Monthly Minutes and Reports

Below are the most recent Task Force meeting minutes, beginning with the most current:

Monthly General Membership Meeting: 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
      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:
    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:

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


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 UniversityThe 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:,9038,7-365-86511_82704-489608–,00.html
        1. Information on previous PFAS testing completed at Ithaca Sanitary Landfill:,9038,7-365-86511_82704-482361–,00.html
        1. Upcoming PFAS Public Webinar Announcements on PFAS changes:
        1. Michigan Department of Health and Human Services (MDHHS) announcement regarding State Wide testing initiative: MiChem,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: 
    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