United States        Region V
             Environmental Protection    230 South Dearborn Street
             Agency          Chicago, Illinois 60604
6792          	
     V       The PCB Contamination
             Problem in
             Waukegan, Illinois

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THE PCB CONTAMINATION PROBLEM IN HAUKEGAN.  ILLINOIS
                  January 21, 1981
                    Prepared By
        U.S. Environmental  Protection Agency
                      Region V
             230 South Dearborn Street
              Chicago, Illinois  60604

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                               TABLE OF CONTENTS
                                                                        PAGE #
CHAPTER I     INTRODUCTION	  1

CHAPTER II    THE PCB PROBLEM AND GOVERNMENT RESPONSE	  2
                   THE PCB PROBLEM	  2
                   THE RESPONSE	  3
                   SUMMARY	  5

CHAPTER III   THE LAKE MICHIGAN PCB PROBLEM	  6
                   HISTORY	  6
                   LEVELS OF CONTAMINATION	  7
                   SOURCES OF CONTAMINATION	  7
                   CONTINUING SOURCES OF CONTAMINATION	  8
                   CONTROL MEASURES	  8
                   CONCLUSION	  9

CHAPTER IV    THE SITE AND ITS CONTAMINTION	 10
                   WAUKEGAN HARBOR	 10
                        Description	 10
                        Contamination of Harbor Sediments	 14
                        Waukegan Harbor Fish Contamination	 18
                        Ambient Water Quality	 19
                        Water Supply	 19
                   NORTH DITCH AND OMC PARKING LOT AREA SOILS	 20
                   SUMMARY	 27

CHAPTER V     THE OPTIONS FOR DEALING WITH THE PROBLEM AND THE
                PROPOSED SOLUTIONS	 29
                   WAUKEGAN HARBOR	 29
                        The Options	 29
                        The Preferred Option	 32
                        The Plan for Cleanup	34
                   NORTH DITCH & OMC PARKING LOT AREA SOILS	 39
                        The Broad Options	41
                        The Preferred Option	 45
                        The Plan for Cleanup	46

CHAPTER VI    FINAL DISPOSAL OF PCB-CONTAMINATED MATERIALS	49
                   THE DISPOSAL OPTIONS	49
                        Incinerati on	 50
                        Secure Landf i 11s	 50
                   THE RECOMMENDED APPROACH	 53

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                           TABLE OF CONTENTS (CONT.)


                                                                         PAGE #

CHAPTER VII    FUNDING SOURCES	 54
                    THE LITIGATION	 54
                         The Special Congressional Appropriation	55
                    SECTION 311 OF THE CLEAN WATER ACT	 55
                         Superfund	 55
                         U.S. EPA's Budget Appropriation	 56

CHAPTER VIII   THE STATUS OF THE CLEANUP	 57
                         Section 311 of the Clean Water Act	 58
                         The Congressional Appropriation	 58
                         Superfund	 58
                         The Litigation	 58
                         Summary	 58

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                                LIST OF FIGURES



FIGURE #   TITLE	PAGE

IV-1       LOCATION OF WAUKEGAN HARBOR, ILLINOIS	 11

IV-2       AERIAL PHOTO OF WAUKEGAN HARBOR, ILLINOIS	 12

IV-3       LOCATION OF OUTBOARD MARINE CORPORATION PLANT AND PCB
            OUTFALLS IN RELATION TO SLIP #3 AND THE NORTH DITCH	 13

IV-4       CROSS SECTION OF SLIP #3	 15

IV-5       EXTENT OF PCB CONTAMINATION	 16

IV-6       NORTH DITCH AND PARKING LOT AREA	 21

IV-7       GEOLOGY UNDERLYING OMC SITE	22

IV-8       NORTH DITCH AREA APPROX. EXTENT OF PCB CONTAMINATION
            OVER 5000 ppm—1977 DATA	24

IV-9       PCB CONCENTRATION PROFILE IN THE NORTH DITCH	 25

IV-10      NORTH DITCH AREA—EXTENT OF PCB CONTAMINATION OVER 50 ppm	 26

V-l        DREDGING OPERATION—WAUKEGAN HARBOR	 35

V-2        SILT CURTAIN PLAN AND ELEVATION	 37

V-3        CROSS-SECTIONS OF LAGOONS	 38

V-4        PROPOSED TREATMENT SYSTEM FOR EXCESS WATER	40

V-5        NORTH DITCH BYPASS (PHASE I)  AND SLURRY WALL (PHASE II)  PLAN.... 44

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                                      -1-


                                   CHAPTER I

                                  INTRODUCTION

    The presence of  high levels of  polychlorinated  biphenyls (PCBs)  in  soils
and harbor sediments  in  the  vicinity of the Johnson  Outboard Division of Out-
board Marine Corporation  (OMC)  in  Waukegan, Illinois, was  first  discovered  in
1975.  Subsequent  new areas  of  contamination  have  been uncovered  as  recently
as last year.  The site contains the highest known concentrations of uncontrol-
led PCBs  in  the country,  and  there  are few precedents  for dealing  with  the
many problems  that it  presents.   It  is inevitable  that   new things  will  be
learned as the  work  progresses,  requiring changes in both  planning and proce-
dures.

    The immediate  threat  to  Lake  Michigan  water  quality,  where  unacceptably
high concentrations of  PCBs  have been  found  in fish tissue, and  the  ultimate
threat posed by this  comtamination  to human health in the area,  have  prompted
the U.S.  Environmental  Protection  Agency (U.S.  EPA)  to pursue  remedy through
two paths:

    - Seeking,  through  litigation, to  require the  OMC as discharger of  the
PCBs, and Monsanto Company as the PCB manufacturer,  to pay the costs for remov-
ing the contaminated material from the environment.

    - Proceeding to solve the contamination  problem before the issue of respon-
sibility is  resolved  by  the courts,  with  reimbursement  expected at   a  later
date from the party judged responsible.

    Investigations into  the  extent  and  nature  of the  environmental   problem
commenced in 1976,  are  still  going on,  and  continue to  provide us  with  new
information.  However, the solution  of the problem depends not  only  upon  our
ability to develop adequate  and  cost-effective engineering  plans,  but  also  on
the availability of funding with which they  can be implemented.   Although  there
are still  some unanswered questions,  it has  been possible in  the following
pages to describe the environmental  conditions that  have been found at  the site
and to discuss  plans  and funding mechanisms the  implementation  of which  will
allow us to take some major cleanup steps.

    The U.S. EPA has  already initiated  a preliminary  action in  response to the
severity of the contamination problem in  Slip #3  in Waukegan Harbor, which was
announced and described in a  November 24, 1980 report.  That plan is compatible
with, and can  be  incorporated  into,  the more extensive program proposed in the
following pages.

    This report presents  an  opportunity for  thorough  and thoughtful public
review of and comment on the  total  approach  that the agency is prepared to take
to resolve the problem.  The  planning process,  both  now and as the project pro-
ceeds, will be flexible enough  to permit us  to take  into consideration  the con-
cerns of the public, as well  as the emergence of new data and new technologies.

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                                      -2-


                                   CHAPTER II



                    THE PCB PROBLEM AND GOVERNMENT RESPONSE
THE PCB PROBLEM

    PCBs, or polychlorinated biphenyls,  are  compounds which belong to  a  broad
family of organic  chemicals known as chlorinated hydrocarbons.   Virtually all
the PCBs  in existence  today  have  been  synthetically manufactured.   Although
they were first  discovered in  the  late 1800' s, they were not produced  until
1929 in the United  States,  where  the  Monsanto  Company has  been their principal
manufacturer.

    A number of  different  mixtures of PCBs  have been distributed  by Monsanto
under the overall trademark of  "AROCLOR",  each  characterized  by the percentage
of chlorine it contains and identified by a number which  refers to that percen-
tage (for example,  Aroclor  1254  is  54%  chlorine).   Aroclor  characteristics
vary according to the mixture.  As the chlorine content increases, for example,
the physical characteristics  change  from  colorless  oils  to  sticky  resins  to
white powders,  and their persistence in the environment increases.  The general
properties of  PCBs  —  unusually  good   chemical  and  thermal  stability,  fire
resistance,  non-conductivity, and low solubility in water ~  have  resulted  in
widespread industrial  use.   Among the most  popular uses  of PCBs have  been  as
fluids in transformers and capacitors and  as dye carriers  in  carbonless paper.

    It was not until the 1960's that  indications of the toxicity  of PCBs  began
to emerge  clearly.    In the  early  60's mink  ranchers   noticed  increases  in
sterility and mortality of the  newborn among animals  with  substantial  amounts
of Lake Michigan  coho  salmon in  their diet, but it  was  not  until  the end  of
the decade that  PCBs  began  to  surface  as  the  cause.  It  was  only after  a
severe human PCB  contamination  accident occurred  in Yusho,  Japan,  in  1968,
that world attention began  to focus on the  magnitude and  scope  of the poten-
tial toxic  effect   of  PCBs on  humans.   The Yusho  victims,  who  had  consumed
rice oil  contaminated  with PCBs, were  afflicted by  skin lesions,  blindness,
hearing loss,  jaundice  and abdominal  pain.  Much of  our data on human health
effects of  PCBs  stems  from  this  incident, and  the affected   population  is
still being   studied.   Among the  other  observed  symptoms  of  PCB toxicity  in
humans have  been chloracne (skin rash),  discoloration  of  the gums  and  nailbeds,
swelling of joints, waxy secretions of  glands  in the  eyelids,  and  the  general
symptoms of lethargy and joint pain.  Many of the risks to  human health  result-
ing from PCB exposure are  perceived as subtle physical and  behavioral  changes.

    There are also  well -documented  tests on laboratory animals that  show PCBs
to cause  reproductive  failures, gastric disorders,  skin lesions,  and  tumors.
Although data  on  the  possible  cancer-producing  effects  of PCBs  in  humans  is
still sketchy,  there are  substantial  indications from laboratory testing that
the compounds are carcinogenic for animals.

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                                     -3-


    The growing body of knowledge of the toxicity and carcinogenicity of PCBs
has been  particularly  alarming in  view of  their remarkable  persistence  in
the environment, a  result  of the high  chemical  stability that made  them  so
desirable in industrial use.  Once released into the environment,  PCBs do not
readily break apart  into  new chemical  arrangements —  they  bioaccumulate  in
the fatty tissue of the organisms that consume them.   Even  more  serious for
humans, PCBs "biomagnify" in the food chain.  This means that at each step of
the food chain - beginning with microorganisms and plants that take in traces
of PCBs from the environment and moving through the smaller fish that eat them
into the larger fish that are eventually eaten by humans - the PCB concentra-
tions increase.

    Since PCB accumulation occurs  primarily in fat tissue, fatty fish, such as  '  .J
salmon and trout, are the most susceptible.   Fish  have been known to bioconcen-
trate PCBs to factors of a hundred thousand  or more times the concentrations of
PCBs in the waters  where the fish live.   High bioaccumulation of PCBs in
human fatty tissue  can  also  occur, and even if the exposure is to very low con-
centrations in the  environment, chronic (long-term)  toxic effects  can result.

    Documented occurrences of high levels of human exposure to PCBs have almost
always resulted  from the consumption  of  contaminated  foods,  contamination
which occurs both as a  result of  accident  (as in the  Yusho  case)  and through
the accumulation of PCBs in fatty  tissues  in the  food chain.   Detectable
levels have been found  in  tissues  of  up to  91% of  individuals in groups tested
in the United States.

    Inhalation and   skin contact with PCBs  are not considered  to  be signifi-  ^  ,,
cant sources of  contamination  for the  general public, but are  of  concern  in  »•"•£
situations of occupational  exposure.  Although PCBs do not  easily vaporize,
recent studies  suggest  that  new  attention  should  be  paid  to the possibly
significant losses  of PCBs to the atmosphere through volatilization.

THE RESPONSE

    As the evidence  of  the  toxicity  of PCBs  accumulated in the late 60's and
early 70's, both government  and industry responded.   Monsanto  restricted its
sales of PCBs to closed system uses (those uses  which do not  release fluids
to the environment)  in  1971 and,  by 1977,  had voluntarily terminated produc-
tion in all their facilities.  Because  of their unusual  persistence, however,
most of the PCBs manufactured between 1929  and 1971 still existed,  and much of
it had been released into the environment.  This release  occurred primarily
through spilling and dumping to surface waters and landfills  and,  to a lesser
extent, through volatilization (release to  the air).

    The federal  government,  particularly the Food and  Drug Administration (FDA)
of the Department  of Health  and  Human Services  and  the U.S.  Environmental
Protection Agency (U.S. EPA) took  a  series  of steps during the 1970's to regu-
late and control human  exposure to these toxic substances.

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                                      -4-


    As early as  1973  the FDA established "temporary" tolerance  limits  for PCB
concentrations for  various  categories  of foods,  setting a  5 ppm  (parts  per
million) limit, at that time, on fish and shellfish.  Thus, interstate transport
of fish shipments containing more toxic levels was prohibited.

    In November,  1975,  the  U.S. EPA convened a National  Conference  on  PCBs in
Chicago to present and  discuss  the  growing body  of data on the persistence and
toxicity of PCBs.  The  U.S. Congress  responded by  including  in  the  Toxic Sub-
stances Control  Act of  1976 (TSCA)  a provision to  ban  the manufacture  of PCBs
except for use in  closed systems, and  to prohibit  their use  in non-closed sys-
tems.  TSCA  required  U.S.  EPA  to   regulate  the  disposal  and marking  of PCBs
and to ban, with certain exceptions,  the manufacture, processing, distribution
in commerce,  and  non-totally  enclosed  use  of PCBs.   U.S.  EPA  published  the
final rules on  marking  and  disposal  in the  Federal  Register on  February  17,
1978.  Final rules on the ban were  published  on May 31, 1979, taking effect on
July 2, 1979.

    The PCB disposal rules developed by the agency to implement TSCA  set 50 ppm
as the level above which materials  must  be disposed of  in a  Federally approved
landfill or incinerator, and established criteria  for  U.S.  EPA to  follow in
making such approvals.

