Meeting Minutes Feb. 16, 2022

The meeting began at 7:04 pm via Zoom with Secretary Brittany Fremion as host, with 23-26 participants.

Chairperson Jane Keon called the meeting to order at 7:00 pm.

I. Additions to Agenda:

A. Item under Correspondence and Communication

II. Approval of December minutes. Ed Lorenz moved, Liz Braddock seconded. Motion carried.

III. Treasurer’s Report [00:01:05]: Gary Smith, Treasurer

A. January 2022

1. The GCCU General Fund Checking balance stands at $6,137.14 and Share Draft Savings Account remains at $5.00. The Money Market Account (Oxford Automotive settlement) has $63,766.53. TAG grant money available for the Former Plant Site (FPS) stands at $19,541.06 (which includes $15,000 of $50,000 in new TAG award funding). The Velsicol Burn Pit (VBS) has $48,698.38. Vel-sicol Burn Pit (VBP) Fund Checking has $131.52. The complete reports will be attached to the per-manent minutes.

2. Memberships are $5/year and t-shirts are still available. Send checks to PO Box 172, St. Louis, MI 48880.

IV. Correspondence and Communication [00:04:25]: Jane Keon, Chair

A. Rec’d a copy of the Tittabawassee River Carbon Amendment study, via Tom Alcamo; will be discussed at later date.

B. Rec’d copy of Multigenerational Superfund Health Report, via JoAnne Scalf, which she’ll present later in the meeting.

C. Sent press release on Excavation Plan for PSA 1 & 2 to local media, published in Gratiot County Her-ald.

D. Letter from reader in praise of the CAG about our perseverance over the years, as well as post on Facebook.

E. Letter of support for Emory University’s request to NIH for another grant focused on connection between exposure to PBB and Covid.

F. Message from Jillian Gordner about Superfund and health discussions—Ed will discuss later.

V. Program: [00:06:35] CAG member JoAnne Scalf presented an update on the Multigenerational Pine River Superfund Voluntary Health Mapping Project. This also ties in with an item of business from January about the shorter lifespan of people living in the St. Louis census tract that Ed Lorenz wanted to bring to our attention.

A. Background: JoAnne has updated her report and map to clarify which health effects were documented and why, as well as clarified there is some data that still needs quantified. The project has taken five years and more than 2,000 hours of work, equal to approximately $100,000 of work. Over 520 residents voluntarily provided information about their health and JoAnne created a geospatial visualization of the data. To date, there has not been a health study specifically for the residents of St. Louis, which represents a unique population of exposed individuals. JoAnne conducted the survey to “(1) gauge the need for future health studies, (2) identify possible disease clusters, (3) delineate the overall scope of the problem, (4) raise awareness, and (5) encourage state and/or federal agencies of the need to either conduct or fund well-controlled, well designed epidemiological studies of this population group and to establish health surveillance programs for better health outcomes.”

B. Methods: JoAnne developed “11 questions to quantify the occurrence of carcinogenic, teratogenic, and mutagenic (carried into second and third generation offspring) effects of persons living in St. Louis for an extended period of time.” In addition, the survey was distributed exclusively to former and current residents of St. Louis by “student volunteers, the author, and the Cutler Memorial Library,” with local news and the CAG providing information about how to participate. The calculations use a population of 3,513 living in 1,475 households as of 2014 (using 2014 US Census data and omitting the prison population). According to JoAnne, “these households have existed since the decades that the chemical plant was operational and represent individuals that would have been exposed to the contaminations during the time of operation, as well as since” the chemical firm’s closure.

C. Findings: Several birth defects were reported, such as heart defects, premature births, genital anomalies, learning disabilities, and other birth defects. JoAnne noted congenital anomalies in particular, signaling a need to determine possible connections to environmental exposures. Total miscarriages re-ported (62) and hysterectomies before age 40 (11) were also alarming. In addition, JoAnne recently quantified 42 residents with type I Diabetes and 47 residents with type II diabetes. Total cancers documented via the survey have also grown, with a total of 262 cases reported by residents, with four of the top 10 deadliest cancers identified by the American Cancer Society among the highest incidences re-ported among survey participants. JoAnne emphasized the importance of health monitoring and frequent screening to improve survival rates and quality of life for residents. (If JoAnne could not verify information, she did not include it in the report.)

D. Discussion: JoAnne closed by explaining that the survey provides answers to questions and concerns community members have had “for a long time.” As such, she argues that the “survey presents a hu-man health plume map that mirrors the chemical contamination exposure plume, leading some credence to the proposed connection between the chemical contamination of the area with the diseases reported in the survey.” While the “survey was not designed to be, or considered as conclusive of a high disease incidence or showing a cause and effect relationship with the various toxic chemicals in the environment and around St. Louis, it is, however, suggestive of certain diseases occurring with unusual frequency in this population and points out the need for definitive studies.”

E. JoAnne’s report is available on the CAG website.

F. Discussion:

1. JoAnne has been in communication with a faculty member at the University of Michigan in the past and hopes to reconnect soon.

2. Jane asked for input on how we can share the data JoAnne collected, and who we can approach with the hope that a study will be implemented.

a) Dr. Tom Corbett recommended sending the report to MDHHS, arguing that they’ve been negligent in this case and need to act because there’s a clear risk in the community—and it should have been investigated years ago. He cited a study in 1990s that found high incidents of cancers and should have triggered action in St. Louis, but they didn’t pursue it. Now we have risks for reproductive issues, learning disabilities, neurological problems, cancers, and beyond from these chemicals, and it would be a great contribution to the entire nation to discover what happened in St. Louis and apply it to other Superfund sites, such as setting up health and diagnostic clinics for the people to determine early what the outcomes are so they have a better chance of surviving. He emphasized that St. Louis residents should be screened frequently and early.

b) Ed Lorenz observed that JoAnne’s work is tied to long discussions about the significance of popular epidemiology, which plays a vital role in identifying issues and raising questions when these things happen but haven't been investigated. This really needs to be passed to some people who have the ability to verify the results. There was a famous case when the CAG started in Woburn, Massachusetts—which became famous for “A Civic Action,” when finally a Harvard public health professor said we have to pay attention to this, we can’t dismiss it. JoAnne’s work is really important and it deserves real, serious follow up.

3. JoAnne would like to pass information to CMU (CMed), too. Jane offered that the CAG should approach the institutions and agencies as a CAG with JoAnne (author), using the group’s reputation and clout to push for support.

a) Jim Hall shared that Dr. Palmer, a physician in Ithaca, worked in CMU’s Health Professions and might be a contact.

b) Liz Braddock also shared that MDHHS recently got pressure from communities following PFAS contamination at Wolverine in Kent County and did cancer research. In addition, MMDHD and Gratiot County has a community health assessment starting this year, which we might be able to use as a tool to build local momentum as well.

c) Dr. Corbett asked if Emory/The Michigan PBB Registry would be able to help with this. He also shared that when he began his PBB studies at the University of Michigan he had to search “high and low for people to help” because it was a contentious political issue—he was even threatened by state representative to stop his work, that they would cut his or the university’s funding, or he could lose his job, which didn’t deter him. He noted that we may find people at Michigan universities who are hesitant to get involved because of the potential political nature of this and possible liabilities.

d) Norm Keon followed up on Jim Hall’s comment— Liz Palmer is oldest daughter of Bob Graham and no longer employed at CMU, but for the VA. He also responded to Liz’s comment, noting his efforts to add questions to the health department’s Patagonia database. He will discuss this further with Liz.

e) Liz also noted that when applying for grants, St. Louis is rated high in social vulnerability index (SVI is based on census data), which might give grant proposals an edge. The higher the number the greater the social and health impacts, and in MMDHD, St. Louis has the highest rating. JoAnne reminded the CAG that she did not include the prison population because they were not exposed during time of the chemical firm’s operation, not to suggest that the prison population doesn’t need support, but that the community has the most unique exposures.

VI. EGLE Report [00:38:10]: Erik Martinson, Project Manager,

A. Railroad spur sampling results — EGLE received the remaining sampling results from EGLE lab (al-ready had data from Eurofins) on February 1st. The EGLE lab data package included DDT 2-4 and 4-4, 4-4 DDD and 4-4 DDE, along with HBB and PBB. Only two samples had detections for DDX isomers and both detections fell below 201 criteria: one to north of 202 S. Watson and one to the south of 202 S. Watson. There were 37 locations with 74 samples total collected. Last week, Eric met with enforcement section to discuss possibility of court-ordered access to the north, but they deemed it inappropriate for attorney general (AG) involvement based on the fact risk to human health was not present nor is there widespread contamination along the rail line. Moving forward, the agency’s plan is to delineate some of the locations of pesticide and other VOC detections, even though below 201 criteria. Weston is looking at approximately 10-15 additional samples. Currently, Weston is drawing and addendum to the railroad scope of work, which Erik will share once reviewed and approved. Timeline for phase 2 investigation will begin with first thaw, likely early March, with hand auger method because detections were shallow. With results, Weston will produce a report and share it with the CAG.

1. Discussion:

a) Gary asked about 201 criteria—doesn’t it mean you can't put housing there? Also, what is the amount discovered? Erik explained that the main criteria is direct contact because of shallow soil collection—we were significantly below direct contact criteria. We did exceed 5 ppm for eco-logical criteria set for the site, which is part of the reason for additional sampling. They are odd locations, right next to the private residence.

(1) Gary followed up, asking, with sampling, will you see how far the contamination goes? Erik answered, yes. The sampling Weston already did was tight—for instance, on the north side of the residence there were 11 samples with 1 detection. So what we propose to do is collect one east and west of that sample, and one a few steps away. Erik will review the figure and following approval, share it with the CAG.

(2) Next, Gary asked how much did the samples exceed the criteria (5 ppm)? Only one spot to north and it was 12 ppm net total DDX. To the south, it came back at .07 ppm, so very low.

b) Jim asked what happens if higher levels are discovered? Will you remove soil? Erik said possibly. What we see now is a very small area (2-inch hole, 0-2 feet), a very small removal.

c) Jane appreciates Erik’s work with enforcement to try to gain access to the area further north, which is closer to the plant site and along the rail line. What else can be done since AG can’t get involved yet? Erik isn’t sure how EGLE can realistically get access to the property to the north given stipulations by the railroad, unfortunately. Jane followed-up, asking if the City of St. Louis owns any portion of northern property? The only other property EAGLE can test has been tested, so the railroad property is the only portion that remains untested. Then Jane pointed out, in the past, the homeowner purchased abandoned railroad property. Is there a chance the City of St. Louis could purchase the northern extension we don’t have access to? Erik said he will look into that.

B. Update on dissolution of Velsicol Trust Fund and protection of O&M Property — The first MOU completed in August and it detailed the 2021 budget; the CAG should have a copy. The second MOU is be-ing drafted pertaining to the 2022 budget and likely finalized soon. Erik will share a copy with the CAG when it’s ready. In December of 2021, the $6.5 million set aside for O&M has been officially transferred to the State of Michigan account so it’s protected, which is good news (RRD-Velsicol Escrow Account). There is potentially a third MOU to outlines responsibilities for EGLE and Land Bank following transfer of properties. Erik will also share it when ready.

1. Discussion

a) Gary asked about the five year review of fish in the Pine River. Erik said yes and EPA will cover later in the meeting.

VII. EPA Report [0:54:40]: Tom Alcamo, Project Manager

A. Program: Jacobs and TeraTherm did a presentation on diminishing returns at the close of the thermal treatment in Area 2 Phase 2 — Jason Cole and Scott Pratt

1. The presentation began with an overview of Area 2, Phase 2, the third and final thermal treatment at the FPS:

a) 4 treatment subareas in Area 2, Phase 2 (A,C,D,E; because the area was too big to do in a single project, which is also why it was broken into two phases)

b) 70 multi-phase extraction wells (in-ground infrastructure, how contaminants removed)

c) 325 thermal conduction heaters

d) 29 temperature monitoring points (sensors in the ground and laterally distributed across the ground)

e) 24 pressure monitoring points (to demonstrate negative pressure necessary for extraction)

f) Operated through December 31, 2021

(1) 263 operation days

(2) ~145,000 pounds of contaminants removed

(3) ~13.8 M kWh delivered to subsurface

(4) ~3.9 million gallons of extracted groundwater treated

2. Diminishing Returns - Performance Standard: The 2012 ROD defined diminishing returns as the performance standard for operation of the ISTT systems; this standard relies upon multiple lines of evidence:

(1) treatment of the source area using ISTT has reached an asymptotic rate of COC recovery (the rate is increasing or stable but not at a rate that demonstrates additional mass can be extracted from the subsurface)

(2) additional input of subsurface energy will not increase COC mass removal rate (if we continue to put in energy does the mass of contaminants we can extract does not increase)

(3) extended operation of the ISTT system offers no further reaction in DNAPL ability and migration from shallow outwash (if the system operated for an extended period of time there wouldn’t be a change in amount or rate of recovery)

b) Data demonstrates that contaminant recovery rate has decreased with time substantially.

c) In addition, energy input reached the point where it did not change mass removal rate, so that continued heating would not significantly increase the total contaminant mass removed.

d) The thermal oxidizer inlet concentrations climbed and then declined, with vapor phase recovery a minor component of total mass removed. Almost 97% of contaminate mass recovered from subsurface was in the form of NAPL. Most of the technologies are in driving vapor phase removal, but the nature of contamination at this site heating was able to mobilize NAPL in the 100 degree range.

e) Extended operation of the equipment therefore provides no further reduction of NAPL mobility and migration. Through 12/31/2021 the TTZ temperature has been at 100 degrees for 146 days. Recovery rate analysis indicates the contaminant reservoir is depleted and the thermal treatment system for this site, in this configuration, has run its course.

f) Finally, in terms of energy input, it exceeds industry best practices. For instance, with benzene, 9/10 times the data we have access to and conversations with vendors, even those outside FPS, put us at 250 KW for cubic yard of material, but at Velsicol, it was easily doubled. It’s very clear that diminishing returns have been reached for this system.

g) Discussion:

(1) Dr. Corbett: Following treatment how will the land be classified? Jason said there will not be housing and deferred to EPA with respect to redevelopment, but the site has more work to go for restoration. Tom Alcamo said this phase was focused on getting rid of the most vola-tile material. He pointed out that there are many remedy components, with the final being a cap that will permit some redevelopment, mostly recreational. A water treatment plant is part of the plans, as it will have to treat hazardous chemicals. Some recent EPA reports on simi-lar sites for redevelopment might inform discussions moving forward, but the goal is to re-move the fence. So contamination will persist, but not at a level that is dangerous.

(2) Scott Cornelius, CAG TA, was very pleased with the ISTT remedy, results, and presentation about how diminishing returns worked. He and Tom talked about the challenge of getting approval for ISTT. Then, Scott C. asked about the NAPL that re-solidified. Tom and Scott Pratt said they recovered 5,000 lbs from those two wells and more than 80% was DDT—he quoted Jason, who says “we melted DDT.” We tested the two wells and it’s all solid/non-mobile; we removed as much as we could.

3. Total ISTT FPS Summary:

a) 3 treatment phases

b) 8 treatment subareas

c) 181 multiphase extraction wells

d) 843 thermal conduction heaters

e) 62 temperature monitoring points

f) 51 pressure monitoring points

g) Project totals

(1) 862 operation days

(2) ~381,000 pounds of contaminants removed

(3) ~35.6 M kWh delivered to subsurface

(4) ~14.0 M gallons of extracted groundwater treated

(5) At a cost of approx. $43 million, including the use of renewable energy from the City of St. Louis (EPA is working on a summary of that information)

4. Jim Hall asked about how the removal of contaminants at the FPS compares to others. Jason said that the Velsicol site recovery quantity was high, but that there are other sites where around a mil-lion pounds of contaminants have been recovered, but it’s important to keep in mind that in other places the contaminants are recovered more easily. He added that the Velsicol site is very different and presented unique challenges.

B. Question of PFAS at the plant site [01:27:00]— EPA will sample groundwater for PFAS in the next round of groundwater sampling. Some drinking wells have already been sampled and there is no immediate human health risk, although Tom thinks there is potential to find the presence of PFAS which will influence design of treatment systems.

C. Question about having climate change analysis conducted at Superfund sites — EPA has some good information on its website and they call it “climate resiliency.” There are resources (FAQ sheets) tied to climate resiliency, groundwater treatment, and containment remedies. So while there are no changes to the contingency plan or CERCLA, we will get guidance on these in our design phase, such as taking into consideration changes in river levels or flooding. Tom can share resources that will provide insight into how EPA will address climate resiliency.

D. Bird study — Tom clarified that EPA didn’t change Matt Zwiernik’s report or conclusions, rather, EPA finished it by cleaning up the data and finalizing the report. The initial report was an executive summary and the second report received many comments. EPA was disappointed because Matt did great work and they think highly of him, but he didn’t finish it and EPA had to terminate the contract with Michigan State University. It was in both the university and EPA’s best interest to complete the report the way they did, using all of Matt’s data.

1. Jane said that some of the paragraphs ended with risk assessment statements and wondered if of them were added by EPA? Frank Dillon answered, as he finished the report: “we didn’t edit or change or add any text to Matt’s report.” Frank works on many Superfund sites across the country and rarely does he get to work with the kind of site specific data Matt generated, so he was excited to get to work with it but frustrated with the format in which it was delivered—it wasn't suitable for EPA documentation at the site, so Frank worked with MSU and Matt to do that, “so anything we did to finish the report was to correct quality control errors in figures and tables, as well as formatting, and to make sure the appropriate supporting documentation was there.”

E. Introduction of RI report for OU-3 and OU-4, which a more thorough discussion coming later — Tom will talk more next month about this, including a future call with Scott Cornelius to discuss the RI.

F. Velsicol Burn Pit (VBP) Update: Tom introduced RPM for the VBP, Jennifer Knoepfle (“Keh-nep-flee”). Jennifer has a doctorate in hydrogeology with over 20 years of field experience and 17 years of experience working on Superfund sites. She has been working with Tom to keep the current team and equipment on site for continuity, as well as schedule and financial efficiency. She and Tom will keep the CAG updated. Welcome, Jennifer!

G. Status of Phase 2 Carbon Amendment experiment — Frank and Amanda Harwood are reviewing the final report and it’s due next month (Tom will share). They are also discussing additional work down-stream, particularly ecological work (i.e. additional sampling in OU-4, floodplain and sediment banks, as well as biological monitoring downstream, including fish sampling).

H. Other — Tom said the FS should be released next week. He hopes to have upgradient slurry wall investigation work plan on the website by Friday. Also, the bathymetric survey of the river bottom will in-fluence downgradient barrier wall design and that work plan is coming this summer. The MW-19 (drilling program on far side of site to determine need of another DNAPL collection trench) will be done in a few weeks. They’re also working on perimeter drain work plan. There are essentially five design and five work plans coming out for this summer. Diane will send materials to CAG officers, which we appreciate because it helps officers who work as volunteers to know what information is on the website and to make time to review it.

I. Tom is also working diligently to get proposals out for review for excavation of PSA 1 & 2 by early March. In addition, he’s working behind the scenes with Army Corps of Engineers (ACE) to get on board for onsite oversight for excavation phase. Hope to award contract in May with technical evaluations (with ACE) in late April, with work on site underway sometime in June (getting equipment on site). We do have infrastructure funding for the construction phase—not design yet. Tom doesn’t expect funding to be an issue.

J. Well 12 with City — The City had a pre-bid meeting and at least 3 contractors are interested in the project, with construction beginning this summer.

K. Five year review — Diane reported that EPA will distribute an ad and do community interviews to inform the report—more details to come, but likely virtual or phone contact. Once the details are pinned down, Diane will share the information so those able/wanting to participate can.

L. Discussion

1. Jane asked about the fish study. Tom said for now, the only study EPA will do is downriver. EGLE will have to do some sampling for their five year review monitoring program for fish, which will re-main on five year schedule. Fish tissue sampling and risk assessment will happen downstream by EPA.

2. Gary asked about five year fish sampling above the dam to determine efficacy of backwater dredging. Erik said the state is on a five year schedule, with the last being in 2018, which makes 2023 five years.

3. Gary also asked if the groundwater collection trench picked up any extra DNAPL. Tom said no, it did not. Scott Pratt said the last time we measured manholes and groundwater collection trench was in December, which speaks well of the extraction system. Tom said they’ll keep testing it and if it’s present, they’ll remove it.

VIII. Technical Advisor Report: [01:45:00] Scott Cornelius, CEC

A. Work underway on RI — Scott is still working to get the Phase 2 work plan comments together, and preparing to sink teeth into the RI. One of the things Tom provided was an email explaining additional data for OU-4 will arrive later, as an addendum. So Scott will review the RI as it currently exists.

IX. Old Business [01:46:00]

A. Update on use of an Owl Projector for in-person/virtual meeting combination — Gary Smith

1. Gary reached out to Norm to see if we can connect with RESD in Ithaca, but hasn’t heard back. He also asked Seville Township about borrowing their Owl but they weren’t able to discuss or address it at their last Board meeting. So we are still working on a way to hold meetings bi-modally.

B. PBB Leadership Team update – Brittany Fremion and Ed Lorenz

1. The postdoc (Dr. Robert Hood) at Emory working with the Michigan PBB Registry team shared his ideas for future research and collected input from group members. In addition, the team discussed additional funding opportunities and reported on fieldwork from a recent trip to Michigan to conduct appointments for the clinical trial and do a few blood draws. They continue to work with MDHHS/MPHI to get the legal paperwork in place so that they can do a Death Index and Cancer Registry study.

2. Upcoming virtual community meetings are planned for Tuesday, March 1st at 6:30 pm and Saturday, March 5th at 10:00 am. CAG members will participate in a community panel; the focus of the meetings with be reporting back important updates to studies, as well as gathering input from com-munity members about future directions for research. Finally, they are planning on wrapping up fieldwork in May and holding an in-person partner meeting later this year.

C. Update on the website [01:49:45]— Ed Lorenz

1. We’ve been getting a bunch of traffic in the last month, with 112% increase with site visits and 98% site visits from unique individuals, which is great.

D. Idea of using CAG website for raising funds for adding people to the PBB health research — Ed Lorenz — Tabled

X. New Business [01:50:25]

A. Participation in Public Interest Research Group (PIRG) on Superfund and health — Ed Lorenz

1. The group hosted a webinar about the Superfund Tax last spring and played a role in getting the Superfund Tax reinstated. They are doing another webinar. If anyone wants to get involved, they welcome participants. It’s an hour and half long via Zoom on March 11th. They are waiting to hear if chair of house energy committee will participate. The goal is to determine next steps and they’re particularly interested in work on the human health side, which is why they are very interested in the CAG. Ed, Dr. Corbett, and JoAnne will likely participate. We will keep everyone updated on the plans.

2. Ed became involved via the Superfund Community Information Exchange, which is for community groups and the person running it is a Technical Advisor out of California (Marcus Griswold). They are working to get community members connected via Facebook.

B. Possibility of PBB Citizens Advisory Board members becoming part of the CAG [01:53:50]

1. Jane shared that on call with Emory, they have several partners, which include CAG officers, but also PBB Community Advisory Board that would like to join the CAG as subcommittee with specialty in PBB-related work. There isn’t an official request yet, but they are considering, so she wanted to give everyone a heads up.

a) Jim Hall said that when we first started we had several subcommittees, so it’s possible, but up to the chair and bylaws. Ed and Jane confirmed.

Please remember to pay membership dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.

The next meeting will be held on Wednesday, March 16, 2022 via Zoom.

Meeting adjourned at 9:00 pm.

