EPA Region 5 Records Ctr.

Monroe County Library303 E. KirkwoodBloomington, IN

6:30 to 9:00 p.m.

August 7, 2007.

237766EPA HEARING

NEAL'S LANDFILLBloomington, IN

Dave NovakEPA Community Involvement Coordinator1 800 621 8431 Ext. 67478

Thomas AlcamoEPA Remedial Project ManagerEPA Region 5 (SR-6J)77 W. Jackson Blvd.Chicago, IL 60604-3590312 866 7278

Thomas WoodUS EPA Region 4Modeling Expert

James ChapmanES EPA Region 5Ecologist

Jeff LifkaProject ManagerTETRA TECH

Eric MortonHHRATETRA TECH

John BassettHydrogeologistEARTH TECH

Jessica FlissProject ManagerIDEM

Paul BlackNEPTUNE

DAVE NOVAK: Okay, we're going to get

started. We've got a long program and the presentation

to show that Tom will go through, prior to the

comments. So how we're going to do it this evening is

going to be the first portion is going to be a

presentation by Tom Alcamo, the Project Manager. And

then you can ask questions during the first portion.

At 8:00 o'clock we're going to stop and get into the

official comments. The entire evening is being

recorded and that's going to be part of the

Administrative Record. And all the comments received

will be responded to under the response in the summary.

Me, I'm the new old guy on the block. I was

on the project from '92 to '97. And the former

project, or not project manager, Community Involvement

Coordinator Stuart Hill retired. Good for Stuart.

We've all got something to aspire to. And having a

little bit of knowledge of Bloomington I got it back to

work with Tom. Pleasure to work with the variety of

different people.

I'm Dave Novak. If some of you know me from

before, and there's a couple of faces I remember.

We've got quite a line up of people assisting us this

evening. Tom Alcamo, of course, the Project Manger, we

have seen quite a number of times.

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Tim Wool, EPA Region 4, he's the Modeling

Expert. He helped Tom a lot with the modeling of some

of the items here.

James Chapman, EPA Region 5, Ecologist. He's

up in the audience.

Jim Lifka, Tetra Tech Project Manager. He's

one of our contractors that works along on the project.

Eric Morton, Tetra Tech Human Health Risk on

the project.

John Bassett, Earth Tech hydrogeologist.

Jessica Fliss, IDEM, Indiana Department of

Environmental Manager, Project Manager.

Paul Black, of Neptune, who is doing

statistical analysis. And he comes to us from Denver,

right? So we've got a multi-state project here.

Again, I'm Dave Novak, Community Involvement

Coordinator and again what we're going to do - Tom will

go through the - do you want questions during the

project?

TOM ALCAMO: No, we'll do questions after.

DAVE NOVAK: Okay, we'll do the questions

after and let him go through his presentation. He's

probably going to answer a lot of those questions

anyway. Hopefully, you'll be able to see everything.

There's a lot of material to cover, so without further

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ado, we'll get right into it and listen to Tom.

TOM ALCAMO: Thanks Dave. If I'm squinting

it's because there's a huge spotlight on me.

I'm going to give you a little bit of

background on Neal's Landfill. Most of the people here

probably know about it, but I'll give you some

background.

Located about five miles west of Bloomington.

Former landfill, accepted industrial and municipal

waste until about 1972. Large quantities of PCBs

disposed of at the landfill from the Westinghouse

capacitor plant that was on Curry Pike. A number of

interim clean-up measures were done in the '80s and

early '90s, including installing a temporary cap and

also constructing a water treatment plant to treat 450

gallons a minute.

To give you an idea where Neal's Landfill is,

downtown Bloomington. It's right off of 48. To give

you more history on the site of the landfill, source

control portion of the remedy began in 1999 and was

completed in 1999 after a large investigation. About

40,000 tons of PCBs contaminated material was taken

off-site, along with about 4,000 capacitors. The

landfill size was shrunk from 18 acres to about 10

acres. The landfill was capped and the need for water

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and sediment applicable units were required and that's

why we're here tonight. A large number of

investigations have been done at this site, including

geophysical - I won't go through each one of these.

But geophysical surveys, residential well sampling

surveys, dye trace studies, treatability study on the

settling of PCBs. Surface water measurements, large

numbers of sampling. I'll refer you to the

Administrative Record -it's in the library - for a

summary of all the, and actually all the data. There's

a nice status report developed by my contractor which

summarizes a lot of the recent data.

One of the additional studies we did was the

groundwater basin delineation, which tried to determine

how water was flowing at and around Neal's Landfill.

We did a large number of fish sampling events for PCBs,

including the air core analysis in both Conard's Branch

and Richland Creek. Large sediment sampling events

were done, and we'll talk about this later, about

development of a Fate and Transport Model.

Just to give you a general idea of some

features, here's the landfill. This is Conard's

Branch. Conard's Branch flows into Richland Creek.

Here's Richland Creek. This is about three miles,

about 3.3 stream miles. Vernal Pike, here's 48 here.

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Vernal Pike. Gives you just a general idea where the

landfill was at and some of the features that we'll be

talking about tonight.

As I mentioned previously, there was a basin

delineation study done. Here's the landfill here. And

there's about a 300, almost 400 acre groundwater basin

that actually drains and flow underneath the landfill

as a release of the spring system down the way from

Neal's Landfill. There's a series of sink holes in

this area we dye traced to determine the size of the

groundwater basin. And basically came about that the

unfortunate thing is that Mr. Neal built the landfill

at the edge of the groundwater basis unfortunately. So

all this 300 acres of water flows underneath the

landfill, becomes contaminated and released at the

spring system adjacent to the landfill.

To give you a little bit more detail, you can

look in the Proposal in Administrative Record if you

want more detail on these pictures.

Here's the water treatment plant that was

built that treats 450 gallons a minute. This is

Conard's branch, the spring systems. Currently North

Springs here, this is pumped back to the water

treatment plant. South Springs is pumped over to the

water treatment plant. And then during large storm

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events these overflow springs turn on because the water

backs up and these springs all turn on and release

water, PCB contaminated water down to, down Conard's

Branch. The direction of flow water, the landfill is

about right here. In addition, one of the major things

that we discovered in our investigation that there's a

series of springs and seeps here that are releasing

PCBs into Conard's Branch untreated during low flow.

So this is kind of a very important part of our

investigation. Certainly a number of citizens in the

past have said that they thought there was evidence of

that and certainly our sampling showed that.

One of the more innovative investigations

that we did at the site was a cave entry. This is

downgrading from the landfill but between the spring

system and the landfill, where a sink hole was dug out.

Individuals actually entered the conduit and basically

tried, we tried to get underneath the landfill to see

how PCBs were being contaminated. Or PCBs were

contaminating the groundwater. Unfortunately, we hit a

blockage, I don't know, about 200 and some feet into

it. So that had to stop due to safety reasons.

Unfortunately, it didn't work. We've closed off that

sinkhole right now and we have an access point. And

the water will be flowing through box culvert that's

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getting built right now. We will still have access to

that in the future if we wanted to go in there.

Just to give you a general idea of some of

the sampling events, or some of the sampling. You're

looking at South Spring, we saw between .48 to 2.6 ppb

of PCB contamination. The drinking water standard is

.5 ppb just to give a general idea of that. One of the

things we've seen since 1999 is a 6 percent yearly

decline in the PCB levels from the South Spring. North

Spring, we're looking ... Even though the flow is much

less at North Spring, we're seeing about .16 to 2.1 ppb

PCBs. Again, as I mentioned previously, small seeps in

springs near North Spring were discovered. And storm

events, we can see flows in excess of 10,000 gallons a

minute with PCB peak concentrations we've seen between

4.6 and 30 since 1999. The last one we did, a little

over a year ago, was about 8,000 gallons a minute with

4.6 PCB high concentration. So we're actually seeing

some decrease over time, since this landfill was built,

during the storm events. Somewhere near Conard's

Branch, sediment sampling we have results between .1

ppm PCBs and 3 ppm. Also bank sampling, we had between

.1 and 66 ppm PCBs. Flood plain we saw between .1 and

19 ppm PCBs. In Richland Creek, in a large sampling

event we did in Richland Creek, showed everything under

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1 ppm PCBs. And certainly near a convolutes

convergence of Conard's Branch and Richland Creek we

did not see any sediment at all. And so that's all

basically down from the 48/43 bridge is where we ended

up finding sediment.

One of the things that we have to do in

SuperFund is do risk assessments and EPA took the lead

on the risk assessment. One of the issues with CBS has

been the difficulty in trying in to get an agreement

with CBS under risk assessment. So EPA decided to take

the lead. Take the lead on these risk assessments and

complete those risk assessments. Jim Chapman, our PhD

ecologist did the ecological risk assessment.

Basically the risk assessment looks like at both birds

and mammals that feed on fish. Why we do that is

because if we protect those two types of receptors

you're going to protect every other ecological receptor

due to the fact is you, such high concentrations in

fish.

Mink. Gives you a general idea of what mink,

if you haven't seen one, what one looks like, and

people may say well, is there any mink around here. We

actually did find a mink thanks to an individual who

owned Neal's landfill, found a road-killed mink at the

basin. This was at the Vernal Pike and 48 bridge.

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This was actually used in our risk assessment that

there are mink in the area.

In addition, there are kingfisher in the area

that we've seen. Evidence of kingfisher in the area.

So they're both species that are present at the

landfill.

To give you a general idea of the sampling

events that were used in the ecological risk

assessment. One thing to point out is that we have

2005 sampling data which shows a little bit lower PCS

levels in fish. And we have not calculated that data.

And obviously CBS wants us to calculate that data

because I think they think it helps their cause. And

so probably we'll take a look at that data during the

response this summer. We'll present that in our

response and the summary. But in any case it's really

not going to affect the results of the risk assessment.