    On April  1,  1977,  the  FDA  proposed  new tolerance  limits for  PCBs.   The
proposal recommended that the  level  for  fish  and  shellfish  be  reduced from 5
to 2  ppm  in response to new data  received  since the  earlier tolerances  were
set in 1973.  This new  information included:  (1)  new toxicity data; (2)  indica-
tions that PCBs were carcinogenic;  and (3) indications of the widespread occur-
rence of  PCB  residues  in  fish resulting from  the  presence of  PCBs   in  the
environment.

    When the  same limits were  published  in  final  form  on June 29,  1979,  FDA
stated that  although  they  were  required to  weigh  public   health  protection
against commercial losses and losses of food supplies to consumers, and although
they had received  considerable  public  comment protesting the commercial losses
that would result from the 2 ppm tolerance level,  the new toxicity and carcino-
genicity data prompted  the  agency to  promulgate the lower limit.   An objection
and request for  a  hearing lodged subsequently  by the National  Fisheries Insti-
tute, however, automatically stayed  the promulgation   of  the  new  level  for
fish, and the 5  ppm limit  remains  in effect  until  this  appeal process  is com-
pleted.

    In addition to the  regulations  promulgated by FDA  and EPA,  various guide-
lines for safe PCB  limits  in the environment have  been  recommended  by  govern-
ment agencies.   The  National   Institute  for  Occupational   Safety   and  Health
(NIOSH) has recommended to  the  Occupational  Safety and  Health  Administration
(OSHA) of the  Department of Labor  that  no  worker  be  exposed to  greater than
1.0 microgram of total  PCBs per cubic meter  of air, for up to  a  10-hour work
day and 40-hour work week.

    U.S. EPA has  used  a  guideline for safe levels  of PCBs in  water of approxi-
mately one part per billion (ppb) for drinking water and one part per trillion

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                                      -5-
(ppt) or less for ambient surface water.  The increased restriction for ambient
water is based  upon  the tendency of the substances to  bioaccumulate  in marine
organisms.  The two  levels  are  roughly equivalent in the  protection  that  they
give an individual  drinking water containing the 1 ppb level and a person eating
1/2 pound  per  week  of  fish which live  in waters containing  the PCBs  at  the
1 ppt  level.   A level  of  14  ppt  is  now  also  being  used by  U.S.  EPA as  a
guideline for  protection  of  fish.   Additionally,   U.S.   EPA  imposes  limits,
through its National  Pollution  Discharge  Elimination  System  (NPDES)  permits,
on PCB  discharges  into  the  national  waterways  by  industrial  and  municipal
facilities.  A  limit of  1  ppb  or less  is  commonly  advocated  at this  time.
Finally, as recently as July  1980, the  Carcinogen Assessment Group of the U.S.
EPA included PCBs  in their  list  of chemicals  identified as  "having substantial
evidence of carcinogenicity".

    Government regulations  can  be  expected to continue to change, over time,
in response to  the influx  of  new and  more  definitive scientific data  on  the
effects of PCBs on human health and aquatic life.

SUMMARY

    PCBs have been manufactured in the United States  for  only half  a  century
and awareness of their toxicity began to develop  little more than a decade ago.
We still know very little  about their  long-term  toxic  and  carcinogenic effects
on humans.  We do  know, however, of  incidents where human  exposure to PCBs  has
caused severe toxic  reactions,  and  of laboratory experiments  where  PCBs  have
been accountable  for a  variety  of toxic  symptoms  and   cancers  in  animals.

    We also know that PCBs  are  unusually persistent, and that,  although  their
manufacture ceased in this  country in  1977, most of the hundreds  of  thousands
of tons that were  manufactured  between 1930  and  1977 are still with us and  are
uncontrolled in the environment. Because of  the  low solubility of PCBs in water
and their high affinity for fatty  tissue,  it appears that  the  primary exposure
by humans to existing PCBs  is through  accumulation in the  food chain.  Thus it
appears that those deposits of PCBs  in  aquatic environments accessible  to  fish
populations pose the greatest threat to human health.

    Government response has been, on the one  hand, to  restrict or prohibit  the
manufacture and distribution  of PCBs in order to  eliminate new  releases  into
the environment, and, on the  other,  to reduce the threat  to human health  from
existing environmental   reservoirs  of  PCBs  by limiting  commerce  in  fish  and
other foods containing  certain  levels  of these  compounds.  As  more data  is
generated and scientific understanding  of  PCBs is improved, it can be  antici-
pated that government regulation and response will  adjust accordingly.

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                                  CHAPTER III



                         THE LAKE MICHIGAN PCB PROBLEM
HISTORY

    Pesticide monitoring programs were  first  established in the Great Lakes in
the late  1960's  in  response  to  public  concern  over  pesticide  contamination
following the publishing of Rachel Carson's Silent Spring.  Due to the chemical
stability of  some of these  compounds and  their  tendency to  bioaccumulate in
the food  chain,  high  levels  of  pesticides such as  DDT (dichlorodiphenyltri-
chloroethane) and dieldrin  were found  in Lake Michigan  fish.   Chemists began
to discover  other unidentified compounds that  were being  coanalyzed  with DDT
and dieldrin  and that  were  interfering  in  the  pesticides  analyses.   These
other compounds  were PCBs, which  were subsequently  added  to the  Great Lakes
fish pesticide monitoring programs.

    An EPA  study of Lake  Michigan  fish  in 1971  found  mean  concentrations in
fish of PCBs (Aroclor 1254) ranging  from  2.7  ppm  in rainbow smelt to 15 ppm in
lake trout.  PCB concentrations in  all  trout and  salmon more than  12  inches
long were  found to  exceed  5  ppm  (the  FDA temporary tolerance level  that  was
set in 1973).   Larger  fish such  as  brown,  lake and rainbow  trout  and Chinook
and coho salmon  contained  PCBs at two to three times  the FDA tolerance level.
Concentrations  increased with  the  percentage  of fat and  the  size  of the fish.
PCB concentrations in Lake Michigan coho salmon were two to three times greater
than in coho from Lake  Huron,  and  approximately ten times greater than in coho
from Lakes Erie and Superior.

    Lake Michigan PCB fish  monitoring programs were also begun  in  1971  by the
States of Indiana and  Wisconsin and  in 1972  by  the State of  Michigan and  the
U.S. Fish and Wildlife Service.  Results from these monitoring programs painted
the same picture  of very high  levels of  PCBs in  larger fish, well  above  the
FDA tolerance level.  The 1971  studies also showed  that  fish  from the southern
part of Lake  Michigan  had  higher  levels  of  contamination  than fish  from  the
northern portion of the lake.

    Responding to this  evidence of severe  PCB contamination,  the  governors of
Michigan and Wisconsin  banned  or  restricted the  sale  of  certain  species  of
Lake Michigan fish  (primarily  salmon and  lake trout) in  their  States  in 1971.

    Shortly thereafter, the sale of PCBs was restricted by Monsanto to manufac-
turers of  closed systems  (1971),  and  the  U.S.  Food  and  Drug  Administration
established the temporary 5 ppm tolerance  level  for fish (1973).

    At about this time,  researchers  were  reaching  the  conclusions  associating
PCB contamination of Great Lakes  coho salmon  with  reproductive failures  of

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                                      -7-
minks (see  Chapter  II).   Other  Great  Lakes Basin  research  implicated PCBs in
the reproductive failure of stocked salmon  populations as well as the reproduc-
tive failure  and decline  in populations of fish-eating  birds,  such as herring
gulls, bald  eagles,  and  the  double-breasted  cormorant,  in the  Lake Michigan
Basin.

    Because of  the  fish  sale  restrictions,  the  establishment   of the  FDA
tolerance level, and Monsanto1s  voluntary  restriction on the sale  of PCBs, it
was expected that the PCB levels would decline substantially, as the DDT levels
had.  By 1974, however, PCB levels in fish had not decreased.

LEVELS OF CONTAMINATION

    High PCB  contamination  levels  have been found  both  in  the  tissues of Lake
Michigan fish,  and  in  the  bottom  sediments of  the lake,  its harbors  and  its
rivers.

    Studies of  lake  trout  and  coho  salmon  conducted  between  1972  and  1974
showed PCB  concentrations  ranging  from  7  to  20  ppm.   Subsequent  testing
indicates that  contamination   levels  may  be  dropping,  but  these  two  species
still tend to exceed the FDA guideline.

    Sediment samples showing  PCB levels  in excess  of 50  ppm have been taken
from the Fox  River  at  Green  Bay,  Wisconsin,  and harbors located at Waukegan,
Illinois; Sheboygan and  Milwaukee,  Wisconsin,  and  in the  Grand  Calumet River
and Indiana Harbor Canal  in Indiana.

SOURCES OF CONTAMINATION

    The primary  source of  PCBs  in Lake  Michigan  in  the  past   was industrial
discharges.  In 1975, the Johnson Motors  Division of Outboard Marine Corporation
(OMC) in Waukegan,  Illinois was found  to  be discharging PCBs to the Waukegan
Harbor and to a tributary of  Lake Michigan  known as the  "North  Ditch."   It  now
appears reasonably clear that this facility was one of the  major sources if not
the major source of PCB contamination in Lake Michigan during the early 1970's.
According to  a  letter  from its  attorney dated  March 24,  1976,  OMC purchased
approximately 8.4 million pounds  of PCB in the  form of hydraulic  fluids  from
Monsanto between 1959  and 1972.   OMC  estimated (on a speculative  basis)  that
15-20% of this  amount  may have been discharged to  water; that is,  between  1.3
and 1.7 million  pounds might  have  been discharged  either to  the ditch,  harbor
or lake.   (More  recently the  company has  been  using  lower figures  for  this
discharge.)  U.S.  EPA's   consultant  has  estimated  that as  much  as  275,000
pounds of  PCBs  remain  in the harbor  sediments  alone.  As  much or  more  PCBs
have been estimated to  be in the North Ditch and parking lot area.

    Simulations done by a USEPA contractor indicate on a preliminary basis  that
discharges from the harbor and ditch to Lake Michigan  were  in the thousands  of
pounds per year during  the peak years that  PCB fluid was in  primary  use.   Esti-

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                                      -8-
mates are  also  being made  of the  contribution of  this  OMC discharge  to the
whole PCB  problem in Lake  Michigan.   The  OMC  discharge,  at  its  peak,  itself
appears to have  represented a sizable fraction of  the  total  load  of PCBs into
the lake.

    This conclusion, together with  its  underlying  assumptions,  is  supported by
information from  other  sources.   OMC  was a large purchaser of PCBs, Monsanto's
second largest customer for hydraulic fluids and  one of the largest purchasers
of PCBs in the  Lake Michigan Basin.  Moreover, a  high  proportion  of OMCs pur-
chases were  of  Aroclor  1248,  the  same  PCB blend  that  is typically  found to
make up one-third or more of the contamination in open Lake Michigan sediments.
Only Lake Michigan shows these significant levels of 1248.   In  1970, for example,
OMC purchased more  than 90%  of  the  1248  sold  in  the Lake Michigan  Basin for
open system use.

    OMC's heavy  leakage of PCBs  to  the  harbor  and ditch  resulted  in heavy
water and sediment concentrations of PCBs.   Natural flow and flushing mechanisms
in the harbor, ditch and groundwater, together  with dredging  operations  in the
harbor, resulted  in  much of this contamination being carried  to the lake.  In
addition, the company  had  and still  has  a water intake in  the  most contamin-
ated portion  of  the harbor which moves  PCBs  through the plant  and thence to
Lake Michigan through outfalls  into the  lake and ditch.   PCB transfer into the
atmosphere from  OMC  stacks  or   from uncovered  contaminated  soils may  also
have reached  the  lake.   Although quantitative division of past  sources  cannot
be done precisely  after the fact,  all  these loads  have certainly  contributed
substantially to the Lake Michigan PCB problem.

CONTINUING SOURCES OF CONTAMINATION

    The PCB-contaminated materials  deposit  at Waukegan  is one  of  the largest
potentially controllable current  sources of PCBs  in Lake Michigan, and  is  by
far the largest uncontrolled reservoir of PCBs in the Great Lakes Basin.   Other
continuing sources of PCB contamination of Lake Michigan include:   (1) addition-
al industrial discharges; (2) atmospheric transport  and deposition  from  incom-
plete incineration,  and volatilization  of  PCBs  from landfills  containing PCB
materials; (3)  Effluents  from   municipal   waste  water  treatment  plants;  (4)
Leaking from chemical waste disposal sites; (5)  Movement of water and sediments
from contaminated  tributary streams  and harbors;  and (6)  Recycling of  PCBs
through the water column and food  chain from  sediments  already in the lake.

CONTROL MEASURES

    The Lake Michigan States have responded to the continuing problem  by  re-
stricting or banning the sale of fish  in which PCB contamination is  at or above
the limit set by the FDA, and by advising members of the public to restrict their

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                                      -9-
consumption of the fish which they catch in Lake Michigan.  The advisories cau-
tion against the  consumption  by pregnant and nursing women  and  small  children
of lake trout  and other species from certain Great Lakes  waters  and recommend
that all people limit consumption of  certain fish to  no more than one meal per
week, or to less  than one-half pound per week.   These  advisories  warn against
any consumption by anyone  of certain fish  species caught in  specific waters.

    In 1977, Region V EPA published guidelines,  based  on studies of PCB accumu-
lation in fish  affected by  contaminated sediments, for  evaluating  Great Lakes
harbor and river  sediments.   Those guidelines called for no open water disposal
of dredged sediments that were  contaminated  by  PCBs to  a level  in excess of 10
ppm.  Application of this guideline  in  the Lake Michigan Basin  has  resulted in
the restriction, curtailment,  or cessation of dredging in the Fox River, Sheboy-
gan Harbor, and Milwaukee Harbor, Wisconsin;  Waukegan Harbor,  Illinois and the
Indiana Harbor  Canal,  Indiana,  pending the   application  of  environmentally
sound dredging and disposal  methods.

CONCLUSION

    High PCB concentrations  began to  be identified in  Lake Michigan fish during
the early 1970's.  Contamination  levels in larger  species were  so  much above
the FDA temporary tolerence  levels,  in  fact,   that  several  adjacent  states
banned or restricted  the sale of these fish.

    These PCB  contamination  levels were attributed primarily  to  industrial  dis-
chargers into  the Lake,  the  largest  of which  appears to  have  been  the OMC faci-
lity in Waukegan, Illinois.