Respectfully submitted,

Brittany Fremion, Secretary

Monthly Meeting Minutes, Sept. 15, 2021

PINE RIVER SUPERFUND CITIZEN TASK FORCE

General Membership Meeting Minutes

September 15, 2021

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording: https://us02web.zoom.us/rec/share/3v9ZRIFK3S2OIECMffLOY8rGHUj2PHHDfuNEnZyRQ1UKSsQ1EarpGO47ZeDHK_95.lgEnQINzp_nvaY45

Access Passcode: 0mD5dF$q

The meeting began at 6:48 pm via Zoom with Secretary Brittany Fremion as host, with 12-15 participants.

Chairperson Jane Keon called the meeting to order at 7:00 pm. This meeting was Zoom bombed and so a new invitation was sent to known participants and resumed at 7:22 pm.

I.      Additions to Agenda: Health Department Update and Clarke Historical Library Exhibit

II.    Approval of March minutes. (Liz Braddock/Nikki Brabaw)

III.   Treasurer’s Report: Gary Smith, Treasurer

A.    August 2021

1.    The General Fund Checking balance stands at $5,463.14. The Money Market Account (Oxford Automotive settlement) has $64,927.40. TAG grant money available for the Former Plant Site (FPS) stands at $7,204.76. Additional TAG funding approved. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $85.62. The complete reports will be attached to the permanent minutes.

2.    Memberships are $5/year and t-shirts $12-13 each (new pricing TBD). Send check to PO Box 172, St. Louis, MI 48880.

IV.  Correspondence and Communication: Jane Keon, Chair

A.    Meeting with St. Louis City Manager and Mayor

B.    Meeting with Technical Advisor to prioritize review of documents

V.    Program [4:00]:  Erik Martinson, EGLE Remedial Project Manager, has prepared a PowerPoint slideshow for the thermal treatment in Area 2, Phases 1 & 2; on the Carbon Amendment study area; and on PSA (Potential Source Areas) 1 & 2.

A.    The CAG watched the drone flyover footage, which EGLE agreed to share for use in presentations and/or our website (Diane said EPA is working with a videographer to piece together a video that contains all the information we want in a manageable file size). Discussion throughout clarified questions about remedies, which were addressed by EGLE and EPA. For instance, PSA 1 has rancid oil so EPA will plan to excavate during colder months to reduce odor.

VI.  EGLE Report [23:00]:  Erik Martinson, Project Manager

A.    Railroad spur investigation: Erik met with EGLE Compliance and Enforcement to see how likely court ordered access would be, which put the issue before the Attorney General, who recommended EGLE press forward with the Access Agreement. A warrant for court ordered access was unlikely to be granted at this point, in part because the threat of substantial danger is unclear. Erik redrafted and removed clauses from the prior Agreements and returned it to the railroad last week (September 7th). He hasn’t had an official response yet. He also sent an email with questions about property ownership in the area (especially area west of W. Tyrell and S. Watson, which extends to the Pine River and EGLE believes is city property). The adjacent property (by 202 S. Watson) along the river might also be city or private property. In consultation with Weston, EGLE will survey the properties to determine ownership and thereby access. Given this information, EGLE is also considering sampling to the south instead of north first.

B.    Discussion: EGLE and/or Weston will connect with city management to determine ownership. The CAG also requested to see the new work plan for the spur, which EGLE plans to share with EPA, too. It is standard protocol for agencies to communicate on this issue.

VII. EPA Report [0:33:58]: Tom Alcamo, Remedial Project Manager

A.    Updates on heating in Area 2 Phase 2 - EPA has recovered about 65,000 pounds, not as much as Area 2, Phase 1, but still a good amount. Reached 100ºC on August 7th and will operate for 90 days (early November). Everything continues to operate well. The NAPL itself is different in substance and will be sampled by lab.

B.    Downstream investigation - OU-4 floodplain sampling should begin soon with access agreements near complete.

C.   RD investigation on hold at this point as EPA awaits approvals.

D.   OU-3 : RI expected to be released around end of October, with proposed plan ready for public comment next spring.

E.    Level of NAPL in MW 48 (99’ well) was 5.5 feet, consistent with past several years.

F.    FS expected end of November at the earliest, more likely December. RI will include additional floodplains further downstream that won’t be affected by OU-3 work.

G.   Video of the (different) DNAPL found in Area 2, Phase 2 - Reached 102ºC (39 days at target) with DNAPL and LNAPL removed. Twice a month the team on site walks the well fields and take sample from each wellhead to ensure the system is functioning and alerts them to the presence of DNAPL. MPE 71 and MPE 72 weren't functioning during these tests and the investigation revealed that it is because of the type of DNAPL. In MPE 71, they discovered that with exposure to air, the contaminants quickly re-densify (within 15-20 minutes). It moves at 100ºC, but with cooling, solidifies into a waxy substance (not hard or brittle, more like stale taffy in texture). The team will be removing the well and removing the NAPL. EPA is unsure of what the exact chemical composition of the DNAPL is, but believe it is very likely to be some kind of DDT. They are continually surprised by what’s coming out of the ground, observing that, “It's the Velsicol site, it keeps on giving.” MPE 72 contaminant is also different in substance, like syrup, fudge, or taffy when it cools. It is clearly more volatile based on odors, but those two wellheads are very close to each other, on river side of DDT building, so it’s not surprising. You can’t pump this NAPL out because it can’t run through system, so they are working on a second containment system to get NAPL from these wells at the wellhead and take it up the site in a different way. They have also checked every other well in the field and usually find dirty water with flakes or ganglia of NAPL that floats at the top and then eventually sinks, which is typical of NAPL. But this new denser form of NAPL is different.

1.    EPA is working with a waste hauler and incinerator in Arkansas to truck the materials, but the pandemic has complicated the transport because of the demand for truck drivers. They are hopeful they will be able to get the materials out of St. Louis soon, but this is a national issue for almost all sites.

2.    Discussion

a)    Q: How far away are these wells from other wells and when the new secondary system is installed, how will it affect the system?

(1)  A: It will pump very slowly so as not to fracture NAPL flow pathways. They’re about 75-25 feet apart. If it's pulled away from another well, it will be okay, as we haven't noted this kind of NAPL anywhere else.

b)    Q: The location is right by the interceptor trench at the shoreline, but there haven’t been any level changes or appearance of NAPL there?

(1)  A: We’re monitoring and haven't noticed, but will pay attention to it. Heat will make the NAPL flow. But it may also never appear in a well or move.

c)    Q: Could it be operating like a dam?

(1)  A: Potentially, but we like to think the system is working. There is an upper limit to see how much we can get, which we need to determine first before commenting further.

H.   Other

VIII.         Old Business [00:57:50]:

A.    CAG website update – Ed Lorenz

1.    We are ready to migrate the website from WordPress to the new platform, Square Space, where we can do things like set up a store and donation portal. When we make the shift from WordPress to SquareSpace there will be some downtime, which is why we waited until after this meeting to initiate the transfer.

a)    The new layout includes features like “Take Action” hot link to membership, meeting information, and other pertinent details that might grow recruitment on every page of the new website. We hope that these kinds of updates will make the site more attractive and user friendly.

B.    Superfund Tax opposition – Ed Lorenz

1.    Ed shared a report from the American Chemistry Council, a lobbying group for chemical industry, which is pretty biased in its interpretation of how the Superfund tax will lead to plant closures and job loss—a very one-directional economic narrative. The policy would double the tax on basic chemicals, like bromine, that are components of other compounds. What the lobby doesn’t account for is the fact that bromine-based products will go up in price to reflect changes, so impact will be in consumption and thereby on compounds we probably shouldn’t be using very often anyways. Their report also overlooks the environmental and human health costs associated with exposures. In addition, from the work of people like project managers and health professionals, economics isn’t just about chemical companies, it includes EPA and healthcare workers. Cleanups cost money too, which also generates jobs.

a)    The Superfund tax is still part of the infrastructure bill inching its way to Congress. If it survives, it will generate much funding for Superfund sites.

b)    Community members can contact their Representatives and Senators to indicate their support.

C.   PBB Leadership Team update – Jane Keon, Brittany Fremion

1.    There is a new grant opportunity, which supports a postdoc, Dr. Robert Hood, whose specialities are in cancer research and environmental exposures, specifically in Appalachia, who is starting to work with the Emory PBB Registry team. The methods for analyzing PBB have changed over time, so he will be working with disparate data to bring it up to date so PBB results can be compared exactly.

2.    Emory has also purchased some new software for all the PBB data to be in one place and easily accessible.

3.    Recruitment for clinical study is still limited to those with high blood levels and ongoing.

4.    Information for Next of Kin Records is available through the Michigan PBB Registry and MDHHS websites.

D.   Addition: Health Department Update — Liz Braddock

1.    MMDHD met obligations for long-term water monitoring and drinking water sampling in St. Louis for properties that need connected to the city system. They are happy to have completed this important work.

2.    MMDHD is still involved in PFAS monitoring for the state, at any point some spots can come up, but there are currently none in Gratiot county. There is one in Clinton County and at Capital Airport. There is also a biosolids site in Ionia County and at the Pearson Township (Republic Landfill Site), which accepted waste from Wolverine in Kent County. The city of Stanton also has some detections.

a)    Q: Have there been PFAS studies in Gratiot County?

(1)  A: Total in Alma and the Ithaca city landfill (another Wolverine connection). Suspects the airports to be next, following trends in state investigations and funding.

IX.  New Business [01:15:30]

1.    Begin to think about nominations for the CAG Hall of Fame, due next month. Awards are presented in a ceremony at the December meeting. Please email nominations to Jane Keon. Last year we also decided to choose one person per year moving forward.

2.    Addition: The Clarke Historical Library at CMU is doing an exhibit in spring 2022 on water issues, which will engage Pine River and CAG Collection. Brittany will keep the CAG updated on plans and opportunities to collaborate.

3.    Jane shared that Theo Von Wallmenich, CH2M Hill and Jacobs employee, accepted a new job. Tom said he is going to be one of the directors of Greenfield Trust. While it is a blow that he’s leaving, we’re all very happy for him. This is a fantastic opportunity, it’s a massive trust, billions of dollars and big cleanups. He’s still in the community and we’d love for him to maintain his membership to the CAG.

4.    Gary asked if Scott Pratt/EPA if they could share the video of the NAPL from tonight, too, especially for those giving talks in the community. 

Please remember to pay membership dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.

The next meeting will be held on Wednesday, October 20, 2021 via Zoom.

 Meeting adjourned at 8:46 pm.

 Respectfully submitted,

 Brittany Fremion, Secretary

Monthly Meeting Minutes - Oct. 20, 2021

PINE RIVER SUPERFUND CITIZEN TASK FORCE

General Membership Meeting Minutes

October 20, 2021

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording: https://us02web.zoom.us/rec/share/3sYcnWHz_EFL-lXK3ELlUeRdatPiDZwabgUkeG9vyozd4xRRj1NJrurkObkW5K-C.84rX00lAqgkCG9Kh?startTime=1634770978000

The meeting began at 6:50 pm via Zoom with Secretary Brittany Fremion as host, with 17 participants. Aides for US Senator Gary Peters and Congressman John Moolenaar attended the meeting, and the CAG appreciates their presence.

Chairperson Jane Keon called the meeting to order at 7:03 pm.

I.      Additions to Agenda: None

II.    Approval of March minutes. (Liz Braddock and Doug Brecht)

III.   Treasurer’s Report [00:01:45]: Gary Smith, Treasurer

A.    September 2021

1.    The General Fund Checking balance stands at $5,923.18. The CAG received two donations in Phil Ramsey’s memory. The Money Market Account (Oxford Automotive settlement) has $64,653.14. TAG grant money available for the Former Plant Site (FPS) stands at $6,854.76. Additional $50,000 in TAG funding approved and distributed in small amounts ($15,000). The Velsicol Burn Pit (VBS) has $48,744.28. Gary was able to transfer funding to cover the cost of the CAG website after connecting with EPA and getting the suspension of funding lifted. Velsicol Burn Pit (VBP) Fund Checking $85.62. The complete reports will be attached to the permanent minutes.

2.    Memberships are $5/year and t-shirts $12-15 each (new pricing TBD). Send check to PO Box 172, St. Louis, MI 48880.

3.    Ed asked about donations to the CAG and whether any funds have been deposited via the website, suspecting that the deposit would automatically be made. Gary recommended a trial run over the next day or two and will report back next month.

IV.  Correspondence and Communication [00:12:35]: Jane Keon, Chair

A.    The CAG sent a letter to EPA Administrator explaining why the former railroad spurs should be included in the Velsicol plan, formalizing the request for an investigation with the hope EPA will address community concerns about the site.

B.    Diane Russell sent the CAG a copy of the latest issue of the EPA newsletter, Pine River Progress, about work at the Velsicol Site (accessible at the following hyperlink: https://semspub.epa.gov/work/05/969695.pdf).

C.   CAG leadership recently received EPA’s final work plan for OU-4 floodplain sampling.

D.   CAG leadership is working on a letter of support for a continuing medical education grant proposal for the Emory team, which maintains the Michigan PBB Registry. If awarded, the project would focus on educating healthcare workers about endocrine disruptors using PBB as a case study.

E.    Ed is in communication with Elena Conis, an academic, who is working on a book on DDT and wants to include information from the 2008 intergenerational conference held at Alma College. The book is expected to be published next spring.

V.    Looking Back [00:19:30]: The CAG discussed a news clipping about a cooperative effort forty years ago (1971) between the City of St. Louis and Velsicol Chemical Company to tear down the old sugar plant (recently mentioned in the Gratiot County Herald). Jane found a small blurb that explains how prior to the chemical plant closure, the city and Velsicol negotiated how to tear down the old sugar plant and what to do with chemicals there, such as DDT. The CAG hopes to find more evidence tied to these efforts.

VI.  EGLE Report [00:21:10]:  Erik Martinson, Project Manager

A.    Erik checked to see if anyone was able to access the drone recording. CAG officers will try to do so and report back.

B.    Railroad spur investigation — EGLE made revisions to the Access Agreement and sent it to the railroad; unfortunately, the version the railroad returned still contained unacceptable clauses. EGLE will hold off on gaining access to the north, as recent research revealed a portion of the southern property (202 S. Watson) was purchased from the railroad in 1994, which is good news, because it's private property and the owner has given EGLE access. Weston is drafting a revised scope of work which reflects these changes, which Erik will share. Recent communication with Weston also included hiring a surveyor to identify property boundaries, which is scheduled for early December. EGLE will do sampling to the north of the private residence and to the south near Crawford Street. Sampling to the north will be performed every 10’ along the former railroad spur along with the sidecar, which appears to extend down toward the residence. As they go further south, EGLE will sample at 20’. Erik feels confident that sampling will cover the areas of concern. Samples include 2 borings at 5’ with surface soil samples. If any abnormalities appear they will do a third boring. Any evidence of contamination in the borings will provide rationale and evidence for court ordered access to northern portions.

1.    Discussion:

a)    Each of the soil cores will be screened with a PID, an instrument to gauge VOC vapors from the soil, along with visual inspection to identify staining, unusual colors, and other things that might be abnormal for soil in the area, such as odors which might be a sign of something amiss.

b)    Does the property owner know of possible contamination? Is he concerned?

(1)  He is worried about possible damage to his property and is aware of the challenges with the railroad. Erik is unsure whether he is concerned about contamination, but noted that the resident was worried about the course of action if contamination is discovered and what a cleanup might entail.

(2)  Jane noted that when DDT waste was dredged out of the river in the 1970s, residents used as fill dirt for their yards, and the railroad may have also used it.

VII. EPA Report [0:31:25]: Diane Russell, EPA Community Involvement Coordinator

A.    Updates on heating and NAPL collection in Area 2 Phase 2 — ISTT system is operating as expected, but the 90 day treatment window will extend beyond November 6 because we have not yet reached diminishing returns. That said, NAPL recovery is slowing. To date the system has pulled 128,000 pounds of contaminants out of the ground. The cost to run the treatment is about $800,000 per month.

1.    The two extraction wells that had different NAPL (MPE 71 and 72) are being pumped three times a week, with about 10 gallons removed each time (30 gallons/week). Again, as this NAPL starts to cool, it solidifies, presenting challenges with removal.

2.    The NAPL is about 80% DDT, as expected. The wells are very close to Manhole 1, near the groundwater collection trench, which staff check weekly and confirmed there is no NAPL present. They are also monitoring Well 48, too. EPA will provide another update in November.

B.    PSA 1&2 — EPA is in the contracting phase for the removal of 100,000 tons of contamination, with funding expected even in absence of the federal infrastructure bill. Construction is expected to begin in spring, likely with the Army Corps of Engineers doing oversight. With new requirements, Jacobs (contractor) cannot do oversight; rather, it must be another firm. EPA will present on the plans early next year.

C.   OU-3 - RI (Remedial Investigation report) expected in early November followed by FS (Feasibility Study report), in December. The public meeting presentation will take place early next year, followed by the Proposed Plan for public comment next spring or summer.

D.   OU-4 sampling work plan and carbon amendment pilot study — OU-4 RI and FS, floodplain sampling downstream in 5 locations along Pine River, with more floodplains added for sampling next spring. EPA shared the workplan for sampling with CAG chairperson and is on the website. Additional sampling for carbon amendment study will be completed next week, with report expected early next year.

E.    City well installation —Last well for city drinking water supply should go out for bid soon. The state is still reviewing the permit, with work expected to begin in spring 2022.

F.    Infrastructure bill update — This is a fund-led site, there isn’t a responsible party, so work is dependent upon general fund money for FPS and VBP. If the bill passes, the EPA Superfund Program will get additional funding, which will put the site in a better position moving forward. VBP may begin if proposed infrastructure funding includes Superfund money. There are major implications if the bill passes.

G.   Other

1.    Diane mentioned that there is a note of remembrance for Phil Ramsey, “a dear friend and fierce advocate,” in the EPA newsletter.

2.    Gary followed up on questions about a different NAPL at the site and asked for clarification about whether it was analyzed. Diane suspects that yes, it had 80% DDT, but will confirm.

a)    Gary also asked what else the NAPL contained (what is the other 20%)? He also asked if the Access Agreements for floodplain sampling were completed.

(1)  Diane will follow up on NAPL results and reported that EPA is sampling 5 floodplains now, so the note about Access Agreements in the minutes might be in reference to spring sampling in OU-4.

(2)  Jane clarified that OU-3 and OU-4 were separated so that work wouldn't be delayed in one area. OU-4 was separated out from OU-3 so work in latter could proceed, which is why sampling there is further advanced, and will allow remediation to begin there while the investigation in OU-4 is ongoing.

b)    Gary asked for updates on MW 48 pumping (“99’ well”), Erik clarified that the 48 well series is adjacent to MP 71 and 72. Gary confirmed that they’re near the intercepter trench (which was “temporary” but now permanent) and asked if the wells are deeper than the trench. Erik said they did pump MP 71 and aren't seeing any L/DNAPL. The CAG would like confirmation on the depths of the wells and interceptor trench.

c)    The CAG would like to follow-up on the request for the video footage Scott Pratt shared of the NAPL at the last meeting. Jane and Diane will address.

d)    Finally, Gary asked if the EPA is still showing air monitoring on the website? Because there seems to be a glitch with the page and data (missing information?). The temperatures are also goofy, there’s no consistency in readings at different depths, which raises concerns about whether the probes are working. The CAG would like reassurance that the site is being monitored well and consistent data is being gathered and shared.

(1)  Diane will look into why some wells have no heat data for different depths (the depths are 1, 6, 12, 18, and 22 feet). But it should be easy to use. She will report back to Scott and Tom. She also suggested a tutorial on using the site.

VIII.         Old Business [01:02:10]

A.    CAG website update – Ed Lorenz

1.    Ed tested the donation function and received a receipt, so the portal is working. He also got an email from Donor Box, the donation platform, thanking him also for the donation. He also gave a tour of the website, highlighting features, such as opportunities to donate and/or join the CAG on each page.

B.    TAG Grant finalization — Gary Smith

1.    See discussion under treasurer’s report. Gary also reinforced the challenges of navigating grants.gov and noting how helpful it was to be able to submit everything via email to Region 5, especially as an organization staffed by volunteers.

2.    The funds were available October 1st, the start of the new fiscal year. Both grants are in good shape, we should be set for 2 years with VBP and 3 years for FPS.

3.    Ed clarified that for the website, we need to determine how to handle donations and the annual platform fee. He encouraged the CAG to get a credit card. Gary opposed and Jane recommended discussion among the Executive Board.

C.   PBB Leadership Team update – Brittany Fremion

1.    The CAG has been involved with the Michigan PBB Registry Leadership Team since 2015, managed by Emory University team. The Emory team is working on a new grant proposal to help develop a continuing medical education course which will use PBB as a case study. While discussion of the course was the focus of the meeting, the team also discussed next of kin requests. A farm family member reported back that she received her father’s records with scans of official documents. MDHHS sent her the records on microfiche and a hard copy, but she needs to determine whether they contain the same information. It is also likely the only copy of the materials. There are also ongoing efforts to identify communities impacted by PBB but overlooked in the 1970s, such as migrant workers and people of color. Finally, Dr. Robert Hood, a postdoc working with the team, reported on his efforts to update some of the data in the registry, particularly elimination rates and half-life of PBB.

IX.  New Business [01:19:55]

A.    Nominations for CAG Hall of Fame – we vote next month

1.    We are still accepting nominations through next month. Jane has already received two nominations and hopes to get a few more.

B.    PFAS regulations – Scott Cornelius, Cornelius Environmental Consulting and CAG TA

1.    Scott reported on the Biden administration’s efforts to tackle the PFAS dilemma in the US. PFAS are forever chemicals because they don’t break down in the environment. Part of the plan is to classify PFAS and PFOAs as hazardous substances, which will make them eligible for Superfund funding, because there is currently a large debate about whether PFAS sites can be remediated. These chemicals are fluorinated compounds used in many products, such as fire fighting foams (why many sites include airports and military bases). Scott talked about Wurtsmith Air Force Base (Oscoda) and Wolverine (Rockford), which used a waterproofing agent that contained PFAS too. He explained that PFAS and PFOAs have been found in cosmetics and fast food packaging, non-stick cookware (Teflon), and dental floss. It’s a stain repellent too, found in products like Scotch Guard. This means there are many means of exposure and it’s not regulated. If industry is moving away from PFAS, it’s mostly voluntary, as the substance is not currently banned or restricted. Scott mentioned that the Rogue River has one of the highest concentrations of PFAS in foam and sediment in Michigan. How did we get here? Scott explained that industry hid PFAS agents by saying they were “trade secrets,” but they’ve causes a host of issues, such as those tied to DDT and PBB. During the Obama era the federal government issued a 70 ppm drinking water recommendation, which couldn’t be enforced; moreover, many argued 70 ppm is too high. Companies who most notably participated in production also include 3M, starting in the 1940s in Minnesota, and DuPont (Teflon production).

2.    How does this impact the Velsicol site?

a)    The compound was used widely so we should suspect that it is present here too. There should be testing to determine such. Scott suspects that most landfills will be required to test for PFAS (as recycling centers have been), that drinking water testing is underway, but also that with designation as a hazardous substance, Superfund sites will fall under testing requirements too.

b)    Next month Scott would like to talk about how climate change will impact Superfund sites. In the next 20 years, scientists predict that Superfund sites by rivers are going to be in trouble, so planning for future is important so we can avoid those problems.

c)    Ed asked that as new information like this becomes available to please share it with him so we can post it to the website. The PFAS Report, for instance, is there.

C.   The CAG will nominate officers and board members in November and vote at the December meeting. Send your nominations to CAG Secretary Brittany Fremion, fremi1b@cmich.edu and/or CAG Chairperson, Jane Keon.

D.   Scott thanked Gary for his time and work on the grant and accounting. George Kubin also thanked the CAG for its work.

Please remember to pay membership dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.

The next meeting will be held on Wednesday, November 17, 2021 via Zoom.

 Meeting adjourned at 8:36 pm.