Just to give you a general idea where we

sample, most important sampling has been near the site.

We have limited samples farther down stream.

Some of the frequently collected species

include creek chub, longear sunfish, white sucker.

Less frequently are green sunfish, the redhorse, the

bottom feeders. We have some actual rock bass and

other species like that we've analyzed and used in the

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human health risk assessment.

Just to give you a general idea of the fish

sampling results showed, I'll refer you to the

ecological risk assessment. If you're more interested

in terms of the detail associated with how the numbers

were calculated and what was done, as you go farther

down away from the landfill the PCB concentrations get

less. That's one of the main, the main things that was

discovered. The highest concentrations are most near

Conard's branch near the landfill itself.

Just to give you a general idea of the

results of the risk assessment, we saw elevated risks

at least two miles down stream from Neal's landfill,

possible but sparsely documented risks, five to six

miles down stream. And little to no risk beyond

thirteen miles.

When we talk about the Human Health Risk

Assessment, we use standard EPA approaches for the

Human Health Risk Assessment. One of the things that

CBS did was at the one mile station, basically in

Richland Creek one mile from the site, they did a

population study to determine what type of fish are

there, how many fish were there, what could fisherman,

what could that area support. For the three mile and

the five mile we did not have data for that, so we used

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very conservative numbers and we used professional

judgement. Of course CBS basically hated this but in

terms of the approach we decided to use both

conservative numbers to continue with our calculations

on the risk. What it came up with was at the one mile

site basically had 6 grams of pelagic which is more

like a sport fish, like a rock bass. And 4 grams of b

which means benthic. So it ended up being about 10

grams a day of fish that we used for a calculation.

Three mile site, about 12.2 and then the five mile site

15.3 grams per day.

One of the things we do, we convert whole

fish data because we do both fillet data and whole fish

data for the eco-risk assessment. We mainly do whole

fish because that's, you know, the animal eats the

whole fish. Most of the time individuals do fillets or

they'll do a pan fish, but mainly fillets. We have a

calculation factor so that we can use whole fish data.

It's 25 percent for sports fish, 50 percent for a

bottom feeder. So the concentration in the bottom

feeder

was 10, the concentration we used in the Human Health

Risk Assessment would be 5. These are all standard EPA

assumption - 50 percent PCB loss in cooking, 30 year

exposure. We applied the most protective cancer and

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non-cancer factors. Basically for children we have a

lower body weight, we assume five times higher intake

for body weight than for the non-cancer facts.

So RME means Reasonable Maximum Exposure,

which means someone who is basically a sports fisherman

that would eat 10 grams a day at the one mile site,

basically had a cancer risk of 3 in 100,000. To

explain the cancer risk, essentially 3 in 100,000 means

3 additional cancer cases in 100,000 individuals. EPA

looks, has a requirement to look between 1 in 10,000

and 1 in a million. Our point of departure is usually

1 in a million. But we find this type of risk

acceptable. You know, it's greater than our point of

departure. We decided this would basically be

unacceptable risk. Hazard Index, which is a

relative measure of non-cancer facts, that's at 1.7.

We look at one as kind of a cut off point. And 8.5 for

a child. This was at the one mile site.

At the State Road 48 site which is about

three miles down stream, we're looking 1 in 100,000

additional cancer risks. If you ate that amount of

fish for a hazard index which is actually acceptable

for adults of under .8 and children a 4, which would

be unacceptable.

What we did with the risk assessment, we came

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up with fish risk goals. The Human Health Risk goal is

basically to be 0.2 ppm PCBs in fillets. At 43/48

bridge, which is about three miles down the stream, the

ecological risk goals are between 1.8 and 2.3 ppm PCBs

in fish on average for whole fish. In Richland Creek,

.7 to .9 ppm PCBs for whole fish.

The next step we did, one of the most

important investigations we did at this site was

development of Fate and Transport Model. CBS took the

lead on the Fate and Transport Model using their

contractor QEA. I had a nationwide expert for EPA help

us with the review of the model. And basically what

the model is, it's a mathematical model that relates

PCB releases from the landfill and basically you can

relate that to fish tissue concentrations. What we use

this tool for is to value clean up alternatives. As I

said, the EPA modeling expert reviewed the model and we

use models at many EPA sites. This model was also peer

reviewed. In addition, one of the most important

things because it is a model, EPA has a remedy reopener

for this just in case the model is not correct.

So what were the objectives of the model?

Basically we tried to model the system and we could

differentiate between the base flow which is the low

flow and storm flows. They wanted to basically

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quantify the importance of sediment in the water column

PCB sources to fish to try to determine what was

affecting fish the most. And basically to look at

clean up scenarios and how that would affect the fish

concentrations. One of the things I want to mention

too in the Administrative Record there's a large

document in there that goes through in detail in terms

of the mathematical equations used, how these were

applied, and etcetera. That is good background, I

don't know if you're interested in further looking at

this information.

Again, as I said the fish, based on the model

can help the model, the way it's developed can help

determine if springs are affecting the fish tissue cut,

the PCB levels in fish tissue, how the water treatment

plant effluent or the treated water is affecting the

fish, how sediments are and how this bypass water as

you mentioned, as I mentioned previously in the North

Spring bypass, those springs and seeps, near North

Spring that are not being captured currently.

The model, as I said, I refer you, and I'm

just going to go through this quickly but there is a

really good detailed document if you're really

interested in much more detail. Has four components, a

hydrodynamic model, a sediment transport model, a PCB

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fate model and a PCB bioaccumulation model. So

basically all these models work together to come up

with the analysis that we're using in our proposed

plan.

Some of the things that were discovered

during the development of the model is the calibration

which basically the model itself we could basically

have that mimic the system at Neal's Landfill and could

predict both the concentration of PCBs in sediments,

water and fish. So it's pretty accurate. As I said,

the model provides a tool to link PCB concentrations in

fish to the sources. And as I said, we're using this

both as a diagnostic tool and a prognostic tool.

So what did the model show? The model showed

not all the PCBs released, as I mentioned previously,

to Conard's Branch during the base flow conditions are

captured by the present system. What's the value of

the water treatment plant. Without the water treatment

plant that's currently there, the PCB concentrations in

the fish would increase probably in the neighborhood of

four times they are right now. The fish in Conard's

Branch have a large terrestrial or land-based diet.

This is based upon sampling they did where they look at

the gut contents of fish. And one of the things that

was determined, there was limited value adding settling

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ponds or expanding the water treatment plant, and we'll

talk more about that later.

Also storm events greater than 500 gallons a

minute will not produce a major affect on PCB levels in

fish. Essentially what's happening is this PCBs that

are in storm events are rushing through the area near

Conard's Branch and they're getting into Richland Creek

and getting diluted. PCB levels in fish are affected

most by low flow conditions. Because basically they're

exposed to that amount of water in a much slower rate

therefore they uptake it quicker, or uptake it more.

And sediment concentrations in, PCB sediment

concentrations in Conard's Branch are affecting PCB

level in fish greatly.

So after we went through the model, these are

the same remedial action objectives we've used for all

the other sites. Basically it's to try to protect the

fish. Because if we protect the fish we're essentially

going to reduce the risk.

So we went into looking, as I mentioned

previously, the model to determine that sediment was a

pretty big component of what the fish were seeing in

terms of PCB concentrations. We decided to evaluate

either the no-action alternative - we don't do a

sediment clean up, or do a sediment clean up.

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Basically what we did is we're using 1 ppm on average

and 5 ppm on average in the flood plain. This 1 ppm

average will be in stream and on the banks. The

estimated volume would be about a little over 1100

cubic yards. This material would be disposed of off-

site. And you're looking at about $1.2 million. So

we're proposing that we need to do a sediment clean up

there. Basically the cost will be $1.2 million.

So then we went through seven alternatives

that we ran in the Fate and Transport Model. The first

one was no action, which basically would shut down the

current water treatment plant. As I mentioned

previously fish levels would increase about 4 times the

current level. And this wouldn't cost anything.

Second alternative we evaluated was just

keeping the system as is without doing a sediment clean

up. And we continue to run the 450 gallon per minute

water treatment plant that treats about 47 percent of

the total spring, it captures 38 percent of the PCB

mass. The PCB levels in Conard's Branch would be

reduced about 69 percent and that's basically due to

the yearly decrease in the South Spring. And decrease

overall in the levels in the springs over time.

They've been decreasing over time.

Richland Creek PCB levels in fish would be

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reduced to between 51 and 63 percent. That ranges

because of the different species. One of the things

here with this alternative is we would not meet the

fish goals that we mentioned previously. The total

cost would be about $1.5 million for operation and

maintenance.

The third alternative we evaluated was again

running the water treatment plant as is. But doing

additional improvements including capturing that North

Spring Bypass water, doing an improvement in the

collection system and also doing a sediment clean up

and also adding a new effluent line. This would treat

51 percent of the total spring flow and capture 39

percent of the PCB mass. The fish levels would be

reduced 83 percent, according to the model in Conard's

Branch. Between 56 and 69 percent in Richland Creek.

And would meet the fish goals in ten years. We're

looking at about $2.8 million in cost.

The fourth alternative is exactly the same as

alternative three, but we would add 2,000,000 gallons

of storage. As you know, at the Illinois Central

Spring water treatment plant we have storage of water

there. And we decided to evaluate to see if that would

have any affect on the fish tissue concentrations. Of

course, the Illinois Central Springs system is much

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much higher in concentrations in this system. But in

any case, adding this 2 million gallons of storage

provides little to no benefit to the fish tissue

concentration. It does increase the PCB mass treated

but it provides very little benefit with respect to the

PCB levels in fish. And the fish goals would be met in

ten years. And that would cost about $4.9 million.

