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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:

    "Air emissions from the unit did not affect operating personnel or the local community. Combustible gas meters indicated that the unit did not leak significant amounts of propane. Therefore, operation of the unit does not prevent an explosion threat much different than that associated with domestic propane usage. Background air sampling and personnel monitoring results indicate that organic vapors and PCB levels were present at levels below the detection limit for the analytical methods. The unit did not cause a sudden release of propane/butane or liquids. Only minor leaks occurred and staging areas soils were not affected."

Similar assessments are available for other NIRTs from EPA and technology vendors, and this data should be included in ATSDR's report.

    ATSDR did evaluate available published and non-published literature on NIRTs applicable to the treatment of PCB-contaminated media. This evaluation was conducted during the expert panel meeting in Bloomington in September 1993. Specific information regarding potential risks and the data gaps associated with technology categories as well as with some vendor-specific technologies can be found in the Proceedings of the Expert Panel Workshop To Evaluate the Public Health Implications of the Treatment and Disposal of Polychlorinated Biphenyls-Contaminated Waste.

##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.

    Neither the panel nor ATSDR specifically addressed the treatment of PCB-contaminated water. In general, PCBs are not readily soluble in water and are often found in water to be associated with suspended particulates. Bioremediation and other technologies for sediments were discussed. If asked, ATSDR will review health risks of a chosen technology once all the details associated with the technology for a particular site are provided.

##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.

    The expert panel and ATSDR considered vitrification as a technology that fell into the solidification/stabilization category. In addition, the recent American Academy of Environmental Engineers/WASTECHR innovative site remediation technology publication series includes vitrification in that category. Air emissions data, limitations, and advantages of this technology are discussed in the Proceedings of the Expert Panel Workshop To Evaluate the Public Health Implications of the Treatment and Disposal of Polychlorinated Biphenyls-Contaminated Waste.

##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.

    ATSDR concurs with this comment. Capping is not the same as landfilling. The expert panel and ATSDR did not discuss capping as a technology because it is not considered a technology that will remediate the contamination. ATSDR generally considers capping to be an interim measure, used to mitigate exposure to surface contamination until a permanent remedy is implemented. Many of the Bloomington sites have been capped, and additional discussion on the health implications of leaving PCB contamination in place appears in the public health assessment (PHA) Volume II, Section VI.

##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.

    ATSDR agrees that comprehensive site evaluations at Bloomington, as at any site, allow a comprehensive evaluation of contaminants of concern, exposure pathways, and possible health risks. ATSDR agrees that the data for the Bloomington sites are limited. However, the consent decree parties are revisiting each site and evaluating whether gathering additional data will help them develop better characterization of the site. We will reevaluate human health risks as additional data that may be pertinent to health risks become available.

##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.

    ATSDR agrees that additional data would be valuable to the development of better site characterizations. As stated in the panel report and in the PHA, Volume II, full characterization of landfills is difficult, if not impossible. Volume I of the PHA contains recommendations for additional sampling to ensure the protection of public health (i.e., primarily private well sampling). The consent decree parties are revisiting each site to determine the needs for additional data. We strongly recommend that the consent decree parties incorporate the recommended sampling into their sampling plans. See also ATSDR response to data quality (first theme addressed in Section III.A.).

##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.

    We couldn't agree more. Prevention is always the best public health policy. However, where contamination already exists, realistic assessment of public health impact is necessary.

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?

    Yes, ATSDR does believe that we should try to limit or prevent exposure to all toxic chemicals under circumstances that would lead to adverse human health effects. ATSDR's mission is "to prevent exposure and adverse human health effects and diminished quality of life associated with exposure to hazardous substances from waste sites, unplanned releases, and other sources of pollution present in the environment." As stated by Barry L. Johnson, PhD, assistant surgeon general and assistant administrator of ATSDR, in his testimony on January 24, 1994, before the Subcommittee on Human Resources and Intergovernmental Relations, United States House of Representatives, "Incineration of wastes should be viewed from a public health perspective in the larger context of generation and management of wastes. Wastes become a public health concern when they are improperly managed and disposed of. Therefore, in a public health context, the most protective action is not to produce waste. Waste elimination or minimization comports with prevention or reduction of health consequences of wastes."

