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.
Addition to Agenda: Silent Spring Institute
Approval of January minutes. (Liz Braddock/Doug Brecht)
Treasurer’s Report [00:00:00]: Gary Smith, Treasurer
January 2021
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.
Reminder about annual dues ($5/year). Send check to PO Box 172, St. Louis, MI 48880.
Correspondence and Communication [00:04:05]: Jane Keon, Chair
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.
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
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.
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).
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.
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.
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.
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.
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.
Discussion
Q: Are people in ANP safe, especially with the “window” or leak in the slurry wall?
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?
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.
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?
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.
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.
Q: What if contaminated groundwater is getting into ANP basements?
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.
EPA will make sure that the new fire chief and county Emergency Manager will get tour of site as soon as it’s safe.
Q: How did EPA find the breach in the slurry wall?
EPA: Through investigation and by drilling, expecting to hit wall, and missing (see November presentation).
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?
EPA: Sand seams within the till have been geologic challenge of this site; also, sand seam is the shallow unit.
CAG: These breaches and seams exist, and so is it possible things are moving that we’re unaware of, such as with this breach?
EPA: We found an area where the wall wasn’t set low enough, not because there was a sand seam.
CAG: But then how do we know this was the only place that happened?
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.
EPA will add the presentation to the website and clarify some of the acronyms used.
Q: Why is BB labeled as pesticide?
EPA: That’s how the lab labels it.
Q: Why was there a dry monitoring well — where did the water go?
EPA: It’s a shallow well that goes dry from time to time; the groundwater elevation drops and it empties.
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).
EPA: Yes. And we will collect additional data because the site will reach a new equilibrium over the next several years.
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?
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.”
CAG: This uncertainty is the point of concern.
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.
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.
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?
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.
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.
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.
CAG: Yes, please—we’re largely volunteers. We want to be prepared. We want there to be open communication. Thank you.
EPA Report [01:01:00]: Tom Alcamo, Remedial Project Manager
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.
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. .
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.
Update on slurry wall investigation – There will be another phase when a new contract is awarded, hopefully by July.
EGLE Report [01:07:00]: Erik Martinson, Project Manager
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.
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.
State of progress on bird and nest studies in the ANP: No updates but will have something to report at the next meeting.
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.
EGLE: We have essentially removed him from the equation, so we are working to identify a different way of doing this.
EPA: The VBP grant was approved.
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.
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.
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.
Old Business [01:17:15]
PBB Leadership Team Update – Ed, Jane, Brittany, Norm
Appointments are being scheduled for May, but given the challenges of in-person events, there are no community meetings.
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.
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.
Progress on new website – Ed
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.
We need pictures! Digital versions or original images, negatives, or slides that could be digitized to improve the quality of photos on the website.
If you have feedback or recommendations for the website please send it to Ed. We want to try to keep it current and updated.
Update on CMU class public history project – Brittany
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.
The Silent Spring Institute (SSI) – Ed
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.
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.
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)
We should reach out to them and consider partnering.
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