Alternative 5 would be doubling the capacity

of the current water treatment plant. Again we,

basically the big difference would be a little bit more

total spring filtrated and captures a little bit more

PCB mass. The PCB levels in fish would not be much

greater than the Alternative 3. I'll show a chart

there that you can look at and compare. The fish goals

again would be met in ten years and you're looking at

about 4.2 or $4.3 million.

The sixth alternative would be, again

Alternative 5, increased to 1,000 gallons a minute.

But add again two million gallons of storage. That is

with the previous Alternative 4, you would see, we see

very little reduction in PCB concentrations in fish.

We do see a little bit of reduction in PCB mass

captured. Cost is about 6.3 million bucks. And the

fish goals would be met in ten years.

Alternative 7 is Alternative 3 which is 450

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gallon a minute system with the sediment clean up. We

would add three storm water settling basins, treat all

the storm water. Basically you would see a little bit

more increase in PCB mass capture, water capture. But

the fish levels would not be improved much compared to

the other Alternative 3, 4, 5 and 6. Again, the fish

goals would be met in ten years. And we're looking at

about 6 million bucks.

So just to compare the numbers, this is the

fish goals in Conard's Branch which the concentrations

would be reduced in Conard's Branch. This is for Creek

Chub. This is for Creek Chub and this Longear Sunfish

in Richland Creek. As you can see from there there's

very little difference with respect to storing of water

and what it does to the fish tissue concentrations in

both Conard's Branch and Richland Creek. And you don't

see much benefit with respect to comparing what's

Alternative 3 to Alternative 7. So really, looking at

this, all these three remedies it's pretty similar in

terms of what they would reduce the levels in fish.

Alternative 2 would not meet the fish goals and neither

would obviously Alternative 1.

So we look at alternatives and compare

alternatives against each other, EPA looks at 90

criteria. Both wildlife and human health and

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environment EPA views that these alternatives 3 through

7 is protective. These two would not be protective.

Compliance with ARARs is a compliance with regulations,

other than this one, Alternative No Action. All the

others would compliant with ARARs.

Long term effectiveness and permanence.

Basically since all the fish goals can be met in ten

years between Alternative 3 and 7, we view those all as

being protective.

Reduction of Toxicity and Mobility, or Volume

through Treatment. You have a little bit more with

some of the higher treatments and storage. But overall

they're fairly similar.

Short-Term Effectiveness is associated with

the risk associated with constructing these remedies.

Basically what's the risk of the construction workers

and the local residents. Essentially, and short-term

effectiveness wise, you see a little bit more problems

associated with constructing the lagoons. But overall

these can all be constructed effectively and without

problems.

Implementability, the same thing. One of the

problems we think with implementability is the concerns

associated with building storage or settling basins

with the attractive nuisance tactilogical receptors and

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things of that nature it could be a problem. And

certainly Fish and Wildlife has stated their concerns

about building something like that without taking that

into consideration.

Again Implementability. And the Cost,

Comparative Cost, basically between Alternative 3 and

7, which are the ones that are protective, you're going

from a range of 2.7 to a little over 6 million bucks.

So we come to the final, not the final slide,

but the final decision what we're proposing here

tonight is EPA prefers Alternative 3 for the Neal's

Landfill site. We continue to operate the system,

improve the local collection system and perform the

sediment stream cleanup. In addition this treats 51

percent of the total spring flow and 39 percent of the

PCB mass. The risk goals are met in ten years. And

the total cost is about 2.8 million bucks.

So we'll open up for some questions and then

basically for public comment you have until September

17th to submit your public comment. There's a couple

web pages you can look at that may help you. A real

nice web page is www.copa.org as most people are aware

of. There's a lot of information. In addition the

library has the complete Administrative Record on disk

that you can get copies of. And you can go to EPA's

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Region 5 website to see further information. In

addition, I think Mitch Rice, if people want a disk

you'll be able to get them disks if they need it,

correct.

MITCH RICE: Of the Administrative Record,

yes. Yeah, I've got them.

DAVE NOVAK: And also, Tom, if anybody wants a

copy of the presentation, we didn't print any, but if

you want them put your name on the sign in sheet

indicating that.

TOM ALCAMO: What I'm going to do is just give

it to Mitch and Mitch will put it on the COPA web page.

DIANE HENSHEL: Will the complete risk

assessment ...

TOM ALCAMO: Oh yeah, it's in the

Administrative Record. Well, Mitch can if he wants.

It's up to him. But we can get you the disk with the

(INAUDIBLE)

TOM ALCAMO: The Eco and the Human Health,

Diane?

DIANE HENSHEL: Yeah. Did you ever change the

model so that it actually matched what the data said?

TOM ALCAMO: Yeah. The model's been calibrated

and we're pretty happy with it.

Page 25 of 80

DIANE HENSHEL: Calibrated any more than what

you showed us at the last meeting?

TOM ALCAMO: No, I think it's basically ...

It's basically ...

DIANE HENSHEL: (inaudible)

TOM ALCAMO: No, no. Well, Tim if you want to

TIM WOOL: The model we're talking about ...

TOM ALCAMO: It's the fate and transport.

TIM WOOL: It is calibrated.

DIANE HENSHEL: The bio accumulation model is

really ....

TOM ALCAMO: I can't hear you.

DIANE HENSHEL HEWITT: The bio accumulation

model is showing problems.

TOM ALCAMO: No, I think ... I think we're

pretty ... I mean it's not perfect. We think we can

trust the results of the model. We feel based on the

modeling system that it's accurate. One of the things

you have to remember at the site too, Diane, is that

we're not walking away from this. We've got

sophisticated monitoring that's been going on for many

years. If the model is inaccurate we're certainly

going to reopen the remedy, number one. And number two

is every five years we have to re-evaluate the

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remedies. And number three is the amount of sampling

that we do including fish tissue, sediment sampling,

water sampling, throughout this project after it's

actually built to ensure that the model is, was

accurate, is going to be done. So this isn't a walk

away remedy.

DIANE HENSHEL: So you're going to do fish and

wildlife studies for the next ten years.

TOM ALCAMO: We'll be doing whatever studies

we need to do.

CHRISTIAN FRIETG: I notice that the

preferred alternative says nothing about picking up

storm water. It says nothing different about picking

up storm water.

TOM ALCAMO: Right.

(UNIDENTIFIED) My understanding from the

science that PCBs can actually become aerosolized

during turbulent events. I don't see the preferred

alternative doing anything about that. Which is maybe

another way of asking why haven't you considered full

removal as an alternative.

TOM ALCAMO: Full removal of the landfill?

(UNIDENTIFIED) Yeah, full removal (inaudible)

TOM ALCAMO: Well, number one is when they

initially did the remediation in 1999 there was air

Page 27 of 80

monitoring done throughout the project. We saw an

average before the project started about 3 nanograms

per meter cube of PCB concentrations. The model took

into consideration volatilization, and yes

volatilization is occurring. But at levels that we

don't view as being a complete pathway for risk.

COURT REPORTER: Could I ask that they

identify themselves when they speak, please.

DIANE HENSHEL: Are you telling me you've been

doing air monitoring to prove that?

TOM ALCAMO: No. We have no plans to ... We

did air monitoring during the '99 remediation.

DIANE HENSHEL: I know that, but I'm talking

about the stripping down the streams.

TOM ALCAMO: We have not planned to do any air

monitoring. We view that as that aspect of being

minimal compared to the actual risk to the fish.

DAVE NOVAK: As you ask your questions, just

so she knows, state your name. We'll do this for both

the questions and then for the comments. Go ahead,

Diane.

DAWN HEWITT: Do you know how many whatever

measurement amount of PCBs has been emitted so far?

TOM ALCAMO: No, I wouldn't know. I wouldn't

know.

Page 28 of 80

DAWN HEWITT: Do you know how much has been

recovered?

TOM ALCAMO: We could probably calculate that.

In terms of what was done at the water treatment plant,

it would take ... It would take a calculation. I don't

know, I'd have to get the data from CBS. But you'd

still have to assume, you'd have to assume some

concentrations. So it still would be a large number of

assumptions that would be put into it. But we could do

that.

DAWN HEWITT: And how much remains?

TOM ALCAMO: How much remains where?

DAWN HEWITT: In the landfill. How much can

we expect to see come out?

TOM ALCAMO: I think we're seeing it, you

know, since the source control was completed we're

seeing about a 6 percent decline yearly, yearly decline

in the spring system.

DAWN HEWITT: In the South Spring. What about

the North Spring?

TOM ALCAMO: Staying about the same in terms

of there's been a slight decline there. And we're

seeing some slight decline in the storm events. So

that's a real number, you know. We had, I had a PhD

statistician look at the data. You know, CBS did some

Page 29 of 80

analysis with that and I had a statistician evaluate

the data. And we feel pretty comfortable in that

decline. Of course, it could change. But that's why

we continue to do monitoring.

DAWN HEWITT: Do you have any idea how much

remains there?

TOM ALCAMO: In the landfill itself?

DAWN HEWITT: Sure.

TOM ALCAMO: Boy, I would hate to guess. But

I guess the question would be, the answer would be is

that material is not, not getting wet, number one. The

levels have been reduced over time since the completion

of the source control. And it's a safe and dry

location. The cap, it's not getting wet and creating

some pathway. Something happens in the future, that's

why we continue to monitor the sites.

DAWN HEWITT: And how long do you expect it to

be emitting stuff? How many years into the future?

TOM ALCAMO: We cost this out for 30 years.

It could be longer than that. It could be less than

that. I can't predict.

DAWN HEWITT: What is the life expectancy of

the water treatment plant?

TOM ALCAMO: We cost out for 30 years. But

that means we're still on the hook for however long it

Page 30 of 80

IS.

DAWN HEWITT: Perpetuity?