##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.

    The best way to prevent dioxins from entering the environment is to minimize the creation of or avoid producing hazardous wastes and to recycle or reuse any wastes if possible by means that do not cause the generation of dioxins. Incinerators are only one source of dioxin in the environment; other sources of dioxin include cigarettes, fireplaces, automobiles, coal-burning power plants, and industrial plants. The newer incinerators are designed to minimize emissions; therefore, replacing old incinerators with state-of-the-art incineration facilities or requiring the old incinerators to be upgraded to have the best available pollution control technology would be desirable. ATSDR concurs that incinerator ash containing significant amounts of dioxin should be managed in a manner that prevents human exposure.

##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.

    Because ATSDR has received so many questions regarding the use of incineration at Superfund sites, the agency staff developed the guidance document Public Health Overview of Incineration as a Means to Destroy Hazardous Wastes. The guidance document points out the site-specific factors that are important for the health assessor to evaluate before determining on a site-specific basis what the public health implications of an incineration facility are. The document does not suggest that all incinerators are protective of public health; rather, it requires that a number of factors be evaluated before drawing any conclusions. In the guidance document, ATSDR implies that poorly run or operated incineration facilities can impact public health and that even a properly designed and operated incinerator, if placed in the wrong location, may adversely effect public health.
    Data gaps do exist for incineration, as pointed out by the expert incineration panel and summarized for Congress by Dr. Johnson in the referenced testimony. However, this does not imply that incineration should be outlawed. Rather, ATSDR considers it important to evaluate each situation on a site-specific basis. To provide data to help fill some of the data gaps regarding the health effects related to combustion facilities, ATSDR is conducting several health studies in communities near incinerators and other combustion facilities. In addition, ATSDR often requests additional environmental data to help make better public health decisions.

##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?

    The panel was asked to discuss PCB incineration in general, not to review any specific PCB incinerators. However, that discussion included data relevant to using Municipal Solid Waste (MSW) as the primary fuel to co-incinerate sewage treatment sludge, PCB-contaminated soils, MSW, and stream sediments. None of the panel members were aware of this combination of waste feeds. Most, if not all, of the panel members thought this combination was "unique" and should be tested in a pilot-scale facility before construction of a full-scale incinerator. They were doubtful that MSW would provide sufficient heating value to maintain stable operating conditions and sufficiently decontaminate the PCB-contaminated wastes if these wastes were mixed with the MSW and sewage treatment sludge.

##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.

    ATSDR congratulates the City of Bloomington for its successful recycling program! Unfortunately, it is not possible to recycle all MSW, so Bloomington does continue to landfill a substantial portion of its MSW. Because the consent decree parties and the community are considering alternatives to incineration, ATSDR included in Volume II of the PHA a discussion of what is known about the potential public health effects of a number of non-incineration remedial technologies.

##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.

    ATSDR did not try to estimate the potential public health impact of the two proposed incinerators because this combination of wastes has not been sufficiently characterized or previously treated in an incinerator. In Volume II of the PHA, ATSDR made the following recommendations:
      1. 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.

      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.

ATSDR agrees that the points made by this commenter should be included in the public health evaluation that will be done if the decision is made to build the incinerators. When ATSDR evaluates the public health impacts of a site, we look at both acute and long-term health effects. Recommendations 2 and 5 above address the commenter's concerns.

##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.

    ATSDR did not include a lengthy discussion of the proposed ash landfill in Volume II of the PHA because little information is available on the analysis of the ash that would be disposed in the landfill. As noted in the response to the comment above, we have recommended that if the decision is made to build the incinerators and bury the ash in the Bloomington area, a thorough public health evaluation be conducted before the incinerators are built.

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