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                                      -10-


                                   CHAPTER IV



                         THE SITE AND ITS CONTAMINATION
WAUKEGAN HARBOR

Description:

    Waukegan Harbor is located on the west  shore  of Lake Michigan  at  Waukegan,
36 miles north of  Chicago  and 47 miles  south  of Milwaukee.  (See Figure IV-1.)
Waukegan, a  city  of  65,259  people  (1970  census),  encircles the  irregularly-
shaped harbor.  (See Figure IV-2.)  It is a busy  fishing and  charter  boat area
and prides itself on being a "Salmon Capital."

    Figure IV-3  illustrates  major  points  of  interest  in   the  harbor  area:

        - Larsen Marine Co., which uses Slip #3 and the north end of the harbor
          for boat docks  and  cranes  to service  its pleasure boat customers.

        - OMC's Plant #2 which has a  water  intake in Slip #3.  An OMC outfall,
          now closed, which  was  the source  of  PCBs  to the harbor,  is  also
          located in the Slip.

        - Vacant land owned by OMC that was the former site of a General  Motors
          foundry.

        - OMC's Plant #1 has a harbor intake across from Slip #1.

        - Waukegan's  water filtration  plant   which  has  an   infrequently  used
          auxiliary water intake in the harbor channel.

        - Waukegan Port  District  which  has heavily  used public  boat  landing
          ramps.

        - National  Gypsum Company  which  receives  gypsum  in  large  boats  at
          Slip #1.

    The area of the harbor, exclusive of the  mouth,  is approximately  37 acres.
Water depths vary  from 14 to 25  feet with some shallower spots near boat launch-
ing locations and  in  the far  upper reaches of Slip #3.  The depth at  any  one
location varies with  time  depending  upon (1)  degree of  siltation and  whether
the area has  been  dredged, (2)  mean  lake level,  and (3) local   seiches  due  to
storms, wind shifts or other causes.

    In order to  maintain the navigational  uses  of  the harbor,  the U.S.  Army
Corps of Engineers traditionally dredged an average of  30,000 cubic yards  per
year of  sediments  near  the main entrance channel.   With the exception  of  the

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                      -11-
             MILWAUKEE
WISCONSIN
ILLINOIS
                     ^CHICAGO
   FIGURE IV-1:  LOCATION OF WAUKEGAN HARBOR. ILLINOIS

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FIGURE IV-2;   AFRTAL PHOTO OF WAUKEGAN HARBOR.  ILLINOIS

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                                   -13-
                                           NORTH SHQBP
                                            E- W PORTION OF NORTH D«TCH
                               NORTH DITCH
                             OVAL LAGOON PORTION OF NORTH DITCH
                              RESCENT DITCH PORTION OF NORTH DITCH
TWO OUTFALLS
TO DITCH
                    OUTBOARD  MARINE
                       CORPORATION .
                  FORMER^*
                  OUTFALL
                                      VACANT
                                      OUTBOARD  MARINE
                                    CORPORATION PROPERTY
                                     (FORMER  SITE OF
                                      GENERAL MOTORS
                                      FOUNDRY)
                                  OUTBOARD MARINE
                                    CORPORATION
                              FALCON
                              MARINE
MARQl ETTE
                                   WATER
                                   PLANT
               W4UKEOAN
               PORT
               DISTRICT
                        LOCATION OF OUTBOARD MARINE CORPORATION PLANT
                        AND PCB OUTFALLS  IN  RELATION TO SLIP #3
                        THE NORTH  DITCH

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                                      -14-


removal of  a  small  amount of  uncontaminated material  (contaminated to  less
than 1 ppm) from the southeast corner by the Waukegan Port  Authority,  no  dredg-
ing has been performed in  the harbor  since  PCB contamination  was discovered in
1975.  Spoils from  the last  dredging (1974) were  placed  in  mounds  up  to  14
feet high  located  on  vacant  land  owned  by  OMC  and  bordering the  northeast
portion of Waukegan Harbor.  The mounds are composed of sand  which for the  most
part contains 2 ppm  or less of  PCB.   Earlier dredge  spoils were usually  dumped
into Lake Michigan.  Slip  #3  reportedly has not been dredged  since about 1950.
The upper  portion  of the  harbor was  last  dredged  about  1957.   Slip #1   was
widened and dredged  in 1968.   Slip #2, formerly  located  at  National Gypsum,
was closed in 1957.

Contamination of Harbor Sediments

    Waukegan Harbor appears currently  to  contain  as much as 275,000  pounds  of
PCBs, which continue to contaminate  the waters of Lake Michigan.  This  contamin-
ation occurs, to varying  degrees, in bottom sediments throughout the entire  har-
bor.

    Harbor Sediments consist  basically of  1)  a  top  soft  "muck" layer,  2)  an
underlying sand  layer  and,  3)  a   generally  impervious  silty  clay  layer.
(See Figure IV-4.)

    The muck layer  varies  from  0 to  10.5  feet  in thickness.   Available  data
have shown that  this layer  is  contaminated  at  all  depths  and  at any given
location in the harbor.  Contamination is  highest in Slip #3  (as high as 500,000
ppm or 50% PCBs)  and decreases  towards the harbor mouth, where concentrations
drop to the 5 to 10 ppm range.

    The sand layer  varies  from  0 to  9 feet in thickness.  The  contamination
level of this  sand is less than 5  ppm,  except  below the old OMC outfall  in
Slip #3.

    The underlying  gray  silty  clay  is  generally  impervious  but may contain
some gravel, sand,  or thin  organic  seams  that  could  allow  PCB  penetration.
PCBs have  been  found to  be less  than  1  ppm in this  layer, except  immediately
below the Slip #3 outfall.

    The zones of harbor contamination  exceeding, respectively,  500 ppm,  50 ppm
and 10 ppm PCBs  are shown  in  Figure  IV-5.  The high concentrations  found  in
Slip #3 suggest that nearly pure PCB hydraulic fluid must have been  deposited
from the OMC  outfall  into harbor  sediments  during the years  of maximum  PCB
fluid leakage.   These  PCBs have  now  spread  out  into the harbor through  the
muck layer.

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                           -15-
BULKHEAD


                 WATER
                 6' to 17'
                             WATER
                                            EXISTING GROUND
                                                SURFACE
                          /
/
            2' to 6' SAND
                 HARDPAN CLAY
             FIGURE IV-4:  CROSS SFCTIQN OF SLIP #3

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                              -16-
           SLIP NO,3
SLIP NO,I
GREATER THAN 500 PPM

50-500 PPM

LESS THAN 50 GREATER

THAN 10 PPM

10 PPM OR LESS
                         JOHNSON
                         OUTBOARDS
                                 CITY
                                 FILTRATION PLANT
                                             LAKE MICHIGAN
              FIGURE IV-5;  FXTFNT OF PCB CONTAMINATION

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                                      -17-
    The total volume  of  contaminated  sediments in the harbors, as shown below,
is estimated  to  be  168,000  cubic  yards,  containing  up  to  approximately
275,000 pounds  of PCBs.  These  calculations  are based  upon ongoing  studies
conducted by U.S. EPA and its consultants, the  Illinois  EPA, CMC consultants,
and others, and are subject to futher refinement.
                 ESTIMATED PCB CONTAMINATION IN WAUKEGAN HARBOR
 ZONE OF PCB               MAXIMUM AMOUNT         APPROXIMATE VOLUME OF
CONTAMINATION *            OF PCBs PRESENT        CONTAMINATED SEDIMENT
More than                                         7300 cubic yards, muck
500 ppm (Slip #3)         270,000 pounds          1500 cubic yards, sand

50 ppm to 500 ppm
(between Slip #1
and Slip #3)              4,000 pounds            39,000 cubic yards, muck


10 ppm to 50 ppm          2,000 pounds            120,000 cubic yards, muck
Total (more than          276,000 pounds          168,000 cubic yards
       10 ppm)

*  [See Figure IV-5.]
    PCBs move  from  contaminated  sediments   into  the  waters  of  the  harbor
through two  major  interrelated  pathways.    In  the  first  pathway,  PCBs  in
sediments become  soluble  in overlying  waters.   Maximum solubility  of Aroclor
1242 and 1248, the  two  primary Monsanto products used by OMC,  is  at the level
of hundreds of parts per billion  (ppb).  Because of the mixing  of  contaminated
waters with clear waters,  and the  adherence of  dissolved  PCBs to  particles
(and subsequent precipitation out of solution),  actual  environmental  concentra-
tions are far below the maximum level.  The 2 to 10 ppb range observed in  Slip
#3 is unusually high for surface waters (see  p.  IV-19).

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                                      -18-


    In the second major  pathway,  PCBs attached to sediment and  soil  particles
become suspended  in  the water  column as  a result  of turbulent water  motion
caused by winds,  waves and  boat  movements.  These  suspended  materials,  along
with the dissolved materials referred to above, are carried outward  by circula-
tion and  flushing movements.   Although  much  of  the  PCB  is   redeposited  into
downstream sediments during  the process,  some enters  the lake.   At  each  of
these stages, the PCBs are  accessible to  living organisms and there  is  the
ever-present danger that they will  enter the food chain and bioconcentrate to
high levels.

    Measurements of the water concentrations of PCBs, water movement,  suspended
solids movement, and other chemistry, are allowing development of  a mathematical
model to  estimate the  current  discharge  of PCBs  from Waukegan   Harbor  to  the
lake through the harbor channel.  The U.S. EPA consultant's preliminary estimate
is that approximately 20 pounds per year of PCBs are discharged from the  harbor
into the lake.

    In the other  significant route  for  transport of  PCBs from   the  harbor to
the lake,  OMC  currently  withdraws  approximately 1  million   gallons  per  day
(MGD) from Slip #3  of  the harbor  for use as cooling water.  After  circulation
throughout the plant,  the water is  discharged  to Lake Michigan  and the  North
Ditch.  Concentrations   of  PCBs  in  the  outfalls result  in  approximately  2
pounds per year  being  discharged directly  to the  lake,  according  to company
figures.

Waukegan Harbor Fish Contamination

    Fish which have lived for  long  periods in Waukegan Harbor enter  the lake,
where they may stay  for  periods of from several days to several   months.   Some
of the  fish  caught  by  fishermen  in the Waukegan  area have undoubtedly  spent
some time  in the harbor,  whether  or  not they  are  caught  in the harbor.

    By mid-1980, U.S.  EPA had  completed  two types of  studies  to determine  the
extent of PCB contamination  of fish in the harbor.   In  the  first, 16  random
samples of fish collected from  the harbor  averaged 18  ppm  PCBs.   All  but three
of these  samples  exceeded the  5 ppm FDA  guideline and all but  one exceeded  2
ppm, the  proposed guideline.  Those  levels  are higher than those found  in  the
lake for the same species.

    In the second study, uncontaminated fish were  exposed  for  30 days to  water
from Slip #3  in the harbor, and  then  placed  in open lake water for an additional
84 days.  The 30-day exposure to the harbor water  resulted  in 20  ppm PCB  levels
in the bluegills  and 12 ppm levels in the yellow  perch.   Even  after the  84-day
exposure to  cleaner  open lake  water,  these levels  did  not drop below 8  ppm.

    Although the determination  of these concentrations was based upon  analysis
of the whole fish, and the FDA  guidelines refer only to the edible  portions  of

-------
                                      -19-
the fish,  the  tests  strongly indicate  that fish  caught  in  Waukegan  Harbor
should never be  eaten,  and that  fish spending even  short periods of time  in
the harbor should not be eaten except on an infrequent basis.*

    For comparison, Illinois EPA analyses of the edible portion of  fish  caught
in Lake  Michigan  off Waukegan  in 1978  indicate  that PCB  levels   for bloater
chubs are  less  than 1 ppm  while  levels in two groups  of lake trout  averaged
3.4 ppm  and  5.4 ppm  respectively,  exceeding either  existing  or and  proposed
FDA levels.  The  Illinois Department of Public Health  has issued  warnings  to
limit consumption of salmon and trout from the lake.

Ambient Water Quality

    The levels of PCBs in  the waters of the harbor, the nearshore  areas  and  even
the lake itself are higher than the water quality criteria currently recommended
by U.S.  EPA.   These  elevated  levels are  of  great  concern because  of their
effect on fish contaminant  levels and human  health, due to  the high bioaccumu-
1 ation factors.

    PCB levels in the open waters of Lake Michigan range from 5  to  10 ppt  (parts
per trillion) and  typically up to  50 ppt  in  nearshore waters,  substantially
above the U.S. EPA  recommended  levels of one  ppt  or less, designed to  reduce
levels in fish to  those  acceptable  for  human consumption.  Levels  in  Waukegan
Harbor are much higher,  ranging  from less than 100  ppt  in the harbor channel
to several thousand ppt  in Slip #3.

Water Supply

    There is an auxiliary  public water supply intake located in  the harbor chan-
nel, which is used  less than one or two days a year.  Monitoring by  the  U.S. EPA
and the State of  Illinois indicates  that it poses no threat to  public health.
The monitoring of  nearby  harbor water  concentrations,  as well  as  of the raw
water actually taken  in during  periods  of use, has always  shown PCB levels  to
be well  below  the  U.S.  EPA current recommended maximum  of 1  ppb for  drinking
water.  Further, the water receives  treatment before  use  and PCBs  have  not  been
detected during testing  of the treated water.   The  situation requires,  however,
that such  testing  be continued  as  long  as the  harbor  contamination exists.
*  Concentrations in whole fish tend to be  somewhat  greater  than  in the edible
portion, but on  occasion the edible portion may  contain even higher concentra-
tions.

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                                      -20-
NORTH DITCH AND OMC PARKING LOT AREA SOILS

    A second  area  of excessive  PCB contamination by  OMC,  in  addition  to  the
harbor sediments, has been  found in the nearby  "North Ditch"  and  in the soils
of the adjacent parking lot for OMC employees (see Figure IV-6).

    The North Ditch  is  a  small  tributary approximately 1500  feet  north  of  the
harbor, which drains  0.11   square  miles of  property owned  OMC and  the North
Shore Sanitary  District.   About  40 percent  of  this  area  has an  impervious
surface (roads,  railroads,  buildings,  and parking  lots).   Upstream  from OMC,
North Ditch drains  an area of  landfill  (which  served as  a disposal  site  for
urban debris) composed  of sandy material.   It  then  crosses the Elgin,  Joliet
and Eastern Railway  Company tracks, via  a 36-inch culvert,  before  entering  OMC
property.