TOM ALCAMO: Yes.

DAWN HEWITT: And what does that mean?

TOM ALCAMO: It means until the levels get

acceptable and it's not causing risk. It could be a

long time.

MICK HARRISON: To follow up on Dawn's

question about how much PCBs remain. My recollection

is that historically Westinghouse said about 40,000

capacities were put in Neal's Landfill. I'm not sure

if anyone can confirm my recollection of that.

TOM ALCAMO: That's you know, the problem with

that and doing the mass balance study that was done a

long time ago, we, for example you can take the Neal's

Dump Site in terms of the amount of capacitors that

went into Neal's Dump. We completely excavated that

site. We saw nowhere near the number. The same with

Lemon Lane. We saw nowhere near the number. I don't

know how many capacitors. There's probably some

capacitors still in there. Probably drained already.

We found no evidence of oil filled capacitors in Neal's

Landfill, whether it's salad oil, they've all been

drained. But there could be some capacitors in there,

but 40,000 was probably a way over estimate.

Page 31 of 80

MICK HARRISON: You're saying an over estimate

of what was put in or an over estimate of what remains?

TOM ALCAMO: I'm over estimating your 40,000

number.

MICK HARRISON: Of what was put in the

landfill originally?

TOM ALCAMO: Yeah. I don't think that's a

valid number.

MICK HARRISON: Okay, because you haven't seen

that many?

TOM ALCAMO: Because I think ... Number one,

we haven't seen that many. Number two is from the

sites we have completely excavated we did not see that

many. The sites we've excavated partially, such as

Lemon Lane, we never saw that many. And I think the

information that went into all that was all conjecture.

And estimates from Westinghouse or whatever, and I

think some of that records are inaccurate. We see that

all the time in SuperFund where there's records that

you can't really trust them.

MICK HARRISON: So it is common for the

potentially responsible party to over estimate how much

contamination they put in a landfill?

TOM ALCAMO: I don't know.

MICK HARRISON: I've never seen that myself.

Page 32 of 80

TOM ALCAMO: I can't speak to that. I'm not a

PRP.

MICK HARRISON: So, for the record, I'm Mick

Harrison, attorney. I'm speaking for myself and for

Protect Our Woods and Sarah Elizabeth Fry, who couldn't

be here tonight. I'll make some comments on her behalf

and then perhaps if others get finished with their

questions and you have some additional time, I have

some additional questions.

DAVE NOVAK: Go ahead with questions now and

we'll take your comments during the comment period.

MICK HARRISON: This is a request, which I

guess is a question. I'd like to see the model that

was used to make EPA's predictions about reduction in

the PCBs in water. Seeing it meaning I'd like EPA to

produce it through Mitch, or otherwise, so that we can

run it with our own input. And I'd like to know the

data that was used to input into the model, including

any assumptions, constants and values used for

variables in the model.

Does EPA consider its obligation under CERCLA

to protect the public and environment be limited to

protecting the public and environment immediately

surrounding the sites, or does that obligation go to

preventing harm from releases from these sites anywhere

Page 33 of 80

in the country, or even globally?

TOM ALCAMO: I think if you could show that

these releases from this site are harming the

environment globally, if you could show that, you know,

that may be something we'd look that. But you have to

show it.

MICK HARRISON: That's my burden as a citizen?

TOM ALCAMO: I don't see that burden as based

on the, let's say for example, air data that I've seen.

Certainly with Neal's Landfill, if there's issues

associated with air emissions at Neal's Landfill we

would deal with those.

MICK HARRISON: Well, you know there were

significant air emissions at Lemon Lane Landfill from

that experience.

TOM ALCAMO: I'm not here to talk about Lemon

Lane.

MICK HARRISON: I'm not talking about Lemon

Lane. I'm using it as an example of how PCBs

volatilize.

TOM ALCAMO: But did you look at the air

monitoring data from Neal's Landfill?

MICK HARRISON: My client has looked at that.

But we are concerned that on-going releases of PCBs

into surface water will lead inevitably to

Page 34 of 80

volatilization of those PCBs into the air somewhere.

It may not happen near Neal's Landfill. But it will

happen. And as you know, we have a global PCB

contamination problem in the United States. Infants

that are breastfed these days have an exposure to PCBs

and related compounds on average some 50 times greater

than EPA's reference dose for dioxins-like compounds.

So I guess I'm wondering why don't we think that if

we're only capturing 50 percent of the PCBs, or

actually 39 percent of the PCBs and releasing the other

61 percent, why aren't we contributing to that already

existing over exposure nationwide and globally?

TOM ALCAMO: When you look at the levels

coming off, basically the model did look at

volatilization. We view those levels as being minimal.

I think you look at the data that's been done in

Bloomington for air data by a completely independent

source back in the late '80s and X90s. You look at the

levels there. They're no different from any town. I

mean you look at Madison, Wisconsin, Chicago, Illinois,

those PCB levels are basically similar to what's in

Bloomington. That's what the data shows.

MICK HARRISON: So can you explain to me where

this 61 percent of the PCBs you're not capturing are

ultimately going to end up? What their ultimate fate

Page 35 of 80

is?

TOM ALCAMO: It's basically going into

Richland Creek. And it's getting diluted. And it's

going to be basically as we saw in our sediment

sampling in Richland Creek, we see low levels, very

much under one, but it's going into the sediment.

MICK HARRISON: That's not an ultimate fate.

That's an intermediate fate.

TOM ALCAMO: Well, I don't know. The

ultimate. I can't predict that.

MICK HARRISON: Well, I think you have some

capability there. Don't you think that these PCBs are

ultimately going into the atmosphere and ...

TOM ALCAMO: Not all of them.

MICK HARRISON: ... are transported in the

air.

TOM ALCAMO: They would go into the

equilibrium with the atmosphere.

MICK HARRISON: I think ultimately a large

mass of them get distributed and then find irreminal

sinks like (inaudible) and people get over exposed.

TOM ALCAMO: I can say from the air data we've

seen in Bloomington by a completely independent source,

there's no difference in the air levels in Bloomington

than there are in Madison, Wisconsin, Chicago,

Page 36 of 80

Illinois, Minneapolis, Minnesota.

MICK HARRISON: Well, that's not my question.

TOM ALCAMO: Well, you bring up the global

aspect. I'm telling you that ...

MICK HARRISON: Well, you're telling me we're

as exposed as everybody else and I'm telling you

everybody else is 50 times too high exposed based on

infants. So that doesn't make me feel better.

TOM ALCAMO: The risk data doesn't show that.

MICK HARRISON: Well, EPA's data shows what

the current overexposure is nationally. I got that

from EPA. So has EPA looked at contaminates other than

PCBs in doing their current work on Neal's Landfill in

determining what to do?

TOM ALCAMO: Yes, there's been other BOC

sampling that was done, particularly associated with

treatment of that and according to the State they'll be

no discharge criteria associated. We've seen low

levels of I think TCE at the site. But under any

discharge criteria.

MICK HARRISON: You mean an MPDS discharge?

TOM ALCAMO: The subsequent requirements for

MPDS yes.

MICK HARRISON: Is there an MPDS permit that

has a limitation for TCE or other solvents for this

Page 37 of 80

site?

TOM ALCAMO: No. No, but we've looked at ...

What we're doing is we're taking, there's a permit in

place right now and we're taking that permit and

modifying that permit to go into CERCLA. And so

there'll be, we're looking at new constituents and

that's where those numbers came about from. We did

some additional sampling that showed low levels of TCE,

not at levels that would require treatment.

MICK HARRISON: Have you looked recently at

polycyclic aromatic fiber carbons and the dioxins and

furans?

TOM ALCAMO: No.

MICK HARRISON: Is it your understanding that

Neal's Landfill was an open burning dump for years?

TOM ALCAMO: Open burning dump. I know it was

mixed landfill that there was burning that took place.

MICK HARRISON: Okay, so burning would be open

burning, right?

TOM ALCAMO: Well, I wasn't there in the '60

and '50s, so I don't know.

MICK HARRISON: Have you looked at Ms.

Kinder's letters to the County Board of Health back in

the early years?

TOM ALCAMO: No, but I've talked to John

Page 38 of 80

Bassett who as a kid went there when there was burning

that was taking place.

MICK HARRISON: So does EPA expect that other

contaminants would be created from the open burning of

this material?

TOM ALCAMO: It may. We have not seen

evidence of that though. We sampled, you know, the BOC

and things like that and PCBs.

MICK HARRISON: Does the EPA historically take

the position that storm flow from the springs at Neal's

Landfill and the other sites should be captured and

treated?

TOM ALCAMO: I think we were concerned about

it until, you know, fate and transport model.

MICK HARRISON: So this really represents a

change in EPA's approach based on a model?

TOM ALCAMO: No, no. I think we've gotten new

data and new information that's formed our opinion.

MICK HARRISON: Isn't that from the model?

TOM ALCAMO: Is that from the model? Yeah, I

think, yeah.

MICK HARRISON: So EPA used to have, used to

insist on storm flow being captured and treated and now

they don't and that's not a change?

TOM ALCAMO: No, that's not true. Don't put

Page 39 of 80

words in my mouth.

MICK HARRISON: Okay, then tell me what is

true.

TOM ALCAMO: I'm just saying... I said that

we certainly were concerned about the storm flow, and

that as we investigated the site further, it was

determined that part of that storm flow did not need to

be captured.

MICK HARRISON: And that's based on the

modeling of that ...

TOM ALCAMO: That's based on the model.

MICK HARRISON: On fish.

TOM ALCAMO: Based on the fate and transport

model.

MICK HARRISON: Of what?

TOM ALCAMO: Of fish.

MICK HARRISON: So, but that model doesn't

address what happens to the PCBs that aren't captured

and may be released and transported nationally or

globally. Those impacts aren't addressed.

