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Supporting Documentation Attached i 10 1^1?, '>-C <­ Superfund Records Center il SDMS DocID 463863 J ,;YT1L: y^W •^W:r-f- HREAK:,, t(/( OTHER: ^^ 9'&^P May 15, 1993 Slieila Eckman and Ross Gilleland Remedial Project Managers US EPA Region 1 JFK Building (HPS-CANl) Boston, Massachusetts 02203 : i .Siiuni ••.Viiiiiim.s .Sirjc; ".iriiiviuin. V.jrn'.iMU 'jr-^Ol-riJiHl Dear Sheila and Ross, •.^!)2l fi.>>;-Ul-i Enclosed are copies of the Lake Champlain Melissa VV. Davis Committee's comments on the EPA's proposed remediation New York Cliuir plan, our technical advisor's report on the plan and preliminary suggestions for the Public and. Scientific vVilliam F. Romond Vermont Cliair Review Committees on the Pine Street Barge Canal Superfund Site. Claire L. Bamett New York Vice Cluiir I look forward to speaking and meeting with both of you soon to develop more of the details for the \ Leslie A. King Vermont Vice Chair review committees. As discussed with Ross, LCC sees the convening of this group as an enhancement to the Peter S. Paine, Jr. existing outreach effort EPA has put in place. We General Counsel feel that implementing such an approach is absolutely necessary to moving us efficiently to a solution that William G. Howland Treasurer has public and scientific acceptance. I know that both of you have a strong desire to resolve this issue Lori M. Fisher in an equitable manner and I hope we can work together Eixecmive Direcior/Secreiary towards that end. Jri Fisher Executive Director Enclosures Printed vn Recvcled Non-Chionne Bleached Paper %g .^s^ May 15, 1993 Mr. Paul Keough Acting Regional Administrator Environmental Protection Agency People ^vorkini:, for John F. Kennedy Federal Building a clean lake since 1963. Boston, MA 02203 14 Souih Williums Sircet Dear Mr. Keough, Burlington. Vemiom 05401-3400 (SO:) 65S-14I4 After carefully reviewing the studies conducted on the site by EPA's various contractors, their analysis pf data, and their conclusions, the Lake Melissa W. Davis Champlain Committee (LCC) concludes that the EPA New York Chair proposed remediation plan is based upon questionable William F. Romond research, is extremely costly both in terms of the Vermont Chair dollar amount and its limited lifespan of thirty years, and would in all likelihood be a cure worse Oaire L. Bamett than the disease. We are encouraged by your recent New York Vice Chair statements that you are flexible to alternative approaches and we urge a continued search with the Leslie A. King local community for creative and appropriate Vermont Vice Chair solutions. Peter S. Paine, Jr. The Lake Champlain Committee's main concerns General Counsel with EPA's proposed remediation plan are outlined in William G. Howland this letter and further articulated in the enclosed Treasurer May 1993 Aquatec report Technical Review of EPA's Risk Assessment and Proposed Cleanup Plan For The Lori M. Fisher Pine Street Canal Superfund Site. Executive Director/Secretary In addition to commenting on EPA's proposed remediation plan we are also recommending a process intended to move us into and through the next phase of the issue to an effective and acceptable solution. As indicated during our conversations and at the various public infomnation sessions we have held, we urge the convening, of Public and Scientific Review Committees for the Pine Street Barge Canal Superfund Site. We feel that such a group is necessary to meaningfully involve the public in crafting a Vermont solution to the problem and to develop a remediation plan that is scientifically and publicly credible. Details on the shape and function of the review committee are included in the enclosed Lake Chcunplain Committee Proposal for Public and Scientific Review Committees for the Pine Street Barge Canal Superfund Site. We look forward to working closely with EPA, local and state officials and the public in this effort. •rr],;l \,m.rhl„r, . w?..,.,.^.-^ p.. Six Problems with EPA's Proposed Remediation 1. The plan is based upon several flawed studies that fail to accurately or comprehensively characterize the Barge Canal site. As a result we do not know if the risks to ecological and hximan health have been underestimated or overestimated. a) The^^leari-up plan was^trd-gg.eredzbecguse^f~EPA~fi-nd-i-ngsjjt ^h;®~> ^-Sslte^poses—aTi"'"unaccept-abLe~ris-k--t0—benthic, inverteSrate^s~——-^Si^^rams, wo-rms-,~sna±rs^ and~insec.tsr^^^^^I£ha.tJll3^eriy't:Re'''se^^ . ; Ho.w.ev.efe,^3-^ EPA—made-th'i7s~j^Udg^emenjt_based_upon__taking only 12 samples>^:::ili;'E~i's~the= op"ifri*bh of^'l^CC'' s technic^j^^S-onsultant^that only three—samples^were~j taken—i-n—a—way-~th"at~'de'finitively showedji^p^uuSlQnjtam±npi:r^'fe3-~wer^ ^^ffe^tirig^,be-nth'i-e~c)rganisms. ^^^_T^|;XKSfell-S3'mprigg^jj^^^^ low -"'tfig '^leve^ the-^f ecl^ai ^government "says ,ppses ^anecorcrgrcai--r-i-sk-.. J^wever, tKeiy We-rer=:fea'ken -from^ areafere'l'a.'ti.vigfv^lFree "o£^"^05^1^3:ar.