    The ditch then enters a 600-foot-long-by-20-foot-wide  channel,  referred to
in this report  as the "Crescent Ditch".  The Crescent Ditch  formerly received
OMC floor drain discharges containing PCBs and  is still  receiving  once-through
cooling water used  in the  plant.  The Crescent Ditch conveys  its  waters to an
"Oval Lagoon" approximately 240  feet  long.   A  culvert at  the end  of  the Oval
Lagoon connects it to a straight East-West channel about 2,000  feet  long which
flows directly to Lake Michigan.

    The North Ditch stream bed  material  is  composed of sand  with  some gravel.
The sand  is  overladen  with  organic debris,  black-grit,  and  finer  sediments,
especially in the Crescent  Ditch and Oval Lagoon.  Cattails and other vegetation
grow along the  ditch, and  the ditch itself contains considerable  algae. Carp
have been seen in it on occasion, and  birds  have nested along it.

    The depth of water  in  North Ditch is influenced by  Lake  Michigan.  During
periods of on-shore  winds,  sand piles up at  the mouth,  even to the extent of
closing it off.   When  lake  levels are  high  with  strong  on-shore  winds,  the
North Ditch level can reach the  top of  its banks.  Then  the  excess  sand  at  the
mouth must be removed to  prevent flooding of OMC property.   During  periods of
off-shore winds, the  North  Ditch  mouth  tends to open up,  the water  level   in
the ditch drops, and there  is a net  flow of ground water up  into  the  ditch.
Lake water can  likewise flow into  North Ditch  or North Ditch water  can seep
into the  lake via the groundwater. During  very dry weather, the flow may  not
even enter the lake, percolating through the  bottom into  groundwater.

    A general picture of the geology underlying  the OMC site  is given in  Figure
IV-7.  Across most of the  OMC property, the  ground  surface has been raised by
the dumping of  artificial fill  material  up  to  an 8-foot depth.  The fill lies
over a sand  layer  which in turn overlays a  clayey silt.   Groundwater  levels
and movements are variable, depending on the stage of the ditch and rainfall.
Groundwater levels  can be within two feet of  the ground surface in  the vicinity
of the ditch, while movement tends  to  be towards the lake.

-------
-21-

     oc
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-22-
                                                oo

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                                      -23-


    The North Ditch  apparently received the  largest  portion of  all  PCBs  dis-
charged from OMC  between  1959  and 1972.  These PCBs may be  found in  very high
concentrations:  as much  as 25% PCBs  (250,000 ppm) had  been found in  surface
sediments near the OMC  outfalls  and 38% PCBs in underlying  sediments  as  early
as 1977.   Concentrations  as high  as  24,000  ppm  were found  7  feet below  the
ditch.*  Figures  IV-8  and IV-9  indicate  the  extent  of   the   problem  known
then.  As may  be seen,  the worst  areas are  immediately  downstream  of  OMC's
former outfalls  which carried  the heaviest  PCB  load  from the  old  die  cast
building.  Downstream surface  concentrations stay  above 50 ppm  almost to  the
lake.  Based on data gathered through  1977, it was estimated that approximately
4500 cubic yards  are  contaminated at  a  level  higher than 50 ppm PCBs,  and  6300
cubic yards at a level above 10 ppm.  Continuing study of soils  and groundwater
on OMC property  has  shown high levels  of  PCB contamination in  water  and  soil
adjacent to the  ditch and  at  depths  below  it.  (See Figure  IV-10).   Thus  the
volumes noted above  are substantial  underestimates  of the amount  of  sediment
and soil which must be removed or otherwise dealt with.

    As has been  discussed  above,  combined  discharges of PCBs to Lake  Michigan
from the  ditch  and harbor  during OMC's greatest  use of PCB hydraulic  fluids
were in the thousands of pounds.

    The North Ditch  discharges PCBs  to the lake  during  its regular flow  and
during rainstorms.  OMC's  consultant  estimated, in  1977,  that  roughly 7 to  8
pounds per year  were  entering  the lake  through  this  route.   In  U.S. EPA's  view
there is the possibility that  the  ditch  could, under special conditions,  produce
large additional releases of PCBs.

    Finally, the slow migration of  PCBs  through the  contaminated  soils  results
in gradual release of PCBs into shallow groundwater aquifers which are believed
to be discharging  into  the lake.    As PCBs  are probably spreading  through  the
groundwater and soils, this source is  believed to be increasing.**

    In late 1979, the U.S.  EPA took  steps  to  implement  the construction of  a
bypass to divert flows around the  most contaminated portion of the ditch.   Pre-
construction soil testing revealed  new  areas  of previously  undiscovered conta-
minated soils in the  OMC  parking  lot  located just  south  of  the  east-west
section of the  ditch.  The diversion construction  was  delayed  while  further
studies were undertaken which  have  shown substantial  additional  PCB contamina-
tion (See Figure  IV-10) in  both the soils  of the parking lot and in the under-
lying groundwater.


*  Data  on PCB  concentrations obtained  by  U.S.  EPA since October  of  1978  are
subject to a  protective  order issued  by  the  Federal  District  Court  at  the
request of OMC.   The  order provides that  such  data cannot  be  discussed  until
"the data and tests are  used  in the  prosecution of this matter."  Since  trial
is not expected to occur  until  later  this  year, U.S.  EPA is attempting to  gain
release of the most pertinent  information for public disclosure.

** U.S.  EPA  data on  the  ditch and groundwater  are subject to  the protective
order.

-------
-24-




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-------
                                      -27-
    High soil concentrations of  up  to 14,000 ppm PCBs were  found  in  1979  just
south of the North Ditch and only 500  feet  from the lake,  in CMC's parking lot
area.  Six  other  samples  exceeded  1000 ppm.  Contamination  of  groundwater,  in
levels ranging from 2 to 680 parts  per billion,  was found in sampling  conducted
by OMC's consultant on  the  OMC site in 1977.   The  concentrations  of  PCBs  that
have been  found  in soils on  OMC property  are  higher than the level  at which
PCB contaminated materials are required by U.S.  EPA regulations to be  contained
in a secure landfill, approved for PCB disposal. *

    Although the full extent  of this new area  of contamintion is  still being
investigated, it is clear that the  parking lot soils  represent,  in actuality,
an unlicensed and unsecure PCB landfill.

SUMMARY

    Since discovery of  the  Waukegan  PCB  problem, U.S.  EPA, with  the help  of
consultants and the  cooperation  of other agencies,  has  performed a  number  of
studies regarding  the  nature  and extent  of the  PCB problem and  its  effects,
both locally and  in Lake Michigan  as a whole.   The results of  these  efforts
may be summarized briefly as follows:

    - The PCB  contamination  site at  Waukegan,  Illinois, as a result of prac-
tices by the  Outboard  Marine  Corporation,  is the  largest known  reservoir  of
PCBs existing in the free environment.

    - Waukegan Harbor  is believed  to contain  up to  275,000  pounds  of PCBs,
distributed within approximately 168,000 cubic yards  of  sediments  with  average
PCB levels above 10 ppm.

    - The North Ditch tributary to  Lake Michigan contains PCB concentrations  as
high as 380,000 ppm.

    - A new area  of soils and groundwater  contamination was found in the OMC
parking lot last year when U.S.  EPA  attempted to  construct a bypass around the
ditch area.  Tests showed  that  contamination  levels exceeded  14,000  ppm  in
soils and extended to 680 ppb  in groundwater, although volumes  are still under
investigation and  some  of the existing data  is  protected  by the  court order.

    - During the  period of  OMC's  greatest  use  and discharge  of PCBs  to  the
Harbor, discharge of PCBs to Lake Michigan  were  in  the thousands  of pounds per
year.  Much of the Lake Michigan PCB problem was created  as a result.

    - Current  PCB  releases  from  the  harbor  to  the lake  are  approximately
20 pounds  per  year, with  additional  discharges entering  the  lake  from  the
ditch, through the groundwater, and  from OMC discharges.


*  Additional  sampling  has  revealed further extent  of contamination  of soils
and groundwater  in this area  but   further  description  cannot  be  provided  at
this time due to the limitations of  the protective order.

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                                      -28-
    - Contamination  of  fish  caught  in the  harbor averages  18  ppm PCBs,  and
two groups of  lake trout collected in the  lake  near Waukegan had 3.4 ppm  and
5.4 ppm  average  concentrations  respectively.  When  these levels are  compared
with the  FDA  temporary tolerance  limits  of  5 ppm  and proposed limits  of  2
ppm, it  suggests  that  all  fish  caught  in Waukegan  Harbor  and  some caught  in
the nearby area of the lake are  unfit  for  regular consumption.

    - Studies demonstrate that after  exposure  to the harbor  waters, even fish
that return to  the lake may  retain  levels  of PCBs  exceeding  FDA  limits  for
several months.

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                                      -29-
                                   CHAPTER V


      THE OPTIONS FOR DEALING WITH THE PROBLEM AND THE PROPOSED SOLUTIONS

WAUKEGAN HARBOR

    The foregoing section of this report has discussed the extensive contamina-
tion of Waukegan  Harbor,  including the presence  of as much as  275,000  pounds
of PCBs, the continued  discharge of PCBs from the  harbor to Lake  Michigan  and
the resulting contamination of  fish.   As  the information available to U.S.  EPA
describing the problem has increased, it has been possible to develop engineer-
ing evaluations of the options available to reduce or eliminate these problems.
A discussion of these options  follows, together with preliminary cost estimates,
where available.

The Options

    There are three general  approaches to dealing with this problem:

    - First, the  no-action  alternative,  which  could include taking  measures
which would mitigate  the  harmful  effects  of the  contaminated  harbor sediments
but would do nothing  to reduce  the contamination itself  or to prevent it  from
continuing to migrate into the waters of the lake and the food chain.

    - Second, a  set  of options  which  would reduce the migration  of PCBs  from
the sediments into the lake and the food chain, but which would require reduction
or elimination  of  present uses  of  the harbor.  This  set of options  includes
closing or draining the harbor,  securing the sediments and attempting to destroy
the PCBs in place.

    - Third, the removal of  the contaminated sediments, which would permanently
and dramatically reduce their  adverse  impacts on the environment while restoring
the harbor to its original uses.

    No Action.  Efforts to  mitigate  the  effects  of  the contamination might
include bans on fishing  in Waukegan Harbor and some nearby Lake Michigan waters,
bans on dredging in the harbor, and restrictions on boat traffic.   These efforts
would reduce the exposure of  fishermen and  their  families  to PCBs, but would
restrict recreational  and industrial  uses   of  Waukegan  area  waters.   Normal
sedimentation would cause water depths to decrease, restricting  industrial  and
pleasure boat traffic.  Although  it should  be  possible to dredge  small areas
in the navigation channel safely  as  long as  safe methods  for toxicant dredging
and disposal were employed,  this would simply replace an immediate large  dredg-
ing project with a  piecemeal  project  to be accomplished  over many years, thus
increasing the  overall  costs  and reducing  the ultimate  benefits.  Discharges
of PCBs into the  lake would  continue, as would  the spread of PCBs  into down-
stream harbor  sections.   In  addition,  PCBs from the  very high  contamination
zones in  Slip  #3  could  spread  into  the  adjacent  soils  and  groundwater.

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                                      -30-
    Closing the Harbor.  Installing a dam across the entire harbor or part of the
harbor would  both  prevent  PCBs from  moving into the  lake  and keep  fish  from
coming into the harbor.   It would  eliminate  all  boat traffic.   Waters  in the
harbor would stagnate.  PCB concentrations would increase  in the water, increas-
ing the possibility of movement of the toxicant  into the air (volatilization).
Highly contaminated sediments in the upper harbor could spread into the adjacent
soils and groundwater.

    Draining the Harbor.  The  permanent  loss  of  part  of the harbor suggests
one further variation of the  harbor closure  option.   In this concept,  a dam
would be  build  across the harbor  and  the water behind  the  dam  pumped through
a water treatment  system back  into the  lake.   Excavation of sediments  would
then occur  with the material  taken  to  a secure landfill  or incinerated.   The
dam would then be opened and the harbor returned to use.

    When water is drained  from the harbor,  however,  sheet piling  and the adja-
cent shore  can be expected  to  cave in.   To  prevent this,  a  slurry wall must be
constructed around  the perimeter  of the  harbor.  Well points  would have to be
installed to  prevent  groundwater   from  entering  the harbor.   This would  be  a
very expensive alternative  and would  necessitate  closing the harbor for more
than a year.   Volatilization  of  PCBs  from  exposed  sediments  could  also  be  a
problem.

    This approach  might  be  more plausible for the  small  area  in  slip #3 imme-
diately around the  old  OMC  outfall, the only spot where  sand  and  clay  have
been found  to  be  contaminated  and where contamination  behind the  sheet  pile
wall is suspected.

    In-place Secure Storage.   In  this  concept, the  upper  (northern) portions
of Waukegan Harbor, including  but  not  necessarily limited to slip  #3, would be
sealed off  by  a dam.  PCB-contaminated  sediments  from  the lower  portions  of
the harbor  would then  be removed,  using a hydraulic dredge, and  transferred to
the sealed  upper portion.  The water in  the upper portion would  be treated for
PCBs.  A slurry wall  made  of clay and  extending down into natural  clays  under-
lying the  harbor  would  be  constructed  around the  sealed portion  to restrict
horizontal movement  of  contaminated  waters.    Finally,  the  sediments in  the
sealed portion would  be  hardened  by an  in-place  fixation method  and covered
with clay  and  soil.   The  upper  portion of the  harbor  would  then  no  longer
exist.  In its place would be a PCB disposal facility.

    Approximate costs (excluding property aquisition) for this approach  are  as
follows:

Contamination Level  Sealed Off     Location  of dam       Approximate cost

    Over 500 ppm (Slip #3)          1/2 way up  Slip  #3   $2 million

    Over 50 ppm (Above Slip #1)    just below Slip  #3   $5.5 million

    Over 10 ppm                    just above  Slip  #1   $13 million

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                                      -31-


    These alternatives do  not conform to conventional  PCB  landfill  practices
and would require a special  waiver  from  U.S.  EPA.   The  upper end  of the harbor
would cease to exist,  restricting  or eliminating Larsen Marine's  business,  if
contamination were secured to  the  500 ppm and 50 ppm levels.   If the dam were
located to  secure  sediments  at  the  10   ppm  level,  it  would probably  affect
National Gypsum  as  well.   The PCBs  would remain  in  proximity  to  the  lake.
Given the  nature of  the underlying  sediments  and the contamination  already
found in clay layers,  U.S.  EPA could not  predict that the PCBs would be immobil-
ized.  Any  penetration  of underlying  layers,  if it  were to  occur,  would  be
more difficult to detect and to deal with than in a  conventional  PCB landfill.