TOM ALCAMO: The risk assessments do that.

MICK HARRISON: Your risk assessment looks at

impacts beyond the Bloomington area?

TOM ALCAMO: No, not globally, no. Not

globally.

Page 40 of 80

MICK HARRISON: That's what I was talking

about. Has there been an assessment of the extent to

which PCBs are being transported through base flows or

underflow springs rather than surface or overflow

springs at Neal's Landfill

TOM ALCAMO: Underflow springs?

MICK HARRISON: Something not on the surface.

Something that doesn't come to the surface, at least

not.

TOM ALCAMO: Yeah, we dye trace. I mean we

feel comfortable in terms of our understanding of the

hydrogeology there. I mean, John do you have any ...

JOHN BASSETT: The affect of the underflow

from the North Spring bypass in the area of North

Spring, I guess you would call that an ultimate

underflow spring. That has been evaluated. Those are

ongoing PCB releases and are, EPA feels, pretty key

element in the overall remediation plan as (inaudible)

actually.

MICK HARRISON: Where does that discharge, do

you know?

JOHN BASSETT: It discharges into the bed of

Conard's Branch from roughly the bend of the North

Spring down several hundred feet.

DIANE HENSHEL: Could you talk louder or speak

Page 41 of 80

so we can hear you.

TOM ALCAMO: Do you want to come up here,

John? Why don't you come up here.

JOHN BASSETT: What we're kind of talking

about is overall, the guess the penultimate underflow

discharge from Neal Landfill. It used to be regarded

as South Spring. North Spring was regarded as an

underflow discharge point as well, diluted with perhaps

some other drainage area. In the past three years or

so, four years, it became apparent that there was

ongoing discharges of PCBs in groundwater through seeps

and springs or channel vent discharges below the North

Spring. And that's come known as the North Spring

bypass. And the modeling that we've been talking about

has indicated that's a very significant source of PCBs

to the aquatic system. Primarily because the discharge

occurs all the time. It's not a storm discharge. The

fish, the ecosystem sees those PCBs 100 percent of the

time. And that, by the modeling, is one of the

principle components of the PCB uptake into the fish

tissue. Tom showed some slides here, I think, of the

percentage of the contribution from the various PCB

sources and the North Spring bypass is right up there

with the principle ones. It was one of the things that

we feel needs to be addressed.

Page 42 of 80

MICK HARRISON: And how will that underflow or

base flow be addressed?

JOHN BASSETT: It will be collected.

TOM ALCAMO: A new collection system.

MICK HARRISON: How are you collecting it?

JOHN BASSETT: Currently it's not being

corrected.

MICK HARRISON: Right.

JOHN BASSETT: When it will be collected is a,

we've only seen really conceptual designs of this. It

is addressed in the proposed plan that it will be

collected. But it would involve some kind of a channel

sump downstream of those discharges to collect and

route that back to the plant.

MICK HARRISON: So you're going to intercept

the underflow somehow?

JOHN BASSETT: Yeah.

MICK HARRISON: I don't know if I should

address this to you or Tom, but do you feel like you've

mapped the underflow at the landfill well that you can

actually predict where the karst is taking this

contaminated water that doesn't come to the surface?

JOHN BASSETT: Well, I'm comfortable with it.

I mean we've delineated the drainage basin. We've

sampled every spring out there that's available to be

Page 43 of 80

sampled as far as PCB discharge, possible PCB discharge

points are concerned.

MICK HARRISON: Are you talking about

discharge to the surface?

JOHN BASSETT: Discharge to the surface.

MICK HARRISON: Yeah, I'm not talking about

that. I'm talking about springs that don't come to the

surface.

JOHN BASSETT: Well, if it comes to the

surface it's a spring. If it doesn't come to the

surface it's not a spring.

MICK HARRISON: What about the underflow that

discharge into the creek, for example, or Conard's

Branch? I mean, now they come to the surface only and

directly by discharging in the bed of the stream or the

creek, right?

JOHN BASSETT: I'm not following the ...

MICK HARRISON: Aren't there flows underground

that never come to the surface before they hit a creek

or a stream?

JOHN BASSETT: Yes. Do you mean like a

circulating groundwater that doesn't come to the top?

MICK HARRISON: I don't know what you want to

call it. You can call it whatever you want. I just

talking about can you track the flow ...

Pace 44 of 80

(UNKNOWN) Convergence of the stream in the

streambed, I've seen that many times, water comes in

from the side.

JOHN BASSETT: I think that's what we're

talking about, the North Spring bypass. If you walk

down that creek channel, I done it, you know, several

times. You don't really sense a discrete discharge of a

spring that you can, you know, stick your finger in and

say that PCBs are coming out right here. But if you

walk down several hundred feet of channel you do see a

noticeable increase in flow and that's got the PCBs in

it.

MICK HARRISON: My question was, do you feel

comfortable you've mapped the underground flow, not the

springs that come up to a surface discharge point where

you can see it. But the underground flow that doesn't

come up to the surface where you can see it.

JOHN BASSETT: Well, I think the whole concept

here is that of a karst groundwater basin. And the

ultimate discharge point for that groundwater in that

karst system are those springs. And to that extent,

yes I'm comfortable that's been mapped.

MICK HARRISON: Tom, as a follow up to Dawn's

question, are there PCB reservoirs still at Neal's

Landfill that have not been excavated?

Page 45 of 80

TOM ALCAMO: Are there PCB reservoirs that

have not been excavated? Certainly there's PCBs in the

landfill. How that is feeding the conduit system, I'm

unaware of how that's doing it. That's one of the

investigations we tried to do where we tried to crawl

underneath the landfill to determine that. So yes,

there's PCBs in the landfill. How they're getting into

the karst system I'm not sure.

MICK HARRISON: Is it pretty clear they are

getting into the karst system?

TOM ALCAMO: We don't see, we do not see back

flooding of the landfill or water coming up into the

landfill. It's somehow taking it out of the landfill.

There may be over many, many, many years things that

were dumped 30 or 40 years ago that that's already deep

in the rock there and therefore that's feeding it.

MICK HARRISON: Do you consider the PCBs deep

in the rock to not be in the landfill as you define the

landfill?

TOM ALCAMO: I'd have to think about that one.

MICK HARRISON: Okay, so let me rephrase my

question. Are there PCBs in the rock under the

landfill that are ongoing reservoirs of PCBs that can

be released through the groundwater?

TOM ALCAMO: Maybe.

Page 46 of 80

MICK HARRISON: So EPA's uncertain about that?

TOM ALCAMO: I don't know exactly what's going

on underneath in the rock in that landfill. I don't

know how it's getting fed. But we certainly feel that

the landfill cap and also the monitoring points we have

within the landfill show that that landfill isn't

producing this major source of PCBs to the spring. And

we've seen a 6 percent decline over time. And that

tells us that the source control remedy actually was

effective. Which is a good thing.

MICK HARRISON: Six percent decrease annually,

you're saying.

TOM ALCAMO: Yeah.

MICK HARRISON: If there is a reservoir of

PCBs in the rock, is that something that your modeling

has accounted for in predicting that the levels are

going to continue to go down from your water treatment?

TOM ALCAMO: No, it's not. I think that's one

of the reasons why we have continuing monitoring.

MICK HARRISON: So how much will this cost to

do these proposed preferred alternatives that you've

tentatively selected?

TOM ALCAMO: 2.89 I think was the cost.

MICK HARRISON: Do you know who will be

fronting that cost, or paying for it up front? Will be

Page 47 of 80

EPA or CBS?

TOM ALCAMO: It depends. I think if we get a

global settlement with CBS Corporation they will be

paying for that.

MICK HARRISON: So you don't know right now

who will fund it?

TOM ALCAMO: We hope CBS. We're still in

negotiation with CBS on a global settlement. We hope

that CBS is willing to fund that.

MICK HARRISON: So you think that capturing 39

percent of the PCBs is worth $3 million?

TOM ALCAMO: Yeah, I think it's the

appropriate remedy.

MICK HARRISON: Would capturing the other 61

percent be worth another $6 million?

TOM ALCAMO: Probably not because of the risk

issue. You're not getting a benefit in terms of risk

reduction.

MICK HARRISON: In the local fish.

TOM ALCAMO: In the local fish.

MICK HARRISON: The 6 percent reduction that

you've seen annually, was there any correlation or

correspondence in the reductions that have been

observed with the effort to clean up the hot spots of

source control remedy in '99 in Neal's Landfill?

Page 48 of 80

TOM ALCAMO: No, there's been no correlation.

MICK HARRISON: I think I'll stop and let

somebody else ask questions. But I have a few more.

DAVE NOVAK: Anybody else have questions? Yes

sir, speak up real loud.

CHRISTIAN FREITAG: You mentioned minks and

kingfishers as two of the species studied. I've

personally seen a number of species of water fowl out

there and those in Conard Branch and those are

obviously consumed by humans also. Have you considered

that?

JAMES CHAPMAN: I'm James Chapman. I did the

ecological risk assessment. For the ecological side we

looked only at animals that feed primarily or

predominately on fish because that's the largest

exposure.

CHRISTIAN FREITAG: Including mergansers?

JOHN BASSETT: Yeah, but mergansers aren't ...

Mergansers are not, they're not as plentiful on the

site as, or as likely of being encountered on the site

as in, particularly in the upper reaches of the river

as kingfisher are. But the kingfisher, essentially•

that risk assessment will cover mergansers because

we're looking at a bird that predominately feeds on

fish. So mergansers would be basically covered under

Page 49 of 80

the kingfisher scenario. I have to add, we don't know,

nobody knows how sensitive kingfisher are to PCBs. So

we had to, in the risk assessment, assess a range of

possible sensitivities to try to capture that

uncertainty.

