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