United States Region V
QH545 Environmental Protection 230 South Dearborn Street
P6U37 Agency Chicago, Illinois 60604
The PCB Contamination
Problem in
Waukegan, Illinois
-------
THE PCS CONTAMINATION PROBLEM IN HAUKEGAN. ILLINOIS
January 21, 1981
Prepared By
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
U.S. Environmental Protection Agency
Region V, Library
230 South Dearborn Street
Chicago, Illinois 60604
-------
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
HI STORY 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-CQNTAMINATED MATERIALS 49
THE DISPOSAL OPTIONS 49
Incineration 50
Secure Landfills 50
THE RECOMMENDED APPROACH 53
-------
TABLE OF CONTENTS (CONT.)
PAGE I
CHAPTER VII FUNDING SOURCES 54
THE LITIGATION 54
The Special Congressional Appropriation 55
SECTION 311 OF THE CLEAN WATER ACT 55
Super-fund 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
-------
LIST OF FIGURES
FIGURE t 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
-------
-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.
-------
-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 nail beds,
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.
-------
-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
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.
-------
-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
-------
-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.
-------
-6-
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
-------
-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 Monsanto's 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-
-------
-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 RGBs 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.
CMC'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
-------
-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.
-------
-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
-------
-11-
MILWAUKEE
WISCONSIN
ILLINOIS
^CHICAGO
FIGURE IV-1: LOCATION OF WAUKE6AN HARBOR. ILLINOIS
-------
FIGURE IV-2: AFRIAL PHOTO OF WAUKFGAN HARBOR. ILLINOIS
-------
-13-
^ 6- W PORTION OF NORTH DITCH
NORTH DITCH
-OVAL LAGOON PORTION OP NORTH DITCH
:RESCENT DITCH PORTION OF NORTH DITCH
TWO OUTFALLS.
TO DITCH
OUTBOARD MARINE
CORPORATION
PLANT 2
'FORMER^**
OUTFALL
»_sJ LARSEN
'/'V MARINE a
4o
VACANT
OUTBOARD MARINE
[CORPOR/TOH PROPERTY
(FORMER SITE OF
GENERAL MOTORS
FOUNDRY)
D
PHU
TON
ntAND
IIEjNT
.
MARQl
CEME!
'MFG.
7_
^1
e1
1*1
ETTE ae
T 3
BX ^
^
OUTBOARD MARINE
CORPORATION
PLANT I
FALCON
MARINE
WATER
PLANT
PdRT
DISTRICT
FIGURE IV-3: LOCATION OF OUTBOARD MARINE CORPORATION PLANT
AND PCS OUTFALLS IN RELATION TO SLIP #3 AND
THE NORTH DITCH
-------
-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.
-------
-15-
1
BULKHEAD
^
1
/
WATER
SURFACE
EXISTING GROUND
SURFACE
/
WATER
6' to 17'
2'\o 6' SAND
HARDPAN CLAY
FIGURE IV-4; CROSS SECTION QF SLIP #3
-------
-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
WAUKEGAN
PORF
DISTRICT
LARSEN
MARINE
JOHNSON
OUTBOARDS
CITY
FILTRATION PLANT
LAKE MICHIGAN
FIGURE IV-5-. EXTENT OF PCB CONTAMINATION
-------
-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, OMC 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).
-------
-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-
lation 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.
-------
-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-
ct:
3
I
o
X
cc
o
-------
-22-
oo
CD
-------
-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 CMC'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.
-------
-------
CO
*3-
O CM
CD i-i
ne
-25-
VO
O
vol
LO
VO
r
OO
OO
CO
CM
in
*
CM
1
o o
O CM
r-l VO
De
o
0
VO
CM
,1
in co
in
o
V
O
in
CM
*
CM
O
O
co
\
i r-.
o
co r»»
co CM
\
1—I
en
?
vo
in
vo
4
CM
CM
o
o
en
•a-
co
CM
vo
co o
i •
co in
i—i
eu i—i
"olo
Eo
as t»-
co oo
O
o
o
o
o o
o o
o
A CO
in r-»
i-H O
I O CM
in !••* t^»
vo
oo vo
* *
•-( CM
§
co
i
O
o
I—I
in
10
co
co
o
i
o
00
i-H I t^t CO
CO
*
o
I
CM
Q_
C3
O O
O O
o o
col
CM
co
D
CM
vo r*»
co oo
D®
O.
