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