 Respectfully submitted,

 Brittany Fremion, Secretary

Monthly Meeting Minutes - Nov. 17, 2021

PINE RIVER SUPERFUND CITIZEN TASK FORCE

General Membership Meeting Minutes

November 17, 2021

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording: https://us02web.zoom.us/rec/share/wKTw5EYk7A-28B2hG8Bi_o7D-RFth52v3GDkuLM4k9mfgCumIwLBwbHJTebY25eE.4uFme-7dvdyi0KCu?startTime=1637193639000

The meeting began at 6:47 pm via Zoom with Secretary Brittany Fremion as host, with 18 participants.

Chairperson Jane Keon called the meeting to order at 7:00 pm.

I.      Additions to Agenda: Correspondence and Communication

II.    Approval of October minutes. (Tom Corbett and Doug Brecht)

III.   Treasurer’s Report [00:01:20]: Gary Smith, Treasurer

A.    October 2021

1.    Gary continued his work to move the CAG account from Huntington Bank to Gratiot Community Credit Union to avoid ongoing challenges with account management and fees, and to bring our work back to a local institution. This has caused some issues with the website donation portal. Gary will keep both the old and new accounts open to make sure everything is settled before closing the Huntington Bank account.

2.    This report is from the Huntington account. The General Fund Checking balance stands at $5,936.88 or $5,936.90 (ledger vs. bank report). The Money Market Account (Oxford Automotive settlement) has $63,780.70. TAG grant money available for the Former Plant Site (FPS) stands at $21,291.06 (the EPA awarded the CAG an additional $50,000 in TAG funding, which will be distributed in small increments). The Velsicol Burn Pit (VBS) has $48,698.38. Velsicol Burn Pit (VBP) Fund Checking has $131.52. The complete reports will be attached to the permanent minutes.

3.    Memberships are $5/year and t-shirts (blue and grey) $12-15 each plus shipping. Send check to PO Box 172, St. Louis, MI 48880.

IV.  Correspondence and Communication [00:17:10]: Jane Keon, Chair

A.    Received Revised Scope of Work for Railroad sampling from EGLE. Erik will talk about more in his report (see below).

B.    Jane shared an article about the new EPA Region 5 Administrator, Deborah Shore.

C.   The CAG received a hyperlink to an NIEHS article about Dr. Michele Marcus and the PBB research at Emory University.

D.   Presentations to CMU Environmental Justice classes by Ed Lorenz and Jane Keon on Velsicol last month. Jane’s focused on the history of Velsicol and the cleanup happening now; Ed discussed the mistakes that Velsicol made and what we can learn from them. Ed is doing a follow-up Zoom meeting with some of the students tomorrow.

E.    The CAG received a response to a letter we sent to the EPA administrator in Washington, DC about adding the railroad property to the Velsicol site. The response indicated it wouldn't happen, coming from Region 5 rather than the administrator we reached out to. The CAG’s argument was that the truck traffic that traveled through the ANP carried contaminants, so we suspect that the railroad traffic likely did the same and should therefore be treated the same way. EPA said if contamination is found, the property owners are responsible for cleaning it up, which means some of it will fall to the dissolved trust, the railroad, and private property owner. Jane emphasized that are an environmental justice community and our residents don't have the capacity to clean up Velsicol’s mistakes. (This is discussed further during the EPA report, below.)

V.    Program [00:21:40]: Brittany Fremion talked about how social justice enters into the PBB Oral History Project, and how collecting accounts from those affected by the PBB Disaster is a form of commemoration of the otherwise invisible event.

A.    Brittany is an associate professor of history at CMU and project director for the Michigan PBB Oral History Project, inspired by community and academic partners at Emory University that maintain the Michigan PBB Registry. We also worked with researchers at the University of Michigan.

B.    Through work with oral history project Brittany became involved with the CAG and is now secretary. At a meeting a few years ago, Ed Lorenz brought up a prior discussion with EPA to establish a community center on the Pine River that would interpret the history of the watershed, document efforts to address contamination, as well as provide St. Louis residents and those of surrounding areas with a place to learn and connect, in addition to access resources tied to the Superfund site(s).

C.   Brittany collaborated with Clarke Historical Library Archivist, Marian Matyn, on an article focused on commemorating contamination, as grown from efforts to document community memories and efforts to address the PBB mix-up. They argue that documenting personal memories in a variety of formats and creating opportunities for community members to share their experiences should be considered forms of commemoration that go beyond the static state in which monuments and memorials tend to exist. As a result, PBB commemoration in Michigan serves several purposes:

a)    First, it ensures that our collective past is both known and transparent.

b)    Second, commemoration serves as a catalyst for action.

c)    In addition, sharing and acknowledging the value of individual memories and lived experiences of those affected can validate their experiences.

d)    Finally, commemoration can also be part of community healing, reinforcing community resilience.

2.    Discussion: [00:35:25]

a)    CAG members shared their observations on why people forget about the PBB accident, as well as proposed additional sites for possible commemoration (i.e. Kalkaska and Mio burial sites). Others expressed concern about the community maintaining the label of “toxic town,” that there is both a desire and need to move beyond it. Tom Alcamo reminded the CAG that there is a possibility to do some sort of exhibit to tell the history of the cleanup, via story board, that can be revisited once the cleanup is done. Brittany and Ed pointed out that a nature center that highlights the significance of community activism and work to clean up the watershed would provide an opportunity to teach others about the important lessons we’ve learned. Ed offered, “We have a story to tell and we really should tell it.”

VI.  EGLE Report [00:45:15]: Erik Martinson, Project Manager

A.    Railroad spur investigation — Weston completed revised scope of work earlier this month and it details two separate tasks, one being surveying of property (202 S. Watson) and the vacated extension to the north (to determine the exact location of railroad property). The second task is the soil sampling itself, which hasn’t changed much (there will be a smaller spacing size to the north). December 3rd is the property survey (about 4 hours); EGLE will sample December 12-14th. Samples will be tested by ELGE and overflow lab (Eurofins) for PCBSA, Tris, and 2,4D and 2,4DDE. Results might take four weeks due to the holidays, which puts us at early January.

B.    Discussion

1.    Gary asked for clarification about visual screening versus lab testing. Erik explained that the visual screening includes smells and discoloration. Scott added that white materials are usually a red flag for those drawing samples, which can help further direct sampling and lab testing.

2.    Gary also asked about who is responsible for the cleanup and whether there is a way to hold the railroad accountable. EPA will get involved if there is an unacceptable risk and Tom reassured the CAG that the railroad would be the viable responsible party, not residents. But the sampling has to demonstrate an imminent threat. If EGLE finds contamination, then EPA will work with the state agency so residents won’t have to pay for the clean up. The trust is no longer a liable party, so EPA would have to fund remedies, along with the railroad. Historically, railroads are challenging to work with and very uncooperative, so the current obstacles aren’t new. This is reassuring to the CAG.

3.    Finally, Jim Hall pointed out that the low-income housing wasn’t sampled either, but if contamination is found on railroad sites, would EPA pursue sampling there, too? Tom said the agency can’t commit to it yet, but if there is some contamination found, EPA would have to reevaluate the situation.

VII. EPA Report [0:59:10]: Tom Alcamo, Project Manager

A.    Velsicol Burn Pit - The infrastructure bill was signed this week and Tom has some details: EPA Remedial Program nationwide is getting 3.5 billion dollars, initially earmarked for all the sites (50-60) with designs complete but no funding, such as VBP. EPA is also hiring as many as 250 project managers nationwide, but also losing many to retirement (search USAjobs.gov). The Superfund tax has also been reinstated. Tom feels confident that funding and cleanup at the site can begin next year, with a new remedial project manager. The new contracting mechanism is too arduous and demanding for Tom to do both sites. There are three remedy components for the VBP: site prep - removal of ash piles; thermal treatment; and hookup of homes to city drinking water supply.

1.    In addition, Tom is also looking at new methods to accelerate the clean up, which would make it easier to get started. He cannot comment on them yet publicly. Also EPA has be tasked to plan for unlimited funding scenario. This would grow and make pipeline money more flexible, also expediting work. Fiscal responsibility is essential, especially with the expectation of scrutiny that will accompany the funding, so expect new systems to be put in place to ensure proper management of funds.

B.    Updates on heating and NAPL collection in Area 2 Phase 2 — Heating continues. EPA has recovered around 135,000 pounds and thought we might be near diminishing returns, but the team recently recovered an additional 5,000 pounds. More money ($1.2 million) has been built into the project to cover the cost of heating through January 15th. Recovery has slowed, but we are not at diminishing returns yet.

1.    Two extraction wells with gooey NAPL: one is empty and the other is still removing some NAPL (5-10 gallons a day). Getting trucks, incinerator slots, and the cost of shipping has been a big challenge. The system is running good though, and EPA will keep the CAG updated.

C.   Carbon Amendment Study - EPA finished sampling in late October for the second phase. Did some mammal and insect studies, as well as additional sampling as part of it. EPA expects results in February or March. Not sure about next steps—might be nothing, might be a third phase.

D.   OU-3 ROD - Hoped to have RI out last week, but will probably be end of November now. We'll have to figure out how to get the documents downloaded and accessible in a reasonable way, perhaps in separate files or print a few hard copies. FS expected in mid-December or early January at the latest. Includes three floodplains, expected in March or April. Should be able to sit down with RI next year to discuss.

E.    OU-4 sampling work plan — EPA sampled four of five floodplains, with one owner asking for delay in sampling until after deer season for one (December). Five additional floodplains will be sampled in the spring and includes an island farther downstream in the Pine River. Data expected in February or March. The sampling went well; EPA had an Alma student help with sampling and would be happy to bring on a CMU.

F.    There are a variety of work plans will come out in the next several months, too: MW19, upgradient slurry wall, perimeter drain, bathymetric survey, etc. There may be multiple RAs going on at the site simultaneously, so still working through the details.

G.   PSA 1 & 2 — EPA has a meeting this Friday with construction firms for PSA 1&2 excavation of about 100,000 tons of soil (site of oil spill, oil refinery, and “Phil’s hill”). This will be a difficult excavation because they will also capture groundwater, which will have to be treated off-site. There are 10 firms who will participate in presentation, with bid package ready in January. This is the first big project put through EPA’s new contracting method, with hope to be done in April or May. The community will see Army Corps of Engineers (ACE) doing construction oversight, so Tom has been in communication with ACE to be eyes and ears for EPA on site. The infrastructure of EPA is growing and getting more complicated, so expect much more involvement with upper-admin for the project. There will likely a learning curve to adjust to new model.

1.    Jim Hall asked if there be a strong odor with the excavation due to presence of petroleum? Tom explained that there will be VOCs, so monitoring will have to happen, but no presence of DBCP which is good news. Odors are common with gas and chemical plants, and it really stinks. Jim recommended that the city might alert residents to what is happening and that there might be an odor. EPA will coordinate with residents, too, as they plan to drive some sheet pile near properties anyways, which will require contact and consideration of how it might influence residential foundations.

a)    Jane also reminded the group of the Horse Creek work (Total Refinery remediation project) and the staging area along Michigan Avenue, which smelled really bad. EPA is hopeful we can avoid that, with Scott Pratt explaining that they’ll do statistical confirmation sampling and constantly fill the hole that’s excavated via backfilling to help with odors, which will be expensive, but worth it. Trucks will be “hot loaded” and go directly to the landfill rather than a stockpile area, so the soil doesn’t sit elsewhere. Hopefully trucks will be available next summer, too, which will help resolve some of the supply chain issues.

H.   Other

1.    The Velsicol Site 5 year review is due next year.

2.    By request, Tom will do a PSA 1 & 2 presentation for the CAG next month.

3.    The cleanup of the VBP will occur in two phases, also called operable unit one (VBP OU-1, which addresses surface contamination) and operable unit two (VBP OU-2, which deals with groundwater). EPA will work with the city to hook up residents to the city’s drinking water in preparation for the thermal treatment in VBP OU-1 to address surface contamination, which will speed up work on the VBP site, as it could be funded through cooperative agreement.

4.    Well 12 permitting still hasn’t been approved by state, but should go out next spring for contractors, with expected completion next fall and testing to confirm that drinking water from personal wells won't be affected. EPA has money if residents need a well (i.e. dries up, no pressure, etc).

5.    One of the big challenges with RI (which will include all of OU-3 and part of OU-4) is the way the floodplains are labeled, which is a disaster (because new floodplains have been identified, some by the state and some by EPA, adding to the complexity of labeling). So there will be a separate RI for OU-4, wherein EPA will rename the floodplains to make easier to identify and discuss them.

6.    The hazardous waste from most of the projects goes to Clean Harbors, an incineration facility in El Dorado, Arkansas.

7.    Finally, if residents get sick, such as headaches from odors caused by excavation in PSA 1 & 2, EPA can find alternative housing (i.e home rental or long-term hotel, for a month or so). EPA has done this before and air emissions are nasty, so people have been temporarily relocated.

VIII.         Old Business [01:33:25]

A.    PBB Leadership Team update – Ed Lorenz, Jane Keon

1.    Conference call/Zoom meeting: There are still problems with MDHHS and their contractor, MDPHI, to get data to researchers to do the studies needed. Michele Marcus, lead scientist, had a call with Corey Grech at MDHHS and he understood the urgency and frustration, and has personally committed to resolving issues with agency and lawyers. In addition, MDHHS decided to audit all consent forms and they couldn’t find forms for 680 people who consented to have their records sent from the state to Emory between 2009 and 2010. This isn't the first time, although it is very worrisome. Corey asked Emory if the forms had been sent back and they were, fortunately. But there are 66 forms that the state flagged. The team continues to work to address these issues and is hopeful to improve the relationship with the state agency.

B.    Vote on CAG Hall of Fame

1.    Two people were nominated and both are very deserving of the award. Jane moved that we admit both and then next year go back to admitting one per year. Carried unanimously.

a)    Ed Lorenz/Wayne Brooks moved that James “Jim” Hall and Gary Smith both be received into the CAG Hall of Fame for 2022. Carried unanimously.

C.   Nominations from the floor for officers and board members to be voted on prior to/at the December meeting.

D.   Reinstatement of Superfund Tax - Ed Lorenz

1.    The bipartisan Infrastructure Act was signed and the Superfund Tax reinstated after being abolished in 1995. There is a good bit of funding coming into EPA as a result.

a)    Ed and Gary talked about “Gary’s pizza delivery” in 2005, wherein Gary delivered a pizza to our member of congress at the time, symbolizing the cost of Superfund Tax. He also delivered manuals prepared by Lois Gibbs with the formula that for a $10 cheese pizza, for every $100,000 of revenue, you could fund the Superfund Program. So this is something the CAG has discussed for a long time.

E.    Website traffic data - Ed Lorenz

1.    There is currently a challenge of contributions button, tied to banking issues, but we will sort it out soon. People tend to make donations over and above donations at end of the year, so it’s important to sort out soon.

2.    We’re monitoring the traffic on the website: 72 people accessed it in October and 66 this month so far. The growth makes sense with recent presentations at CMU, which is exciting. About half of the hits are from Michigan and the rest from other parts of the US (i.e. Illinois, which is home to Region 5 office). While this is modest, it is promising.

IX.  New Business [01:19:55]

A.    Postponed: Climate change and Superfund sites – Scott Cornelius, Cornelius Environmental Consulting and CAG TA

B.    Gary Smith/Doug Brecht moved that the CAG authorize the secretary and vice chair to sign checks. Carried unanimously.

Please remember to pay membership dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.

 The next meeting will be held on Wednesday, December 15, 2021 via Zoom.

 Meeting adjourned at 8:50 pm.

 Respectfully submitted,

 Brittany Fremion, Secretary

Minutes Dec. 15, 2021 Monthly Meeting

PINE RIVER SUPERFUND CITIZEN TASK FORCE

General Membership Meeting Minutes

December 15, 2021

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording: https://us02web.zoom.us/rec/share/EZamhjcVvtp90i-nQSv-vosRZ_MMwO3ugm4SntXPNlHg58t31vTCOE1yxxD7MXK1.blIr6rTdRMbSwE1R

Access Passcode: 5Pw%yk=M

The meeting began at 7:02 pm via Zoom with Secretary Brittany Fremion as host, with 21-23 participants.

Chairperson Jane Keon called the meeting to order at 7:00 pm.

I.      Additions to Agenda: Correspondence and Communication;

II.    Approval of November minutes. (Doug Brecht and Ed Lorenz)

III.   Treasurer’s Report [00:00:00]: Gary Smith, Treasurer

A.    November 2021

1.    As of December 14, 2021, Huntington Bank account is closed. Our new bank is the Gratiot Community Credit Union.

2.    The General Fund Checking balance stands at $5,936.88. The Gratiot County Credit Union General Fund Checking and has a balance of $1,982.25 and the Share Draft Savings Account total stands at $5.00. The Money Market Account (Oxford Automotive settlement) has $61,778.45. TAG grant money available for the Former Plant Site (FPS) stands at $21,291.06. The Velsicol Burn Pit (VBS) has $48,698.38. Velsicol Burn Pit (VBP) Fund Checking has $131.52. The complete reports will be attached to the permanent minutes.

3.    Memberships are $5/year and t-shirts (blue and grey) $12-15 each plus shipping ($5.80). Send check to PO Box 172, St. Louis, MI 48880.

a)    T-shirts vary in price by size, the but the Board will discuss a flat rate that includes the cost of shipping, especially if we add them to our website. Ed was able to connect the new bank account to the website for donations and memberships. Ed and Gary will provide an update next month.

IV.  Correspondence and Communication [00:06:10]: Jane Keon, Chair

A.    Phone call to state legislature regarding bird study funding – Jim Hall

1.    Jim was able to connect with state legislators about funding for a follow-up bird study and they indicated that it shouldn't be a problem.

B.    Phone call from the Detroit News regarding our attempts to get a follow-up bird study. We are waiting to find out if there will be an article; the journalist had many questions for Jane.

C.   Jane shared that she read the chapter on the Superfund sites in St. Louis in the new book by Dr. Tom Corbett and that it is very well done. Dr. Corbett thanked Jane for reading it and providing feedback. He continues to work on the book, which is almost complete.

D.   Mayor Jim Kelly emailed Jane following communication with the Congressional Intergovernmental Liaison for EPA’s Region 5 Office. The Liaison connected with him for a quote about recent announcements about funding for the VBP Site for a press release. The City is excited that the funding may be available to start the cleanup and to be featured in the Region’s reporting.

E.    The Gratiot County Herald covered Hall of Fame inductee announcements.

V.    CAG Hall of Fame Awards: [00:09:42] Recognition for the long service of two founding CAG members: Gary Smith and Jim Hall.

A.    Remarks:

1.    Gary Smith (S-M-I-T-H): Ed Lorenz, Vice Chairperson, shared remarks about Gary, noting that “it’s hard to imagine the CAG without Gary.” He has been involved in many ways and his service as treasurer has been really important; but so too is his service to the country during the Vietnam War, his work in the community, such as with the fishing derby. Ed also commended Gary as “a model of up-cycling,” work that has prepared him for his “biggest up-cycling experience, which includes plans for how to use the FPS property once the clean up is complete.” In addition, Ed shared that Gary has been “a major fundraiser for the CAG, too, playing a bankruptcy expert with Jane, and they alone convinced a judge to gives us more than $100,000 in the Oxford settlement.” When it came to documenting communication, Gary insisted that EPA record everything in full, not just summaries of citizen comments, as well as noting those individuals who were present and participated in meetings. He was integral to the bird study, “comes up with good ideas and has often done the hard work, too, such as delivering a pizza.” Gary has 23 years of service to the CAG and community and, while modest about his contributions, that's what a good leader does, is share the credit. And Gary is a good leader.

2.    Jim Hall: JoAnne Scalf, Jim’s sister and CAG member, shared remarks about him, roasting him at the start by saying “the only reason Jim joined the CAG is because someone told him that there’s a free buffet at every meeting,” demonstrating that wit and humor run deep in the Hall family. JoAnne noted that Jim’s contributions are unsung, yet he always answers the call, from serving as a youth coach and helping lead the fishing derby to his participation in PBB Registry studies and engagement at community meetings. In addition, she noted that “The different hats he has worn in the CAG are impressive” and have been many. His best talents include his “adaptability, his artful persuasion and composure, and how he sculpts solutions through collaboration; his laser focus, task-based and team-work, and perfectly timed and lighthearted humor.” He and Gary have put 23 years of work into the CAG, putting pressure on lawmakers, the EPA, the health department and other agencies. His solution-based work scope has helped with cleanups, as well. JoAnne closed by saying, “Thanks to Jim, the Hall legacy in St. Louis is six generations strong,” noting that the cleanup and progress seen so far wouldn’t have been possible without him, and that his work to create a safe living and working environment for future generations is “an inspiration to us all.”

VI.  PROGRAM: [00:25:35] Technical Advisor Scott Cornelius presented on how climate change might impact Superfund sites. The presentation slides will be appended to the permanent minutes.

A.    Scott shared a paper that he found a few months ago on climate change, which was part of the presentations at the reinstatement of the Superfund Tax meetings that he and Ed attended. The lead scientist who wrote the paper identified major risks associated with climate change, which holds important implications for the CAG. Scott’s recommendations for CAG based upon this information include:

1.    The CAGs questions tied to concerns about climate change include:

a)    What effects will climate change have on the remedies at the FPS and VBP Superfund sites?

b)    What impacts will climate change have on the RD parameters for the FPS and VBP Superfund sites’ remedies?

c)    Most importantly, when will the analysis of the effects of climate change on the proposed remedies for these sites be completed?

2.    The designs of sites going forward should take into consideration inevitable changes in water elevations, especially the VBP and FPS, which are on the Pine River. With this in mind, Scott recommends:

a)    Both the FPS and VBP Sites’ RDs must take into consideration the future changes in the Pine River’s elevation due to climate change and

b)    The CAG should request an analysis of this issue be prepared before the FS ad remedy selection, and presented at a public meeting.

3.    Scott’s rational includes the following:

a)    Climate change is a game changer and all remediation needs to take that into consideration in the design phase;

b)    The effects of climate change on surface water levels has far reaching consequences for all river, floodplain, and sediment cleanups;

c)    The areas once only submerged occasionally by flooding, such as floodplains, must be treated like submerged bottomlands because in 20 years or less they may be submerged;

(1)  For example, spreading activated carbon on a floodplain (even if a viable remediation technology) that will be submerged in 20 years or less is not a scientifically sound remediation strategy and a waste of funds.

(2)  As such, the goal should be to get the remediation right the second time and eliminate the need for a third remediating because of another failed remedy.

B.    Discussion:

1.    Concerns were shared about the integrity of the perimeter wall with expected flooding tied to climate change, as well as implications for the carbon amendment study. In addition, Scott explained how and why flooding would be a major issue in mid-Michigan.

VII. EGLE Report [00:47:35]: Erik Martinson, Project Manager

A.    Railroad spur investigation — Erik reported that the property survey was conducted at 202 S. Watson on November 29th, in addition to a survey of the vacated right-of-way at Watson and Tyrell. Everything went smoothly and lined up with previous surveys. The only issue the team encountered was on the north side of the private property, where the vacated right-of-way from Tyrell is 30 feet, and so when vacated, the southern 15 feet was given to the private property owner and the other 15 feet to the north given to the Railroad. As a result, the proposed boring figure included in the scope of work shows borings further north than the team was able to sample (proposed to do 20 to the north, but they were only able fit in 12). Weston finished sampling at 5:00 pm today (done in two days). They completed a total of 37 locations down to 10 feet below ground surface. Visual evidence was consistent with previous drilling efforts (lots of clay down to 10 feet). They did not hit any till, which was expected given the height above the River’s surface. Weston delivered samples to state lab this evening and EGLE’s overflow lab, Eurofins, will pick up the remaining samples in the morning. So that’s real progress, finally.

