Honeywell is currently remediating Onondaga Lake under the federal Superfund program in accordance with a 2007 Consent Decree entered into with DEC. The remediation includes the offsite treatment and containment of highly contaminated lake bottom sediments at the Wastebed 13 Facility near the town of Camillus. Minnich and Scotto has been retained to evaluate residential exposure to air contaminants arising from Facility operations.
Principal findings and recommendations include:
• Employment of Flawed Methods in the Supplemental HHRA
EPA, in their June 2010 Supplemental Human Health Risk Assessment, concluded that risk to the Camillus residents from exposure to Facility air emissions would be well within acceptable levels. We have determined, however, that EPA employed flawed methods to assess this exposure, thus rendering invalid their conclusion of acceptable risk.
• Employment of an Inadequate Air Monitoring Program
We have determined that the air monitoring program currently in place at the Facility provides little value to the Camillus residents.
• Exceedance of Facility Major Source Threshold for HAP
Based on a compliance assessment for Hazardous Air Pollutants (HAP), the Facility exceeds the HAP “major source” threshold under Section 112 of the 1990 Amendments to the Clean Air Act.
• Unacceptable Safe Levels Throughout the Community
Based on air dispersion modeling results, exceedances of safe-level thresholds are predicted to occur across much of the Camillus community over the duration of the remediation for:
(a) naphthalene, for long-term (annual) exposure; and (b) naphthalene and benzene, for short- term (1-hour) exposure.
• Reduction of Facility Emissions
Results demonstrate an immediate need to reduce Facility emissions in order to comply with residential safe levels and to avoid a Title V designation for HAP.
• Replacement of the Existing Air Monitoring Program
Results demonstrate an immediate need to replace the existing air monitoring program with a state-of-the-art, real-time independent community air monitoring (ICAM) program, control of which should rest with the Camillus community. The ICAM program should be based on EPA Method TO-16 – the only practical way to demonstrate, in real time, the causative relationship between Facility emissions and residential exposure.
SECTION 1 - INTRODUCTION AND OBJECTIVES
The Onondaga Lake remediation commenced on July 30, 2012. From the start, there were numerous odor complaints and reports of adverse health effects from the community. Honeywell implemented several emission-reduction measures from August until mid-September, but DEC finally ordered the temporary shutdown of the operation on September 20 while Honeywell and DEC attempted to come up with a more effective remedy. Remediation operations resumed
3 weeks later (October 11) and continued until the (planned) winter shutdown on November 19. Remedial operations are scheduled to resume this month.
The remediation is expected to last three or four more years. The remedy involves the hydraulic dredging of approximately 2.7 million cubic yards of lake sediments, and the capping of about 400 acres of lake bottom. The dredged sediment slurry (i.e., the water/sediment mixture) is piped a distance of 3.9 miles to a secure facility in the town of Camillus, designed specifically for the treatment and long-term containment of the contaminated sediment. Essentially a hazardous waste Treatment, Storage and Disposal Facility (TSDF), the Facility is located primarily on a parcel of land designated as Honeywell’s Wastebed 13.
Section 2.1 presents a description of the Facility process. Section 2.2 discusses the current situation. Section 2.3 identifies the principal community concerns.
Section 2.1 Facility Process Description
The treatment and containment of the sediment slurry involves a two-step process:
Step 1 - The slurry enters one of three enclosed screening buildings where oversized materials (large rocks and pieces of debris) are removed and temporarily stockpiled for eventual placement within the SCA. The air inside each screening building is sent through a dedicated vapor-phase granular activated carbon (VGAC) adsorption system for removal of volatile organic compounds (VOCs) before being discharged to the atmosphere.
Step 2 - The screened slurry is pumped through a pair of pipes into high-strength containers (geotextile tubes) for treatment (dewatering) and long-term containment. A preconditioning polymer and a coagulant agent are injected into the pipes to optimize the quality of the sediment slurry before it enters the geotextile tubes.
The contaminated water (filtrate) drains from the geotextile tubes to an onsite liquid management system (a filtrate storage basin) where it is held and treated to applicable water quality standards. The filtrate is then pumped to an onsite wastewater treatment plant (WTP) for primary treatment, and finally to the Onondaga County Metropolitan Sewage Treatment Plant for secondary treatment and ammonia removal before discharge back to Onondaga Lake. We assume that the vented air from the onsite WTP is not being treated before being released to the atmosphere.
As each geotextile tube undergoes dewatering, additional slurry is added until it is filled with dewatered sediments. After a filled tube has dewatered for several weeks, it has sufficient integrity to support another tube placed on top of it. Up to five layers of tubes comprising an area of about 65 acres will be required in order to accommodate all of the dredged lake sediment.
