A primary concern for all proposed remediation options is the arbitrary determination that > 50 PPM is a PCB waste and < 50 PPM is not a PCB waste. It is the total PCB not the average that is crucial in determining the impact on human health. For this reason all of the material must be considered PCB and a treatment option used that can safely and effectively deal with both. (Eco-Logic’s thermal reduction process does this.)

Failing to treat < 50 PPM waste as a PCB material poses many hazards to human health with the proposed treatment options. It also poses technical disposal and transportation problems.

All the incineration options do not consider the permitted up to 49 PPM, PCB waste as PCB’s in the PAH disposal options. This will generate dioxins and furans in large quantities and pose a threat to health wherever the incinerator is located.

Incineration is the only option proposed for the high level (>50 PPM) PCB. Incineration especially in an urban area poses profound risk to human health and the environment

The dredging will re-suspend the PCB and distribute it throughout the pond. CBCL consultant report on the treatment options admits (7.3.1.2) that careful dredging to separate the PCB from PAH will be difficult or impossible to do. The result of a clumsy attempt will be to dilute the concentration of PCB to below the 50-PPM regulatory threshold. In options 1,3,4,5 the 30,000 tonnes of high-level PCB areas are not delineated and it appears no attempt will be made to isolate the PCB’s. The plan appears to be to dredge without distinction, test for average concentration in 500 to 1000 tonne batches and only where high concentrations are suspected. This will dilute the average concentration of PCB and dramatically underestimate the high level PCB concentration.

Each and every proposed option would include some form of incineration. Regardless of the choices made by anyone who fills out a workbook the proponent will be able later to say that the community agreed with an incineration scheme.

All sediment extraction proposals will allow naphthalene, benzene, xylene and other volatile PAH compounds to migrate to residential area (CBCL(7.6.2.3)) where they will pose a risk to human health.

Option 1 Excavation of North Pond, Containment in South Pond.

All material must be tested for PCB content. Only testing for PCB where they are suspected will result in large quantities of PCB going undetected. Testing in suspect areas in 50- 100 tonne batches will underestimate the volume of high-level PCB.

Moving it from one side of the pond to another and making a mound will not be effective in removing the hazard to the marine or terrestrial environment. Solidification and Stabilization could be used to slow the leaching that will result from this plan.

This is a crude and wasteful proposal.

Option 2 Excavation of both ponds, Containment at Coke Ovens.

The promise of the JAG cleanup was to start cleaning at the top of the hill (the coke ovens) and work down to the bottom of the hill (the tar ponds). This proposal does the opposite. It takes material from the bottom of the hill and moves it to the top of the hill and dumps it there where it will slowly make its way to the bottom of the hill again.

This will mean the creation of a 20-acre (9 Hectare), 20 M high landfill at the coke ovens that will result in dust, odor and groundwater contamination in both Whitney Pier and Ashby. The suggestion that the resulting hill could be incorporated as a green space is offensive.

The > 50-PPM PCB will be incinerated offsite and generate dioxins and furans.

Option 3. Soil Washing, Bioremediation, Co-Burning, Containment.

Dredging and testing for PCB will be as in option 1. This will result in dilution of PCB below 50 PPM and will miss large hotspots where they are not suspected.

High level PCB would be thermally desorbed in a treatment facility to be constructed on the coke ovens site. The desorbed PCB’s will probably be incinerated (hydrogen reduction is mentioned as a possibility)

The Hydrogen Reduction (Eco-Logic) process that could safely and cost effectively do all of the material is not considered for the PAH (low level PCB) material. Instead Soil washing and slurry phase bioremediation that will require up to 8 Hectares of land at the coke ovens for storage and treatment cells will be used. The fugitive emissions from this plan will degrade the soil, air and water in the surrounding community. The soil washing fines will either be incinerated or landfilled at the coke ovens site. Residual material is toxic and will be landfilled at the coke ovens to a height of 20 Meters. The residual material from the Eco-Logic- Torbed process is much reduced in size and free of organic contaminants, but like other options listed would require assistive technology to stabilize and contain any metals encountered during processing.

Materials from both ponds would be excavated and sorted as above. The high level PCB material would be sent to an offsite incinerator. The low level PCB/PAH material would be used as fuel at a power plant or cement kiln offsite. The PCB in the sediment would generate dioxin and furan emissions. The residual ash is toxic and will have to be landfilled. The material deemed PAH < 50 PPM will not be accepted for co-burning in the US if the PCB content is above 2 PPM. This limits the possible co-burn options. It also shows the danger inherent in ignoring PCB content up to 50 PPM.

This is the most dangerous and unacceptable option. As well as all the problems identified in the previous options with disturbing, processing and treating the sediment the material would be burned and landfilled at the coke ovens site. The burning would generate dioxin and furans as products of incomplete combustion from both the high and low level PCB/PAH sediment. The toxic ash byproducts would be placed in a 4 hectare 15 meter high landfill at the coke ovens site to contaminate soil and water and begin to move slowly back down the hill to the harbour.

This plan is to leave the sediment where it is except for the high PCB area in the south pond cover it and leave it unchanged. None of the contaminants would be destroyed except for offsite PCB of the south pond high level PCB’s. This is unacceptable because the toxins will continue to leach into the harbour and community forever.

Ditching and sheetpiling will minimize groundwater movement on the site. This will be ineffective in stopping the groundwater migration. A pump and treat system to manage dissolved phase hydrocarbons will require many wells and interceptor ditches as well as a treatment facility in perpetuity to be effective.

A .5-meter bioremediation or landfarming of the soil will generate air emissions and odors across the whole site that will migrate into the surrounding community. The massive amounts of benzene and naphthalene will produce dangerous gases in the community despite unsubstantiated claims to the contrary.

The massive contamination down at least 10 meters and the entire buried infrastructure will remain untouched and be an ongoing source of contaminant migration.

The areas to be set aside for the stockpiling, processing and management (landfilling) of tar pond sediment will inundate the surrounding community with toxic air, soil, and water emissions.

Another mountain of untreated toxic soil would be created on the eastern end of the coke ovens to allow the untreated dumping of contaminated soil from the Coke Ovens and Tar Ponds sediment. The contaminants and infrastructure below 2 meters would be left untreated.

Separated contaminants would be incinerated offsite. This would generate Products of Incomplete Combustion (PIC’s) offsite.

This option would require setting aside a large area for soil washing, stockpiling and managing the waste. This would result in fugitive emissions of dangerous PAH inundating the surrounding communities. A four hectare landfill would be required that would further contaminate groundwater and cause migration of contaminants into residential neighborhoods.

Similar to option 3 but pyrolysis or desorption not soil washing would separate the contaminants. A landfill onsite, stockpiling and management/ landfill are still required on the coke ovens site. This would require long-term maintenance and monitoring to ensure no offsite contamination.

Offsite co-burning at a yet to be determined site would create emissions offsite. No co-burning facility has been willing to accept this waste so far. If no co-burning facility has been identified is it a viable option to be presented as a choice or is it smoke and mirrors to the onsite incineration schemes that are the predetermined choice?