1.    There were a few last minute changes to the scope of work, related to borings (proposed 50 and completed 37), again, mainly because of the survey and property ownership to the north.

2.    Also, there was a an issue with the lab in California slated to do the soil analysis for PCBSA. The lab is relocating and so Erik delayed sampling. If there are elevated levels of DDT or DDX in any of the other samples, then EGLE will go back and add it to the analysis.

3.    The other issue was with the EGLE lab, which didn’t think it would be able to take any samples, which was surprising, but Erik and Weston negotiated to deliver a few more samples to Eurofins, which will analyze for VOCs, Tris, 2,4 DDD and 2,4 DDE, and EGLE will do the remaining pesticide samples (28 compounds, including HBB, PBB, and DDT isomers). The sampling meets expectations, with the exception of PCBSA.

4.    Finally, Erik expects to have the lab results in the next month and may be able to share some of the information at the January meeting. The official reporting and presentation will come later, though.

B.    Discussion

1.    Erik didn’t observe any visual indications that the soil samples that looked off, but that doesn’t mean much in his experience. Much of the soil is clay so the compounds can get bound up tightly. Also, the DDT wouldn’t give off much for the VOC reader, which the weather can influence, too. There weren’t any obvious odors, either. Something to note, however, was that during the first boring push on the north side of the private property, they hit refusal at 1/5 foot below the surface and it was a railroad spike—so they are in the correct location.

2.    Erik also reported that he hasn’t had any communication with the Railroad since the end of September; he cut off communication when he discovered they could do the sampling without needing access to their property. He’s hopeful that if contamination is observed with the current sampling and analysis, it will provide sufficient evidence to compel their cooperation via court ordered access.

3.    Jim asked if EGLE/Weston had the railroad spike, which might be nice to have as an artifact for a future exhibit at the FPS. Erik said he would check.

4.    Finally, Erik will have an update on the dissolution of the trust property cooperative agreement in January.

VIII.         EPA Report [0:59:47]: EPA not present but Jane shared a recap of the thorough written report Tom Alcamo, Project Manager, shared (appended to permanent minutes).

A.    Heaters still running full blast in Area 2 Phase 2, scheduled to operate until January 7th, with additional funding added to the budget if diminishing returns not yet met by then. Two of the extraction wells were modified because of NAPL composition, and pumped by hand, and the team is still removing 10-15 gallons per day at those two wells.

B.    RI and FS for downstream expected to be released soon, with hyperlink to digital version because of the document’s size; EPA will provide CAG with hard copies for organizational records.

C.   The contract for PSA 1&2, where Midwest Refinery was located and site of soil excavation, is expected to be warded in spring 2022.

D.   VBP scheduled to receive infrastructure funding, which is very exciting. We will get a new Project Manager for that site. Tom will introduce that person to the CAG; it is someone with RPM experience elsewhere, given nature of Velsicol sites.

E.    Discussion

1.    There are many early 2022 deadlines, so it looks like the new year is going to be very busy. The CAG will need to coordinate with the TA soon to make decisions and plans. But we are eager and excited for the work.

IX.   Technical Advisor Report: [01:05:51] Scott Cornelius, CEC

A.    Review of Final Uniform Federal Policy Quality Assurance Project Plan (QAPP) for OU-4; this is one of two documents the CAG asked Scott to review (the next will be the Carbon Amendment Planning, Phase 2 Work Plan, which he will present in January).

1.    In April 2021, CH2M/Jacobs provided a 512 page umbrella operational document to EPA for the Velsicol Chemical Corporation Superfund site OU-3 and OU-4, outlining Remedial Investigation (RI) activities from April 2021 to October 2022. The purpose of the QAPP is to further define the chemical contamination and asses the use of carbon as a remedial technology by providing guidance for the RI activities.

a)    OU-3 includes the Pine River, adjacent riverbanks, and floodplains downstream of the St. Louis hydroelectric dam to the upstream side of floodplain 1.2

b)    OU-4 includes the Pine River from the upstream side of floodplain 1.2 to the confluence of the Pine, Chippewa, and Tittabawassee Rivers near Midland, Michigan.

2.    Problem Statement 1: Site-related COCs (Total DDT, HBB, and PBB) have been released into the Pine River and deposited in riverbank and floodplain areas during flood events. The extent of riverbank and floodplains oil contamination is not adequately defined.

a)    Goal of Study 1: Determine the nature and extent of floodplain contamination sufficient to complete baseline risk assessments, assess the need for remediation, and develop potential remedial options. (These are great and on target, according to Scott.)

3.    Problem Statement 2: Arthropods and worms in the floodplains that are consumed by wildlife have the potential to bioaccumulate chemical contaminants.

a)    Goal 2: The data in this carbon amendment portion of the study will be used to assess whether activated carbon can reduce the bioavailability to worms and anthropoids (this is good, Scott said), and subsequently reduce bioaccumulation in higher trophic-level organisms, such as mammals and birds.

(1)  Scott pointed out that the highlighted portion isn’t adequately covered in prior work plans or the document. If the experimental design is adequate, they can do the first part, but not necessarily the second.

4.    Problem Statement 3: Collection of worms or other anthropoids for the carbon amendment study is labor intensive and and results in termination of the collected species.

a)    Goal 3: Determine if the use of SPME sample preparation (a surrogate stick that acts like worm fat) can be used to predict the bioavailability of DDT, PBB, and HBB in soil as an alternative to collecting works and arthropods.

5.    The RI sampling design and rationale for activities in both OU-3 and OU-4 further refined the extent of DDT, HBB, and PBB, and other Velsicol Chemical related contaminants in sediments, floodplain soils, and biota. In OU-4, activities included (a) assessing the effects of activated carbon on bioavailability of these contaminants in lower-level trophic organisms and (b) assessing SPME. 

6.    The QAPP includes a lot of significant details, setting standards that EPA has to meet and providing the community with an important tool and resource. This is a “building block” document and, overall, very good in terms of detail and coverage. There are a few concerns about “leaps and assumptions made,” but they also point to the importance of TA review and community engagement with the document.

7.    Discussion [01:21:45]

a)    Concerns about Goal 2 (highlighted above) were explored further. Scott explained that the extent to which EPA/contractors can reduce bioaccumulation in higher level organisms is problematic. There are also some issues with the extent to which activated carbon penetrates the soil to reduce bioaccumulation in higher-level mammals.

(1)  Would they have to also test and sample higher-level mammals (birds, etc)? Scott said yes and explained why, expanding upon why the claim to reduce bioaccumulation in mammals and birds is a much larger study.

b)    What is the mechanism in carbon that is supposed to reduce bioavailability? Activated carbon is used in water treatment systems, wherein carbon acts as material with holes and binding sites that attract contaminants, which works well when water moves the carbon and contaminants around, allowing them to bind. DDT that is microns away from the carbon won’t migrate to bind to it, especially when stuck in soil.

(1)  Some data in lab conditions produced some results that suggested it could work. So there is limited success, but there are other issues, such as worms appear to avoid the carbon, moving away from it rather than engaging with. It can also have detrimental effects on the worms. So this is more of a pilot that will help us understand how/if this is an effective remedy.

(2)  Jane shared that Dow Chemical did some experimental work with carbon, which is the source of inspiration here, although Dow gave up on the experiment. Scott confirmed that Dow evaluated it and decided not to proceed. Gary added that the collaboration between EPA and Alma College is really great, but that the use of SPME rather than worms in this case should also be noted. Scott provided additional insight into SPME sampling, explaining that it’s not an apples to apples comparison. However, there remains a commitment to the study. Gary offered that the state might be really interested in the outcome of the study, especially if there aren't any major long-term, positive results—especially those pertaining to bioaccumulation.

(3)  The CAG can/will revisit this next month during Scotts presentation on the second phase of the carbon amendment study.  

X.    Old Business [01:35:40]

A.    PBB Leadership Team update – Brittany Fremion, Jane Keon, and Norm Keon

1.    Clinical Trial Update: The Emory team has almost hit their benchmark of 100 participants, making the study successful in terms of recruitment, especially in the midst of a pandemic and other unexpected challenges.

2.    Dr. Marcus, lead scientist for the Registry, was also scheduled to meet with MDHHS reps again this week about ongoing issues with the agency and MDPHI, and will keep us updated. She shared that reporting back to her team and community members, who have known to contact legislators and write letters, has been a good negotiating tool with the agency.

3.    The next community meeting will be virtual and is being planned for early March. The last virtual meetings were really successful. This spring the meetings will be less about recruiting participants and more about reporting back to community members and getting input for future research to address community concerns and needs. If anyone in the CAG or community has thoughts about priorities for future research, please share them with Jane, Ed, Norm, and/or Brittany.

4.    The Team continues to collaborate with partners at the CMDHD and recently discussed the possibility of adding questions about concerns tied to environmental chemicals to the 3-year community health assessment conducted by MidMichigan Health, as well as the new texting platform the district is using to connect with the district’s community members as a means of connecting the Registry team with PBB community members.

5.    Finally, work on the PBB Registry Patient Portal is ongoing.

6.    Jane added that the meetings are really interesting and informative, and that she learns a lot from talking with them.

B.    Vote Results for CAG Officers and Board Members [01:39:20]

1.    Office of Chairperson: Jane Keon (incumbent)

2.    Office of Vice Chairperson: Ed Lorenz (incumbent)

3.    Office of Secretary: Brittany Fremion (incumbent)

4.    Office of Treasurer: Gary Smith (incumbent)

5.    Board of Directors:

a)    Jim Hall (incumbent)

b)    Margaret Hoyt (incumbent)

c)    Norm Keon (incumbent)

(1)  The Executive Committee (consisting of all elected officials) will determine whether to add another two people to the Board of Directors.

C.   Latest results on the thermal treatment website [01:40:50] — Gary Smith

1.    Gary reported ongoing concerns and issues with the data shared via the EPA monitoring website. There are people in the community who want/need to have this information, and deserve the reassurance that the site is both operating correctly and updated regularly.

2.    Discussion: Jane recommended calling Region 5 and asking someone to update the data on the website and present at the January meeting.

D.   Website traffic data [01:50:40] - Ed Lorenz

1.    Traffic is up 3% this month compared to last month: 71 different visitors who looked at 106 pages, with the most views at the college and university partners, where we work, meeting minutes, and “lessons” pages. Less than half are from Michigan, but there were a lot from Ohio (Columbus, specifically). Gary shared that there is a teacher in Ohio who has assigned Jane’s book, which might be a source of the Ohio visitors.

2.    Ed will connect with Gary to see about adding t-shirts to website, he just needs a photo and price ($20 would include shipping and a small profit for the CAG).

XI.  New Business [01:56:15]

A.    JoAnne will be opening her Voluntary Health Map survey in February for another round of mapping. She will share announcements and information with the CAG in the weeks ahead. Ed will post it to the website and we’ll look forward to a future presentation with updates on her work.

B.    In addition, JoAnne and Jane engaged in a conversation with community members in a St. Louis Facebook group about the PBB Registry. The former chemical worker was understandably frustrated with the Registry work but with insights shared, came around and it ended up being a productive discussion with many community members.

 Please remember to pay membership dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.

 The next meeting will be held on Wednesday, January 19, 2022 via Zoom.

 Meeting adjourned at 9:05 pm.

 Respectfully submitted,

 Brittany Fremion, Secretary

General Membership Meeting Minutes – April 21, 2021

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording: https://us02web.zoom.us/rec/share/Rebga0vjTUSj7NIlEyVLnAgqRrJe-ze4YKZaPzrASIIZ89azF066i60p217SKiPU.2ojm_cX4DDTctBXm

Access Passcode: @2V&A6E8

The meeting began at 6:45 pm via Zoom with Secretary Brittany Fremion as host, with 30-32 participants.

Chairperson Jane Keon called the meeting to order at 7:00 pm.

1. Additions

   1. Item added under correspondence and communication (included below).

   1. CAG Treasurer, Gary Smith, asked about EPA’s rejection for use of TAG funding for Technical Advisor (TA) to assist with investigation at the railroad spur site. EPA Project Manager, Tom Alcamo, said the spur is not officially part of the Velsicol Superfund Site and that the TAG team can send an official letter to clarify. The CAG maintains its stance that there is a need to pursue investigation with guidance from TA. EPA said that the area was sampled in RI and deemed not part of the cleanup, which is the core issue. The CAG TA, Scott Cornelius, shared that when he previously worked for state (DEQ Project Manager) on the creamery site the spur was identified as a possible site of contamination and that the boundaries for treatment can change if contamination is detected, which is what happened with the Velsicol Site and adjacent neighboring properties (ANP) and Breckinridge site.

2. Approval of March minutes. [00:07:15] (Liz Braddock/Wayne Brooks)

3. Treasurer’s Report [00:07:55]: Gary Smith, Treasurer

   1. March 2021

      1. The General Fund Checking balance stands at $4,986.40. The Money Market Account (Oxford Automotive settlement) has $65,075.16. TAG grant money available for the Former Plant Site (FPS) stands at $9,339.26. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $85.62. The complete reports will be attached to the permanent minutes.

      1. Reminder about memberships ($5/year) and tee shirts available ($12). Send check to PO Box 172, St. Louis, MI 48880.

   1. Gary submitted reimbursements for the annual non-profit fee, income tax return, and the CAG postal box, which haven’t been approved in three months. Tom said that they are justified charges and the delay is caused by the income tax return differentiation between CAG and TAG filings. The issue should be resolved soon.

   1. The CAG is still waiting to hear back from EPA about potential merit review. Tom said it shouldn’t be a concern right now; rather, it’s tied to applications for additional TAG funding, which EPA will consult on when another funding request is initiated.

4. Correspondence and Communication [00:19:00]: Jane Keon, Chair

   1. Response from the CEO of the Michigan Public Health Institute (MPHI) regarding CAG letter about the misplaced records that praised the discovery of records and action to address. Overall, it is good the CAG registered concerns and copied state legislators on the initial letter.

   1. Article in the Morning Sun about cleanup at the OU-1 of the Velsicol Superfund Site. The CAG is grateful for exposure and support of local press.

   1. The CAG wrote a letter to EPA delineating the percentage breakdown for the TAGs and EPA agreed to our percentages: 60% of costs to the Velsicol Plant Site TAG, 20% to VBP TAG, and 20% for “other,” which includes PBB and other health-related activities, as well as other sites linked to Velsicol (Gratiot County Landfill and Smith Farm).

   1. Jane received a note and comment from a reader of Tombstone Town wherein the referred to her as a “civic historian.” Jane likes that phrase and thinks we should use it more often, especially for those who are documenting and engaging in the work of sharing the history of the CAG.

5. Program [00:24:20]: Students of CAG Secretary Dr. Brittany Fremion will give a presentation on their digital public history class project regarding our CAG and the cleanups at the Velsicol Superfund sites.

   1. The class worked with the CAG and JoAnne Scalf (Multigenerational Pine River Voluntary Health Map) to create a digital history project that explores the history of contamination in the Pine River watershed. Site visitors will be able to browse an interactive timeline, engage with maps that visualize health impacts, and explore primary sources and 5-12 lesson plans. The goals are to raise awareness about the history of contamination in the watershed and health impacts, as well as provide resources for educators and grow community engagement with the CAG. The class broke into four groups that worked on four components: (1) interactive timeline, (2) digital archive (gateway), (3) Story Map, and (4) curriculum. A student from each group reported on their methods for developing each component, including collaboration and software, and then gave tours of the materials they produced. Students also shared what they learned while working on the project.

   1. Discussion

      1. The tentative title for the project is “The Pine River Project,” but as pointed out by community members, further clarification might be needed to tie it to St. Louis and Mid-Michigan. As a result, the project may be called “The Pine River Project of Mid-Michigan.”

      1. The group also talked about outreach to engage the interest of local educators, as well as encouraging guest speakers from the CAG to meet with students/classes.

      1. Mike Soltis invited the class to present to the Gratiot County Local Emergency Planning Committee this summer.

      1. Finally, Jim Hall asked the students if they found their passion working on this project, to which they enthusiastically replied. For instance, one student pointed out that the process was really enjoyable, especially working on curriculum to raise awareness. Another student shared that part of their joy in learning to become a public historian and museum professional is helping people grow and learn from the past. An MA student offered that creating the digital archive demonstrated the importance of doing so in the midst of a pandemic—that digitized sources and materials are valuable pieces of evidence. A GIS MA student also talked about how powerful it was to develop a component in her area of interest in service to the community. Finally, a public history senior talked about her family’s connection to this history and how much more meaningful it made the work.

      1. JoAnne complemented the students and their professionalism, then encouraged the curriculum team to identify curriculum for Gifted and Talented Students, as well as connect with home school groups. She also reinforced the importance of meetings with CAG members or even participating in local school assemblies.

      1. CAG leadership asked for links to the components and will provide feedback as able.

      1. A soft launch of the project is planned for Mid-May and will be announced via the CMU Department of History blog, [Re]Collection History.

6. EPA Report [00:57:00]: Tom Alcamo, Remedial Project Manager

   1. Update on Area 2, Phase 1 of the Velsicol Site – cooling cycle: EPA haven’t started studying yet but will start measurements later this summer. They are currently restoring the one acre area by regrading and seeding.

   1. State of progress in Area 2, Phase 2 of the Velsicol Site – heating cycle: Heating started on/around April 12th and is in the very early stages, continuing into the fall (rue to initial estimate) with air monitoring data on the website. There isn’t a heating map yet because heating has just started. There haven’t been any hiccups and the team is hopeful for a smooth 90-day heating cycle at 112º F. Finally, they hope to have aerial views to share at the next CAG meeting.

   1. State of progress on OU-3 and OU-4 of the Velsicol Site – downstream of the St. Louis dam: EPA expects RI for OU-3 to be released toward the end of the summer. The OU-4 carbon amendment study is online and phase 2 activated, with some carbon laid and initial study almost complete. Soil and worm samples reveal that the carbon is really working its way into the subsurface to a depth of nearly 3-4 inches in several areas, and in every grid it’s worked down 1-2 inches. The project team will do some additional ecostudy in OU-4 this summer, looking for some animals and insects, to see how it compares to the previous floodplain work that Dr. Matt Zwernick did in 2016.

      1. Discussion

         1. Does the additional ecostudy go into all of OU-3 and OU-4? No, OU-3 is done with no additional sampling. Need to plan for OU-4 and further sampling downstream, with current focus on phase 2.

         1. Does OU-3 go to Madison Road and then OU-4 starts? No, from dam up to floodplain 1.2, which is just past the curve in the river by the athletic fields, and that’s OU-3. Carbon study is in OU-4 now. EPA will provide a map at the next meeting with these boundaries.

         1. Phase 2 work plan was released at the end of January 2021. The website says it was posted to website 3/29/2021, which was probably when it was finalized.

   1. Update on slurry wall and groundwater investigation: no updates or work expected before the fall.

   1. Discussion:

      1. Update on the contracting processes this summer for PSA 1 and 2 by MI 146, with design under review and a contract awarded for excavation of 100,000 tons next year.

      1. The VBP is not currently funded despite rumors that the budget will be increased, but we are still waiting. The current list of unfunded sites is also rather large. The CAG will write a letter to its federal representatives for support.

      1. Last well in city drinking water supply and well house with transmission main work being done this summer. Waiting on contact for drilling and installation, which the city is handling with its engineering firm and state doing permit work.

      1. EPA is still removing about 20,000 gallons of wastewater from the collection trench. There is no increase in water, which pumps in equilibrium with river, or increase in DNAPL (about 6 inches in one of the manholes, which they will keep monitoring). To protect the manhole piping from the heat from the Area 2, Phase 2 thermal treatment, they have also taken steps to protect the piping from the heat, including real-time temperature monitoring and a water cooling process that pushes 4-5 gallons of water through the system per minute. The piping is buried 3 feet underground and this is a precautionary measure. In follow up, the CAG asked for integrity testing and long-term monitoring of the piping.

7. EGLE Report [01:22:55]: Erik Martinson, Project Manager

   1. State of progress on railroad spur contamination site: Unfortunately no progress, it’s still with Mid Michigan Railroad’s legal department, which has to give the okay to grant access. Erik was told anything associated with Superfund Site takes more time to review. He remains hopeful for encouraging news on site access in the next few weeks.

      1. EGLE will re-send the large package of aerial photos, especially those that show where the railroad ran through the community and plant site.

   1. State of progress on bird and nest studies in the ANP: No updates.

   1. Discussion:

      1. The CAG pointed out that the railroad suggests there is a connection to the Superfund Site, despite exclusion from ROD. EGLE explained that it’s not included in OU-1 like ANP and Plant Site, and that investigation of creamery didn’t show contamination. But the railroad is likely wary of it becoming part of the site.

      1. How can the CAG support work for bird study?

         1. EGLE needs to reevaluate how and when to begin, especially with the current work being done on the plant site, so it won’t be something done soon. Excavations might influence study and so they are seeking further guidance from experts—the state biologist and/or contracting Weston to do the work. EGLE is in contact with David Kline about continued interest in another bird study.

         1. There is a community desire to know where the robins are nesting. With excavations slated to begin next year at the earliest, now seems to be the best time to undertake the work. The CAG doesn’t understand the hesitation. Erik will reach out to EGLE management and report back next month. Jane pointed out that we have the standard operating procedure from the previous study for continuity and to help with process. There are also some people in the neighborhood who might help collect dead birds who were trained for the first study. Funding for the study remains a concern, but Erik will continue to advocate for it.

8. Old Business [01:37:40]

   1. PBB Leadership Team Update

      1. We have the go-ahead to notify former chemical workers and their families about the MDHHS webpage on PBB and Next of Kin Request for Transfer of Records Form. They can fill in the first part of the form and ignore the instructions to provide other documentation/certificates (see appended guides). So one of our upcoming projects is to notify chemical workers and their families so they can access data and records held by state of Michigan.

      1. Emory received word of tentative approval of the grant extension, so scheduling will continue for appointments for the clinical trial, the multi-generational study, and the comprehensive health study. Over 250 people from the waiting lists have been contacted. There are 1900 people on the waiting list for blood draws.

      1. Covid shutdowns caused significant delays to reporting, but we are excited to share that PBB blood results are on their way for two-thirds of people who have been waiting to see them for over a year.

   1. Progress on website – Ed Lorenz [01:55:26]

      1. TAG funding for website discussed previously. In regard to connecting with former chemical workers and providing information about their experiences, we’ll be sure to include that information on the website homepage. Other updates tied to new business, below.

9. New Business [01:43:30]

   1. Discussion of Multi-generational study on DDT exposure ties in with the neighborhood mapping survey being conducted by JoAnne Scalf – No updates other than work with CMU class.

   1. Ed added a report on a new study to website from April 15, 2021, that explores long-term consequences of DDT exposure. One of the lead authors of the study is Dr. Barbara Cohn, who was supposed to attend the Intergenerational Conference a few years ago and otherwise involved in organizing the event. There is interest in following up with her to see if she might be able to apply work here.

      1. The findings remind Ed of the PBB community, they have a cohort of 20,954 women who were pregnant at some point between 1959 and 1967, and looked at DDT presence in women and then followed the daughters — about 9,000 — with a major report published in 2015 that demonstrated a significantly higher rate of breast cancer among them (daughters then aged 47-57). These women have 365 granddaughters who are now over 20 years of age and who are childbearing. While it’s too early to see if they will have the same breast cancer risks, they do have evidence of two of the predictors: twice the rate of obesity and twice as likely to reach menstruation before the age of 11. These chemicals remain a point of great concern.

      1. Also, there’s a response to the 2015 study of daughters and one of the two authors was Linda Birnbaum, who wrote a summary about the DDT work and because of our contact with her from the symposium in 2020, we should bring this up with the PBB group, as we do have a local cohort in the Registry that also gets DDT results and several of the breakdowns.

