million cubic yards of PCB contaminated sediments from the Kalamazoo River on to the Allied

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1 This is a report on research and analysis of the proposed EPA plan to dump over one million cubic yards of PCB contaminated sediments from the Kalamazoo River on to the Allied Paper site located on Alcott between Burdick St. and Portage Rd. I will analyze the chemical life of PCB's, the health effects of PCB's, how they are effecting the river, how they will effect the proposed dumpsite. I will uncover the full scope of pollution that is contained in the Kalamazoo River. I will look deeply in to the proposed dump site, which has the Portage Creek running right through the center of the dump site. I will be looking at the politics behind this project and why the city commission is practically powerless to stop it. I will look at the social effects of dumping these wastes in this neighborhood, which is one of the poorest with one of the highest Latin and African American concentrations. I will look at several alternative options for disposing of these toxins. Finally I will also look at the economic factors that are in play, such as: land value, dumping costs, and the cost of alternative treatment. The area of concern in all of this is an abandoned paper mill in the middle of downtown Kalamazoo. According to the EPA designations for the Allied Paper, Kalamazoo River, Portage Creek superfund site, this paper mill is Operable Unit #1. The other OU s are located at different sites along the 80-mile stretch of the Kalamazoo River. OU #1 is the only unit that interacts with the Portage Creek. OU #1 is also the site of Allied Paper. The only other OU of interest to the clean up project of immediate concern is OU #5, which is listed as the Kalamazoo River and Portage Creek. The major contaminates at these sites, as well as the other operable units, are Polychlorinated Biphenyls. There are over 40 other contaminates in the river and creek, however the PCB s are of the most concern as they are in the highest concentrations. Some of the other contaminates in the river include benzene, toluene, dioxin, arsenic, vinyl chloride, DDT, and

2 DDE to name a few 1. Most of these chemicals are in low concentrations compared to the concentration level of the PCB s in the water, however no current data exists on the contamination levels. The Mayor of Kalamazoo does not even have data more current then 2003 on the contamination levels of ground water in the area. There are several different types of PCB s that can exist. A polychlorinated biphenyl molecule consists of two benzene rings that share a single bond between carbons and have multiple chlorine molecules occupying bond sites that naturally would contain hydrogen. The chlorine bonds can take place at any of up to 5 different sites. Figure 1: For a PCB to form chlorine must bond with the corresponding site on both benzene rings. The amount and location of chlorine bonds determines how stable a PCB molecule will be. As a general rule the more chlorine bonds there are, the more stable a PCB will be. These molecules do not exist in nature and are produced most commonly as a result of de-inking paper but are used for several other applications as well. The PCB s that are most commonly used in industry are the most stable ones. These PCB compounds are the least likely to degrade over time and do not commonly react through biological processes. The United State Environmental Protection Agency classifies PCB s as potentially carcinogenic. Since PCB s are not easily removed from the environment by nature they tend to bioaccumulate in biological life of the region. The PCB s remain intact as they move through the food chain and become more concentrated as they move through the food chain. One example of this is if a fish in a contaminated area eats worms from that area the fish will store the PCB s 1

3 from its food source inside its fatty tissues. Then something else eats the fish and stores those PCB s in its fatty tissue. After a while of this the PCB s build up to levels of unhealthy toxicity. 2 In one case from the Kalamazoo River the egg shell of an Eagle was found to have PCB levels so high that it was classifiable as toxic waste. Some sites along the Kalamazoo River have been found to have PCB levels at 1,000 parts per 1,000,000, or 1 part per 1, The current EPA plan is to dispose of a large quantity of sediments and riverbanks that have been contaminated by land-filling them at the Allied Paper site, OU #1. The EPA plans to suction dredge most of this material from the bed of the Kalamazoo River. Around 4400 pounds of contaminated material is to be dumped on this site. This material is to be dumped on top of over 150,000 cubic yards of PCB contaminated material that was dumped there, temporarily, back in 1998 and The EPA acknowledges that the site at OU #1 does not meet with their own regulations in regards to landfill sites but claims that a layer of clay, that was laid down by Allied Paper when the site was used to dewater waste sludge, is thick enough to provide an essentially impermeable layer between the contaminated wastes and the city ground water supply. The Shari Kolka, the Remedial Project Manager for Region 5 of the EPA, also claims that the topography of the clay layer is such that water run off and lechate will flow away from city water sources and in to the Portage Creek. The EPA plan also calls for placing a water impermeable cap over the top of the toxic dump site. According to EPA officials the original dewatering lagoons were considered a land fill site when they were built and are exempted from meeting any regulations due to a 2 Roberta C. Barbalace. The Chemistry of Polychlorinated Biphenyls. EnvironmentalChemistry.com. Sept Accessed on-line: 4/3/ Copyright WorldNow and WOODTV. March 30 th 2007

4 grandfather clause. They also claim that the water impermeable materials used to cap off the contaminated deposits in 1998 and 1999 covers the requirement that a layer of water impermeable PVC line the dump site. According to design requirements for any form of land fill there must multiple protective layers lining the bottom of a land fill to ensure that lechate from the landfill does not leak in to the ground water supply of the local area. There must be a thick layer of clay followed by several layers of PVC lining. There must also be a lechate collection system to collect the lechate from a landfill and send it to a wastewater treatment plant. The dumpsite at OU #1 does not meet these requirements for the most basic of landfill sites. The dump site at OU #1 is owned by Allied Paper. As the owner of a site of pollution the EPA designated Allied Paper as a Probably Responsible Party in the Kalamazoo River Superfund Site, other PRP s involved at this superfund site include Georgia Pacific, Plainwell Paper, and others. As a PRP Allied Paper is partly responsible for covering the costs of the clean up at this site and the Kalamazoo River as a whole. The EPA and Allied Paper negotiated a final solution to the PCB pollution of the Kalamazoo River and it is fair to assume that Allied Paper negotiated for the cheapest possible solution to the pollution they were responsible for releasing. Based on the cradle to grave concept Allied Paper, as the creator of the pollution, is the party responsible for cleaning up the pollution. By dumping the PCB contamination on a site they already own Allied Paper can reduce the cost to them of the clean up. These negotiated solutions have mostly taken place behind closed doors. In a statement made by the Mayor of Kalamazoo at a rallied held at the dumpsite it was announced that the EPA had wanted closed-door negotiations with the city commission on this issue. The city s legal recourse to this action has been severely limited by the EPA designation

5 of this project as a time critical removal action. This has given the EPA full ability to force this project through to completion. According to the EPA a time critical removal action is defined as a removal action that is generally of short-term response actions taken to abate or mitigate imminent substantial threats to human health and the environment. 5 These designations do not allow for any legal action to prevent the clean up action. They are intended to provide an immediate, short term, solution to potentially very harmful environmental situation. The Allied Paper plant has been listed as abandoned since EPA fences have been in place around the site since 1996 to prevent direct contact with PCB s. However, during this entire time operable unit #1 was not listed as being time critical