Alan Muller, Green Delaware, questioning and commenting at the meeting

Tuesday night, there was a meeting in Delaware City regarding the “Standard Chlorine of Delaware, a/k/a Metachem Superfund Site.”  This meeting was to gather comments on the “OU3 Proposed Plan.”

Here’s a link to the News Journal article about it — and the full story is below:

EPA: Metachem toxins will linger

Comments must be sent in by August 14, 2009, postmarked if mailed by that date, to:

Hilary Thornton, Mailcode 3HS23
US EPA, Region 3
1650 Arch Street
Philadelphia, PA  19103


Here are my comments, sent just now:

Overland Comments – Metachem

Now, take a few minutes and work on yours!


The way they handle these proceedings, it’s misleading and diversionary, a false, technical compartmentalization of the problem and solutions, which leads to a preordained, incomplete, and probably ineffective “clean-up.”  Part of the problem is that it’s  not clear that cleaning up is a priority.  My impression is that they’re just interested in “dealing with it” in some way, the CHEAPEST way, checking off the “OU3 box” and moving on.

Their plan, their PREFERRED plan, is to cover it up and move on to “OU4.”  Their “Preferred Plan” is, direct from their powerpoint slide 8:

2A.  Surface Cap/Institutional Controls
Impermeable Surface Cap
  • Cap materials TBD during Remedial Design Phase
  • Cap materials and thickness would vary depending on future land use
Institutional Controls
  • Future land use must not interfere with ongoing remedies
Five-Year Reviews
  • Required for any Superfund Site where contaminants remain
Est. $11.5 – 18.5 Million

Why look! Imagine that!   This is the CHEAPEST of the options.  All options are “cap” crap, with “materials TBD” and, based on prior past bad experience with DNREC’s “hare-brained” ideas (yes, that’s a direct quote)for “beneficial use” and using coal ash and sewage sludge to cap the dump next to the river:

  • I asked whether they’d use coal ash in the “TBD” cover material, and they would NOT commit to rejecting coal ash.
  • I asked whether they’d use sewage sludge in the “TBD” cover material, and they would NOT commit to rejecting sewage sludge.

This is where that compartmentalization becomes a problem.  They said that was not an issue for “OU3” and that it would be addressed in the “design phase.”  Uh-huh, and the public is involved in that exactly HOW?  And hello — WHAT the impermeable surface is has much to do with the appropriateness of using an impermeable cover.  Rainfall on the impermeable cover will trickle off the cover over the edge, onto and into the ground, groundwater, etc.   Even if it’s asphalt, that should be considered.  Isn’t the EPA is in the process of addressing coal ash, and a rule pending?

Cost… Their “preferred” option 2A costs $11.5-18 million.   The others?

The other options, from their powerpoint:

2B Surface Cap/ICs, with Soil Vapor Extraction
Same surface cap and ICs as mentioned in 2A, plus an in Situ SVE system:
  • Est. 200-500 air extraction wells at 50′ depth
  • Treat contaminated air from beneath the cap
  • treat off-gas from SVE system before discharge
  • Additional sampling to identify “hot spots”
  • Pilot study first, to test effectiveness
  • Est. $19.1-20.2 Million
2B Surface Cap/ICs, with ISTD
Same surface cap and ICs as mentioned in 2A, plus in Sit thermal Desorption:
  • Est. 2,800 heater and 1,400 heated vapor extraction wells, 8-12′ apart through 330,000 sq. ft. area
  • Additional sampling to identify “hot spots” within 10′ of barrier wall
  • Pilot study first, to test effectiveness
  • Est. $92.8-99.8 Million

Let’s see… $11.5-18.5 v. $19.1-20-2 & $92.8-99.8.  Doesnt’ take a rocket scientist to see that the cheapest “option” is “preferred,” and since when is cost the primary driver?  Is this an indication of how they value those living here, drinking the water, breathing the air?

Oh, and did I mention they admitted, finally, that the contamination goes down at least 140 feet!  That’s something they haven’t wanted to talk about before.