    In-pi ace Destruction.

    Biological agents.  It has been suggested  that  biological agents (microbes,
worms) that have been tested  in  laboratory  situations could  be  released  to
Waukegan Harbor  or used  after sediments  had  been confined by a method similar
to that  described  above.  No  tests have shown,  however, that these  organisms
will degrade PCBs of  the type that are  found  in  Waukegan Harbor  in  a natural
environment.  U.S. EPA  scientists  advise that  any  expected degradation  would
be on the  order  of only a few per  cent.  If the  organisms did  work, to  any
extent, there  is no  assurance that PCBs below the surface  would  be affected
unless the  sediment were stirred.  Further,  there  has  been no examination  of
additional risks that  might result  from  application of  the organisms  and  stir-
ring of the sediments.

    Chemical agents.   Several chemical methods for destruction of  PCB materials
are under development.   At the present  time  none  will   work for  sediments  in
aqueous environments,   nor  even  for water-containing  sediments after  removal
from the harbor.

    In-pi ace Fixation.  A  Japanese  firm has  developed a method  for  turning
contaminated sediments into a  concrete-like material.   Costs have  been  quoted
at $20 to $40  per  cubic yard  or  roughly $300,000  if fixation were limited  to
the materials  above 500 ppm.  Long-term stability has not been  demonstrated
for the technique, however,  and  as  the concrete begins to deteriorate,  it  can
be expected to release PCBs back  into the environment.   The resulting concrete-
like harbor bottom would also create  great difficulties in dredging the harbor
bottom, thus severly  restricting  harbor use.

    Removal of the Sediments Through Dredging.  Dredging is  a proven alterna-
tive which  would remove the  PCB-contaminated  sediments from Waukegan Harbor.
It would,  however,  require   selection  of  a  dredging  technique  that  would
restrict the  dispersal   of  additional   PCBs  during  the  dredging  operation.
There are three  main  types  of dredges applicable to this  project:  mechanical,
hydraulic and  pneumatic.   Mechanical  dredges,  which include  clamshell,  dipper
and bucket-and-chain  dredges,  scoop  up  sediment and  bring it to the surface,
where it  is  placed  in trucks  for  disposal.   A clamshell  dredge  would  be  the

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                                      -32-
method of  choice if  there  were  no concern  for either  dispersal  of  PCBs  or
incomplete removal  of sediments.  There  is,  however,  considerable disturbance
and suspension of  sediment  with the clamshell dredge.  An  estimated 15 to 30%
of the muck  sediment is  spilled  when  a  clamshell  lifts  it out  of the water,
creating significant turbidity, and further spillage may occur when the materi-
al is placed in waiting trucks.

    The hydraulic dredge  uses a  suction  line,  a pump and  a  discharge line to
convey the  sediment to a basin  where  it  can be dewatered  and  treated.   Tur-
bidity is far less than from a mechanical  dredge, and this technique is ideally
suited to the  harbor muck.   Sand dredging  of the type needed in a small  zone
of slip #3 would, however, require use of a cutter head to loosen the material.

    Use of a hydraulic dredge requires a dewatering basin.   If  the basin  were
at a  remote location  or  in  a  barge  there  would  be  considerable chance  of
spillage.  The  only  open  land  for  location  of  a  dewatering basin available
close enough to assure a  clean  operation  is the  OMC property  formerly  owned by
General Motors.  (See Figure IV-3).

    Pneumatic dredges  use  compressed  air  to force  the  sediments through  a
pipe at  the  bottom.   Less  water is conveyed with the  sediments  than with  a
hydraulic dredge.   A  pneumatic dredge  could  be  expected to  be effective in the
muck layer  but  less effective than  a  hydraulic dredge for sand.  The use  of
compressed air might generate increased risks of volatilization.

    Roiling of bottom sediments can  be  kept to a low level  with both the hydrau-
lic and pneumatic dredges.  Silt curtains could be situated outside the area of
dredging to restrict movements of sediment.  The main drawback to these methods
is the need to first dewater and then to dispose of or incinerate the sediments
offsite.   Dewatering  would  require temporary  use  of the  OMC vacant  land.

    Dredging can be done  safely and  results  in  genuine cleanup,  but it is  more
costly than some of the methods outlined above.  Harbor usage would be restrict-
ed only during a period of a few months when dredging occurs.   Following dredg-
ing, water depth  would be  greater than  before  and full  harbor use  could  be
achieved.  The effects of contamination would be permanently  reduced or elimi-
nated, depending on the size of the dredging project.   The cost of dredging the
harbor sediments which  are contaminated  above  10 ppm, currently estimated  to
be 168,000 cubic yards, would be in the vicinity of ten million dollars, inclu-
ding the costs  of dewatering, water treatment,  loading  into trucks  and  site
restoration.  Disposal  costs  would  add  $6  to $33  million,  as discussed  in
Chapter VI.
The Preferred Option

    Dredging and  removal  of  the
clearly the only available option
tives:
 contaminated  sediments  from  the harbor  is
that will accomplish all  the following objec-

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                                      -33-


    - Restoration of the harbor to its full  recreational and commerical functions

    - Removal of the severe PCB contamination risks to consumers of fish caught
      in the harbor and lake environs

    - Reduction  of  a major source  of PCB contamination of Lake  Michigan  fish

    - Complete  and   permanent  removal of  the contamination  problem from  the
      area

    These clear  benefits  to the  citizenry of Waukegan  and  the  Lake  Michigan
Basin more fully justify  the  costs  of remedial work  than do the  other  options
currently available.  In  addition,  this  option would remove to a secure  loca-
tion up  to  275,000  pounds  of  a contaminant  whose  toxic effects  are  serious,
and whose persistence in  the  environment makes it  a  potential  threat  to  human
health forever.

    If the harbor is dredged, the project  should  remove  all of those sediments
contaminated above 10 ppm.  Recent studies strongly indicate that  risk of  human
exposure cannot  be   completely  eliminated  without  removal  of all  sediments
above the 10 ppm PCB level.

    U.S. EPA's consultant has done simulations of the effect of various  removal
strategies on  average PCB concentrations in  fish,  which now  routinely exceed
health guidelines,  in  Waukegan  Harbor.   Preliminary   figures  indicate  that
removal of all  soils contaminated at  or  above the 100  ppm level  would result
in concentrations in fish exceeding  the  FDA  guideline  of 5  ppm in the  most
contaminated portion of  the harbor.   This  would drop to over 3 ppm near  the
mouth.  Similar  effects  could  be expected  if  removal  took   place at levels
exceeding 50 ppm.  Simulations for PCB removal to 10 ppm level  indicate  average
concentrations in fish  would generally  be about 3 ppm  throughout  the  harbor,
below the current FDA guideline  but above the recommended guideline  of 2  ppm.
Simulations for 1 ppm indicate  little further decrease  in fish  contamination.
Only if  dredging  is conducted to the 10 ppm  level,  therefore,  can we expect
contamination in fish to stay within the existing FDA limits.

    Information to support the 10 ppm dredging objective comes from several  other
sources.  U.S. EPA's 1977 Great Lakes criteria for sediments established 10  ppm
as the level  beyond  which  harbor  sediments  are classified  as heavily polluted.
The criteria are, in turn, based  on  tests  of exposure of fish to  PCB-laden
sediments, and waters in  contact  with PCB-laden  sediments,  as  well  as  on  con-
sideration of  contaminant  levels  in  other  harbors.   Taken  together,   this
information supports the view that dredging to 10 ppm should reduce fish levels
to within the 5 ppm  FDA  guideline.

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                                      -34-
The Plan for Cleanup

    The U.S. EPA,  with the assistance  of its engineering contractor,  Mason  8
Hanger, has proposed a  program for dealing with PCB  contamination  in Waukegan
Harbor based on  hydraulic  or pneumatic dredging of  all  sediments contaminated
above the 10 ppm  level  (See Figure V-l).  The proposal  is  compatible with the
plan for dredging  slip #3  of  Waukegan Harbor made  public  by the U.S.  EPA  on
November 24, 1980.   This approach  is  presented schematically  in  Figure  V-l,
and described below.

    a.  The sediments  will  be  dredged  with a hydraulic or pneumatic dredge and
conveyed to lagoons through a pipeline.

    b.  Lagoons will  be constructed for  the dewatering and  temporary  storage
of the dredged sediments.

    c.  The  sediments  in the  lagoon will  be dewatered and  the excess  water
treated at  an  on-site  treatment  plant  before  it  is  discharged back  to  the
harbor.

    d.  Special handling of the most highly contaminated sediments  in  slip  #3
will be provided  by  a  combination of protective barriers, removal  methods  and
storage.

    e.  The dewatered sediments will be removed to  a permanent storage facility
as soon as the necessary arrangement has been made.

    U.S. EPA's  November 24, 1980 proposal  for  slip  #3  dredging covered  the
dredging, treatment and  storage  of up  to  15,000  cubic yards  of muck, including
harbor materials exceeding  500  parts per  million PCBs.   The  newest  information
has refined that  estimate  to  8800 cubic  yards of  muck and  sand.   The  full
proposal extends that plan to a total of 168,000 cubic yards of material  exceed-
ing 10 ppm.  The area to be dredged can be seen  in  Figure IV-5.   This proposal
is contingent upon the  use  of the  vacant OMC property adjacent  to  the harbor
for the temporary storage and treatment facilities.

    The Dredging Operation.  The  dredging  operation  involves  three  phases.
Phase I consists of dredging slip #3.   Phase II  involves dredging between  slip
#3 and  a  point north  of the mouth  of slip  #1.   Phase III  includes dredging
from that point  to the  boundary of the  10  ppm level.   The full project  can
take place in one field season.

    During the dredging  operation, the  roiled  sediments  in slip  #3  must  be
prevented from further  contaminating other  areas  of the harbor.  Also,  there
must be little interchange  of  the waters  between the  slip and  the  harbor.   To
perform both of these  functions, a containment  device (silt curtain)  will  be

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                                      -36-


put into  place  across  the mouth of slip  #3.  Design  of the curtain will allow
for stress  generated  by  water  level  fluctuations.  At  present,  a double silt
curtain (Figure V-2) is  being considered.  Additional  containment will be pro-
vided during  removal of  the contaminated sand and  clay  at the tip of slip #3.
A coffer  dam  is also being  considered for use in this location.

    For the  second phase of  the  operation, a silt curtain similar to the one
used in Phase I  will   be  placed across  the harbor  near the mouth  of  slip #1.
The dredge  will   start  at  the  north  end  of  this portion  of the  harbor and
work south.

    A silt  curtain will  be deployed around the  dredge  in Phase III.  The cur-
tain, in  this case, will  not be anchored  to the  harbor  bottom  but will move
along with the dredge  as  it works its way through the harbor.  A  low turbidity
dredge will be  used, thus reducing  sediment disturbance and placing less reli-
ance on the silt curtain  for  its containment.

    Continuous water quality  monitoring  will  be  conducted during all phases of
the dredging  operation to prevent dispersal of additional  PCBs.

    The most  heavily contaminated sediments (slip #3) will  be removed first, so
that:  (1)  any  of the slip #3  material  that  is  roiled  up will  have a greater
chance of being removed during the subsequent dredging and  (2) the most heavily
contaminated  material   will  be  placed in  a  confined  area  of the  lagoon  and
covered by  less-contaminated  sediments  to minimize the  volatilization  of PCBs
from the  lagoon site.

    The Lagoons.   The  Waukegan  Harbor bottom muck  sediments will  be slurried
with water and transferred to storage lagoons on  OMC  property (Figure V-l) for
settling.  The excess water will  then  be withdrawn, treated to remove residual
PCBs, and returned to  the harbor containing PCB concentrations  of less than 1
ppb.

    Lagoon construction  will  be  similar to  that  of a  secure  landfill,  with
impermeable clay liners  and leachate  collection  systems.   One possible design
is shown  in Figure V-3,   section A-A, which shows a  cross-section through the
bottom of the lagoon.   Above the existing ground  will  be a one-foot clay liner,
with a leachate  collection  system  above  it.  The leachate  collection system
will have perforated pipes  located  in an average  one-foot-thick gravel layer.
Above this  will  be three  feet  of  impermeable  clay  which will  be compacted
during construction to achieve  a permeability  coefficient  of  at  least  10-7
cm/sec.

    A six-inch thick layer  of sand is being considered  for placement above the
clay liner.    Its purpose would be to facilitate the dewatering of the sediments
in the lagoon.  The slightly  contaminated (generally  less  than  5 ppm PCB)  sand
piles on  OMC  vacant land might  be used  for this  purpose.   The  muck sediments,
under natural   sedimentation,  would   achieve  approximately  the   same  moisture
content as  they  possess   in the harbor  after  a  few  weeks.  Drainage  systems
will be used to further reduce water content.

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                   -37-
                              SILT CURTAINS
PLAN  OF  SILT CURTAINS-SLIP 3  DREDGINg
NO  SCALE
                                    FLOATS
                Ji
                        SILT
                        CURTAIN
                                    -WEIGHTS
                         BAND
                        SECTION  A-A
             ELEVATION  OF DUAL  CURTAIN
      FIGURE V-2: SILT CURTAIN PLAN & ELEVATION

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   -38-
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                                      -39-
    The sides  of the  lagoon  will  be diked.   A possible  design  is  shown in
Figure V-3,  section  B-B.   The three-foot  clay  liner will  extend  up the slope
of the  lagoon  from  its  bottom and  will  be  in contact  with  the contaminated
sediments.  The  dike sides  will  have  3:1 slope  for stability,  and  the dike
will be constructed  of soil  material brought  in  from off site and, perhaps,
material from  the sand  piles.   The  leachate  collection  system will   extend
through the dike  walls,  as shown, to  facilitate the  collection  of samples and
the removal of any leachate collected.