For the human health side of it, I don't do

the Human Health Risk Assessment, but we looked at fish

consumption for the human health because that's, in

terms of what someone's expected to be exposed to over

the course of a year, and over the course of multiple

years, eating fish is more likely to result in larger

total amounts of exposure as opposed to eating water

fowl, since no one's expected to get that many meals of

eating birds.

ERIN HOLLAND: I have a point of information

to clarify what you said earlier. I know that Option 3

is going to treat 51 percent of the spring flow and

reduce PCB amount by 39 percent. What's the current

state of those two figures?

TOM ALCAMO: It's a little bit less than that.

Basically what the preferred remedy does is deal with

that water that is bypassing the current collection

system. So it's going to be increased a little bit.

You can compare Alternative 2 to Alternative 3. So

it's going to be a little bit greater. And one of the

Page 50 of 80

issues has to do with the PCBs in fish that are being

exposed to that water that is not being collected. And

that is definitely contributing to a large portion of

their PCB concentrations. So that's why it's only a

slight difference. But it's a big difference.

DAVE NOVAK: Other questions. Yes, sir. Just

while he's walking up here, we'll be taking the

questions until 8:00 and then we'll get into the

comments.

MICK HARRISON: There was a slide that

indicated 50 percent of PCBs are lost during cooking.

And apparently that 50 percent was not consider in the

Risk Assessment calculation, is that correct?

TOM ALCAMO: That's correct. Hold on while I

check. Eric is that basically normal standard EPA

procedure?

ERIC MORTON: Yeah. There's some variation

but it's cooking and trimming and what not that amounts

to that ...

MICK HARRISON: I understand the trimming part

because you're basically not consuming those. Where do

the PCBs go that are cooked off, do you know?

ERIC MORTON: It comes off in the fat and oil

when you pull the fish out. Then you're not going to

be consuming what's normally ...

Page 51 of 80

MICK HARRISON: It's in the residual cooking

oil?

ERIC MORTON: Yeah. That would probably be

one big part of it.

MICK HARRISON: Some of it is volatilized?

ERIC MORTON: I would imagine it would be.

MICK HARRISON: Do any of the PCBs get

converted into something more toxic like dioxins,

furans, or other dioxin-like compounds from the

cooking, the heat?

ERIC MORTON: I'm not a ... I wonder if the

temperatures are extreme enough to result in that. I

mean, if you heat it enough under like in an

incinerator where you can get some conversion. But

you're talking about cooking so I'm not sure that those

conditions are such that you would convert it to

dioxins.

MICK HARRISON: What about grilling?

ERIC MORTON: I'm just not aware ... I'm not

sophisticated enough on the principals of it to know

whether that would be enough. I doubt it though. But

I don't know for a fact.

MICK HARRISON: EPA's never put out any

cautions about people eating like grilled meats and

stuff that have the burnt.

Page 52 of 80

TOM ALCAMO: I'm not aware of it, but that

doesn't mean they're not out there.

MICK HARRISON: I seem to remember something

about that.

TOM ALCAMO: I do remember where barbeques

because of the Ph's, but not ... I'm not heard anything

in terms of dioxins or any of that stuff.

MICK HARRISON: Can someone explain how you

calculated this 39 percent capture figure?

JOHN BASSETT: Basically the treatment system

captures 51 percent of the total flow that goes through

there. And that's not based on a single year. That's

a long term hydrograph that they're using. They have

the measured concentrations. So when you capture 51

percent of the flow you know what the flow was there

and you know what the concentration was. You know what

the total mass was.

MICK HARRISON: Of PCBs coming in?

JOHN BASSETT: Yeah, to the treatment system.

MICK HARRISON: How do you know that?

JOHN BASSETT: Because it's been measured.

MICK HARRISON: Sampled and analyzed?

JOHN BASSETT: Sampled and analyzed and you

know that the flow's coming down to the treatment

system.

Page 53 of 80

MICK HARRISON: Okay.

JOHN BASSETT: So when you treat 51 percent of

water we know how much mass is associated, given the

flow that was going at that time. So you take the

concentration that was coming out at the time, multiply

it by the flow and that's the load that came through

that point.

MICK HARRISON: I got that.

JOHN BASSETT: Okay, the reason why it's not,

if you treat 51 percent of the flow, you should treat

51 percent of the load.

MICK HARRISON: I wasn't going to say that,

but I'm interested in the rest of your explanation.

JOHN BASSETT: The reason why that's not the

case is because it does not capture all the storm water

flow. And when the storm water flows goes up higher,

you have higher flow, not necessarily higher

concentrations. But you have more loading going on.

That's how ...

MICK HARRISON: Now there's still a remaining

portion. How do you determine how much of the mass of

PCBs coming in that 51 percent that's captured, I

understand how you're calculating the mass coming in,

which is the concentration based on your analyses times

volume of water. But then you've got an output

Page 54 of 80

somewhere. How do you know how much PCBs are being,

still coming out.

JOHN BASSETT: Through the treatment system.

MICK HARRISON: After treatment.

JOHN BASSETT: That's monitored as well.

MICK HARRISON: So it's all analyzed?

JOHN BASSETT: Right.

MICK HARRISON: Okay. And is there any way to

tell what amount of PCBs are lost to volatilization in

between those two points where you analyze?

JOHN BASSETT: Okay, now I'm going to handle

the volatilization thing. PCBs is an extremely

hydrophobic compound. It does not like water. The

only portion of PCBs that's available to volatilize is

the portion that's in the dissolve phase. And that is

.000 some percent of the total PCBs there. If

volatilization was a major pathway for PBCs to leave

the system it wouldn't be there any more. The major

component that moves PCBs through the system is the

carrying of water and sediment down through the system.

MICK HARRISON: What do you mean by wouldn't

be there any more?

JOHN BASSETT: Something that volatilizes

readily would not be a persistent chemical. It would

be out of there. And it would be in equal agreement

Page 55 of 80

with the atmosphere.

MICK HARRISON: You mean at its first

opportunity exposed to the atmosphere?

JOHN BASSETT: Yes.

MICK HARRISON: Which would be the point of

where it reaches the surface?

JOHN BASSETT: Yes. In Neal's Landfill, yes,

it's not in the surface. But we have PCB sites

throughout the United States that have an air interface

their whole time there and they've been there for 70 or

80 years.

MICK HARRISON: You say PCBs in water that are

exposed to the air remain in the water?

JOHN BASSETT: They remain in the sediments.

MICK HARRISON: In the sediments?

JOHN BASSETT: Yeah. They typically remain in

the sediments and then whatever dissolved portion

that's in the water column is available to volatilize.

MICK HARRISON: Okay, I've seen a study that

indicates that you have percent losses of PCBs from

volatilization from water.

JOHN BASSETT: You can, but that's a magnitude

discussion. You don't have PCBs in near the

concentrations here to have that kind of affect.

MICK HARRISON: We'll have to think about

Page 56 of 80

that. Do you have any studies that support what you're

telling me at the moment? Any documents you can show

me?

JOHN BASSETT: There's several ... If you do a

... There's all kinds of literature. I'm sure I could

find you some.

MICK HARRISON: Would you make some of it

available maybe to Mitch to put on the web or

something?

JOHN BASSETT: I can try when I get back,

sure.

MICK HARRISON: I appreciate that. Were any

PCBs found in either the cave that you showed or any

caves that you've explored at the site?

TOM ALCAMO: Yes, in the sediment. I think

there was, was it 50 some parts per million in the

sediment.

MICK HARRISON: 50 parts per million? 50

even?

TOM ALCAMO: I don't remember the exact

number, but it was somewhere in that range.

JOHN BASSETT: 50 and some change. It's in

the Administrative Record.

MICK HARRISON: This was sediment in the cave?

TOM ALCAMO: In sediment in the cave.

Page 57 of 80

MICK HARRISON: So the water moving through

the cave left the sediment. Okay.

TOM ALCAMO: Water basically, it would get

flushed out, most likely, the sediment I mean. It

depends on the site of the storm. I think we had some

lower concentration - I think it ranged from I know

there was some lower below 10 numbers to the highest I

remember was 50 something if I remember. And I can

get, it's in the Administrative Record. But I can find

it for you if you want it.

MICK HARRISON: That's okay. So you're saying

that the contaminated sediment in the cave gets flushed

out in storm events?

TOM ALCAMO: Yeah, it probably does. And

during low flow amounts too.

MICK HARRISON: You indicated that air

releases of PCBs were not addressed in the Risk

Assessment I believe you said because you did not

consider there to be a complete pathway of exposure for

a risk assessment.

TOM ALCAMO: No, I didn't say that.

MICK HARRISON: You didn't say that?

TOM ALCAMO: I said it's a complete pathway.

Or if I did, I misspoke. It's a complete pathway, but

the results are so insignificant that compared to the

Page 58 of 80

other portions of the risk and how it's calculated

doesn't make a difference.

MICK HARRISON: In terms of local impacts?

TOM ALCAMO: In terms of how EPA does its

standard risk assessments.

MICK HARRISON: That's probably local impact,

is it not.

TOM ALCAMO: Probably.

JAMES CHAPMAN: I'd just like to add something

to that. On the ecological side I did do a calculation

to look at air concentrations compared to the

concentrations of PCBs in fish. And this is based on

partitioning from lipids to water to air. And the air

concentrations are somewhere on the order of about 1/10

millionths of the concentration that's found in fish.

So in terms of looking at risks, the ecological

receptors to animals, wildlife, the air pathway just

isn't one that was going to result in risk.

MICK HARRISON: You mean by inhalation by the

animals?

JAMES CHAPMAN: Yes.

MICK HARRISON: I'm not talking about that .

I'm concerned about PCBs released air deposited and

accumulated in the food chair. Did you assess that at

all?