These options are the only ones looked at, the only ones that are under consideration.

CONSIDER THIS: One other option I want them to consider is to dig up part of the site, the cleaner part, and put a liner down there and take the contaminated dirt from the rest of the site and bury it there with the solid multi-layer liner, and then cover it.

Here’s an example of that in Minnesota, showing that it can and should be done.  This is a scenario where it’s been sitting there since before the mid 70s, it has contaminated ground water in Lake Elmo and Oakdale, Minnesota.  They’re using three layers of liner over packed clay and another three layers of plastic, plus sand with a collection and draingae system.  In the Metachem case, they know groundwater is contaminated, that it’s seeping down, so what, short of this, will stop it?  Take a look — Tom Meersman did a very good job on this:

History-making landfill do-over in Washington County

Hazardous 3M trash buried decades ago in Washington County is being dug up and will be reburied with a protective lining.

By TOM MEERSMAN, Star Tribune

In a $20 million job that’s the largest of its kind in state history, workers in protective suits are unearthing trash in Lake Elmo that hasn’t seen the light of day for more than three decades.

Their mission is not to burn the wastes or haul them off to another state, but to rebury them in a state-of-the-art pit that will keep chemicals that went into Scotchgard and other 3M products from getting into any more drinking water.

Excavating 33 acres of garbage, and then putting it back in the same place, may seem like a curious way to handle trash that has rested undisturbed since 1975.

However, the former Washington County landfill is not your typical dump. Wastes taken there from the 3M Co. in the early 1970s have contaminated groundwater in nearby Lake Elmo and Oakdale.

That has led to one of the biggest attempts to go back and undo decades-old environmental practices that the metro area has ever seen.

Residents have switched to clean sources of drinking water, but the chemicals are still in the landfill, a potent source of contamination for years to come unless removed or isolated.

“We probably would not be doing this extent of work if not for the PFCs,” said Jeff Lewis, referring to chemicals formerly made by 3M that were dumped legally at the landfill and were used in products such as stain-resistant coatings and nonstick cookware.

Lewis, who manages the closed landfill program for the Minnesota Pollution Control Agency (MPCA), said that 3M agreed to pay about $8 million of the cleanup costs, and the remainder comes from a combination of garbage fees, state bonding and insurance recovery money.

Lewis said it’s impossible to separate the 3M wastes from that of other companies, and from the huge volume of trash from Washington and Ramsey counties. The former landfill was the first to be permitted in the state, and operated from 1969 to 1975.

Old and new school work
The removal part is old tech. On Monday, a pit the size of a college football stadium was buzzing with heavy machinery. A backhoe with a huge maw was eating into a wall of trash and dumping it into waiting off-road dump trucks. At the bottom of the 90-foot pit, four dozers were spreading clay that will form the base of the landfill. Compactors with huge spiked rollers were smoothing it.

The installation is new tech. The landfill will have three layers of heavy plastic liner, separated by layers of geosynthetic material. Teams of workers unrolled huge rolls of the liner on the other side of the pit. The seams of each layer are melted together much like a swimming pool liner.

Lewis said the new landfill will hold mainly old garbage but is designed with a higher level of protection often used to handle hazardous wastes. It will have three distinct layers to prevent any contaminated water in the landfill from reaching ground water: two feet of compacted clay at the bottom, three layers of heavy plastic above that, and two feet of sand and a collection and drainage system above the liners.

“We’re confident that we’re building a system that will work,” Lewis said.

Not everyone shares that optimism.

“I don’t understand how this could have been a viable solution — to dig this up, put in a liner, and then put it all back into the ground,” said Judith Blackford, who lives a half-mile east of the landfill. She and others at public meetings advised MPCA officials to truck the trash away to be burned or buried elsewhere. That’s the approach that 3M is taking for three company-owned sites where chemical wastes were buried.

Lewis said that the landfill contains many times more waste than all of the 3M sites combined — more than 2.5 million cubic yards of trash in all, and much of it was mixed with large amounts of dirt when it was buried and covered. Hauling that much waste elsewhere would cost three times more than the $20 million being spent, he said, and burning it would be astronomical.