   1. Scott (TA) shared additional comments on the program: St Louis sits in a news void—we don’t tend to draw big regional papers; rather, the only people who knew about the cleanup and work being done are people in the area because of reporting by the Morning Sun. So it’s hopeful to have a project that will help to illuminate what’s going on and underscore the need for more studies, wildlife and human health, because they need to happen.

*Please remember to pay membership dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.

**The next meeting will be held on Wednesday, May 19, 2021.

Meeting adjourned at 8:58 pm.

Respectfully submitted,

Brittany Fremion, Secretary

General Membership Meeting Minutes – March 12, 2021

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording: https://us02web.zoom.us/rec/share/rHfbMt7xP-

Access Passcode: 5H3*zJTc

The meeting began at 6:45 pm via Zoom with Secretary Brittany Fremion as host, with 26 partic-ipants.

Vice Chairperson Ed Lorenz presiding and called the meeting to order at 7:00 pm.

I. Approval of February minutes. (Doug Brecht/Wayne Brooks)

II. Treasurer’s Report [00:01:35]: Gary Smith, Treasurer

A. February 2021

1. The General Fund Checking balance stands at $4,933.96. The Money Market Ac-count (Oxford Automotive settlement) has $65,069.28. TAG grant money available for the Former Plant Site (FPS) stands at $9,619.26. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $85.62. The complete reports will be attached to the permanent minutes.

2. We have received approximately $630 in donations with annual memberships this year.

B. Reminder about annual dues ($5/year). Send checks to PO Box 172, St. Louis, MI 48880. T-shirts are available for $12.

C. Still awaiting news on merit review process from EPA; no news on audits.

D. Gary submitted the amended information to EPA for theTAG, as well as annual taxes and non-profit status.

III. Correspondence and Communication [00:07:05]: none

IV. Program [00:07:30]: CAG Member JoAnne Scalf presented her work on the Pine River Vol-untary Health Map, a health mapping project she began several years ago. The project tracks health problems of people who lived or who now live near the Superfund Site in St. Louis.

A. JoAnne developed the project over the past 5 years, amounting to nearly $100,000 in personal hours and resources donated to the project. She recruited more than 500 par-ticipants in the study, which documents the variety of health problems residents of St.

Louis have experienced, including but not limited to: cancers, birth defects, and fertility issues. With this in mind, the study is designed to answer two questions:

a) Do any of the health issues occur at higher levels than expected for the general population?

b) Could any of the health problems be caused by exposure at the chemical plant and/or misuse of products at the facility?

B. In answering these questions, the study:

1. Gauges the need for future health studies;

2. Identifies possible decease clusters in multigenerational populations starting at the source;

3. Delineates the overall scope of the problem;

4. Raises awareness about potential exposures and their significance;

5. And alerts state and/or federal agencies to the need for well-funded, -controlled, and -designed studies to establish health surveillance programs for this high-risk commu-nity.

C. Methods include a voluntary survey and GIS map that documents the occurrence of ill-ness, which demonstrates higher outcomes of certain diseases—and in the absence of a comprehensive health study. JoAnne’s project ultimately demonstrates that is a legacy and multigenerational issue, and the need for more research.

D. Discussion:

1. JoAnne shared some personal testimonies she gathered from community members through discussion of survey provide additional insight into the presence of chemi-cals in personal residences and likely exposures from childhood play, such as chemi-cals found stored in residential basements and kids playing in puddles of mercury.

2. Dr. Tom Corbett, a PBB whistleblower and scientist, commented on some of the find-ings, such as similarities in cancers likely tied to PBB exposure, particularly gastroin-testinal cancers, which became prevalent and predominant among that community in the 1990s. He also noted that this is important information that can be tied to repro-ductive health and exposure to other chemicals. He commended and congratulated JoAnne on the amount of work she has done and the information she documented.

3. JoAnne is working to bring this information to the attention of scientists at the Univer-sity of Michigan’s School of Public Health and Epidemiology, and is collaborating with a member of the Citizen’s Climate Lobby. But it has been hard because the study is popular epidemiology, rather than scientifically-based. But the information she has documented again demonstrates the need for further research.

4. The CAG will continue to push for help in getting a comprehensive health study.

V. EPA Report [00:27:15]: Tom Alcamo, Remedial Project Manager

A. Update on Area 2, Phase 1 of the Velsicol Site – Cooling cycle ongoing.

B. State of progress in Area 2, Phase 2 of the Velsicol Site – heating cycle – Jacobs and Terra Therma working on ISTT and expect to start system testing within the next week, with heating in early April depending on testing. The website is being updated to include air monitoring data. As circumstances improve, EPA also hopes to resume tours of the site. Well 12, a well water well installed to provide additional water to Odowa(?), with permitting and design under review, with construction starting this summer. This is part

of the cooperative agreement with city in case there are some effects on well water, that EPA has funding to respond quickly.

C. Phase II of Carbon Study — EPA should have an update and report ready by the end of month.

D. State of progress on OU-3 and OU-4 of the Velsicol Site (the St. Louis dam, banks, ath-letic field, and downstream floodplain) — Still evaluating risk assessments with RI drafted and expected to be ready for release later this summer.

E. Discussion

1. Clarification on sampling and ecosystem study in floodplain (OU-3 and OU-4), near carbon amendment study. We still need a feasibility study for further downstream ar-eas (OU-4), but EPA will be walking the river and looking at additional banks and floodplains. Could be sampling as far as Chippewa River, which there doesn’t seem to be indication of risk, but EPA will evaluate as part of contract for RI.

2. Will OU-3 work be related to carbon amendment study? No. Alma College collabora-tion and study tied to OU-4, Phase 2 work plan, under review, with release expected at end of month. Diane will send information via email when available.

3. Is EPA doing any PFAS sampling? No current PFAS sampling, but EPA will do some for groundwater investigation. Initially the state evaluated the site and didn’t find fluorinated compounds or PFAS, nor did a study in adjacent Mill Pond fish, which had non-detects. The CAG Technical Advisor, Scott Cornelius, asked Erik Martinson to share a copy of the report(s).

4. What is the status of funding for the Velsicol Burn Pit Site? Recent changes in lead-ership in Region 5 headquarters may lead to additional funding for new sites, alt-hough there are a large number of unfunded sites that are new, including Velsicol Burn Pit (Velsicol site is ongoing, so not new); it’s unlikely that we’ll get funding for VBP anytime soon, especially with changes to contracting process.

5. Is there an update on the slurry wall investigation? No new information here because EPA is on hold until it gets a new contract for remedial design, which won’t happen until mid-summer, with hope of award by June/July. New contracting mechanisms for EPA are supposed to help save money, but they are not more efficient. Expect more information this summer.

VI. EGLE Report [00:42:25]: Erik Martinson, Project Manager

A. State of progress on railroad spur contamination site – Still no response form Mid Michi-gan Railroad regarding access package, which was submitted in early February. They provided a 6-8 week timeline and we are still within that timeframe. Westin will follow up next week.

B. State of progress on bird and nest studies in the ANP – No timetable but it is on EGLE’s radar. Preliminary discussion with Westin, but there is no anticipation of action soon.

C. Discussion

1. What chemicals are going to be analyzed in work plan for railroad study?

a) EGLE: VOCs, SVOCs, metals, DDT (both isomers). Erik will send Scott Cor-nelius, CAG Technical Consultant, the work plan.

VII. Old Business [00:46:05]

A. PBB Leadership Team Update – We want to be more comprehensive tonight, especially with the focus on health studies tonight. But we have lots of updates with the Michigan PBB Registry (Emory University team) and state health department, MDHHS.

1. Letter to Michigan Public Health Institute regarding lost file of 20 consent forms from people in the 1970s PBB long-term study – Norm Keon

a) MPHI was formed because the Michigan Department of Public Health (now MDHHS) wanted a nonprofit, research agency that could operate without the need to go through the state legislature—essentially, get around bureaucracy. Over the past several years, MPHI has grown tremendously, especially in con-tracting (see recent article in Detroit News here: https://www.detroit-

b) MPHI lost records on a thumb drive related to PBB Registry several years ago, causing alarm. Fairly recently, through our work with Emory, we learned that they had waivers from 20 people that were never processed by MPHI and thereby never sent to Emory or acted upon. This was a last straw so the Executive Com-mittee decided to send a letter to MPHI and copied public officials, that Jane wrote and Norm edited.

c) Discussion

(1) The CAG considered following up with the Detroit News journalist, depending on MPHI’s response to our letter.

(2) According to the Emory team, MPHI has a new team in place and the fact that they reported the oversight is promising.

(3) When Norm first found out about MDHHS website, especially regarding next of kin records, he thought of his friend, whose father worked as machinist at the chemical company, and “could make any part.” He worked in all areas of the plant and died of a rare stomach cancer. Norm shared the next of kin forms with his friend, who has Parkinsons, and they weren’t in favor of com-pleting it because it’s so onerous. It also costs money to get some of the rec-ords. The requirement for several proofs of documentation constitutes a ma-jor, initial roadblock for community members.

2. Difficulty in obtaining PBB records for deceased relatives on State webpage—Brit-tany

a) While there is definitely positive progress in our work with the MDHHS on PBB research, there remain some complications. MDHHS has a new website dedi-cated to PBB with the next of kin form. However, as Norm mentioned, the agency requires significant documentation, which has both deterred and complicated community access to deceased ancestors’ records, which are important to their descendants health. So the PBB Leadership Team recommends that community members just complete the first page of the form and submit it incomplete to demonstrate interest in the records.

(1) MDHHS PBB website: https://www.michigan.gov/mdhhs/0,5885,7-339-

(2) Link to Next of Kin form: https://www.michigan.gov/documents/mdhhs/2020-

b) Discussion

(1) Jim Hall shared experience of a friend who lived on Jackson Road, downwind of the landfill, and also developed Parkinson’s. Dr. Corbett commented that there are likely higher incidences of Parkinson’s because it is linked to certain chemicals, as documented by JoAnne’s study (5 incidences).

(2) Ed Lorenz shared a memory from the early 1990s, when he saw a bunch of drums stored on Smith Farm. There was an EPA settlement about the drums that predated work at the plant site. They just sat out in the open, “there were a ton of them.”

3. Notification to former chemical workers and their families about State webpage on PBB, Michigan PBB Registry studies, and upcoming appointments—Ed [01:15:00]

a) Summary and updates on current health work that’s ongoing to raise awareness and encourage others to get involved, which include the projects below, but we really want people to take advantage of opportunity to return Registry records to study (next of kin form).

(1) Recruitment and Maintenance of Comprehensive Health Study (CHS, known as the Michigan PBB Registry)

(a) Participants include 3,569 family members from quarantined farms and 251 chemical workers who volunteered in 1976 when the study began.

(b) Chemical workers were dropped from the study in 1990.

(c) Now includes about 7,000 participants from children who have been added to the study, along with restored chemical workers.

(d) There is a waiting list of around 1,900 people who want to be tested and added to the Registry, recruited from community meetings, but we need funding (about $300,000).

(2) Clinical Trial Extension (CTE) – Weight loss study to remove PBB

(3) Effort to match Registry members with cancer death index

(4) Multigenerational Epigenetic Study (MGES)

(5) Public Health Action Plan

(6) State Biomonitoring Grant includes PBB

(7) PBB Oral History Project

(8) Adding back next of kin records

b) Current Upcoming Efforts (all events are socially distanced, no large gatherings this spring):

(1) Recruitment Appointments May 15-16 and May 22-23 in 65 mile radius of St. Johns.

(2) Overcoming blood sample processing delays related to lab instrument issues and then the pandemic.

(3) Fundraising to add people to the CHS (tied to discussion of website below).

(4) Informing families of deceased record access (next of kin form).

B. Progress on new website – Ed

1. We have done a lot of work on the website. We received many donations this year with memberships, perhaps because of website push, but we don’t have a portal to

raise funds through memberships, purchase of shirts, or donation online. There is a platform called Donor Box which is a recurring donation system that allows people to sign up for monthly donations. The host platform takes a small percentage of pro-ceeds, as well as a small fee for processing credit cards, but the funding would go to Emory to pay for processing bloodwork for people on the waitlist.

2. Discussion

a) Can CAG use TAG money to support some of these updates to the website? Also, this would help us to meet our requirements for non-profit status. But we must consider how fundraising would impact taxes and TAG status. Tom asked Ed and/or Jane to email him about scheduling a meeting to discuss. These ques-tions are really important, because you can’t intermix the TAG and CAG, but there could be partial funding for website based upon our work for community.

C. Update on CMU class public history project – Brittany

1. Students have broken into four groups focused on four components: a digital time-line; an interactive map tied to JoAnne’s study and to acquaint visitors with the com-munity, river, and site; a “digital archive” that works like a gateway or clearinghouse for primary sources; and curriculum tied to those components. We hope to have a draft of the project prepared for presentation at the April CAG meeting for community input and feedback.

D. Ed is presenting at a virtual forum on the Superfund budget, using St. Louis as a case study, Thursday, March 18th from 11-12:30 pm.

Meeting adjourned 8:40 pm.

Annual dues are $5/year. Send checks to PO Box 172, St. Louis, MI 48880. T-shirts are availa-ble for $12.

Next meeting date: April 21, 2021

Respectfully submitted,

Brittany B. Fremion, secretary

General Membership Meeting Minutes – February 17, 2021

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording: https://us02web.zoom.us/rec/share/qolAM9Vv-BIjRGsUAU8V7xyiT7QenbCX8h_H2v5c-acM-l-iAjnh-Wx3XU6qZQDu.ipdWScsXIALkGli0

Access Passcode: jS87j.@G

The meeting began at 6:55 pm via Zoom with Secretary Brittany Fremion as host, with 32 participants.

Chairperson Jane Keon called the meeting to order at 7:00 pm.

1. Addition to Agenda: Silent Spring Institute

2. Approval of January minutes. (Liz Braddock/Doug Brecht)

3. Treasurer’s Report [00:00:00]: Gary Smith, Treasurer

   1. January 2021

      1. The General Fund Checking balance stands at $4,802.85. The Money Market Account (Oxford Automotive settlement) has $65,064.29. TAG grant money available for the Former Plant Site (FPS) stands at $9,619.26. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $85.62. The complete reports will be attached to the permanent minutes.

   1. Reminder about annual dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.

4. Correspondence and Communication [00:04:05]: Jane Keon, Chair

   1. Articles and radio news about the MDHHS PBB webpage, with contact information for Michigan PBB Registry that Emory University runs now. The site includes information on how to accessed deceased relative’s records. This is important because at the time of the first study, the state catalogued all children in a family involved in study in their father’s folder, so when the father passed in later years his children had no access to their own data. This new access is therefore a really good thing.

5. Program [00:06:05]: Groundwater data update showing monitoring wells, the ANP (Adjacent Neighborhood Properties), and the area where the slurry wall is leaking – EPA Project Manager, Thomas Alcamo, and CH2M/Jacobs Project Manager, Scott Pratt

   1. Scott provided a general overview of the data collected from groundwater sampling, the work for which was conducted between October and November 2020, and included groundwater elevation measurements and groundwater sampling from 64 monitoring wells (13 offsite, 51 onsite; tested for volatile organic compounds/VOCs, semi-volatile organic compounds/SVOCs, pesticides, PCBs, pCBSA, wet chemistry, and metals). The data will be used to support future remedial design activities, such as the DNAPL/groundwater collection system, groundwater extraction and treatment, perimeter drain, and up gradient slurry wall (UGSW) investigation.

      1. Wells were grouped by location, either on- or offsite. Groundwater contaminants and concentrations for areas outside of the in-situ thermal treatment (ISTT) area are consistent with data from 2008 as defined in the RI. But concentrations in onsite ISTT areas (main plant site) are significantly reduced (i.e. concentrations of benzene and chlorobenzene).

      1. Onsite, pCBSA is still present but nonvolatile and still below safe drinking water criteria. [Note: While volatile compounds can turn into gas, pCBSA is a byproduct of DDT manufacturing and not vaporous, so nonvolatile.] The state level for pCBSA is 7300, but we’re uncertain about what the discharge criteria might be when pumping water from the site, so EPA will have to take that into consideration when designing the system.

      1. This data was just collected and much more study is warranted; this report is a snapshot of what’s going on and EPA intends to study the data further. Overall this data on the plant site is good.

      1. Outside the plant site, contaminants and concentrations remain close to historic levels documented previously—what we expect—including some pCBSA, five semi-volatile compounds all below actionable level for Michigan drinking water criteria (i.e. arsenic). A few other contaminants either meet or are just above levels (i.e. benzene and chlorobenzene), not detected, and/or consistent with historic data.

      1. EPA clarified that if levels are above the drinking water standards offsite (outside the fence line), then EPA has to restore it; if it’s onsite (within fence line) then it has to be contained. For the homes in the ANP, the water in the shallow zone needs to be at set drinking water standards.

   1. The map included in the report depicting groundwater flow is consistent with the one from the RI in 2008, showing that groundwater is still flowing around the slurry wall and plant site, but that the slurry wall has served its purpose (i.e. to block contaminants from going into the river or traveling from the site via groundwater, despite elevation problems). The breach in the slurry wall near Watson and Center Streets continues to be a point of concern and will require additional study, but EPA sampling suggests drinking water levels are not being exceeded and that there is not a large plume leaving the site.

   1. Discussion

      1. Q: Are people in ANP safe, especially with the “window” or leak in the slurry wall?

         1. EPA: The drinking water isn’t an issue because it’s provided by an outside supplier. Offsite there is little risk, as opposed to onsite, which is a significant risk. We will never be able to clean up groundwater on the plant site, which is why we contain and treat it, and make sure it doesn’t leave the site. The issue is what is the all doing with respect to the treatment system?

         1. CAG: The collection area that is supposed to be built around the site is not there yet, so none of the leaks are being contained, nor have they been for the past 25 years.

      1. Q: The Report mentions Velsicol site being 100-acres and including the entire neighborhood, so does that mean that the compliance area now includes the ANP or is it just where the fence is located?

         1. EPA: Just the fenced area, a site boundary established when added to the NPL or Superfund list and then expanded following investigation to confirm actual boundaries and point of compliance. Outside the boundary EPA has to restore drinking water to meet standards, inside it has to be contained.

         1. Liz Braddock, MMDHD representative, said the agency has information on monitoring wells and tests; if there is concern about public health she can coordinate an investigation. There haven’t been any complaints or reports of flooding to date.

      1. Q: What if contaminated groundwater is getting into ANP basements?

         1. EPA: There aren’t high levels of contamination in groundwater in ANP, so basements aren’t a concern. If investigation of breach in slurry wall suggests otherwise, then we will act, but evidence so far doesn’t suggest that there’s an issue. Years of sampling data and historical record shows that ANP is safe, that “You could drink the water at these wells.” But if that information changes, we’ll respond—and will continue to investigate and study to be sure. We may even install some additional wells, especially near the breach.

         1. EPA will make sure that the new fire chief and county Emergency Manager will get tour of site as soon as it’s safe.

      1. Q: How did EPA find the breach in the slurry wall?

         1. EPA: Through investigation and by drilling, expecting to hit wall, and missing (see November presentation).

         1. CAG: So if EPA didn’t have knowledge of gap until that study, but this is a fear the community has expressed, then how can we be certain that there aren’t other breaches? The groundwater report also reveals that there was not a groundwater elevation contour map because of uncertainties due to sand seams. So how can we be certain? How do we know?

            1. EPA: Sand seams within the till have been geologic challenge of this site; also, sand seam is the shallow unit.

            1. CAG: These breaches and seams exist, and so is it possible things are moving that we’re unaware of, such as with this breach?

               1. EPA: We found an area where the wall wasn’t set low enough, not because there was a sand seam.

               1. CAG: But then how do we know this was the only place that happened?

                  1. EPA: We have groundwater data and sampling to help us understand what is going on with the wall—it’s not just the measure of drilling for the wall, it’s supported by other data that provides additional insight for these kinds of questions, especially with the up gradient wall. Assessment of the wall will be based upon multiple lines of evidence: more drilling, dye tests, piezometers, etc.

                  1. EPA will add the presentation to the website and clarify some of the acronyms used.

      1. Q: Why is BB labeled as pesticide?

         1. EPA: That’s how the lab labels it.

      1. Q: Why was there a dry monitoring well — where did the water go?

         1. EPA: It’s a shallow well that goes dry from time to time; the groundwater elevation drops and it empties.

      1. Q: Observations indicate that the slurry wall is inhibiting water flow off-site, except for a certain well—is that where the breach is located? Some of the information in the report is unclear (i.e. also maps and keys cut off, lack of pagination, and use of acronyms not identified elsewhere in the report).

         1. EPA: Yes. And we will collect additional data because the site will reach a new equilibrium over the next several years.

      1. Q: The data validation report from the lab at the end of the groundwater report raises concerns due to uncertainty about how to interpret the data, which seems to suggest that some valuations seem greater than control limits. How should we interpret this?

         1. EPA: The laboratory equipment has to be calibrated by estimated values, especially with such heavy contamination and lots of samples and huge concentrations that have to be validated by chemists, who take a close look at the data to determine if there are issues; if there are, it’s usually labeled “r” or estimated as “j” or “uj” or “undetected, but estimated.”

         1. CAG: This uncertainty is the point of concern.

            1. EPA: Some of the data we have is really certain, but data validation is necessary for the wide variety of chemicals at the site, especially when being measured in the parts per trillion (ppt) range, that it’s really difficult. I trust the chemists.

            1. Suggestion made to invite a chemist to the next CAG meeting to talk through the data and processes, as well as how control limits are set.

      1. Q: The EPA has done more sampling than the CAG thought they’d ever do. This is a really complex site, and when we got a bird study in neighborhood done it added to the complexity of it, just like the sand seams. Is there any potential for more sampling around the ANP to see if there are sand seams working as a conduit, or helping to move contaminated groundwater that way?

         1. EPA: Yes, we will likely be putting more monitoring wells in as part of new contract; the data doesn’t deter us from doing so. Expect to talk more about it this summer.

      1. Q: The CAG was told it would be given the groundwater report but the only way we got it was because our Technical Advisor found it when he was looking for something on the website. We don’t do that out of habit; we were told you’d notify us. We weren’t notified so we only discovered the report a few hours before the meeting.

         1. EPA: We said the report would be released before the end of the month and it was. But if you want to be notified, we can do it.

         1. CAG: Yes, please—we’re largely volunteers. We want to be prepared. We want there to be open communication. Thank you.

6. EPA Report [01:01:00]: Tom Alcamo, Remedial Project Manager

   1. Update on Area 2, Phase 1 of the Velsicol Site – cooling cycle: Not much work on because of demands at other sites and delays with contract changes. What remains is the remedial design contract, but hope to have contracting in place later this summer through excavation phase. Not much of an update at this point.

   1. State of progress in Area 2, Phase 2 of the Velsicol Site – heating cycle: It’s been a tough couple of weeks with the bitter cold weather. The team is about 75-80% done with Phase 2 well field. Next big step is in early March when the transformer will be laid to meet demands for electricity at site, then we’ll get heating going on/around March 22nd. The CAG is grateful for the onsite team’s commitment to the project and work given the challenges presented by the cold. .

   1. State of progress on OU-3 and OU-4 of the Velsicol Site – downstream of the St. Louis dam: Still working through comments on RI, with the hope it will be released sometime this summer.

   1. Update on slurry wall investigation – There will be another phase when a new contract is awarded, hopefully by July.

7. EGLE Report [01:07:00]: Erik Martinson, Project Manager

   1. EGLE has reviewed the groundwater report and is in agreement with data and findings in the report, specifically in the depiction of groundwater flows in the shallow deep and city intake well zone, and looks forward to additional investigations in UGSW and potentially in ANP areas.

   1. State of progress on railroad spur contamination site: As of February 1, Westin submitted all of the required paperwork and access permits with required access fees to the railroad and we’re still waiting to hear back from them, but are hopeful this is the final push and that they have what they need for internal environmental review. EGLE still hopes to start surface soil sampling in early spring.