    Procedures will  also   be  employed  to minimize  volatilization  during  the
initial placement  and  temporary  storage  of  the  sediments   in  the  lagoon.

    The temporary  storage  lagoon will  be large enough  to contain  all  of the
sediments to be dredged, plus slurry  water.  A  lagoon with  a capacity of  55,000
cubic yards  should  be  large  enough  to  contain 7,300  cubic  yards  of  slip #3
muck sediments, up to 2,000 cubic yards of excavated  Slip #3 sand and clay and
up to 45,000  cubic yards  of  slurry  water,  including water used  to  clean  out
residual sediments and  flush  out  slurry lines.   Two  lagoons  will  be needed to
contain everything contaminated at a  level above 10 ppm.

    Although the  storage  lagoon  is  sufficiently  well   designed  to  provide
security for these materials  for a  long  period of time,  U.S.  EPA intends  its
use only  for  temporary storage, preferably  less than 2 years and in  any case
not more  than  5 years.   Dewatered  contaminated  soil   and  the  contaminated
lagoon liner  will  then be removed  for  final  disposal,  and  the  land  will  be
restored to a condition suitable for  industrial  use.

    Treatment of Excess Water.  Excess  water used  to  slurry harbor sediments
into the lagoon, plus water used  in  vacuuming up  remaining contaminated harbor
sediments and flushing out slurry lines, will be treated for PCB removal before
being returned to  the  harbor.  Treatment will  consist  of  (1)  settling of the
sediments in the  lagoon,  (2)  allowing excess water  to overflow a  weir placed
at one  end  of the lagoon  into  a smaller sedimentation  basin  where a polymer
will be added  to  coagulate  and  settle  fines,  (3)  pumping the  sedimentation
basin water through pressure filters, and (4) conveying filter effluent through
carbon filters to a  clear  well.  The  water in the  clear well  will  be monitored
for PCB content  before it  is returned to the  harbor.   A  1 ppb  limitation  of
PCB concentration for water returned to the  harbor will  be maintained.  Figure
V-4 illustrates  the  proposed  treatment  system.  Rainwater and  leachate  water
will be treated in essentially the  same manner, except that the  operation will
be interim"ttant and the system smaller.

NORTH DITCH AND OMC PARKING LOT AREA SOILS

    Chapter IV of this report has discussed the extensive contamination of the
North Ditch and nearby soils, including recently-discovered contamination of a
section of CMC's  parking  lot.   A court order prohibits  full  public  disclosure
of the data collected in this  area,  and the extent  of parking lot contamination

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is still  under investigation,  but  it  is  expected that  the total  amounts  of
PCBs may exceed the  amounts estimated for the harbor,  and  the  volumes of con-
taminated material are  expected  to  be comparable to the amounts in the harbor.
The contaminated  materials  include the ditch  sediments and  waters,  the soils
under the  ditch  and  parking  lot,  and  the  surrounding  groundwater.   The
following discussion  summarizes  the various  options  that  have  been evaluated,
with preliminary  cost  estimates where  available.   The discussion  is limited,
to some extent, by the restrictions of the court's protective order.


The Broad Options

    Five broad options appear available for dealing with this problem:

    - First, the no-action alternative.

    - Second, construction of a bypass to convey storm waters and OMC effluents
      around the zones  of  contamination.   (The bypass is  viewed as a necessary
      preliminary to any of the next three cleanup actions).

    - Third, destruction of the PCBs in place.

    - Fourth,  in-place  secure storage  to  limit further  movement of  the con-
      tamination into other parts  of the environment.  Both in-place fixation
      and in-place slurry wall confinement are considered.

    - Fifth, excavation  of  the contaminated  materials  and  disposal  of them in
      a manner  which  prevents  further  adverse  impact  on the  environment.

    No Action.   In this approach, one would take only those steps necessary to
reduce public  exposure  to  PCBs.   These might include  further  fencing  around
contaminated portions of the  ditch  and soil  areas to prevent  access  by  the
public or OMC  employees,  and  restrictions on  fishing  in nearby areas  of Lake
Michigan.  Such an  approach  would  be  equivalent  to locating  an  uncontrolled
PCB landfill on  the shores  of the  lake.  PCB discharges to the lake  and  the
spread of contamination through  soil,  sediments  and groundwater would continue
and the migration of PCBs to the lake from those soils would probably increase.

    North Ditch Bypass.   A  bypass  would intercept  the flow  of surface  water
that presently passes through  the  highly contaminated  Crescent  Ditch  and Oval
Lagoon sections of  the  ditch and direct these flows  into  a new  storm  sewer.
The straight, east-west  ditch  section would then  be cleaned out  and replaced
with a new  storm  sewer  or ditch system leading  to  Lake Michigan.   This  effort
would result in substantial  reduction of PCB discharge to  the  lake, reduction
of contaminated groundwater movement, and reduction of recharge  into contamina-
tion soil zones by ditch waters.   The spread of contamination from sediments,
soil  and groundwater  would continue, but at  a reduced rate.   Construction  of

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                                      -42-


the bypass would thus allow some time to deal  with contaminated soil,  sediment,
and groundwater issues.   Construction of the bypass is estimated to cost approx-
imately $2.4 million plus disposal  costs,  for approximately 6000 cubic yards  of
material.  This material could be taken directly to a disposal  site or it could
be stored in the temporary disposal facility proposed for the  harbor  on  vacant
OMC land.

    In-Place Destruction.  As has already been discussed in the harbor section,
biological and  chemical  approaches  to  in-place destruction of  the  PCBs  cannot
be relied upon  at this  time.   At  best,  further  research  and development  of
these methods may possibly  lead  to their use to reduce the amounts of PCBs  in
secure storage after other options are applied.

    In-Place Secure Disposal.  The  contaminated  sediments  and soils  in the
North Ditch and parking lot area are in one sense already in "storage" although
they are certainly not secure.   Securing them in their  present place  of  storage
requires adoption of  solutions that would  prevent their movement  through the
soils, into the  groundwater,  and into the air.   In  order to  insure  this  kind
of long-term security in the landfills they license for  storage of toxic  mater-
ials, U.S. EPA (which regulates such sites under TSCA) and the State of Illinois
employ stringent requirements.  The U.S. EPA normally requires at least  3  feet
of low permeability clay as  a  liner and a leachate collection  system  to  act  as
a backup in case any PCBs get through the clay.  Proximity to bodies of surface
water and groundwater  is also restricted.  On  the OMC  site,  with  groundwater
sometimes only  2  feet below  the surface and  the lake  only  a short  distance
away, it  is  difficult to  imagine  how equivalent  levels  of security   could  be
accomplished, especially under conditions of long-term erosion of the  shoreline
and very  high  lake  levels.  The  State of Illinois  is  even more  restrictive,
requiring at least 10  feet of  clay,  and  stricter permeability limits for the
clay.

    These landfill  requirements  reflect  the  high priority  given to  reducing
the threat of  any leaching  of PCBs from landfills,  of which  the  North Ditch
and the parking lot  area is an unauthorized example.  The  amounts  of PCBs and
volumes of contaminated  material  at Waukegan  are very large,  yet the PCBs are
in contact with systems  that  connect them directly with the  environment,  they
lie in permeable sand instead  of being enclosed in impermeable clay,  and their
"leachate collection system" leads directly to Lake Michigan.

    In-place Fixation.  This  method  of  turning   the  existing  sediments and
soils into  a  concrete-like  substance  was discussed  in  the   harbor  section.
This method has  the advantage  of  being less  costly than  excavation.   Quoted
costs are $20 to $40 per cubic yard plus equipment costs, compared  to  costs  of
$50 to $150  per cubic  yard for  disposal  costs alone,  if  the materials  were
excavated.  The PCBs would, of course,  still  be in place and the concrete would
deteriorate, perhaps  20 to 100  years  in the  future,  releasing  the   PCBs and
leaving a  situation  similar  to the  present   one.   The method  may have  very
useful application in  limited  situations, as  in  cases  where  contamination  is
found under buildings and cannot be dealt with in other  ways.

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                                       -43-
    In-pi ace Slurry Wall Confinement.   (See  Figure  V-5)  This  concept would  in-
volve construction of  vertical  walls of Bentonite clay 2.5 feet wide extending
25 to 30 feet into the natural  silty and clay layer  underlying the  PCB contamin-
ation to effectively cut off horizontal  groundwater  motion.  Such walls could be
installed on OMC  property around the perimeters of the Crescent Ditch, the Oval
Lagoon and the parking lot contamination zone once the bypass has been construc-
ted.  Well  points could also  be installed  inside  the  slurry  walls at depths
sufficiently below the groundwater table to assure that  any  groundwater movement
is inward and  to  allow treatment of those  groundwaters  that  may  enter through
the slurry  walls  or  the underlying  silt.   This  approach, together  with the
bypass, could reduce and perhaps prevent PCB migration.

    This option has  several  disadvantages.   The  first is the lack of long-term
reliability of the  slurry  cutoff walls.   Failure of these  walls  could result
in excessive leaching  from the  area and perhaps  further groundwater contamina-
tion.  There are  similar concerns  over the  permeability  and  uniformity of the
underlying silty  clay layer.*

    In-place secure disposal  approaches raise other  serious  questions related
to the long-term  use and character of the site: Will the Lake Michigan shoreline
erode and threaten the secure  storage  areas thus constructed?   Will  the area
flood or be overtopped by very  high lake levels?  Will the use of this property
be maintained  indefinitely  for  secure  storage?   These  questions  raise doubts
about the long-term  usefulness  of  the  approach.   The  relatively low  cost  of
slurry wall   confinement,  however,   encourages   serious   consideration  of  its
implementation on a short-term  basis if funds for the more expensive excavation
approaches are not readily available.  Construction of a slurry wall and leach-
ate collection system around the entire North Ditch and parking lot area conta-
mination zone should cost less  than $3 million.

    Excavation of Contaminated  Sediments and Soils.   This option  would include
removal of the  most  contaminated soils and  sediments  in the  Crescent  Ditch,
Oval Lagoon, and  parking lot   areas  by excavation  and/or  dredging  after the
bypass is accomplished.   A  dredging  approach could  be  used  for the  shallow
areas of  contamination  in  the  Crescent  Ditch  and  Oval  Lagoon  but  it  would
require dewatering similar to  that  proposed for the  harbor.  As  excavation  is
needed for deeper  sediments  in all   cases,  it would be more  cost-effective  to
do the entire job by  excavation alone.   Following excavation, the  contaminated
material  could be taken directly to  a final disposal facility.

    The difficulties   inherent   in excavation can  be satisfactorily  overcome.
Removal of contaminated materials below the  water table  would  require lowering
the water table  through well   points  to  permit  excavation   under  dewatered
* Information on U.S.  EPA  measurements regarding this issue  is  subject  to the
protective order.

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conditions.  Where deep  excavation is required,  slurry walls to  the  depth of
the silty  clay  would be  constructed.   Ground waters  removed  could be treated
with sand  filtration  and carbon absorbtion  to  a contamination level  of 1 ppb
PCBs or  less.   Construction  of the  bypass  would allow  excavation  from the
Crescent Ditch and Oval  Lagoon to  occur  in  a dewatered condition  without  roil-
ing the  sediments.    Where  contamination is  very deep  near OMC  buildings,  a
structural slurry wall could  be employed with bracing to prevent damage to the
structures.  Contaminated soils would be exposed only briefly and then covered,
to minimize volatilization.   Given these precautions  and techiques, excavation
could remove  contaminated  sediments  to the  desired  degree,  with  excavated
areas backfilled  with clean materials and the contaminated  materials  taken to
a final disposal  facility.   Additional  measures could be taken at the site to
restrict movements  of lower  level  contaminated  materials  that might  remain.

    The cost  of the  excavation  approach would  be in  the  area of  $9 million
exclusive of disposal costs, which will  add $30 to $100 or more per cubic yard,
as discussed in Chapter VI.  It is  the only approach that provides the permanent
reduction and virtual  elimination  of  the discharge of PCBs  to  the lake and the
spread of  PCBs  through  the soils  and   groundwater.   It would  make  the  site
available for future  industrial uses.

The Preferred Option

    Construction of a bypass  around the  North Ditch  is an essential  first step
to implementation of other options and itself accomplishes the following objec-
tives:

        - Greatly reducing discharges of PCBs from the ditch to the lake due to
          surface runoff

        - Greatly reducing  recharge to  and  interchange with the  contaminated
          groundwater system

    Once the contaminated flows  from  the ditch  have  been dealt  with it will be
necessary to select and  proceed  with  a   solution  to  the  problems  caused by the
presence of the large volumes of PCB-contaminated  sediments  whose  uncontrolled
migrations through the  environment are  more subtle,  yet,  in  the  long  term,
equally threatening to human health.  While the  ongoing studies can be expected
to further clarify the issues,  investigations to date  indicate that  only the
excavation of the contaminated  soils and  sediments  in the  North Ditch and
parking lot area  will allow the following  objectives  to be accomplished  on  a
permanent basis:

        - Virtual  elimination  of the  spread  of  PCBs through soils,  sediments
          and groundwater

        - Virtual  elimination  of  PCB discharges  to  the lake from  the  ground-
          water system.

        - Removal  of the  potential  of  PCB movement through the  underlying silty
          clay layer.

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                                      -46-


    Although the slurry wall confinement approach could offer short-term secur-
ity, only  the  excavation  option eliminates the  risk  of PCB releases  to the
environment posed by  slurry wall containment, and  the  possible  penetration of
the silty clay layer.

    While bypass construction  progresses,  the  precise delineation of the  areas
and volumes to be excavated can be accomplished.   U.S.  EPA already has a  rela-
tively good  picture of the distribution of PCBs  in the  soil  and groundwater
and has made estimates  of  the  amounts  of material   needed  for removal.    Their
consulting engineer  and  hydrogeological  contractor  are  completing  reports
based on the data which should  allow more precise estimates to be made.  Public
release would be subject to the  protective order.

The Plan for Cleanup

U.S. EPA,  with  the  assistance  of its engineering  contractor, Mason  & Hanger,
has prepared a  proposed  program  for dealing  with PCB  contamination  in the
North Ditch and the OMC parking  lot  area  based on the  immediate construction
of a  North Ditch bypass  and  subsequent excavation  of the most  contaminated
materials from the  bypassed portion  of the ditch,  nearby soil   areas  and the
parking lot area.