Page 59 of 80

JAMES CHAPMAN: No. But again the same

principle applies. The majority of the PCBs are, as

Tim Wool discussed, are staying within the aquatic

system. There is volatilization that occurs but it's a

very minor, I mean it's a very, very small percentage

of what comes off of the site. One of the

characteristics of the model that had to satisfy was

the mass balance. The PCBs coming in to the model, the

model treats the landfill as a black box. What comes

out of the landfill is empirical data of what the

concentrations are that we can measure that are coming

into the system. And the model then runs through its

calculations of what kind of uptake occurs, what kinds

of losses occur to the PCBs and how much of it at the

end of the distance down river, how much of that PCB is

flowing downstream. Those amounts have to balance all

the way through this model. And we're not seeing out

of this system massive, massive amounts of PCBs going

into the atmosphere.

MICK HARRISON: Based on the model, or based

on measurements?

JAMES CHAPMAN: It's both. The model has to

conform with what we have in terms of empirical data.

MICK HARRISON: What data do you have on your

releases of the PCBs at Neal's Landing?

Page 60 of 80

TOM ALCAMO: We only have data from 1999.

JAMES CHAPMAN: But we have measurements of

what the concentrations are coming out of the landfill

into Conard's Branch and we have measurements of what

the concentrations and flows are at Richland Creek at

the downstream portion that the model includes. I

forget just how far downstream that is. And then the

model also treats, you know, what's happening to these

PCBs in between. How much of it's going to sediments,

how much of it's coming into fish, those sorts of

things. And it balances out. If there was large

releases through this stretch of PCBs into the

atmosphere this model wouldn't be working. We would

not at the end have the correct amount of PCBs coming

out of the system as what we're starting with at the

top.

MICK HARRISON: In terms of predictions of

fish concentrations or sediment or whatever you're

talking about.

JAMES CHAPMAN: Everything, the whole model

all the way through has to, it has to satisfy the mass

balance requirement. You can't have PCBs being created

out nothing or disappearing into nowhere.

MICK HARRISON: So does your model allow you

to calculate an amount of PCB released to air along the

Page 61 of 80

streams or the creeks of the rivers?

JAMES CHAPMAN: I believe that's part of the

model.

TOM WOOL: Yes. Though the model simulation

wasn't run, it certainly, you could set your loadings

from Neal's Landfill to zero and put in the atmospheric

concentration of PCBs in the area and then you could

figure out what component the atmosphere is feeding

into the food chain. And you will find that it is

going to be very, very, very small.

You have to understand, volatilization is not

a one way process. It's a two way process. It is

gradient based. It's a function of concentration in

the water and concentration in the atmosphere. If the

concentration in the atmosphere is greater than what's

in the water, it does not go out. It goes in. So it's

MICK HARRISON: So if there's so little PCBs

coming into the environment from the atmosphere, how

did we get infants being 50 times overexposed in the

food chain?

TOM WOOL: There's areas in the United States

that early on that we were setting clean up levels that

would potentially be recontaminated by the background

atmospheric concentration. But what you're trying to

Page 62 of 80

allude to that is the volatilization from Neal's

Landfill is a major contributor to the global pool.

And in the case here, it's not, it wouldn't even show

up as spec. It's concentrations are ...

MICK HARRISON: Any data you've got on that

I'd love to see it.

TOM WOOL: You compare the concentrations that

you see here at Neal's Landfill to some of the other

PCB areas of the United States, these are minuscule.

MICK HARRISON: You mean in the soil?

TOM WOOL: In the soil, in the water, in the

landfill.

MICK HARRISON: What about in the rock?

TOM WOOL: In the rock. I've worked on sites

where PCB concentrations in the sediment were not

measured in parts per million. They were measured in

percent.

MICK HARRISON: I appreciate that. I think we

have some of that here. We certainly saw some in Lemon

Lane that was left in place during the clean up.

TOM ALCAMO: Not in sediments you didn't.

MICK HARRISON: No, I'm talking about a pool,

they've got PCBs in them.

TOM ALCAMO: But of course it was capped. Of

course it's been capped.

Page 63 of 80

MICK HARRISON: Yeah, but that doesn't keep it

from moving to the groundwater.

So anyway, let me see what you have on that.

I'd love to see it, and do some calculations. Has

there been any attempt to determine how much PCBs are

in the carbon when you take the carbon out of use, out

of service in the filters? To see how much you've

actually captured there?

TOM ALCAMO: No. But they replace the carbon

when they start seeing detection limits over a time

period. The carbon is monitored and then that

basically gets to a point where we're starting to see

detections. They take that carbon and they ...

MICK HARRISON: I appreciate that they change

it out when they think it's not efficient any more.

TOM ALCAMO: But I don't think they actually

... I don't think they actually sample the carbon. You

sample the carbon to determine disposal criteria for

it. But I don't think they do a complete study on the

carbon in regards to the concentrations. They do a

sampling pursuant to the disposal plans.

MICK HARRISON: That was my question. Because

it seems to me if you really want to know empirically

how much PCBs are being captured and removed and

controlled, you can do a sample of your carbon and heat

Page 64 of 80

it, off gas the PCBs and see how much was there. And

see if it matches what you're saying. What you

predict. And if it doesn't, then you've lost PCBs

somewhere. So I suggest you think about doing that.

TOM WOOL: Correct me if I'm wrong, you have

measurement of influent and effluent?

TOM ALCAMO: Yes.

TOM WOOL: So you know it's performing.

MICK HARRISON: Well, you know something is

happening.

TOM WOOL: Well, you know the flow into the

system and concentration in this system. You know the

flow out and the concentration out. You know the mass

captured.

MICK HARRISON: You think you do, but over

time do the PCBs stay on the carbon?

TOM ALCAMO: Yes.

TOM WOOL: Yes.

MICK HARRISON: Well, then why don't we do a

little test and confirm that? Shouldn't be a problem.

TOM WOOL: Collect water and it has 10 and 2

is coming out.

MICK HARRISON: I'm just suggesting you do

something to confirm your theory. Which is do an off-

gas test on your carbon and see if the PCBs really are

Page 65 of 80

there after a period of time. What have you got to

lose?

DAWN HEWITT: When Alternative 3 is put in

place what will be the staffing of the water treatment

plant?

TOM ALCAMO: I'm not sure on that. That's

certainly being discussed. There will be maintenance

requirements and right now it's, I think there's no

permanent staffing there that CBS has at the plant. I

don't know if that's going to change. It may or may

not. But certainly people go to that facility I think

every week. I'm not sure in terms of the MPDS

requirements are, but in regards to those criteria,

we'll certainly take a look at it because it is

important that ... It's a batch plant where they

collect the water in a big tank. And then when the

tank gets full at a certain elevation, it runs. It's

like our Illinois Central Spring water treatment plant,

which is manned during the day. But at night it runs

automatic and it calls them when there's problems. You

know, when it measures something incorrectly. The

other plant's the same way, when there is a malfunction

it calls the person. You know, it has that capability.

So, essentially it doesn't need to be manned 100

percent of the time.

Page 66 of 80

DAWN HEWITT: And it is occupied, CBS

Westinghouse?

TOM ALCAMO: Yeah, I think they have a

contract employee. I don't think it's CBS per se. They

contracted that out.

DAWN HEWITT: And what happens to the

contaminates captured there?

TOM ALCAMO: In the carbon, then once ... The

carbon is disposed of depending upon the concentrations

in the carbon. Sometimes it's landfilled, sometimes

it's regenerated in a furnace depending upon the

concentrations. The last batch they took, had to take

to landfill capable of accepting PCBs greater than 50

ppm. In addition, it gets sludge there that they

sample, that they take off site based upon the

concentrations.

DIANE HENSHEL: I greatly appreciate the

amount of PCBs stripped off at Richland Creek and

Conard's Branch compared to places like Susquehanna and

the Hudson. But I really don't appreciate the EPA

dismissing it as completely insignificant because in

fact when you do consider global PCBs, it's all the

little ones added together that really do contribute a

huge amount in the end. And it's not just the major

sites. So I realize that we're orders of magnitude

Page 67 of 80

lower than the Hudson in terms of stripping, and that

the amount that's contributing to the risk assessment

is probably small, even through I'd really appreciate

to see some verifying data of air sampling. But I

really appreciate also that even if you guys do

represent our government, that you don't just dismiss

this as insignificant in the global economy.

TOM ALCAMO: I think in terms of insignificant

we are not doing that. I mean if we thought it was

insignificant we wouldn't even look for it or we

wouldn't even do the calculations for that. I mean

there has been air monitoring done at Bloomington. A

lot of air monitoring. It may not be the requirements

of what some people want, but there has been a lot of

air monitoring done and you know that. And so we have

not taken this insignificantly. If we thought there

was a problem there we would do something about it.

But certainly this has been brought to our attention by

a number of people. We haven't overlooked this.

DIANE HENSHEL: Great, that's not my

understanding. When you're looking from the perspective

of Bloomington, and Mick is asking about global and I

think it's important that you at least acknowledge that

even though (inaudible) in Bloomington it's not a

contributing factor per se within the global

Page 68 of 80

environment. It is a contributing factor. And it may

be a very small contributing factor, but many, many,

many of these situations all over the country and the

world, put together create a major amount. So

therefore, I just prefer that you indicate so in your

verbiage.

TOM ALCAMO: You know, you look at the air

data that was done prior to us removing - 650 million

pounds of PCBs from this town - okay, and treating

nearly a billion gallons of water. And you look at

that air data, and this air data is no different than

it is in Chicago, Madison, Wisconsin, Minneapolis. So

in regards to risks, we've taken this issue seriously.