I
en
-P -
en
OO
er>
i 10
CM
CM r** i^H
i CO
OO CO
O
CM
CM
r
i r
W V A ^ T^__
CT>
co
r-~
oo
.—i i r-
i
vo
en
rs CM
O)
c -=c
3 D-
00
co
CO
1—t
•
o
CO
CM
s-
Q.
OQ
t_)
Q_
CD
>
UJ
ce:
•a: wi
Q. ••-
LU O
c
•i- O
O LU
CO i— i—
o
o
-u
«
£
o
o
CM
vo
o
CO
o
o
co
en
o
o
o
CM
10
oi
5-
O
O
4-
ir>
in
•
i—i
-------
-26-
co
to
<
a.
>
QQ
<
<
Q
l^s.
r«^
en
PQ
o
Q_
a.
a.
LO
en
LU
>
O
II
O
LU
05
CD
OC
=>
Q
a
o
UJ
o
u
<
<
CQ
O
QL
Q.
Q.
CD
LO
> -^
O O
oo
co en
h- en
< r^.
o CD
o I-H
LU CO
_l Z
Q- O
O
CO
8-
Q_
Q_
a.
O
LO
co
\-
<
CD
X H-
O CO
Q; LU
Q- >
Q- -Z.
oc
o
-------
-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 OMC'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.
-------
-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.
-------
-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.
-------
-30-
Closlng 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
-------
-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-place 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-place 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
-------
-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.
Rolling 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 contaminated sediments from the harbor is
clearly the only available option that will accomplish all the following objec-
tives:
-------
-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.
-------
-34-
The Plan for Cleanup
The U.S. EPA, with the assistance of its engineering contractor, Mason &
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
-------
-35-
OQ
cr:
-------
-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.
-------
-37-
SILT CURTAINS
PLAN OF SILT CURTAINS-SLIF 3- DREDGING
NO SCALE
FLOATS
J'±
CURTAIN
'WEIGHTS
BAND
///^///Z:///^///^ W^>/CtMT
SECTION A-A
ELEVATION OF DUAL CURTAIN
FIGURE V-2; SILT CURTAIN PLAN & ELEVATION
-------
-38-
-------
-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 intermittant 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 OMC's parking lot. A court order prohibits full public disclosure
of the data collected in this area, and the extent of parking lot contamination
-------
-40-
OO
OO
u_
ce;
o
u_
oo
>-
oo
oo
o
Q.
O
ce:
a.
CD
-------
-41-
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
-------
-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.
-------
-43-
In-place 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.
-------
-44-
.d
o
z
UJ
-Mi*
2 5 i
X UI l-
Ul (E V)
00
-------
-45-
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-contarninated 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.
-------
-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 offsite 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.
-------
-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
-------
-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.
-------
-49-
CHAPTER VI
FINAL DISPOSAL OF PCB-CONTAMINATED 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-pi ace 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.
-------
-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 OMC 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
-------
-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 OMC's parking lot. The
facility would extend approximately 30 feet below ground elevation and
would be lined with 5 to 10 feet of recompacted 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 theaboveon-site option,thetwolagoonsfor 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
-------
-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 other are its relative
unsightliness; the need for permanent dedication of the property to this
use; and the long-term maintenance requirement.
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.
-------
-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.
-------
-54-
CHAPTER VII
FUNDING SOURCES
Preceeding 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
-------
-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 PCB 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.
-------
-56-
The 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.
-------
-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.
-------
-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.
------- |