    Bypass Construction.  The bypass  work  is similar to  that  proposed  by U.S.
EPA in 1979  except  that the new  storm  sewer system will  run  in the east-west
portion of  the  Ditch  instead  of through the  contaminated parking  lot.   The
approach, which will  include  some excavation,  is  to direct the flow now enter-
ing the  ditch  around its  most  contaminated portions  (the Crescent  Ditch and
Oval Lagoon) and to tie it into  a  new  storm  sewer system which  will  replace
the east-west portion of the ditch  (Figure V-5).

    The first  step  will  be to  intercept  surface   water  now directed  to the
North Ditch from areas  west of OMC's property,  and from  OMC  property itself,
with a new  storm  sewer collection  system.   The new sewer will  be constructed
to a  point  just west  of  the east-west  part  of the  contaminated  North  Ditch.
During construction, it will be necessary  to block  this  new storm sewer and to
temporarily bypass any water that it collects until  construction in the section
is completed.

    An estimated 6000  cubic yards  of contaminated  sediments  in the east-west
ditch will  then  be  cleaned  out, dewatered and either  disposed  of  off site  or
stored temporarily  in  the  lagoons on  OMC property.   A  wastewater  treatment
system will also  be available  if  it  should be discovered  that  the dewatering
of the storm sewer installation yields contaminated groundwater.

    As the new storm  sewer  is   installed in the east-west portion  of the North
Ditch, it will  be   necessary to install a  second  storm  sewer to pick  up any
flows from the  existing parking  lot and the remainder of  OMC's buildings.   The
two storm sewers will be built simultaneously along the centerline of the east-
west section of the  North  Ditch until  the entire bypass is completed.

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                                      -47-
    By the time the bypass is completed, the area surrounding the two new storm
sewers located  in  the  east-west  portion  of  the North  Ditch will  be "clean"
and can be  paved  over as an extension  of  the existing parking lot.  This work
should provide  removal  of the  contamination in this portion of the North Ditch
and divert  all  flows  proceeding to  Lake Michigan from passing through contami-
nated portions of the ditch.

    Excavation of Contaminated Sediments and Soils.  When  the bypass  is  com-
pleted, the spread of PCB contamination from surface water runoff will virtual-
ly be eliminated.   Because of the  characteristics  of the  soil,  any migration
of PCBs laterally  from  the  ditch will  be limited, provided the  migration  is
not allowed  to  continue  over  many  years.   Elimination  of the   surface  water
entering the ditch  will allow a  complete  cleanup program to  proceed  with re-
duced risks, as follows:

        a.  The Crescent  Ditch  and  Oval Lagoon  will  be  excavated using slurry
            wall and/or coffer dam techniques to reach the deepest contaminated
            material.

        b.  The parking lot and any other contaminated soil areas will be exca-
            vated, using well point techniques (and also slurry wall techniques
            if needed) for deep excavation.

        c.  Waters encountered  in  excavation will be treated prior to discharge.

        d.  The  excavated material  will  be  removed  to a  permanent  disposal
            facility.

    Excavation of the deeper areas  of  contamination will  require special  mea-
sures to protect buildings on the  OMC sites.  U.S. EPA's contractor has perform-
ed a  feasibility  study  for  the  practical  limits  of  excavation  on  the  south
side of the Crescent Ditch which  has  resulted in the  formulation  of two alter-
native plans.  The first plan is  to  build  a cellular  coffer dam type structure
completely encircling the Crescent Ditch.  The second plan is to  build a slurry
wall that can be  braced from side  to   side for  lateral  stability.   Either the
coffer dam or the slurry  wall  would be as  close to the  existing  structures  as
is practical, on  the south  side  of the  ditch,  to prevent disturbance  of the
OMC buildings.

    Either a coffer  dam or a slurry wall enclosure is necessary to  allow excava-
tion under dewatered  conditions,  so that  the levels  of contamination can  be
measured during excavation and so  that the nearby structures will not be damaged.
In order to accomplish  this the  coffer dam or slurry wall  must be deep  enough
into the clay layer to prevent any  significant leakage under its  lower  edge.

    A similar plan could be used  for the Oval  Lagoon.   There  are  no structures
close enough to  the sides of  the lagoon,  however, to  limit  the  width  of the
area to be  excavated.   Therefore, a non-structural  slurry  wall  method may  be

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                                      -48-
more economical, especially if there are not high concentrations of contami-
nation in deep soils outside the confines of the lagoon itself.

    Finally, it is proposed to remove a substantial amount of material * from
the northeast part of OMC's parking lot.  A well point system will be install-
ed around individual zones to draw the water level down below the level of
contamination so that conventional earthmoving equipment can be used.  Each
zone will be kept small enough so that nearby structures are unaffected.   The
project will benefit from the presence of the bypass, which removes one major
source of recharge water.  Waters will be treated before being returned to the
bypass system.  A slurry wall system may be necessary for the deepest contamina-
tion thus far encountered.

     Excavated materials from the several  areas of excavation will be taken
directly to the final disposal facility.  The excavated areas will be backfilled
with clean material.
* It is not possible to further describe the extent of cleanup, the number of
cubic yards proposed to be remopved or the number of pounds of PCBs present,
given the restrictions of the protective order.

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                                      -49-


                                   CHAPTER VI


                  FINAL DISPOSAL OF PCB-CONTAMIMATED MATERIALS
    Previous sections of this report have discussed the extent of contamination
and the specific plans proposed by the U.S. EPA to remove the most contaminated
materials from Waukegan Harbor, the  North  Ditch  and the OMC parking lot areas.
The preferred  alternatives  proposed—dredging  of the  harbor  and construction
of a  bypass followed  by excavation  of the  North Ditch  and  OMC  parking lot
areas—require that  final  disposal  arrangements  be  made for  a  large quantity
of contaminated  material.   The  plan  for  harbor  cleanup  involves  a  two-step
operation.  In the  first  step,  the sediments would  be dredged  and placed in a
lagoon, where they are held in temporary storage.  In the second step, they are
removed from the  site to a  final  disposal  area.  Excavation of the sediments
and soils in the North Ditch  and  parking lot  area,  however,  would require only
a single  step, since the materials  would be moved directly to  a  final disposal
area as they were evacuated.

    The harbor plan  calls  for  dredging approximately  168,000   cubic  yards  of
sediment  in  which  contamination  exceeds  10  ppm PCBs.   (Approximately  47,000
yards of this contamination exceeds 50 ppm PCBs.)  When this material is remov-
ed from the dewatering basins  for disposal,  approximately 30,000  additional
cubic yards of  clay used  for the liner,  and sand  from  the OMC  site  that  is
being proposed for  use in  construction,  will  also require a permanent disposal
facility.  Therefore, in  round  numbers, we  will  have  some  60,000  cubic yards
exceeding 50 ppm and  some  140,000 cubic yards between  10  and  50 ppm.   A small
amount of  additional  yardage  could be  included  from the  excavation  of the
east-west portion of  the North Ditch  during bypass  construction.   Equivalent
amounts may  well  be  excavated  during  the  final North Ditch  and  parking lot
area cleanup, which will  require final  disposal  as well.

    The yardage in the harbor above the 50 ppm level  has  been  calculated sepa-
rately because TSCA  regulations  (See  Chapter II) require  a  specially-approved
disposal facility for materials contaminated at or above that level.

THE DISPOSAL OPTIONS

    Some final  disposal  alternatives  have  already been discussed.   Biological
destruction methods  are  unproven.  Chemical  destruction  methods appear  to  be
unsuitable for sediments and  soils containing water.   Slurry  wall  confinement
in-place of  contamination   in  the  Crescent  Ditch  and  Oval Lagoon  parts  of
the North Ditch (after bypass), and  of  the  OMC  parking lot  area  contamination,
have been described  as effective in the  short-term  and less  expensive  than
excavation approaches, but  as not providing  the permanent protection  given  by
excavation.

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                                      -50-


    Two broad final disposal options  remain:  incineration and secure landfills
(which include existing licensed PCB landfills, nearby landfills which could be
adapted for this  use, and  parts  of the  CMC  site which  could be  adapted  for
secure disposal).

Incineration

    No PCB incinerator has  yet  been licensed for commercial  use,  although  one
in Arkansas (ENSCO) and  one in  Texas (Rollins) are nearing  U.S.  EPA approval.

    Costs for incineration would be most  favorable  if the incinerator could be
brought to the  OMC site  and the  residues after  incineration could  be  judged
clean and disposed of on the site.  U.S. EPA's consulting engineer has investi-
gated several  incineration  technologies and  reports  that  costs could be  well
in excess of $100  per cubic yard.  Further, it does  not  appear that available
technology would  meet U.S.  EPA  requirements  without  extensive testing  and
development.  Although incineration  could destroy PCBs,  it  appears  to involve
much more delay  and  considerably  more  cost than  does the use  of  secure land-
fills.  Removal  to a  secure landfill  appears to  be the  only  reasonable final
disposal method presently available.

Secure Landfills

    The closest commercial landfill  now licensed by the U.S. EPA for the dispo-
sal of  PCB  contaminated  materials  is  the  Clermont  Environmental  Reclamation
Site (CECOS) at  Williamsburg,   Ohio  near  Cincinnati.  U.S.  EPA's  engineering
contractor has advised that the landfill's user charge would  be  $90 per cubic
yard and that transport  costs  would  be approximately $1300 per 20  cubic  yard
truckload.  Disposal   of  200,000 cubic  yards  of contaminated  harbor sediments
above 10 ppm would thus  cost approximately  $33 million.  If  one  assumes  that
only the 60,000  cubic yards above 50 ppm  need  be taken to  CECOS,  costs would
be approximately 10 million dollars.   If a cost of $50 to  $100 per  cubic  yard
for local disposal  of the remaining 140,000  cubic yards  which are in the 10 to
50 ppm  contamination  range  is  added, total harbor  disposal  costs would be in
the $17 to $24 million range.

    Given the high cost of disposal  at the Ohio facility, U.S. EPA's contractor
has recommended that  closer landfills  and  the OMC  site itself be  considered
for final disposal.   Preliminary  investigation  has  indicated that one or  more
nearby sites can be found which, with appropriate preparation, can be made suit-
able for secure  disposal  of this  material and thus  could  be  licensed.   Cost
estimates for nearby  landfill  disposal   (including  transportation)   are  in  the
range of $50 to  $100  per cubic yard  or $10 to $20 million for 200,000  cubic
yards.

    U.S. EPA's contractor has also examined  several  approaches to  on-site dis-
posal of materials dredged from  the  harbor and materials  present in OMC's North

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                                      -51-


Ditch and parking lot  area.   These approaches are, in  general,  less  expensive
than off-site  landfill   disposal   and  require  little trucking  of  materials.
They are, however, subject to concerns regarding the proximity of Lake Michigan,
the high  water table, possible  future  use  of  the site,  erosion  of the  Lake
Michigan shoreline, potential flooding,  etc.  They also  commit  portions  of the
OMC site to permanent use for a PCB waste disposal  facility.  For these  reasons
the site  is  more risky  than the  type  of site the  regulatory  agencies  would
normally consider approving.

On-Site Secure Storage.  Ultimate  disposal  on the  OMC  site itself would  cost
on the  order  of $30 per  cubic  yard.   This would be  a  substantial  improvement
over the  existing  situation.  It  replaces  the uncontrolled PCB landfill  that
the OMC  site  has become  with a  controlled  PCB landfill  site  that  uses  good
protective practices and  can be  expected  to be secure  in  the  short term.   The
Lake Michigan shoreline  is  not,  however,  a very good long-term  location for  a
PCB disposal   facility.   The  two major  OMC   site   options  are  as  follows:

        1.  On-site secure storage facility under QMC's  parking  lot.  The
    facility would  extend approximately  30  feetbelow  ground  elevation  and
    would be lined with 5 to 10 feet of reconnected clay imported to  the  site.
    A leachate  collection system  embedded  in  gravel would  be sandwiched  in
    the clay  liner.   The leachate system would lead to manholes  for  pumpout
    and treatment.  The disposal  facility would be capped  with  at least  3  feet
    of clay and surfaced  with bituminous  pavement   or  concrete so  that  its
    present use  as  a parking lot  could  be  continued.   The facility would  be
    surrounded by a 2  1/2-foot  slurry  wall  (that  would be needed  in any  case
    for excavation  of  the area)  tied  to the natural  silty  clay  layer.   The
    cost of implementing  this  concept for the harbor materials  alone would  be
    in the neighborhood  of $6 million.   A  larger  facility would be  needed  if
    excavation of North  Ditch and  parking  lot area  materials   were  included.

    The use of  an underlying clay liner  leachate  system  promises  more  secure
    disposal  than use  of the in-place  slurry wall  confinement  system, as  has
    been previously discussed.   In particular, less  reliance  would  be  placed
    on the integrity  of  the  underlying  natural silty  clay layer,  because  of
    the construction of  a  5-to-10 foot  clay liner, and less reliance would  be
    placed on the slurry cut-off walls,  since  sidewalls  of compacted clay  at
    a 3-to-l  grade would  be constructed.

    A number  of drawbacks remain.  The  approach demands much on-site handling
    of materials, requires  extensive  dewatering during  construction, and  in-
    volves disruption of  OMC's parking  lot for a long  period.

        2.  On-site secure storage facility on OMC  vacant land.   In  this  varia-
    tion of the above  on-site  option,   the  two  lagoons   for  dewatering  and
    temporary disposal  of harbor  materials would be constructed  to the standards
    normally suitable for long-term disposal.  The  lagoons would be built  with
    a ten-foot  clay  liner,  a  leachate  system sandwiched  in the liner,  and  a

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                                      -52-
    cap of  clay  and topsoil.   The lagoons  would  be constructed  above ground
    and to  a  height  of about 35 feet.  The  cost  for harbor materials disposal
    alone would be approximately $6 million.