   1. State of progress on bird and nest studies in the ANP: No updates but will have something to report at the next meeting.

      1. CAG: With Matt Zwiernick inaccessible, please consider alternative approaches and means of pursing this work. The CAG can share copies of his protocols and residents to help with bird collection who were trained to do so.

      1. EGLE: We have essentially removed him from the equation, so we are working to identify a different way of doing this.

   1. EPA: The VBP grant was approved.

      1. Treasurer: Yes, we were approved. But we are encountering difficulty with the merit and outputs/outcomes targets. I’ve tried to find information online, but we expected further contact about guidance per prior communication at meetings.

      1. EPA: We will talk with grants people. Expect to track volunteer hours which is required under the grant for a 20% match, but we’ll likely have to assign compensation in case we get audited.

      1. Treasurer: The CAG has documented hours for several years now, but there is a lack of understanding about what specifically EPA wants. There was a training session in 2016, in which we participated, but now we seem to not be doing things right. We’re happy to comply we just need to know what EPA wants. We will wait for further direction.

8. Old Business [01:17:15]

   1. PBB Leadership Team Update – Ed, Jane, Brittany, Norm

      1. Appointments are being scheduled for May, but given the challenges of in-person events, there are no community meetings.

      1. We should also highlight the positive outcomes from our advocacy. The CAG sent letters to MDHHS and state representatives about the importance of community members being able to access deceased family members’ records, as well as giving Emory the authority to continue work on the PBB Registry. We’re pleased to see progress and will send a follow-up letter to the agency to express our excitement.

      1. There were recent challenges presented by a Grant of Authority document, the language in which initially prevented Emory team members from accessing public records archived by the state, which we are helping to address.

   1. Progress on new website – Ed

      1. The CAG was approved early on to use grant money to create and maintain the website, so there is precedent, perhaps for assistance to maintain the website. Ed will email EPA Project Manager to ask about the potential of using some of the grant funding for the website.

      1. We need pictures! Digital versions or original images, negatives, or slides that could be digitized to improve the quality of photos on the website.

      1. If you have feedback or recommendations for the website please send it to Ed. We want to try to keep it current and updated.

      1. Update on CMU class public history project – Brittany

         1. Jane, Ed, and Jim Hall met with the class in late-January to talk about the CAG’s history and how they came to be involved, as well as what keeps them going 20 years later. They also shared ideas about the project’s focus, audience, and content. Students will submit their ideas for the project later this week and we hope to present the project at the April meeting.

      1. The Silent Spring Institute (SSI) – Ed

         1. Emory brought SSI to our attention. It is the result of citizen science in the Cape Cod area and it reminds us of the Pine River Voluntary Health Map. Since launching that first project, SSI has become a national organization based in Boston. They developed a digital interface called DERBI, which is a health reporting application that can be used by individuals so they have their records on hand, but it also combines that information with data from others, so a single exposure reflects widespread exposures and can alert healthcare providers. We encourage Brittany’s class to explore this resource further for their project.

         1. One of their current priorities is flame retardants, and they include information about PBB and Firemaster! They are exploring exposures in women firefighters; they also have a healthy green campus initiative based upon use and persistence of flame retardants in cheap furniture on campuses. They also have a private drinking water well subproject.

         1. There’s also a fascinating documentary on the project with one of the nation’s leading cancer researchers, who played a big role in drawing ties between cancer and chemicals (link to film: https://silentspring.org/news/unacceptable-risk-dr-margaret-kripke-cancer-and-environment)

         1. We should reach out to them and consider partnering.

      1. Notice about upcoming Zoom presentation on March 4 at 2:00 pm on Superfund funding.

Please remember to pay membership dues by mailing checks to PRSCTF, P.O. Box 172, St. Louis, MI 48880.

 The next meeting will be held on Wednesday, March 17, 2021.

Meeting adjourned at 8:38 pm.

Respectfully submitted,

Brittany Fremion, Secretary

General Membership Meeting Minutes – January 20, 2021

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording: https://us02web.zoom.us/rec/share/QMcVWLN-RQeSwIgMpIgjklslZ4ktLdeSUH2ITVU652ldp6O2FVuCZ-weenzoNguU.xrrAmncBadMsxlEq?startTime=1611187376000

The meeting began at 6:48 pm via Zoom with Secretary Brittany Fremion as host, with 38-40 participants.

Chairperson Jane Keon called the meeting to order at 7:00 pm.

1. Approval of November minutes (no December meeting), with corrections. (Doug Brecht/Liz Braddock)

2. Treasurer’s Report [00:03:00]: Gary Smith, Treasurer

   1. November 2020

      1. The General Fund Checking balance stands at $7,160.16. The Money Market Account (Oxford Automotive settlement) has $65,053.59. TAG grant money available for the Former Plant Site (FPS) stands at $19,996.76. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $85.62. The complete reports will be attached to the permanent minutes.

   1. December 2020

      1. The General Fund Checking balance stands at $15,180.23. The Money Market Account (Oxford Automotive settlement) has $65,059.12. TAG grant money available for the Former Plant Site (FPS) stands at $9,619.26. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $85.62. The complete reports will be attached to the permanent minutes.

   1. Reminder about annual dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.

   1. Follow-up since November

      1. Outstanding billing approved by EPA.

      1. EPA’s new grant system went live in December.

      1. VBP TAG extension still pending.

      1. Gary followed up with Tom on downriver study.

3. Correspondence and Communication [00:12:15]: Jane Keon, Chair

   1. Articles about the CAG Hall of Fame recipients in the Morning Sun and Gratiot County Herald

   1. Year End Report for 2020.

   1. Articles about the Michigan Department of Health and Human Services launching a webpage on their website devoted to the PBB studies, with information about how to get involved.

   1. Quarterly Progress/Performance Report for the EPA Technical Assistance Grant for the Velsicol Superfund Site.

   1. Phone calls and written correspondence with the author of the Rise and Fall of the Michigan Chemical Corporation. (See New Business below)

   1. Letter to EPA about the slurry wall investigation (See EPA Report below)

   1. Emails regarding the status of the Technical Assistance Grant for the Velsicol Burn Pit Superfund site. (See New Business below)

   1. Letter to NIH to support Emory University request for extension of grant funding.

4. Program [00:13:00]: Highlights of the 2020 Year End Report and completion of 22 years of volunteer efforts by the Pine River Superfund Citizen Task Force, Jane Keon

   1. Quarterly reports to EPA provide an overview of our efforts and inform the Year End Report delivered by the CAG Chair at December meeting, which normally includes a potluck. Because of ongoing challenges related to the pandemic, we cancelled the December meeting. The report is attached to the minutes.

5. Technical Report [00:21:55]: Scott Cornelius, CEC

   1. Due to connectivity issues, Scott joined by phone. December was a low-key month, so nothing to report tonight. CAG just received responses from EPA about slurry wall comments, which will be discussed at next meeting.

6. EPA Report [00:22:55]: Tom Alcamo, EPA Project Manager

   1. Update on Area 2, Phase 2: Construction continues, with about 65% of construction done. Still expect to begin heating in March. Changes with EPA contracting and funding of projects has presented some challenges. Scott Pratt is finishing report on groundwater monitoring (i.e. approximately 65 wells, water level measurements), should be available soon.

   1. Carbon Amendment Study: EPA awarded new contract to Otie/Jacobs. Planning stages for second phase of carbon amendment study, with goal of late spring or early summer startup.

   1. OU-3: RI still being reviewed, delayed because of end of contract period for EPA.

   1. Response to Gary’s comments about downriver residents. Tom confirms there has been contact and that EPA does not need assistance with outreach.

   1. Discussion

      1. There was concern about how the new contracting process at EPA might affect the VBP site. Tom doesn’t anticipate challenges because the project has separable service, which will allow work to proceed in phases. The benefit of the new contracting mechanism is that it makes bidding more competitive, but has added a layer of bureaucracy and requires more paperwork.

      1. CAG can expect groundwater monitoring report by the end of the month.

      1. There was also discussion about possible shifts in funding with new federal administration. Tom is unsure, but pointed out that there are a number of sites that remain unfunded, so there’s a big backlog. Jane pointed out the significance of the Superfund tax being reinstated, mentioning that the CAG has written letters to federal lawmakers about why it’s important. (Superfund taxed chemical companies at low rate to sponsor funds for sites like Velsicol, which are orphan sites. But since that money has run out, all the orphaned sites around the country don’t have a company funding cleanup and have been suffering.)

7. EGLE Report [00:33:00]: Erik Martinson

   1. Railroad Spur Investigation: Work is ongoing, but slowed because of covid and holidays. EGLE had to submit a different application with environmental review. Erik spoke with Weston, who completed and submitted the application this week. Still waiting to hear back, but Erik is hopeful we will have an update by the next CAG meeting. EGLE hopes to start drilling in the early part of spring, but it will depend on when the application process is complete. Nonetheless, this is more progress than we’ve had in 8 years.

8. Old Business [0036:00]

   1. PBB Leadership Team Update: Ed and Jane represent the CAG, Brittany represents CMU and the Michigan PBB Oral History Project, and Norm MMDHD. The leadership team has monthly conference calls with researchers at Emory who run the Michigan PBB Registry, the long-term health study, along with members of the PBB Citizens Advisory Board, which includes farm families from across the state.

      1. The latest call focused on MDHHS contracting with MPHI, which issues the grant of authority for PBB research and records. The latest grant of authority was going to make it even more difficult for Emory to continue to work on studies for the PBB Registry. So leadership team members have written letters to MDHHS and, most recently, Norm shared a document from the PBB era on this issue, which has led to a reworking of the grant of authority. This is a major accomplishment that will facilitate ongoing work to determine the long-term health outcomes from that disaster. Congratulations to Norm and the Leadership Team!

      1. The CAG also sent a letter to NIH supporting extension of the clinical trial for another year or two.

         1. Discussion: In the future, Norm hopes to share with the CAG his work to access the document. Ed emphasized the significance of these efforts, noting that this is a positive step, including MDHHS launching a PBB page on its website after pushing back on these issues for a long time. For example, families were previously unable to access records for deceased relatives and that information is important for their health history and care. Moreover, it allows descendants to be added to the Registry.

   1. CAG Website (pinerivercag.org)

      1. Ed continues to update and add information to the website, highlighting some of the ongoing challenges. He continues to welcome feedback.

         1. Ed has received some additional help from his son, a tech guru, who recommended that we make a few upgrades, particularly with making payments online and secure (i.e. membership dues, donations, merchandise). He also recommended a new platform, which could cost up to $400/year, but would get us a really phenomenal site. He spoke about the importance of having a strong online presence. Tom said that it might be possible to use grant money to support work on the website.

9. New Business [00:54:00]

   1. Dr. Corbett’s book, “The Rise and Fall of MCC,” provides new insight into the history of the company. Dr. Corbett shared two chapters, one on the Velsicol Site and another on the PBB mix-up. Jane shared her observations, highlighting new information to her, such as how cross-contamination in the facility likely altered PBB/Firemaster product and may help to explain why some livestock suffered more than others. MCC also made a lot of salt products for animals and Jane used to buy salt blocks for her animals there too, so it’s possible they were contaminated too.

      1. Discussion:

         1. Jane and Ed spoke about a 13-page EPA Report from 1980, which is new to CAG. It describes the pipes that come out of the plant site and into the river, and when they were put into use, starting in May 1936. There is also information about what was dumped at the burn pit, as well as old city landfill and Smith farm which is really disturbing. Even stuff about dredging of river and what was dumped on the plant site is discussed.

            1. Tom Alcamo is not familiar with the report and would like a copy.

         1. Dr. Corbett explained that as we approach the 50th anniversary, an updated history of MCC and what it has done to St. Louis is long overdue. His book starts with the geology of the region and significance of brine deposits, as well as early inhabitants and beauty of the river, which only took 150 years to wreck. He based his work on several sources, including MCC annual reports and Articles of Incorporation. He also spoke about the importance of the long-term health study, but also frustration about lack of follow-up by the state (before the PBB Registry was transferred to Emory). For instance, Dr. Hal Humphries who worked for MDPH (now MDHHS) worked on an early cancer study and was just starting to see increase in digestive cancers 20 years later. The obvious next step was to redo the cancer study every 5 years, with the expectation that there would continue to be an uptick. But the study stopped, which was shortsighted. The last chapter will focus on multigenerational research and what we’ve learned in the past 50 years to bring the history up to date, with the caveat that there’s still a lot more to do.

         1. Dr. Corbett also spoke about his personal experience during the PBB mix-up. In early 1970s he was an anesthesiologist who had a lab to study effects of anesthetics, which e became interested in after his wife noticed that the gases he administered on patients had distinct smells. He was doing this work when he started reading about PBB in newspaper. He connected with leading environmental health scientists, who thought it was a likely carcinogen, but no one was studying it at the time, so Dr. Corbett started a mice study. He noted birth defects and tried to alert MDA and MDPH, as well as presented his findings at meetings, but no one would listen. Dr. Corbett also grew really concerned about breastfeeding, which he spoke about publicly in the 1970s. Dr. Corbett also played a very important role in getting leading environmental health expert Dr. Irving Selikoff to come to Michigan to study the early health impacts of PBB exposure.

   1. Possible collaboration with CMU class on digital public history project [01:16:30]

      1. Brittany is teaching a public history class at CMU that would like to work with the CAG to create a virtual project. Prior communication with the EC has pointed toward an educational focus, but Brittany wants more input from community on the topic. There is an interest in building a project that would focus on health. Jane, Ed, and Jim Hall will meet with her class next week to talk about some more details. Brittany will provide an update at the next meeting and welcomes community input and feedback over the next few months.

   1. Status of TAG for VBP site [01:25:00]: Gary spoke about the ongoing challenges, especially with new project officer, new grant process, and merit review. Tom reported TAG approval as of January 6th, but that there is a glitch with the system and processing. The CAG has concerns about the merit reveiw process, however, as well as miscommunication about TAG approvals.

Please remember to pay membership dues. The next meeting will be held on Wednesday, February 17, 2021.

Meeting adjourned at 8:35 pm.

Respectfully submitted,

Brittany Fremion, Secretary

Pine River Superfund Citizen Task Force

YEAR END REPORT-2020

First Quarter:

• A CAG member contacted our state senator who chairs the EGLE committee, about the need for a bird study

• Six CAG members made presentations or served on panels at a PBB to PFAS conference at the University of Michigan

• CAG member Norm Keon received a special tribute from the Michigan governor for his 50 years of service in public health

• CAG member Ed Lorenz presented research on Superfund for the national NPR program “Here and Now”

• CAG member Jane Keon was interviewed by WCMU radio

• The CAG chair met with the local health officer and epidemiologist regarding PBB originating at plant site

• A CAG member wrote an account of CAG/TAG events in 2019

• Documents on Velsicol dumping were provided to the Gratiot County Administrator

• Bid invitation letters were sent to three potential contractors to give technical advice on the slurry wall investigation

• A technical consultant was hired to review past and present studies and documents on the slurry wall surrounding the chemical plant site in St. Louis

• A dispute was filed with EPA regarding the technical consultant invoice from which payment was withheld

• Our technical advisor presented a program on the carbon amendment pilot study incorporated with CAG questions and concerns

• Heating is underway in Area 2, Phase 1 of the Velsicol Plant Site

• The carbon amendment experiment is ongoing in OU-3

• The slurry wall investigation is ongoing

• About 75% of the extraction wells in Area 2, Phase 2 have been bored

Second Quarter:

• April, May, and June CAG membership, Technical Committee, and Executive Committee meetings cancelled due to COVID-19

• CAG leadership communication during Michigan “stay at home, stay safe order” via email and phone

• CAG Chair communicates with new EGLE project manager, Erik Martinson

• Concerns about potential COVID-19 interruptions of heating at Area 2, Phase 1 were alleviated by EPA project manager, Tom Alcamo

• Four CAG officers (J. Keon, N. Keon, Lorenz, Fremion) took part in monthly PBB Leadership Team conference calls with researchers from Emory University on April 10, May 8, and June 12

• CAG submits letter in response to decision over dispute with EPA regarding the technical consultant invoice from which payment was withheld

• CAG submits additional letter following EPA response to carbon amendment pilot study

• CAG submits letter of support for research team at Emory University pursuing PBB/COVID-19 NIEHS grant

• CAG member Ed Lorenz compiled Velsicol dumpsite documents for researchers from Emory University

CAG member Jane Keon helps researchers at Emory University, Central Michigan University, and the University of Michigan develop a timeline for publication on PBB mix-up

• CAG sends letter to EPA requesting reports promised about past projects and outlining concerns

• CAG leadership investigates the possibility of meeting remotely in July.

Third Quarter:

• Heating concluded for Area 2, Phase 1 at the former chemical plant site on September 14, 2020

• Almost 183,000 pounds of DNAPL recovered from Area 2, Phase 1 of chemical plant site, more than double the amount expected

• The carbon amendment pilot study is complete in OU-3 with report expected in October

• The slurry wall investigation is complete, report expected in October

• Progress in Area 2, Phase 2 continues, with construction beginning in October 2020 and operations projected for April to November 2020

• Erik Martinson from EGLE has begun the railroad spur investigation

• The Executive Committee met remotely twice, once in July and again in September

• General Membership meetings were held via Zoom in July, August, and September

• CAG leadership communication outside remote meetings continued via email and phone

• CAG membership received monthly updates from Chair, Jane Keon, via email and at remote meeting.

• CAG Chair communicated with EGLE project manager, Erik Martinson, regarding several studies (i.e. bird/nest study and railroad spur)

• CAG Chair interviewed by WCMU and Morning Sun about thermal treatment at former plant site CAG submitted a follow-up letter in response to EPA decision over technical consultant invoice

• CAG Chair communicated with hydrologist, former chemical plant worker, technical consultant, and executive committee about underestimation of DNAPL and potential migration of chemicals at former plant site

• CAG sends letter to EPA requesting Emergency Removal Action (ERA) following discussion at July general membership meeting

• CAG submitted additional letters following EPA response to underestimation of DNAPL collected in Area 2, Phase 1

• CAG member (Lorenz) attended an EGLE webinar about PFAS contamination sites in Michigan in August

• CAG member (Lorenz) compiled research connected to possible PFAS contamination from Lobdell plant site, which he shared at the August and September general membership meetings.

• CAG executive board members discuss archival collection at Alma College and consider transfer of materials to Central Michigan University’s Clarke Historical Library

• Erik Martinson of EGLE is assisting with the location of CAG documents copied in 2011

• Additional CAG records donated to Clarke Historical Library at CMU

• CAG member (Smith) distributes digital document for in-kind reporting

• CAG member (Brabaw) develops Google spreadsheet to compile data for quarterly reporting, following EPA feedback on last TAG extension request

• Multiple press releases sent to local and national outlets about progress of Area 2, Phase 1 project at chemical plant site, virtual PBB community meetings, DNAPL quality, and slurry wall investigation.

• Four CAG officers (J. Keon, N. Keon, Lorenz, Fremion) took part in monthly PBB Leadership Team conference calls with researchers from Emory University on July 10, August 14th, and September 11th.

• CAG members(Lorenz, J. Keon, Fremion) present at the PBB Registry virtual community meetings on September 22 and 26th (Hoyt, Brabaw).

• CAG continues work to revise and produce new narratives for the organizational website in preparation for a major update, as led by the Vice Chair Ed Lorenz.

Fourth Quarter:

• A newly located breach in the 1980s slurry wall is reported by EPA

• A letter is sent to EPA from the CAG advocating the old wall not be used. Included with the letter are the formal comments on the slurry wall investigation written by the CAG’s paid Technical Advisor, Scott Cornelius

• The CAG requests EPA sample in basements located in the ANP now that it is known contaminated groundwater has leaked into the neighborhood for decades

• EPA plans to conduct a second phase of the slurry wall investigation

• EGLE reports railroad spur investigation has stalled due to the Mid-Michigan Railroad owners’ misconceptions about the project

• Work will continue through the winter to ready Area 2, Phase 2 of the plant site, with a start-up of the heating in March, 2021

• Predesign work has begun for the perimeter drain

• The TAG extension request for the Velsicol Burn Pit is still pending

• Former CAG member Murray Borrello was appointed to the state’s Environmental Permit Review Commission

• The CAG wrote a letter to our state senators about the Michigan Public Health Institute contract language that adds barriers to PBB research

• CAG member Ed Lorenz is working with IT helped Matt Ogle to design a new website

• The CAG Technical Advisor has compiled comments from the CAG in response to the report on the first phase of the carbon amendment study. The Executive Committee is reviewing the comments before submission to EPA

• EPA reported that the Remedial Investigation report for OU-3 is due for release in early 202. Both Velsicol Site Operative Units 3 and 4 are located downstream from the dam in St. Louis

• Drilling is underway for the final new drinking water well located in Arcada Township with piping to St. Louis

General Membership Meeting Minutes – November 18, 2020

The meeting began at 6:55 pm via Zoom with Secretary Brittany Fremion as host, with 17-20 participants.

Chairperson Jane Keon called the meeting to order at 7:05 pm.

1. Approval of October minutes (Liz/Wayne).

2. Treasurer’s Report [00:01:00]: Gary Smith, Treasurer

   1. The General Fund Checking balance stands at $65,048.07. The Money Market Account (Oxford Automotive settlement) has $4,782.61. TAG grant money available for the Former Plant Site (FPS) stands at $22,359.26. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $85.62. The complete reports will be attached to the permanent minutes.

   1. Gary has been busy this month, working on the following:

      1. He is still awaiting approval of September and October billing, which can often take time, but expenses are outstanding.

      1. The VBP TAG extension request still pending.

      1. EPA is switching to new grant system which will go live in early December and might be the cause of delays. Moreover, we have a new project manager at EPA Region 5 headquarters.

      1. Gary followed up with Erik Martinson (EGLE) on work plan for Railroad spur, as promised at October meeting.

      1. He received a phone call from EPA reiterating the agency’s final decision regarding the appeal about a bill for our technical consultant.

      1. Gary will follow-up with Tom/EPA about downriver property owners for carbon study sampling releases, per discussion at October meeting.

3. Correspondence and Communication [00:11:00]: Jane Keon, Chair

   1. News article in Morning Sun about former CAG member, Murray Borrello, appointed to the state’s Environmental Permit Review Commission. The CAG is excited about the appointment and extends congratulations.

   1. News articles in Morning Sun and Gratiot County Herald about new leak in old slurry wall. These articles prompted calls from community members requesting clarification on whether the leak was a new discovery, which Jane clarified, as well as sent an email to the reporter to clarify that while there were old issues with the slurry wall, this was a newly discovered leak and to reinforce the difference moving forward.

   1. Letter to state senators about Michigan Public Health Institute (MPHI) contract language. See remarks under Old Business.

4. Program [00:13:38]: Theme Backgrounds for New Website, Ed Lorenz, Vice Chair

   1. New layout inspired by review of other non-profit websites, particularly those related to environmental issues (i.e. Audubon Society, Circle of Blue, Nature Conservancy). Key features:

      1. Fundraising is a primary focus—efforts to acquire donations to support long-term health studies as well as work of CAG.

      1. Images that are visually appealing, as well as help tell important stories, with quick links that facilitate navigation.

      1. Headings in tool bars are clear and concise, as well as reflect areas of focus.

      1. Clear mission and goals.

   1. Themes available on WordPress website are in the thousands. Ed requests suggestions or top choices from CAG members. Choices should be guided by:

      1. Visual appeal — Easy to read, clear purpose, concise in narrative.

      1. Whether the site will convey information quickly and easily — Many websites focus on membership as the primary audience, as opposed to being a tool for (a) outreach and recruitment, which we aim to do, as well as (b) provide information on contamination, CAG activity, and collaborations.

