable)
and Westinghouse should not accept anything less. The citizens of Monroe
County will not expect anything less.
The HBCGs also do not take into consideration the additional environmental
protection requirements (i.e. lower PCB cleanup level) necessary to protect
the natural resources of Monroe County and State of Indiana. A cleanup action
level between 2 to 10 ppm appears to be necessary in order to achieve the
minimal ecological protection. (based upon review of the US Fish and Wildlife
Services and State of Indiana Department of Natural Resources' investigations
and documents).
I agree with the City of Bloomington's position to the off-site landfilling
alternative. The concentrations found in the materials stored in the ISF
prohibit their use in remediation (on-site containment) of Winston Thomas.
There is no reason why the cleanup of Winston-Thomas cannot begin this construction
season.
It is time for Westinghouse to begin cleanup at Winston Thomas and the
other Consent Decree sites. The cleanup level should be set between 2 and
10 ppm.. Westinghouse has proven in the past that cleanup activities can
be done with success. Westinghouse is capable of achieving an acceptable
cleanup program. Please feel free to call or write me to discussion these
comments.
Sincerely,
Dennis E. Williamson, R.E.H.S. # 549
Monroe County Health Department
February 13, 1997 |