“This will be as good a construction of any in the state,” Lewis said of the MPCA’s solution. “It’s got a lot of safeguards built into it.”

Peter Tiffany, an MPCA senior engineer, said no surprises have come to light so far in the nearly 300,000 cubic yards of waste removed. He recalled one day when a dump truck full of red tape drove away with the tape flying like streamers.

Work will proceed in stages

Patrick Hanson, who oversees the work for MPCA, said the project will not likely be finished until late 2011.

Work will proceed in stages, he said, with waste moved into finished segments of the landfill as others are being lined. The state has received some complaints about construction noise since work began in early June, he said, and one call about odor. The contractor is spraying the waste with a slurry of cement and cardboard paper to reduce odors, he said, and has scheduled minimum heavy equipment operating during weekends when nearby residents are more likely to be home.


And the full Metachem story from the News Journal:

EPA: Metachem toxins will linger

Agency briefs public on plan for site cap

The News Journal

Cleanup managers will have to monitor the Metachem cleanup site — the former Standard Chlorine plant near Delaware City — for a century or more before toxic chemicals there break down naturally to safe levels, a federal official said at a public briefing Tuesday.

Hilary Thornton, project manager for the Environmental Protection Agency’s work at the abandoned chemical plant, offered the summary while outlining the agency’s plan to spend $12 million to $19 million to install a waterproof cap for 22.8 of the plant’s 64 acres.

Other options considered — including drilling thousands of 50- to 70-foot-deep heat-treatment wells — would have cost as much as $100 million, but would leave behind intact toxic chemicals that still would need capping, long-term monitoring and access limits.

“It could easily be 100 years or more,” Thornton said of monitoring needs. “It could be 200 years. We do have evidence of breakdown of these products, but what’s present at this site are very high concentrations and that makes it very difficult for natural breakdown to occur.”

Soils as deep as 75 feet are so contaminated that they would be ineligible for disposal in some hazardous-waste landfills, Thornton said, and would require incineration at a plant in Texas.

State and federal taxpayers already have spent about $100 million since 2002 stabilizing the abandoned chemical plant and recycling or destroying chemicals left behind.

Company officials for years fended off state and federal demands to properly operate and clean up the plant and remove accumulated wastes before Metachem Products abandoned the business.

“It’s rather irritating to me that our regulators weren’t doing their job, and we as taxpayers end up paying the bill,” said Delaware Sierra Club member Al Denio. “Given the nature of some of these compounds, I would like to see a good faith effort to get as much out of there as you can.”

The plant’s former owners declared bankruptcy and walked away from the factory in 2002, leaving behind some $65 million in debts and more than 40 million pounds of waste chemicals and products. The bankruptcy forced the entire cleanup cost onto federal and state taxpayers.

Millions of pounds of chemicals used to make herbicides and pesticides were spilled over the years. The company once ranked as one of the world’s top producers of chlorobenzenes, and for a time spun off waste products later used to make the banned herbicide Agent Orange.

Although federal and state officials said in the past that human health and exposure risk were limited, regulators now concede that major threats include polychlorinated biphenyls (PCBs) and dioxins, among the most toxic and long-lived substances known.

Federal contractors already have encircled about 33 acres of the former plant with a wall buried to a depth of up to 70 feet. A network of wells funnels groundwater inside the wall to a central treatment system designed to treat nearly 100,000 gallons of contaminated water daily, cutting off leaks to nearby Red Lion Creek.

Officials are still awaiting results of a U.S. Geological Survey study of contamination in upper portions of the Potomac Aquifer, a deep groundwater layer used nearby for public drinking water supplies.

Also pending is a decision on how to treat tainted soils and sediments in the remaining portion of the plant. Tests of a chemical treatment process for the soils failed to eliminate PCBs, Thornton said earlier this year.

The EPA is taking written public comments on its preferred approach through Aug. 14.

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