   1. Headings and themes revised based upon keywords and purpose:

      1. Home (Mission, Membership, Contact, Meetings, Minutes, Leadership Team, Finances, Legal Background, Bylaws)

      1. Our Work (Location, Partners, Public Officials and Agencies, Private Stakeholders, Media)

      1. Time Line

      1. Resources (Documents, Photos, Films/Videos, Names & Terms)

      1. Get Involved (Contact Form, PBB Registry, Elected Officials)

      1. Press Room (recent news stories)

      1. Store (Membership, Donation, Buy Stuff)

   1. Materials Needed:

      1. Good photos, especially of meetings and community (send to lorenz@alma.edu)

      1. Short (two-sentence) bios from board members that explains their work with and connection to the community, as well as a phone number and email address, and photo.

      1. Decide on a phone number for the CAG — whose?

      1. Get an agreed upon email for the CAG.

   1. Discussion

      1. There is a place for site visitors to submit questions to the CAG, but there was difficulty accessing them and many of the messages were junk/spam. Be sure that there is a filter, but also, an opportunity for communication.

      1. The CAG is grateful that Ed has taken this on, especially with his experience and work with the organization since its formation. (Thanks, Ed!)

5. Technical Report [00:43:00]: Scott Cornelius, Cornelius Environmental Consulting

   1. In August EPA released the data evaluation report for up-gradient slurry wall (UGSW) investigation (i.e. existing slurry wall) and in September they released the findings of carbon amendment pilot study phase one. Scott had a technical meeting with EPA consultants, EGLE, and Alma College, from which he developed list of questions over two topics and presentations.

      1. Slurry Wall: EPA has released brief summaries, which are overall optimistic. Critical review of both the UGSW and carbon amendment pilot study, however, do not support some of the findings. For instance, EPA reports that the UGSW is performing as designed, but their findings revealed a new leak in a portion of the wall EPA seeks to reuse. The purpose of the investigation was to determine if part of the slurry wall could be reused to save money, despite long-term failure of the rest of the wall, but the CAG is opposed to being pennywise if it would endanger community health and wellbeing. Moreover, the investigation was limited (i.e. the wall is 3,100 feet long, EPA took 5 samples amounting to 1.25 feet total). They also found an area where construction materials did not meet minimum requirements to prevent penetration/movement of groundwater. Scott will consult with the CAG executive committee to work out final comments and questions for EPA, which are lengthy and detailed.

      1. Carbon Study: Similar issues. EPA reports evidence of binding with contaminants, particularly DDT, downriver from the dam. Sampling of worms prior to application of carbon and post application showed 60% decrease in contaminants, but the data for background worms without treatment showed 84% reduction. So there must have been many uncontrolled variables causing differences, such as the variation in the concentrations of chemicals in soils and sediments. The variation in sampling could account for that reduction, but data doesn’t demonstrate if carbon had any affect or if it was just variation in sediments. EPA intends to do another phase and perhaps this is something that should be taken into consideration.

         1. Also, to bind, carbon has to be in direct contact with contamination and, in this study, application was only in the top inch of surface soils and distributed widely, but this is not an adequate form of delivery for the remedy as again, there may be migration and variation in concentrations of contaminants at deeper levels. This is a common stumbling block—finding a good way to deliver a treatment. Even if there were a 100% reduction in the top inch, there could still be contamination below, which could continue to move. We have to remember that these contaminants bioaccumulate and biomagnify. The treatment therefore seems to have many problems, which phase one did not figure out.

         1. Solid phase micro-extraction conducted with Alma College Lab collaboration, the absorption process is known as bioavailability wherein a fiber is intended to absorb DDT, similar to how worms do. However, worms migrate through different levels and therefore are exposed to variety of contaminants. This is why, for instance, in fish consumption advisory studies they use native rather than caged fish because they move throughout the ecosystem. Fibers don’t move, worms do. EPA must proceed with worm collection and not depend on fibers.

         1. Another question the CAG continues to ask is: what species of worms inhabit the floodplain? This is just as important with fish consumption studies. These differences matter.

         1. Another missing component of the carbon amendment study is the dose and response curve. This requires lab work but will help with interpretation of field data. The carbon amendment study (and Dr. Harwood’s conclusions) demonstrate that there are not enough samples taken or replicas, or statistical analysis about spreading the material (visual observations vs. quantitative measurements).

      1. Essentially, the design of study was inefficient to achieve the goals outlined and the CAG has many comments and questions.

   1. Discussion [01:05:00]

      1. What is being done to monitor the groundwater in St. Louis with the breach in the slurry wall?

         1. Diane Russell, EPA: There is no indication that there is an imminent or immediate threat and if there were, there is a mechanism that would be triggered. ANPs are on city water, there are monitoring wells in the neighborhood, and there has been sampling.

         1. Liz Braddock, MMDHD: There is long-term (annual) sampling of wells not yet connected to city water. This is groundwater monitoring for those residents currently using wells for drinking water. This includes 10-11 properties, under contract for 2021 to be connected to city water soon.

         1. Jane Keon requested information from EPA for the location of monitoring wells in the neighborhood itself.

            1. Diane: There are monitoring wells in ANP and included in the work plan, which is available on the website.

         1. Concern expressed about ANPs with basements that get water seepage regularly, which was groundwater related and demonstrates that this isn’t just a drinking water issue. How do we know if there is monitoring or whether there may be issues with this?

            1. Jane proposed another survey of ANP, which Jim and Gary undertook a few years ago, to see if there is seepage.

            1. Jim Hall asked EPA to do the survey this time. Diane will pass the request on to Tom.

6. EPA Report [01:17:50]: Diane Russell, Community Involvement Coordinator

   1. Groundwater investigation: Jacobs (contractor) finished sampling both on- and off-site, including MW-19 area, ANP wells, wells near slurry wall gap, MW-48, and wells near river. The work plan is accessible at the following link: https://semspub.epa.gov/work/05/962314.pdf

   1. State of progress in Area 2, Phase 2 of the Velsicol Site: Construction continues, including new electrical circuit under North Street, liner installation complete, and 50% of air lines, water lines and heaters have been installed. Project is on schedule for startup in mid to late March 2021.

   1. State of progress on OU-3 and OU-4 of the Velsicol Site: EPA awarded a new contract for Otie/Jacobs for the RI/FS and is on schedule to release RI for OU3 in early 2021, and discussions can begin on the next phase of the carbon amendment study.

   1. Other site work: DNAPL/groundwater collection trench is operating under a new contract and continues without issue. No additional DNAPL recovery from the manholes. The City awarded the contract for the Well 12 installation and drilling is underway, with operation anticipated by fall 2021. EPA is working on a new contract for Remedial Design (RD) likely to be awarded in spring 2021.

   1. Discussion

      1. Gary followed up on request for list of property owners.

7. EGLE Report [01:30:00]: Erik Martinson, Project Manager

   1. No major updates on railroad spur contamination site, as EGLE continues to be delayed by Mid-Michigan Railroad for access to property. Westin (consultants) will reach out again. Erik will also draft a letter requesting a formal response.

   1. Erik shared information related to well locations in ANP, too, based upon his prior work with Westin, which includes cluster wells on North, Bankston, and Watson Streets, with another set on the corner of Mill and North Street. Each of those well clusters include shallow, intermediate, and deep wells, with shallow being best connected to the issues in ANP.

8. Old Business [01:33:40]

   1. PBB Leadership Team Update – Ed, Jane, Brittany, Norm

      1. Jane helped draft a letter to senators thanking them for their assistance and support with PBB records, but also draw attention to ongoing challenges related to participant and researcher access. MDHHS and MPHI have proposed a new solution wherein they would assign new identification numbers to each record rather than maintaining original PBB IDs, but they would destroy the key with linkages for both IDs preventing future matches and studies, including death and cancer data, for which Emory has funding to do. We believe senators have made some phone calls because the state health department is now indicating a willingness to revisit identification numbers and the cancer match. CAG and PBB Leadership Team members have reviewed state and federal public health codes—and cited both—in correspondences, emphasizing the importance of public health authority in these cases.

      1. Latest MPHI loss of data again (previously, data on a lost flash drive): Data in their system was deleted from servers and they claim that those participants have withdrawn from the study when they have in fact not—Emory has printouts provided by MDHHS when data was complete, providing evidence for deletion. This is yet another difficulty in a long list.

      1. Blood draws for clinical study must continue on time and have been made possible because of an advisory board member working with a phlebotomist, with help of St. Johns MMDHD. However, due to latest emergency orders, we received word that the draws this weekend have been postponed. There are a lot of people who have already finished the trial and many more beginning.

      1. Discussion

         1. Data on withdrawals over the life of the PBB Registry suggests that there weren’t many associated with data breaches, even though the loss of participant information is troubling. Since involvement with Emory, only 14 have withdrawn, compared to major withdrawals in 1970s due to lack of follow up by the state.

         1. Emory has developed a form for family to add deceased relatives to study, even if previously withdrawn.

      1. The epigenetic study continues, with small number of three generation families who have agreed to participate, but some having a hard time getting necessary family members to do so.

   1. Decision on archival destination: The Executive Committee voted last month that CAG materials and records will henceforth be donated to the Clarke Historical Library at CMU. Many of the records are already there and this will grow and make collection accessible.

      1. Transfer of additional records from EGLE for CMU, with records from 2012 to 2020 need added at some point too.

9. New Business [01:49:45]

   1. Report on Historical Society of Michigan History presentation – Ed, Brittany: The HSM invited Ed to present on the history of the PBB mix-up and he invited Brittany to co-present. Ed focused on the lessons learned from the mix-up, providing insight into the St. Louis community’s experiences and CAG work, while Brittany talked about the Michigan PBB Oral History Project. There were approximately 120 people who signed into the presentation via Zoom, with a few people reaching out to both Ed and Brittany for additional information and to share insights.

      1. Brittany will email the hosts to see if there is a recording that can be shared.

   1. Vote on CAG Hall of Fame nominees (by email or Zoom meeting poll):

      1. Bernie Bessert – founding member of CAG and farm family member.

      1. Murray Borrello – founding member who teaches environmental sciences at Alma College and has been appointed to state commission. He remains very active in upstream cleanup efforts.

      1. Norm Keon – founding member and state health department employee, epidemiologist for a number of county health departments, as well as very active in PBB Leadership Team and CAG.

      1. George Kubin – mayor of St. Louis for many years and instrumental in bringing new water system to city, convincing DOJ and EPA through a lawsuit to support.

      1. Ed Lorenz – retired political science and history professor at Alma College, as well as founding and active member of CAG and PBB Leadership Team.

      1. Melissa Strait – chemistry professor at Alma College, founding member and secretary for several years.

   1. Annual Christmas Potluck and Hall of Fame Award: Plaques will be made and then executive committee will have to determine how best to award.

Next meeting date: December 16, 2020

Meeting adjourned at 9:04 pm.

Respectfully submitted,

Brittany Fremion, secretary

General Membership Meeting Minutes – October 21, 2020

The meeting began at 6:53 pm via Zoom with Secretary Brittany Fremion as host, with at least 20 participants.

Chairperson Jane Keon called the meeting to order at 7:04 pm.

1. Minutes for July were approved with changes (Liz/Wayne).

2. Treasurer’s Report [00:01:25]: Report delivered by Gary Smith, Treasurer.

   1. Gary reported that the General Fund Checking balance stands at $5,307.56. The Money Market Account (Oxford Automotive settlement) has $65,042.72, TAG grant money available for the Former Plant Site (FPS) stands at $22,359.26. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $80.62. The complete reports will be attached to the permanent minutes.

   1. EPA denied the CAG’s final objection over payment to technical advisor.

   1. Quarterly Performance and VBP Output and Outcomes Reports submitted by secretary and treasurer to EPA for TAG Program.

3. Correspondence and Communication (shared via agenda).

   1. News articles in Gratiot County Herald, Morning Sun, Circle of Blue, Environmental Health News, and Great Lakes Now about progress at the plant site, the virtual PBB Community meetings, past environmental disasters, and current pollution problems in the Pine River.

   1. Quarterly Progress Report for the Velsicol Site.

   1. Velsicol Burn Pit Outputs and Outcomes.

1. Technical Committee Report [00:08:00]: Report delivered by technical advisor, Scott Cornelius of Cornelius Environmental Consulting.

   1. Update on discussion with EPA, EGLE, consulting firms and Alma College representatives following a conference call on October 2, 2020, about slurry wall investigation.

   1. Presentation on EPA Slurry Wall Investigation. The slurry wall was installed by Velsicol in the early 1980s.

      1. Objectives of investigation were to: (1) evaluate the effectiveness of the upgradient slurry wall (UGSW); (2) conduct a data evaluation to assist in the design of a perimeter containment and groundwater collection trench (i.e. prevent migration); and (3) apply similar investigation methods to previous slurry wall evaluations. The focus of investigation is on the portion of the wall along adjacent neighborhood properties (ANP), away from the river, with hope of retaining that portion.

      1. Conclusions from study [00:47:00] reveal that (1) groundwater mounding inside the UGSW is apparent over majority of extent, indicating that it is working as a barrier to groundwater flow over majority of the area; but, (2) groundwater appears to migrate along the UGSW area near ANP, suggesting it’s not completely keyed into the till, which is the portion EPA seeks to retain.

   1. Discussion:

      1. [00:49:00] CAG hopes for further study, which takes community concerns into consideration, especially with possible breach in slurry wall EPA seeks to keep. The ROD signed in 2012 stipulated a new wall around the entire plant site. When EPA suggested reusing wall along east side of plant site, community and CAG, especially raised questions of legality. CAG also wants to ensure the wall safe and there’s much distrust in walls integrity following RI and now this investigation. Further investigation needed.

      1. [00:55:00] Concern expressed about investigation and breach, especially over health of Pine River and drinking water supply. Scott Pratt, EPA consultant, clarifies that dye test results reveal that while there is some migration, it is well below any level of concern. He also pointed out that this has been an issue since the UGSW was installed—it’s not new. Jane Keon, CAG chair, reinforced community preference for 2012 ROD sheet pile wall around entire perimeter, rather than reusing any portion of UGSW as EPA suggests. In addition, ROD includes pumping wells that will be installed around the site to collect contaminated groundwater for treatment at an on-site plant, providing an additional barrier.

      1. [1:07:00] Data in mid-1990s showing that water migrates off plant site (ATSDR 1993 indicated the system is failing), based on other data, which investigators should find and consult. It’s important to know that there is additional evidence that demonstrates the UGSW is a long-term failure because original remedy was not a good one.

2. EPA Report [01:09:00]: Tom Alcamo, Project Manager.

   1. Update on Area 2, Phase 1 of the Velsicol Site: no update.

   1. State of progress in Area 2, Phase 2 of the Velsicol Site: EPA is now working through the winter to prepare the site, which includes removing all heaters and refabricating for new area with additional changes made to the flexible membrane liner, extraction wells, and liquid lines associated with the system. The treatment plant has been winterized as well. Big news is work with city to provide additional electricity to the site; the city will be boring under North Street to do so. Expected to finish preparing the site in January with start up by late March. Money is available for work, despite funding at EPA being really tight, especially for design work (EPA end of year is October 1), which will be done primarily next year. Additional sampling will be done this fall and presented at November meeting. Predesign for perimeter drain and barrier wall, with possible addition of collection trench, in the works too.

   1. State of progress on OU-3 and OU-4 of the Velsicol Site: Expect to finish carbon amendment study (RI and/or FS) in early January. Still waiting on some property owner releases for floodplain work.

3. EGLE Report [01:17:30]: Erik Martinson, Project Manager.

   1. No progress in connecting with Dr. Matt Zwiernik regarding dead bird and nest/egg studies.

   1. EGLE plugging Dow brine wells in Gratiot County, with closes being right on county line. There are a number that are along the Pine River, but none within St. Louis city limits. The project will take about 10 years to finish, with next set of wells expected to be done in next year. There are some Velsicol brine wells in area.

   1. Still facing complications with railroad company over access, but intend to continue to pursue so that the investigation can proceed. Erik will clarify questions about work plan with Gary.

4. Old Business [01:27:00]:

   1. Progress on website improvements: Ed Lorenz, vice chair, has most of the narrative for the website prepared, it just needs published to the website by Matt Ogle, CAG tech guru.

   1. Report on virtual PBB Community meetings: Ed, Jane, and Brittany all participated. Approximately 180 people total attended the meetings.

Meeting adjourned at 8:39 pm.

Respectfully submitted,

Brittany Fremion, secretary

General Membership Meeting Minutes – September 16, 2020

The meeting recording is available at the following web link with the password below, with timestamps included in minutes:

Meeting Recording:https://us02web.zoom.us/rec/share/7D-alTEfGVadSF1Cv2s3wb4gndosREPe4OYvvXx7MAVciUipmtkyCeCfTFu_KQqY.YZ5-b-LfCvyrUHXX

Password: %m7LEz3d

The meeting began at 6:50 pm via Zoom with Secretary Brittany Fremion as host, with 18-20 participants.

Chairperson Jane Keon called the meeting to order at 7:00 pm.

1. Minutes for July were approved with changes (Wayne/Gary).

2. Treasurer’s Report [00:00:20]: Report delivered by Gary Smith, Treasurer.

   1. Gary reported that the General Fund Checking balance stands at $4,782.52 following payment to Technical Advisor (May invoice). The Money Market Account (Oxford Automotive settlement) has $65,037.37, TAG grant money available for the Former Plant Site (FPS) stands at $24,415.51. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $80.62. The complete reports will be attached to the permanent minutes.

   1. EPA denied CAG objection to ruling about dispute over payment for technical advisor. Gary submitted a second letter with additional materials requested by EPA.

   1. Technical Assistance Grant (TAG) money may not be used for Zoom meetings despite the need for virtual meetings to adhere to social distancing guidelines established by the state during the global pandemic, per CFR 200.6 and starting August 13, 2020. Tom Alcamo/Diane Russell (EPA) will look into other platforms that might be eligible.

   1. TAG for Velsicol Burn Pit (VPB) extension application revisions needed. CAG will resubmit with greater detail for output and outcomes per EPA request.

3. Correspondence and Communication [00:12:30]: Report by Jane Keon, Chair.

   1. Newsletter from Diane Russell with update on former plant site projects.

   1. Chair received letter from oldest child of Donald Wilkinson, who started MCC with his brother and sister. Linda has read Jane’s book, Tombstone Town, and wanted to provide additional detail about her life and time in St. Louis.

   1. Agenda lists

      1. Press release to media on EPA picking the right spot (Area 2, Phase 1);

      1. Press release on upcoming virtual PBB Community Meetings;

      1. Newspaper and radio coverage on DNAPL quantity, thermal treatment, and slurry wall investigation.

4. EPA Report [00:19:25]: Report delivered by Tom Alcamo.

   1. Improvements made to EPA Velsicol Chemical (and Velsicol Burn Pit) webpages, including public presentations since 2015. Diane Russell reports that programs and reports will be posted there, organized by topic.

   1. Design for VBP has to be revised, in part because of new contracting system (every contract in Region 5 is ending so a new bid process will begin). CAG can expect new specifications to be prepared early next year. Budget for Superfund is extremely tight, but there is currently money for Velsicol sites.

   1. Jason Cole and Scott Pratt delivered a program on diminishing returns translating information in EPA memo on Area 2, Phase 1 [00:28:30].

      1. The site was just over an acre in size with 52 multi-phase extraction wells and heated with 242 thermal conduction heaters. The temperature was monitored at 16 locations across the treatment area with 13 pressure monitoring points. The system ran through Monday, September 14, for a total of 348 operation days. The system recovered around 182,998 pounds of contaminants via 12 megawatt hours and treated nearly 4.1 million gallons of extracted water, amounting to a “substantial undertaking.”

      1. The system was determined to have reached its operational ending point via diminishing returns. According to the 2012 ROD, diminishing returns is defined as “the performance standard for operation of the ISTT systems” and “relies upon multiple lines of evidence to demonstrate that the physical capacity of the ISTT system to remove contaminants from the subsurface has been reached.” The evidence for Area 2, Phase 1 demonstrates such, and includes:

         1. energy input—“treatment of the source area using ISTT has reached an asymptotic rate of COC recovery” (i.e. has contaminant recovery decreased with time);

            1. Indeed, contaminant recovery decreased with time even though heating remained above 100 degrees Celsius.

               1. There was a “pause” around day 100, but thereafter a peak in vapor phase concentration as temperatures reached 80 degrees Celsius. As time and temperature continued to increase, vapor concentrations dropped, but massive recovery of NAPL began. From day 175 forward, there was a corresponding increase in rate and cumulative recovery. Then it plateaued in the last month of system operation, with nearly 183,000 pounds of NAPL recovered.

         1. temperature—“additional input of subsurface energy will not increase COC mass removal rate” (i.e. do we see a characteristic or demonstrable change in rate or mass of contamination removed with continued heating);

            1. Energy input reached a point where it did not change mass removal rate.

               1. For almost half the project duration, the subsurface temperature was greater than 100 degrees Celsius, a substantial amount of time and temperature, or energy input, reaching about 40,000 kW per day. Around day 250 the system recovered nearly 22,000 pounds of NAPL in a single day, which wouldn’t have been recovered without prolonged heating.

         1. and contaminant recovery—“extended operation of the ISTT system offers no further reduction in DNAPL mobility and migration from shallow outwash” (i.e. if we continue to operate system, can we remove any more NAPL which is potentially mobile from the subsurface).

            1. No further reduction of NAPL mobility and migration with extended operation of system. The recovery rate analysis indicates that the contaminant reservoir is depleted.

               1. Continued operation would not alter ultimate end point.

         1. Energy input at Area 2, Phase 1 site exceeds industry practice—and was almost double that of Area 1, which also exceeded the standard.

         1. Treatment ended Monday, September 14, 2020.

         1. Per CAG request, six post-treatment borings 2-5 feet into till demonstrated that contaminants and mobile NAPL removed. Samples taken from areas where NAPL would be most likely to be located. While not required line of evidence, conducted to reassure CAG and community.

         1. Next Steps:

            1. ISTT heater removal and equipment redeployment commissioned for 9/2020 to 12/2020;

            1. Complete construction of Area 2, Phase 2 between 10/2020 and 3/2021;

            1. And Area 2, Phase 2 operations projected for 4/2021 to 11/2021.

   1. Program discussion [00:53:55] included questions about DBCP presence and other chlorinated and brominated compounds recovered by system, which were confirmed present in very substantial concentrations, as well as some unidentified compounds, in the NAPL. Project team also explained that NAPL from this site was different in appearance and weight than that recovered in Area 1. Conversation closed with consideration of how these contaminants migrated in the environment and consequences of human exposures, especially in 1960s and 1970s.

   1. Tom Alcamo [01:17:27] reports on slurry wall investigation and reveals that there’s a 50 foot gap near Watson Street that has likely been there since Velsical installed it. Evaluation of groundwater between 2015 and February 2020 does not show changes in concentrations, but EPA will need to determine if groundwater could get through the gap. EPA is planning a webinar and collaboration with Alma College faculty and students, which could help with monitoring.

   1. The carbon amendment pilot study is complete [01:21:17] and report done. There were 50 10×10 grids and used about 8,000 pounds of carbon. The study began in August 2019 with samples taken in November 2019 and May 2020. Quick results: 66-79% reduction in DDT levels in worms. Dr. Amanda Harwood will give a webinar. EPA hopes to move into next phase of study in spring 2021.

   1. Video of DNAPL sent to lab for evaluation shared with CAG from Area 2, Phase 1 [01:27:25]—it was really dense, almost 17 pounds per gallon (note: a gallon of water is 8.34 pounds).

5. EGLE Report [01.31:48]: Report delivered by Erik Martison.

   1. Bird study still on hold because Dr. Matt Zwiernik is out of the country with uncertainty about his ability to complete follow-up study. There remains an intention to complete the study, but at this time there are budgetary issues preventing EGLE from getting to it before the end of 2021 (i.e. planning).