And we have looked at that. You are absolutely

correct, are PCBs leaving this town and going into the

atmosphere, yes. Is it contributing to the global

problem, along with millions and millions of other

sources including indoor air. You can see papers out

there regarding indoor air that shows huge levels

coming from caulk in indoor air. So we are taking this

seriously. If we didn't, you know, we have taken the

information that you've given us, and others, and

evaluated that. But it is from an insignificant

standpoint in terms of the risk here.

Are PCBs leaving Bloomington - yes.

Page 69 of 80

DAVE NOVAK: We're got about another ten

minutes before we get into the comments. So if you've

got some more questions. Once we get to the comments

we're not going to talk.

JAMES CHAPMAN: I think this bears on some

data that's not for Bloomington, but I think this is

worth bringing up and at least thinking about. It's

Chicago, we know that Chicago is the major source PCBs

air emissions and air deposition to Lake Michigan. And

so there's been efforts made to see if we can identify

major sources and address them in Chicago and try and

get this air emissions down. Because the PCB levels in

fish in the Great Lakes are plateauing and it appears

that now it's driven by air deposition. And the

results are somewhat disappointing. They looked at

transformer yards, sludge drying beds and landfills.

And they did very nice work where they measure PCB

concentrations in the air upstream, you know, up wind

and down wind of these areas and made, did them over

different periods of time. Made calculations of

emissions on a yearly basis and for some of these

sources it was kind of scary how much PCBs were coming

off of these. But at the end it turned out that they

were accounting for at very best 8 percent of the PCBs

coming out of Chicago. Overwhelming it seems that the

Page 70 of 80

sources of PCBs to the air are diffuse sources.

Unfortunately they're probably residences, offices,

public buildings, you know, transformers out on power

lines. Just a multitude of things, you know. Caulking

is a source, fireproofing materials at one time,

acoustic tiles. It doesn't say that there's nothing

that can done, but I think it's a real misconception to

think that you can go after an air source from a

particular point and think that this is going to make a

large difference. This may not make any difference.

It may not even make a measurable difference of what's

actually circulating in the air. Personally I found

this study to be a little bit, a little bit

discouraging.

But I just want to point this out because to

take action under SuperFund we have to be able to

connect risks, measurable risks to be able to justify

the expense and the efforts that it would take to, you

know, justify the work that we're expecting

corporations or other responsible parties to do. And

it's just extremely difficult to make that kind of case

for these pathways, as opposed to looking at the

exposure through a food source, such as fish where the

risk are measurable and can be directly related to a

specific site.

Page 71 of 80

DAVE NOVAK: We've got time for a few more

questions. When we get to the comments, and we'll

slide right into that, ask that you come down and use

the microphone because definitely we do want to get the

comments. That's going to be used to finalize the

determination on the Alternative and the revenue.

Whoever wants to comment, please come down, state your

name, spell your name and then go on with your comment.

We're not going to do any talking, other than to call

on you during this period. So, who wants to start out.

MICK HARRISON: I'm Mick Harrison, attorney

for Sara Elizabeth Fry and Protect Our Woods. Ms. Fry

would like to make the following comments and she will

submit some additional detail in writing by your

deadline. I did want to ask that at the end of the

meeting you clarify the deadline. In your literature -

well, I guess there it is, September 17th. So we'll

get on that.

The expectation that an end (inaudible)

solution and water treatment can work in a karst

environment is unrealistic. Karst is unpredictable and

uncontrollable and that's why EPA correctly stated some

decades ago now that these Bloomington area PCB

contaminated sites should be completed excavated.

Which is also what the City agreed at that time. I'm

Page 72 of 80

not sure why the City has forgotten that at the moment.

But Ms. Fry and Protect Our Woods and I would like to

request that EPA go back and reconsider its position

and do additional excavation of PCBs at Neal's

Landfill. Not only in the soil but in the rock, in the

karst, wherever it can be found, and maximize the

removal. The expectation that water treatment and

sediment treatment will be effective when there are

still PCB reservoirs in place at Neal's Landfill is

simply unrealistic and it's not protective of public

health and the environment locally or global.

Ultimately what matters for a persistent

toxic compound such as PCBs which bio-accumulates, bio-

magnifies in the aquatic and terrestrial food chains is

the total mass of PCBs released. Ms. Fry and I

disagree with EPA's position stated here tonight that

unless a single source can be shown to have a

significant impact standing alone that can be tied to

local risks that it is not actionable under SuperFund.

We got into this mess of being over-exposed by allowing

multiple PCB release points, multiple PCB contamination

sources over the years through some very unwise

practices. It's the accumulative impact of all those

sites that have created this over-exposure problem and

there's only one way to deal with it. We got into the

Page 73 of 80

mess by allowing multiple exposures, multiple release

points. We're going to get out of the mess by

eliminating those one at a time. There's no other way

to do it. And Bloomington is one of the major PCS

release points in the country.

It's not the only one, but it has to be

addressed. And leaving PCBs in the environment to be

released over time is an abandonment of EPA's

obligation under SuperFund. And in Ms. Fry's view, and

mine, it's an abandonment of our ethical obligation to

future generations.

Ms. Fry, Protect Our Woods and I would like

to request that EPA reconsider its decision to not

capture and treat storm flow. Some years back Mr.

Ellis in a hearing before the Federal Court where Mr.

Hopkins was present, stated, "Your Honor, if I may. On

Lemon Lane we have learned that in the past couple of

years the most serious problem was actually not in the

landfill itself, but in some springs known as Illinois

Central Spring that are downstream, down gradient, in

groundwater terms from the landfill itself. We've

learned that PCB contaminated groundwater appears at

these Illinois Central Springs and goes from there to

contaminate Clear Creek. We discovered that the worst

of these problems exist during the large storms where

Page 74 of 80

it's possible -" We don't have confirmation on this,

I'm still quoting. "But it's possible that in one very

large storm there could be as many as, as many PCBs

released into Clear Creek as on 4,000 normal days."

Ms. Fry would like EPA to thoroughly assess and then

address base flow or underflow springs as well as

surface or overflow springs.

Ms. Fry would like there to be an explicit

thorough assessment of PCB releases from Neal's

Landfill at all points in this process - before water

treatment, during water treatment and post water

treatment - releases into the air that contribute to

the total mass of PCBs released.

Ms. Fry would request, as would I, that there

be a renewed assessment of the extent and scope of

contamination at Neal's Landfill. Initially samples

were taken, I believe it was 100 feet apart. That

characterization was inadequate. On one occasion 719

capacitors were found in an unexpected location because

that pool of capacitors was not picked up with the 100

foot grid sample. There are other areas that must have

been missed.

I remember the testimony of my friend, John

Foster - who has since passed on - that there were

known contaminated areas outside the boundaries of

Page 75 of 80

Neal's Landfill that had been ignored. Some of those

still need to be addressed.

EPA is, in our view, legally incorrect in

excluding additional excavation as at least an

alternative to be considered and evaluated in their

proposal, and in our view additional excavation is

required.

Thank you. And we'll submit some additional

details in writing.

DAVE NOVAK: Anybody else have a comment?

DAWN HEWITT: My name is Dawn Hewitt. I think

you said that the goal is 0.2 ppm PCBs in fish. Is

that right - something like that? Well, I think it's a

little bit disappointing that your goal isn't zero.

Because that's how they were before this, this

contamination problem happened. And I think that

really should be your goal, and anything less than that

is disappointing. I would expect Westinghouse to have

as a goal something that's cost effective. But when

we're talking about the Environmental Protection

Agency, their goal should be completely clean and out

of the environment. It seems like what you're saying

to us is that now that this genie is out of the bottle,

we can't get it back in. We can get some of it back

in, and we can get as much of it back in as we're

Page 76 of 80

willing to pay for. And maybe we could get even more

of it back in if we were willing to pay more, but we're

not willing to pay more. And that's not good enough.

During storm events you said a lot of PCBs go

down stream and are washed away. So what your

suggestion is that the solution to pollution is

dilution. Even though it ends up in the Aleutian. And

that's my community that is contaminating places tens

of thousands of mile away. And that's not okay.

That's not okay. And who's going to be held to a

higher standard if not you. We just expect better, and

we really want better from you.

DAVE NOVAK: Other comments. Anybody else?

If there's no other comments, we can conclude the

meeting. We thank you all for coming and reminder that

comments are still being accepted via internet.

TOM AliCAMO: One second, Tom. With the

extent, Mick you asked about the extension of the

public comment period. It's September 17th. We did

send out additional postcard. We sent out I think in

the neighborhood of 3,000 postcards to individuals,

something to that affect, which corrected that.

Certainly I think, Mitch, you've corrected that on the

COPA web page. And if you want copies of the

Administrative Record or any documents you can either

Page 77 of 80

get a hold of me and I'll send you the disks or you can

get a hold of Mitch and we'll get it for you. But

again, it's September 17th.

DAVE NOVAK: As far as the comment, the

meeting will go until 9:00 o'clock. We'll be hanging

around. Those who are here, you can remain. If

anybody else walks in we'll take their comments up

until 9:00 o'clock. But as far as you folks are

concerned ... Thank you.

ADJOURNED AT 9:00 O'CLOCK.

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STATE OF INDIANA

COUNTY OF MONROE

I, Christie A. Fisher, hereby certify that

above hearing of August 7, 2007 beginning at 6:30 p.m.

and concluding on that date at the Monroe County Public

Library, Bloomington, Indiana in re: Neal's Landfill,

was recorded by me.

I further certify that the transcript was

prepared by me. The original transcript file is in my

possession. The typewritten record was provided

electronically to the EPA in Chicago, Illinois.

I certify that I am not in the employ or a

relative of any party.

IN WITNESS WHEREOF, I have hereunto set my

hand and affixed my notarial seal this 17th day of

August, 2007.

(Not signed electronically)

My commission expires

11-20-2012

cf/cf

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