^eontamination affd threej:3sampi'esr^o^lna€^=prl3Vi*^^^ informati5Gn=:^to—drawjiany;^;^'-"'"-^ coneiU'sa:ons^£i-~dWeK?ne(ed'lmore—i^fo^ the-ext.ent and lev¥l~~of—i contami-na'Ci^. in - the~su-rfacS'^'^e'dimenCs Be"f'or^dl~gging~.up_3he 'siteW b) EPA plans to dig down to a depth of 2 0 feet in the canal to eliminate the risk to the benthic invertebrates that live in the upper s.u^ace — 6-12 inches — of the canal sediments. Coal tar contamination below this habitat layer, although potentially hazardous, presents low immediate risk to the invertebrates. EPA's own studies indicate that soil contamination below five feet presents minimal exposure to animals and other biota. We have found no justification for digging down 20 feet to protect the ecological community that lives in the upper sediments. c) EPA failed to determine if the site poses a risk to human health by inadequately investigating the potential risks to people who breath the air or drink the water. With regard to air, just one 8-hour sampling event was conducted to determine the risk to people who live and/or work in the area. The tests were done at nearly four orders of magnitude higher than state standards — standards EPA is required to meet — rather than employing more sophisticated sampling methods to conduct a sensitive test. With regard to water, EPA determined that the adjacent Lake Champlain waters do not appear to contain elevated__level.s_o.f_tpxic compouTids_from_yie_J|arge_Canal. rHowever ,_Chaj£IqoncluslQ^i^was—reaehed ^by^Saking—a—l-imitgdlnu^er oT"^sampi-es—and—running---tes-ts—wi"^£K:rdete^tijon lim-i-fes--'COnsililerabry~Ei§i^^^than­ fegulred'^to meejb. ; The-"bott"omTilTe~is';—•we-don-'-t-^knovrT'f"^he lake's water"T.s affected by the Barge Canal. We need to, because 50,000 people get their drinking water from an intake pipe approximately one mile north of the site. 2. The plan would destroy a functioning wetland to create a landfill. a) If built, the containment disposal facility (CDF) will de^troy_^__^ several—functi-ons~of~th'e~ex±sting-wetjg7id3V^ii-^ ^ljOngEt'efmi:Kearj£fi_of--the~sit-e-.—-One~^~^he major functions of^a_w.e.tland_ _i s-2to;;;;^trap_s.eciilnent'si::andl^^ f f.e r i ng—Lake;::;Ch amp l-alrT^froiii" 7;ghe3;slte3:j3n£a5dh'antsii(:aiid^ other sur?a^e~funof~f~ffoSTthe surrounding areas). The wetlands act essentially as a "sink" in which the high concentrations of organic materials absorb contaminants. Walling off and capping the wetland will likely eliminate this buffering capacity and potentially increase the risk of contaminants reaching the lake in the event of runoff events or failure of the CDF. b.),_ALthGugh—by~ea-ppilig3^hie33;7etl"and_and~Bvrilding,.^ CDF7~EPA—p-lans_to r-ml n im-i^e~th'e""adyerse imp act to=^€h e--si-t e-''s-^wi-l-d--l-i--f e-,—-t he—Feii@y^^o#=^ ^th-i-s=^Ha-bit a-t'-^'f fom~aiOirba-n—z ong*^ i ..the^^ghima 1 s that^usejbhe_w.ejtl:andsrrthah—th.e_^s,ite_^in^i_t:^^ =due5tp. the^sca-iS^-nd3;n.t'ens:i4:-y=(3£3Jh'e=p.roposed-cdi"*;'*-^VT^<^ ?;;r^ " pjlo.p.o.s.ejL.-^solut-i-'ori'^iS—thje—ecoloq-ica-li^^^^ f__!Lurb an—re newa-l-JL,^ rSz:i!ng~a-~neiqHtoorh'o^odSi^S5rde?==eo=^m^ """" ~~—"^ ""^ c)EPA:!:Clplah-r,eq.uir.es__the__creat,ion j5_f-45^et]^and_habi.ta.t^'o:ffHs'i£^ make~^u^f.or^des.tr-uction—ofr:tK^^et11and--tbe^^^ How,e^^r7r:iwetd-ands—are—dif.f-icult--to_r.e,plicate—andrri^-tr^^ '^e—w,oud-d—be—ab-l-er=^teo;pfuXl-y—dug^ggite^ti ::;S^^st:in"g3{etland': " '• ^^ 3. The plan will release aromatic toxins into the air as toxic waste is being removed from the canal bottom and uplands soils, potentially endangering public health. a) Activities associated with the construction of the CDF will release Benzo (a) Pyrene and benzene - two carcinogenic by-products of the site's coal tar contamination - into the air. EPA estimates that the concentrations of benzene due to excavation will be over 2,500 times the state standard and the concentrations of benzene over the water in the CDF will be 8 0,000 times- the state standard. Despite these air quality problems, EPA has not developed a plan for mitigating these increased risks to the people who live and work in the area and will need to breath the air.
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