    Advantages of  this  approach over  the other on-site  option are  that  only
    one disposal   facility  would be  constructed for the  entire project; there
    would be  less  leaching,  over time, than  in the below-ground alternatives;
    little material handling and site disruption would be required, and no slur-
    ry walls would need to be constructed.
    Disadvantages of  this  approach  compared  to  the
    unsightliness; the  need  for permanent  dedication
    use; and the long-term maintenance requirement.
                 other  are  its  relative
                 of the  property  to this
           SUMMARY OF COSTS OF FINAL DISPOSAL OPTIONS (HARBOR ONLY*)

                            (PRELIMINARY ESTIMATES)
Disposal Option
Disposal at CECOS (Williamsburg)
Ohio

Disposal of 60,000 cubic yards
at CECOS and 140,000 cubic yards
at a local landfill

Disposal of all material at a
local landfill

Disposal at a disposal facility
under the OMC Parking Lot

Disposal on OMC vacant land in
lagoons
 Dredged material over 10 ppm
 plus liner, cap, & dike material
 (200.000 cubic yards)

$33 million
$17 to 24 million




$10 to $20 million

$6 million


$6 million
* The  addition  of  disposal  costs  for  materials   excavated  from  the  North
Ditch parking  lot  area  would  increase  these  costs  significantly.    Those
costs and  yardage  estimates  are  now   being   refined,  the  refinement  being
based on new sampling data.  Preliminary estimates are subject  to the
protective order.

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                                      -53-
THE RECOMMENDED APPROACH

    The conclusion  reached  by the U.S.  EPA  is  that both  short-term and long-
term interests would  be best served by  removal  of these materials  to  a well-
designed PCB  disposal  facility in  a  better  location  than the OMC  site.   The
CECOS facility is certainly  suitable  in this regard.  The  high  cost of trans-
porting the materials to  CECOS  for final disposal, however,  has  prompted  U.S.
EPA to  look   for  a  more  cost-effective use of  the public funds  involved.

    Closer potential sites have been investigated, and the agency believes  that
one or more suitable sites are available for the purpose.  The use of OMC sites
for disposal, as  has been discussed, is less expensive than any off-site disposal
and this can  be  an effective containment strategy  in the short  run.   During
the time provided by the bypass, all such options  will be given more intensive
examination.

    Finally,  proper incineration technology is not now easily available, and is
expected to continue to  be costly even when available.   It is intended, however,
that those materials  with  the highest concentration  of  PCBs be  segregated  so
that they can be readily  retrieved from the disposal  facility for later incin-
eration, if this  becomes desirable.

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                                      -54-


                                  CHAPTER VII

                                FUNDING SOURCES
                                I WIILS-tllWI WWI\WL.W

    Proceeding chapters have assessed the Waukegan area PCB contamination prob-
lem and the  options for  cleanup.   The next  step  is to  analyze  the potential
sources of funds  available  to  undertake the cleanup  effort.   The U.S.  EPA,
through the U.S.  Department  of Justice,  has  filed suit  against  OMC and  Mon-
santo, asserting  their  liability  for  the PCB contamination  in  Waukegan,  and
has asked  the  court  to  hold  them  responsible  for  the  necessary  cleanup.

    There are several funding mechanisms, i.e.,  special  appropriation,  Section
311 of the Clean Water Act, and Superfund, which  will  allow the commencement of
various aspects of cleanup before liability is determined in the pending  litiga-
tion.  Any money  expended  under  these  laws  would  be ultimately  recoverable
from the  responsible  parties,  after responsibility has been determined  by the
court.  This chapter discusses the scope and limitations of the various  funding
mechanisms potentially available for cleanup of the Waukegan area PCB contamina-
tion.

THE LITIGATION

    Following the breakdown  of  negotiations  between the  State  of Illinois and
OMC late  in  1977,  the  United  States  Attorney  for the  Northern District  of
Illinois filed  suit on behalf  of  U.S.  EPA  against  OMC in  Federal  court  on
March 17, 1978.  The complaint alleges that OMC  used hydraulic  fluids composed
of PCBs  in  its  Waukegan  diecasting  facility of  Johnson  Outboards for  many
years, and that the leaks  and spills of the fluid, discharged without treatment
into Lake Michigan  and  Waukegan Harbor,  were a  violation  of the Refuse  Act,
the Clean Water Act, and the common law of nuisance.  The United States  further
alleges that, as  a  result  of this  contamination  , Lake Michigan  waters  and
aquatic life have been  harmed  and  pose a threat to health  and  to the environ-
ment.  The complaint asks that OMC  dredge and dispose  of  North  Ditch sediments
in a safe manner, similarly  clean  up contaminated  harbor sediments,  and pay a
money penalty for violation of the Clean Water Act.

    OMC subsequently filed a third-party  complaint  against  its  supplier  of the
PCB-bearing hydraulic  fluid, alleging  negligence  and  a  breach  of  products
liability law by  the  Monsanto Company  as the manufacturer  and  supplier  of the
PCBs.  In  addition, after  a review  of  documents  produced in discovery,  the
United States  also  sued  Monsanto   in  July 1980,  alleging  violations  of  the
Refuse Act and  products liability  standards and negligence  in  Monsanto's  con-
duct as supplier of the PCBs.

    In answer to  OMC's  claim, Monsanto  recently filed a crossclaim for reim-
bursement against OMC.  Finally,  pursuant to a  ruling by the  Seventh  Circuit
Court of Appeals, the State  of  Illinois  has  been allowed to file  its own  suit
in Federal court  against  OMC.  While  the State  is currently  participating in
discovery, OMC  has  filed  a  petition  for certiorari  with  the Supreme  Court
asking for review  of the Circuit  decision.   The  Supreme  Court  has  not  yet

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                                      -55-
ruled whether it will consider the case.  A settlement of this case against OMC
and Monsanto, or a judicial decision, will determine responsibility for cleanup
of the Waukegan area.

The Special Congressional Appropriation

Since the  PCS  contamination  in  the  Waukegan  area  was  first  identified  in
1976, members  of  Illinois'  congressional delegation  have  had  great  interest
in its cleanup.  As  a result of their  continuing  concern  about the contamina-
tion problem, the  Illinois delegation were  instrumental  in obtaining,  in the
fall of  1980,  a  congressional  appropriation  of  $1.5 million  to enable  the
U.S. EPA  "to begin  the cleanup  of  Waukegan  Harbor".  This  appropriation  is
currently available for the stipulated purpose.

SECTION 311 OF THE CLEAN WATER ACT

    In the event of an oil or hazardous waste spill, or an actual or threatened
discharge of  oil or  hazardous substances  into  or upon the  waters of the United
States, Section 311  of the Clean  Water Act  sets up  a mechanism through which
the Federal  government is authorized to respond  to the pollution emergency.
Section 311  and the  implementing  regulations  establish  a  "contingency plan"
including a  "National  Response  Team" (NRT),  a  "Regional Response Team"  (RRT),
and an "On-Scene Coordinator" (OSC)  as  the parties  authorized  to ensure proper
cleanup in an emergency.  While  U.S. EPA and  the  U.S.  Coast Guard  have  the
main responsibility for implementing the regulations, other agencies (including
state and local representatives) can, in their areas of expertise, offer advice
to the RRT.

Once a hazardous waste site  is  identified as threatening, or  an oil  spill  has
entered the waters of the  United  States,  it  can be  classified as "311 action-
able".  Usually an OSC is  assigned to a large  spill  or  cleanup activity.  The
discharger is then given an opportunity to clean  up  the area  on its own, while
the OSC  monitors  the  activities.    If  the  responsible party  refuses to  take
action or is  not performing effectively for other reasons,  the OSC can  initiate
Federal activity to  ensure public  safety and the  protection  of the waters  of
the U.S.   The OSC directs Federal  efforts at  the scene of a  discharge or poten-
tial discharge  and  also  consults  regularly  with the  RRT in  carrying  out  a
cleanup activity.   The RRT serves  as an advisory team to  the OSC.

    If a  discharger  refuses  to clean up the  spill   himself,  the OSC and  the
RRT, with the approval of the Coast  Guard, can  initiate  containment and clean-
up activities  using   funds for  that  purpose   authorized  under  Section  311.
Actions under  Section   311  focus  on  containment  and  prevention of  further
degradation of  the  waterways.  At least part  of the proposed  Waukegan  area
cleanup efforts would be eligible  for funding under Section  311.

Superfund

In December 1980, after months  of debate and  discussion,  Congress  passed  the
Comprehensive Environmental Response,  Compensation and Liability Act  of 1980,
popularly known as "Superfund".  This act establishes a  $1.6  billion  fund  for
five years that will  enable the  Federal  government  to pay  for  cleanup  costs
resulting from releases of hazardous substances  into the  environment.

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                                      -56-
    Th e fund will pay for cleanup of sites or spills and will compensate Feder-
al and State  governments for damage  to  natural  resources.  The fund  will  not
pay for medical  expenses or loss  of property or  income.   This new  Act esta-
blishes strict  liability for those who  release  hazardous substances  into  the
environment, but deletes  reference  to joint and  several  liability,  relying on
common law  principles  to determine  when parties  should be  severally liable.
The government  can  sue  the  liable parties  to recover  the  costs  incurred in
remedying releases  of  hazardous  materials   into  the  government,  but the  Act
places limits on the amounts of liability and  does  not provide for third-party
compensation.

    U.S. EPA is preparing a  "National Hazardous Substance  Response Plan" which
will establish response  procedures,  including  methods to discover, investigate
and remedy releases from facilities which pose substantial dangers.  Each year
a priority list  of  sites will  be  published.  According to  the Act,  the first
100 listed sites requiring remedial  action will include, to the extent practic-
able, at least  one site from  each  state.   The  entire Waukegan  area cleanup
effort would  appear eligible   for  funding  under  the  Superfund  legislation.

U.S. EPA's Budget Appropriation

    The operating funds  allocated to  U.S. EPA's midwestern  regional  office  and
research laboratories  out  of congressional  appropriations each year  provide a
limited source  of funding for   scientific and  engineering  investigations,  such
as those required to deal with  the  Waukegan  problem.   Without special  legisla-
tion, however,  (see  above) the agency is  not authorized to expend  funds to
initiate cleanup.

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                                      -57-


                                  CHAPTER VIII

                           THE STATUS OF THE CLEANUP
    To solve the PCB  contamination  problem in the Waukegan area,  it  is  neces-
sary to take the following steps:

    1.  Conduct the  scientific  investigations necessary to determine  both  the
extent and effects of the contamination.

    2.  Identify and  evaluate the engineering  options  available to  clean  up  or
mitigate the contamination.

    3.  Develop  the  detailed  engineering  designs  for the  selected  cleanup
option.

    4.  Secure funding authorization for the project.

    5.  Implement the cleanup project.

    Scientific investigations to determine the extent  of the  PCB  contamination
problem in Waukegan began  shortly after the  contamination  was first discovered
in 1975.  These efforts  were escalated  in 1978  when several  new  studies were
undertaken.  In 1980, USEPA's consultant,  Mason  & Hanger,  began  to examine  the
engineering options for  solution to  the PCB contamination problems  using  the
results of previous investigations  and  conducting additional  ones  as  the need
arose.  These scientific  and engineering studies were funded out of the U.S.  EPA
annual operating budget.

    This report has described, within the limits of the court's protective order,
the extent of  our current  knowledge  of PCB  contamination  in the  sites  under
investigation.  It  also  discusses  the  various  engineering options which have
been examined  for  cleaning up  or mitigating  the contamination.   Finally,  it
identifies a  set  of  "preferred" options  which   clearly provide the  greatest
environmental protection to Waukegan  and the Lake Michigan Basin.  For two  of
these, the dredging  of  harbor  sediments and  the  construction  of  a  bypass
around the North  Ditch,  the extent  of  contamination and  the costs and  bene-
fits of the  cleanup  are  well  understood.   For  the third, excavation of  the
sediments and  soils  of  the  North  Ditch and  Parking Lot Area, further  inves-
tigations are necessary.   These investigations are underway.

    This report provides  the public  with the results of the scientific investi-
gations, and presents them  with  the opportunity  to  review and comment on  the
analysis of engineering  options  that has  been conducted.   These comments,  as
well as those  received from Federal,  State and local agencies, will  be  incor-
porated into the on-going decision  making process.

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                                     -58-
    At this  stage the  availability  of  a  funding mechanism  becomes critical,
and its own purviews  and  requirements  will  determine the actual implementation
of and timetable  for the  cleanup.   The status  of the project  in  relation to
each of the   existing  funding  mechanisms   (See  Chapter  VII)  is  as  follows:

Section 311 of the Clean Water Act

    Some action has already been taken to apply Section 311 to appropriate por-
tions of the  Waukegan contamination problem.  U.S.  EPA's  On-Scene Coordinator
(OSC) proposed, and  the Regional Response  Team  (RRT)  endorsed, the  plan  for
dredging slip  #3  of  the  harbor when  it was determined that it posed  a  sub-
stantial  threat  of discharge  of PCB.   The OSC  has  authorized  and the  U.S.
Coast Guard has approved the development of plans and specifications for dredg-
ing the harbor as  well as  constructing the  North  Ditch  bypass.   Additional
funding for at least part  of  the project   may  be made  available  through  this
mechanism, upon the  recommendation   of the   OSC  and the approval  of  the  RRT.
These designs should be ready beginning in  the Spring of 1981, making it possi-
ble to proceed immediately with implementation.

The Congressional  Appropriation

    This $1.5  million is  available  to  fund  immediately  implementation  of  por-
tions of the project, as the designs are completed.

Superfund

    The Waukegan  PCB  contamination  problem has been  selected as  one  of  the
earliest sites eligible to  receive  Superfund money.   Those funds  are expected
to become available within the next six to  eight months.

The Litigation

    The exchange  of  documents  is substantially complete,  and depositions  have
begun.  Although  the  trial  was  scheduled  by the former  presiding judge  to
begin on April  6, 1981,  that  date  is  subject to change  by  a  judge  recently
assigned to the case.  Whether the case is  resolved through settlement negotia-
tions, the judge's decision, or  a jury's verdict,  it will  assign the responsi-
bility for payment for the clean up  and disposal  of the contaminated materials.

Summary

    The litigation which is underway will determine who is  ultimately responsi-
ble for paying the costs of  cleanup. .Execution  of cleanup need not wait until
that determination has been made, however,  but can proceed  with the understand-
ing that  reimbursement  by the party  found responsible  will ultimately be made.

    The timetable for the  cleanup depends upon the understanding of the problem,
the selection   of  cleanup options,  the execution  of engineering designs  and,
above all,  the availability of funding mechanisms.   It will be the  constraints
of these  funding  mechanisms, ultimately, that  shape  the  final  execution of the
project.

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