   1. Railroad spur investigation is moving ahead. EGLE has access to three of four properties—the final property owned by Mid-Michigan Railroad. Once access to parcel is granted, EGLE hopes to start drilling (end of October). Some questions about scope of work and map denoting borings.

6. Old Business [01:40:30]

   1. Virtual PBB Community Meeting dates and format announced, with CAG members participating in community panel (J.Keon and Lorenz).

   1. Progress on website improvements reported by Vice Chair, Ed Lorenz.

   1. Follow-up discussion by Vice Chair, Ed Lorenz, about EGLE webinar on PFAS and concerns about possible contamination connected to Lobdell, which had twice as many employees than Wolverine and Total, so it was a larger operation, but is not yet listed as probable PFAS site.

7. New Business [01:49:19]

   1. Presentation by JoAnne Scalf on the Pine River Superfund Voluntary Health Map, which documents health issues among St. Louis residents via a voluntary health questionnaire. She argued that the data for the community is skewed by the prison population, but when removing the 3,500 incarcerated individuals in the community, the incidence of cancers, for instance, is above national averages. In addition to collecting information on specific health outcomes, the comment section of the questionnaire has garnered additional information, such as the unexpected number of women under 40 who have had hysterectomies.

      1. JoAnne presented her work on the Voluntary Health Map at the From PBB to PFAS Symposium at the University of Michigan in February 2020, with the hope that she would connect with researchers who could help monitor and evaluate resident health, which might be replicated in other communities.

      1. The Map includes three generations of residents with more than 600 data points.

      1. An epidemiologist at the University of Michigan is interested in working with JoAnne to grow the project and identify correlations with the PBB community. She will keep the CAG updated on their work.

      1. JoAnne’s work underscores the significance of community knowledge and represents a tremendous effort to document health outcomes.

Meeting adjourned at 9:06 pm.

Respectfully submitted,

Brittany Fremion, Secretary

Quarterly Progress Report

Velsicol Superfund Site, OU1, OU2, OU3, OU4

September 30, 2020

Report Number: 91

Report Period: July 1, 2020-September 30, 2020

Grant Recipient: Pine River Superfund Citizen Task Force

Recipient Group Representative: Gary Smith, Treasurer

Report submitted by: Brittany B. Fremion, Secretary

Progress Achieved:

Heating concluded for Area 2, Phase 1 at the former chemical plant site on September 14, 2020.

Almost 183,000 pounds of DNAPL recovered from Area 2, Phase 1 of chemical plant site, more than double the amount expected.

The carbon amendment pilot study is complete in OU-3 with report expected in October.

The slurry wall investigation is complete, report expected in October.

Progress in Area 2, Phase 2 continues, with construction beginning in October 2020 and operations projected for April to November 2021.

Materials Produced this Quarter:

July, August, September Technical Committee meetings cancelled due to COVID-19.

The Executive Committee met twice, once in July and again in September.

General Membership meetings were held via Zoom in July, August, and September.

CAG leadership communication outside remote meetings continued via email and phone.

CAG membership received monthly updates from Chair, Jane Keon, via email and at remote meetings.

CAG Chair communicated with EGLE project manager, Erik Martinson, regarding several studies (i.e. bird/nest study and railroad spur).

CAG Chair interviewed by WCMU and Morning Sun about thermal treatment at former plant site (July).

CAG submitted a follow-up letter in response to EPA decision over technical consultant invoice.

CAG Chair communicated with hydrologist, former chemical plant worker, technical consultant, and executive committee about underestimation of DNAPL and potential migration of chemicals at former plant site.

CAG sends letter to EPA requesting Emergency Removal Action (ERA) following discussion at July general membership meeting.

CAG submitted additional letters following EPA response to underestimation of DNAPL collected in Area 2, Phase 1, as well as final reports for (1) carbon amendment pilot study, (2) slurry wall investigation, (3) downstream study, and (4) riverbank sampling near dam.

CAG Chair communicated concerns about final reports on various projects, as well as underestimation of DNAPL and potential migration of chemicals following heating at Area 2, Phase 1, with EPA project manager, Tom Alcamo.

CAG member (Lorenz) attended an EGLE webinar about PFAS contamination sites in Michigan in August.

CAG member (Lorenz) compiled research connected to possible PFAS contamination from Lobdell plant site, which he shared at the August and September general membership meetings.

CAG executive board members discuss archival collection at Alma College and consider transfer of materials to Central Michigan University’s Clarke Historical Library.

Additional CAG records donated to Clarke Historical Library at CMU.

CAG member (Smith) distributes digital document for in-kind reporting.

CAG member (Brabaw) develops Google spreadsheet to compile data for quarterly reporting, following EPA feedback on last TAG extension request.

Multiple press releases sent to local and national outlets about progress of Area 2, Phase 1 project at chemical plant site, virtual PBB community meetings, DNAPL quality, and slurry wall investigation.

Four CAG officers (J. Keon, N. Keon, Lorenz, Fremion) took part in monthly PBB Leadership Team conference calls with researchers from Emory University on July 10, August 14th, and September 11th.

CAG members present at (Lorenz, Keon, Fremion) and many others attend the PBB Registry virtual community meetings on September 22 and 26th (Hoyt, Brabaw).

CAG continues work to revise and produce new narratives for the organizational website in preparation for a major update, as led by the sVice Chair.

Agenda and minutes for monthly CAG membership meetings produced and distributed.

CAG officers submit time/expense sheets to Treasurer, Gary Smith.

All documents produced in accordance with TAG grant guidelines and paid for with TAG money are forwarded to Region 5 by our Treasurer and reference appropriate TAG deliverables.

The quarterly progress report was assembled and submitted.

Difficulties Encountered:

Reports on the slurry wall investigation and carbon amendment experiment are complete, and we are eager for the promised public presentations.

The second year downstream wildlife study is still three years overdue.

We still have not seen results for the bank sampling downstream from the dam.

CAG still waiting to see EPA design work for Burn Pit site.

We continue to use volunteer hours to dispute a withheld payment in the TAG program.

We still have no data on the spills along the Velsicol railroad siding.

CAG officers pay out-of-pocket to cover cost of a Zoom account in order to hold remote meetings to keep general membership updated on our efforts, as well as facilitate work with EGLE and EPA.

Outputs Outcomes

Remedy: Heating concluded for Area 2, Phase 1 at the former chemical plant site (9/14/2020). Almost 183,000 pounds of DNAPL extracted—more than double the amount estimated. Ongoing efforts to reduce contaminants at the plant site address community concerns about environmental health. The CAG’s ability to engage with EPA proves significant in helping to inform site remedies as well as translate work for the community.

Public Outreach: Press releases sent to local and national outlets providing updates on Area 2, Phase 1, DNAPL quality, thermal treatment, slurry wall investigation, general membership meetings, and virtual PBB community meetings. Press releases are an important means of relaying information about ongoing remedies to St. Louis residents and the wider Gratiot county community, as well as alert the general public of our progress. CAG Chair also participated in interviews with WCMU and The Morning Sun.

Community Engagement: Monthly CAG meetings resumed remotely via Zoom due to COVID-19. CAG officers host remote meetings monthly for the general membership, with approximately 18-26 participants at each meeting held via Zoom. These meetings are vital to our ability to keep community members updated, as well as facilitate work with EGLE and EPA. In addition, the CAG chair provides monthly updates to membership via email.

Presentations: Four CAG officers took part in monthly PBB Leadership Team conference calls with researchers from Emory University The PBB Registry community meetings were held virtually due to COVID-19. CAG members served on panel and gave presentations (9/22 and 9/26), facilitating community involvement in the investigation of long-term human health impacts tied to the Velsicol sites.

Communication: CAG submits several letters following up on EPA responses and delays with reporting. Communicating ongoing concerns about EPA investigations is vital to the community and facilitates a working relationship between both entities. At least 5 letters are drafted, reviewed, and sent.

Reporting: All documents produced in accordance with TAG guidelines and paid for with TAG money are forwarded to Region 5 by our Treasurer and reference appropriate TAG deliverables. These products keep everyone informed on the current challenges and successes of the CAG. Our ability to work with technical consultants facilitates ongoing work with EPA and empowers community members as stakeholders in remedies.

Education and Outreach:CAG continues to revamp website and work with local educators. Our CAG meetings are the focal point for community members to let EPA know of their concerns, such as disclosing information about other dump sites. Our efforts can be grown by enhancing the organizational website to better reflect our purpose, offer opportunities to connect, and share sources relative to our work.

Documentation: CAG explores opportunities to grow historical record by expanding archival collection. The CAG, in collaboration with faculty, staff, and students at Alma College, has built a collection of archival documents spanning nearly two decades. Some of the materials were digitized by MDNR (now EGLE) and a portion preserved in the Clarke Historical Library at CMU. We continue to consider how to best make the materials accessible to community members, but also educators and researchers.

Activity Anticipated in Next Quarter:

Preliminary results and presentation of carbon experiment in the downstream flood plain.

Results and presentation on slurry wall investigation.

The report from the second year of study downstream (OU-3).

A formal report on riverbank sampling for DDT levels around the edge of the high school athletic field.

The Design Plan for the Velsicol Burn Pit Superfund Site.

The wildlife toxicology study for OU-4 of the downstream portion of the Pine River.

Resolution of the dispute with EPA over payment to our technical advisor.

Website updates.

General Membership Meeting Minutes: August 19, 2020

The meeting began at 7:00 pm via Zoom with Secretary Brittany Fremion as host, with 20-23 participants.

Chairperson Jane Keon called the meeting to order at 7:01 pm.

1. Addition/Revisions to Agenda

2. Minutes for July were approved with changes (Ed/Doug).

3. Treasurer’s Report [00:04:00]: Report delivered by Gary Smith, Treasurer.

   1. Gary reported that the General Fund Checking balance stands at $4,853.48 following payment to Technical Advisor (May invoice). The Money Market Account (Oxford Automotive settlement) has $65,031.85, TAG grant money available for the Former Plant Site (FPS) stands at $24,415.51. The Velsicol Burn Pit (VBS) has $48,744.28. Velsicol Burn Pit (VBP) Fund Checking $80.62. The complete reports will be attached to the permanent minutes.

4. Correspondence and Communication [00:14:15]: Report delivered by Jane Keon, Chair.

   1. EPA Newsletter

   1. Letters to EPA requesting Emergency Removal Action (ERA) and follow-up on underestimation of DNAPL recovery from thermal treatment in Area 2, Phase 1.

   1. Press coverage

   1. Request for extension of Technical Assistance Grants (TAG) for Velsicol Burn Pit site. No expenses because of limitations in available electricity for treatment.

5. EPA Report [00:19:25]: Report delivered by Tom Alcamo, EPA Project Manager.

   1. Update on heating and DNAPL collection in Area 2, Phase 1.

      1. Site is still on lockdown because of covid-19, but continue to run thermal system. No additional recovery of DNAPL in last 3.5 weeks. Most DNAPL recovered between early May and July. DNAPL recovered in Area 2, Phase 1 is heavier in nature (approximately 17 pounds per gallon) with around 179,000 pounds (revised) recovered and removed by a total of 12 tankers with the last on site July 2. Contractors remain vigilant with weir tanks. There have been no changes with the collection trenches. Already reached diminishing returns in vapor phase; will start looking for diminishing returns in liquid phase (just started analysis). EPA did six borings in worst areas recently and waiting on report, but visually it looks good. EPA also awarded a new contract for operation of collection trench due to changes to contracting mechanism/conclusion of previous award. Contract awarded to United Total Integrated Systems, which is a joint venture with [CH2M current firm?][1] and a Native American firm out of Wisconsin on August 1.

   1. Plans for Area 2, Phase 2. [00:25:25]

      1. EPA is using different procedures for construction firms and with changes to contract process, expect to begin thermal treatment in Area 2, Phase 2 next spring or summer, which would run until end of 2021 or early 2022. In summer of 2021 EPA will begin procurements for excavation of PSAs 1 and 2, which will be very laborious. Goal to begin excavation of PSA 1 and 2 in March 2022. This fall EPA will focus on design of groundwater system and vertical barrier wall, as well as in situ chemical oxidation areas that need addressed. EPA will also do bench studies on HBB and DDT. Those studies are dependent on funding, but EPA confident. Groundwater treatment is a more complicated design with need for more treatability studies, especially with perimeter drain (to lower elevation of water in site below that of river), so much modeling needs to be done in order to begin.

   1. Report on slurry wall investigation. [00:28:30]

      1. Finishing up review of data and anticipates release of report very soon. Preliminarily can say that there is a breach in the wall up gradient, which will be in the report.

   1. Carbon amendment study update. [00:29:00]

      1. Amanda Harwood made some changes, so EPA just received data. Will release report in next 30 days.

   1. Discussion of ERA request. [00:29:40]

      1. Report on EPA response to CAG letter requesting ERA with clarification provided by EPA in discussion with CAG and TA, Scott Cornelius. EPA hopeful treatment in Area 1 took care of any migrating NAPL. EPA sees no change in data from 2008-2016, with additional sampling to be done. Site doesn’t meet requirements for ERA because not “imminent or substantial danger,” but being addressed as part of ongoing remedial program.[2]

      1. EPA believes thermal treatment has improved quality of groundwater in area, even if leaking, with additional sampling to be done this fall. If EPA finds evidence of NAPL flowing into river from site, then may trigger ERA Program.

   1. Discussion of underestimation response letter. [00:45:10]

      1. CAG again asked why so much more DNAPL than expected in Area 2, Phase 1. EPA provides detailed information in letter, as well as argues cause linked to the location of treatment; based upon significant amount of DNAPL recovered, EPA argues that the treatment is in the right spot, especially with density of DNAPL, and that the technology is working and will reduce costs to state.[3]

      1. Discussion of public participation, especially CAG involvement, in EPA design processes and reporting.

      1. PBB production facility located on Area 2, Phase 1 site.

6. EGLE Report [01:03:00]: Report delivered by Erik Martinson

   1. Railroad Spur Contamination Site

      1. Weston is done with historical review of railroad spur contamination site. EGLE waiting to approve study after requesting a few changes. There are some issues with access to a few parcels which has delayed work, but EGLE hopes to resolve them soon (i.e. unclear ownership/parcel designation). Weston also needs to issue RFP for drilling contractor and set up lab. EGLE hopes to get into field mid-September.

      1. Residents can expect to see driller and driller helper, with level D suits. Drilling will consist of 30 borings from sidecar rail by former creamery site and 30 borings along main line from M46 to Crawford and Watson (dead end). EGLE may move to Phase 2 where there is evidence of contamination moving south. There currently are no plans to investigate to the east along Crawford.

      1. CAG/TA requested copy of scope.

7. Old Business [01:11:00]: Report by Jane Keon.

   1. Updates on PBB clinical trial. Trial is ongoing, thanks to support of PBB Leadership Team member and study participants.

8. New Business [01:15:00]: Report by Ed Lorenz, Vice Chair.

   1. Notification of online PBB community meetings scheduled for September 22 (Tuesday) 6:30-8:30 pm and September 26 (Saturday) 9:30-11:30 am. Additional information about the event will be distributed by CAG leadership as it becomes available.

   1. Website improvements discussed. Request for Executive Committee members to submit short biographical statements, photos, and contact information.

   1. Ed presented research on possible PFAS contamination from chromium plating at closed Lobdell/Oxford Factory. [1:20:10]

      1. History of site and relationship to CAG, new investigation, and concerns.
         
         

      1. [4]

      1. Liz Braddock, Environmental Health Director at Mid-Michigan District Health Department, provided additional insight, offering the following resources after the meeting:

         1. Information on previous PFAS testing completed at Alma Total Refinery: https://www.michigan.gov/pfasresponse/0,9038,7-365-86511_82704-489608–,00.html

         1. Information on previous PFAS testing completed at Ithaca Sanitary Landfill: https://www.michigan.gov/pfasresponse/0,9038,7-365-86511_82704-482361–,00.html

         1. Upcoming PFAS Public Webinar Announcements on PFAS changes: https://content.govdelivery.com/accounts/MIDEQ/bulletins/29b0c95

         1. Michigan Department of Health and Human Services (MDHHS) announcement regarding State Wide testing initiative: MiChem https://www.michigan.gov/som/0,4669,7-192-26847-506387–,00.html

Meeting adjourned at 8:52 pm.

Respectfully submitted,

Brittany Fremion, Secretary

General Membership Meeting Minutes: July 15, 2020

The meeting began at 7:00 pm on Zoom with Secretary Brittany Fremion as host.

Chairperson Jane Keon called the meeting to order at 7:04 pm.

Minutes for January were approved (Doug/Margaret).

Treasurer’s Report: Report delivered by Gary Smith, Treasurer. Gary reported that the General Fund Checking balance stands at $6,253.44. The Money Market Account (Oxford Automotive settlement) has $65,026.33, TAG grant money available for the Former Plant Site (FBS) stands at $25,028.01. The Velsicol Burn Pit (VBS) has $48,744.28. VBP Fund checking $80.62. The complete reports will be attached to the permanent minutes.

Correspondence and Communication (included in agenda but not discussed):

1. Letter to EPA and their response regarding data for various projects underway

   1. Letter of support for Emory University to NIH regarding a grant linking PBB exposure to susceptibility of COVID-19

   1. Press release on heating at Area 2, Phase 1 and double the DNAPL

   1. News articles generated by press release and radio interview

   1. Letter to EPA Grants Management Officer objecting to their decision for nonpayment to our Technical Advisor, itemizing their incorrect interpretations

EPA Report: Update on the heating and DNAPL Collection in Area 2, Phase 1 and plans for Area 2, Phase 2. Report delivered by Tom Alcamo, EPA.

• Heating of Area 2 currently at 105ºC and will continue. EPA expected heating to be done in early July, but still waiting to hit diminishing returns. So far, EPA has retrieved 115,000 pounds of contaminants from the 1.5 acre site in Area 2, which is the location of the former bromine plant—more than double the projected amount. Little is being recovered in vapor, as most DNAPL is in liquid phase at this point in time. Heating costs approximately $1 million per month. There are currently no water contamination issues, but EPA has had two DBCP hits, both while cleaning DNAPL from weirs/filling tankers. Now that this is a known issue, EPA is better prepared and more careful when weirs are open.

  • To date, 12 tankers of DNAPL have been transported to Arkansas for incineration. The DNAPL in Area 2 is different from Area 1; it’s more heavy and early investigation indicates DBCP present along with unknown brominated compounds, which makes sense given that it’s the location of the former bromine plant. There is also a dip in the till in Area 2 that could have led to the pooling of DNAPL.

  • Area 2, Phase 2 is another 1.5 acre site and treatment cannot begin there until Area 2, Phase 1 is finished. EPA will not do construction this winter, so they are planning to continue work in Area 2, Phase 2 for next spring or summer. The area has been drilled and wells are in, but it will take a number of months to get the system operating. Area 2, Phase 2 will also require additional electricity because of its depth and size.

  • When asked about confirmation sampling, EPA reports no plans to do so. Rather, EPA said it will look for criteria for diminishing returns and do some borings, but because of hydraulic and vapor control, EPA doesn’t view DNAPL as leaving area. Borings are used to satisfy community; EPA views work from point of source control—that there are other contaminated areas, but this treatment is addressing areas with greatest contamination.

  • Community member expressed concerns about diminishing returns versus confirmation sampling, especially with underestimation of DNAPL. EPA encouraged use of hired technical consultant and submission of questions.

EGLE Report: Updates on bird and nest study, railroad spur contamination, and Seville Township dump contamination. Report delivered by Erik Martinson, EGLE.

1. EGLE is evaluating bird and nest study, and will report back.

   1. EGLE connected with consultants looking into historical evidence and learned that their research was delayed due to COVID-19 related closures, but their work has resumed. They are working with property owners to get permission to do borings along the former railroad spur. Pending access, EGLE expects to do around 60, 5’ borings along the former railroad, but may adjust those projections in accordance with what historical inquiry gleans. EGLE hopes to begin borings in mid-August.

   1. The Seville Township dump site scored too low to fall under EGLE Superfund Section, largely because of its remote nature and lack of receptors. EGLE will look into brownfield classification, as community member concerned about residential wells.

Old Business: Report delivered by Jane Keon, Chairperson.

1. PBB Updates:

   1. May community meetings cancelled due to COVID-19, but plans in the works for remote meetings this fall.

   1. The clinical trial is ongoing, with help from two community members who assisted with blood draws and clinical work. Emory PBB Registry team is working to identify a way to continue the clinical study in light of COVID-19 challenges.

   1. New epigenetic study finds that exposure to PBB alters DNA methylation (heritable changes in gene expression without alteration to DNA sequence) in sperm. The study indicates that maleexposure to PBB can affect future generations—children and grandchildren. For more information about the study, visit: https://factor.niehs.nih.gov/2020/7/papers/dert/index.htm

   1. Discussion of unfulfilled EPA data requests. EPA said reports are not ready but that slurry wall, carbon amendment, and riverbank sampling should be prepared in August. Ecological risk study downstream is being reviewed and should be ready this fall. Community member and technical consultant inquired about baseline data, as well as replacement of trees.

New Business: Discussion.

1. What could have caused underestimation of DNAPL in Area 2, Phase 1?

   1. EPA expected to remove more material and they are, as covered in ROD and presented on at least two meetings. It is extremely difficult to estimate amount of NAPL, but anticipated large volume because of location.

   1. How did EPA develop estimate?

      1. It is common to get a higher return than projected with thermal heating remedies. Thermal heating of Area 2, Phase 1 will cost $45-50 million alone, with an estimated 8 tankers of DNAPL—we’re at 12 tankers and need more. EPA argues that the volume is a sign that the area has been well-defined.

   1. The area identified in the RI is larger, around 12 acres or so, but with EPA sampling and modeling, the area shrank significantly. How do we know there isn’t another pool or that EPA modeling didn’t miss anything?

      1. EPA bored, defined, and are heating. EPA believes thermal project is in the right spot.

   1. How far out from the edge of the defined areas for treatment does heating go? Has it been easy to determine movement of DNAPL?

      1. EPA would have to look at map again, but vapor and hydraulic controls help to address.

   1. Is the interceptor collection trench working?

      1. EPA: Yes. Amount of NAPL hasn’t changed in months.

   1. What happens when water removed from interceptor collection trench?

      1. EPA: We remove it. There are NAPL seams in the river, but the pressure of water helps to prevent NAPL from moving.

      1. When water was taken down in river, some of the NAPL moved up and into the river bed. This is due to the pressure exerted from the elevated water table inside the former plant site being higher than the river elevation.

   1. What about water at plant site?

      1. EPA: Water inside the plant site is currently higher than in the river. When doing a dye trace study this is helpful to determine any leakage of material from the site into the river or inland towards the ANP (adjacent neighborhood properties). Having such a high water table inside the site is bad because it enables contaminated material to leak into the river. Results of this investigation will be released in a report in August. There will be a drain around the entire site at end of project. It will be on the interior of the Former Plant Site (FPS) and below the river elevation which will help to capture and treat contaminants. The pressure from the river water being above the elevation of the interior of the FPS will cause water to enter site instead of material leaving the site. MW-19 area needs further investigation to confirm NAPL isn’t migrating into river.

   1. Are we still polluting the river right now?

      1. EPA: In the area where there isn’t a collection trench, probably. I don’t have data that shows that. Collection trench was placed in areas with greatest contamination.

      1. EPA Emergency Removal Program would be triggered with evidence of contamination.

   1. What sampling or monitoring is EPA doing right now that would alert removal team? How would we know if contamination of river is happening?

      1. We have groundwater data, but a more specific investigation in the future, maybe next year depending on funding, around MW-19 area.

      1. No monthly monitoring at the moment.

Meeting adjourned at 8:00 pm.

Respectfully submitted,

Brittany Fremion, Secretary