Section 2.2 Current Situation
The U.S. Environmental Protection Agency (EPA), in their June 2010 Supplemental Human Health Risk Assessment (HHRA), concluded that there was no potential for adverse offsite exposure to airborne contaminants emitted from the treatment and containment facility. Nonetheless, following much public comment at that time, Honeywell agreed to install a water misting system around the geotextile tubes to reduce air emissions and to implement a community air monitoring program to assure the residents that there would, in fact, be no harmful offsite impacts.
However, upon startup of the remediation (July 30, 2012), numerous residents began experiencing severe odors and a host of deleterious effects; complaints were filed promptly via DEC’s project hotline. In at least one instance, the air quality was so bad that an individual was forced to seek emergency treatment at the local hospital. Other acute symptoms included the occurrence of repeated nosebleeds, severe asthma attacks, burning sinuses, nausea, and headaches lasting more than three days. The air monitoring system currently in place at the Facility confirmed the presence of elevated levels of numerous gaseous compounds, including benzene and naphthalene.
In August through mid-September (prior to the DEC-ordered temporary shutdown), Honeywell implemented various emission-reduction measures, including the installation of a floating cover atop the filtrate storage basin, and the covering, via large tarps, of those geotextile tubes which had finished dewatering. These mitigative measures also included the installation of VGAC adsorption systems in the screening buildings (which, according to planning documents, were supposed to have already been in place when the remediation began).
The remedy put in place during the 3-week shutdown involved the installation of a second tier of misters around the geotextile tubes, and the addition of a proprietary detergent to the water to cause a chemical interaction with the emitted gases, thus masking or neutralizing the odors.
From operation resumption (October 11) until shutdown for the winter (November 19), the residents reported that the misters had little or no beneficial effect, and instead felt they now had yet another airborne compound about which to be concerned.
We were unable to find information in the available project documents concerning the additive composition. We have since reviewed manufacturer literature which indicates the additive is not toxic, but suggests it can be an irritant when aerosolized. However, we have determined that the misters do not reduce contaminant emissions nor does the manufacturer make any claim that they do.
Project planning documents from Honeywell dated as recently as May 2012 (e.g., the Onondaga Lake Remediation Operations Community Health and Safety Plan) insisted that all sediment management processes would be performed in a closed system, and that the slurry would never be exposed to the open atmosphere. Attempts to reduce emissions to acceptable levels notwithstanding, the latest design drawings and the project history to date continue to show otherwise – namely that some processes are uncontrolled.
Community trust eroded further during a January 31, 2013 public meeting when DEC, in tacit acknowledgment that airborne exposure had indeed been occurring, identified a total of 22 potential emission-reduction measures Honeywell would be considering prior to the resumption of lake dredging later this month; these actions spanned all facets of the facility sludge handling and treatment activities. This acknowledgment contradicts existing project documents and the understanding given the community by DEC, in earlier public meetings held prior to the remediation start-up, that not only would there be no air emissions or odors during Facility operations, but they “would not even know that Honeywell was there.”
After review of all available information, we believe the geotextile tubes are the main source of emissions within the Facility. Two emission mechanisms from this source are: (a) volatilization of filtrate during tube draining (mostly lighter molecular weight VOCs, such as benzene); and (b) sediment off-gassing (mostly heavier VOCs, such as naphthalene) prior to final covering. Other VOC sources, believed to be less significant, are the filtrate storage basin, the screening building (should VGAC system breakthrough occur), and the onsite wastewater treatment plant.
Section 2.3 Principal Community Concerns
The affected community has two principal concerns: past and future adverse airborne exposure, and deficiencies in the air monitoring program currently in place.
Section 2.3.1 Adverse Airborne Exposure
As discussed earlier and evidenced by the reported acute effects, many residents contend they were exposed to high levels of toxic air contaminants during the first year of remediation.
Of particular concern are the laboratory analysis results from lake sediment samples collected in 1992 and 2000, which show very high concentrations of naphthalene. For example, the Record of Decision (ROD), which includes a summary of this data, showed a depth-weighted mean naphthalene concentration in the top 2 meters of the lake-bottom surface of 79.2 milli-grams per kilogram (mg/kg), or 0.0079 percent by mass; the greatest concentrations in each strata were typically above 500 mg/kg, or 0.05 percent by mass, with the greatest concentrations in the top layer of the lake-bottom surface (0-to-2-centimeter depth) as high as 26,000 mg/kg, or
2.6 percent by mass.
A volume of 236,000 cubic yards of contaminated sediment was dredged from the lake during Year 1. This represents about 8.9 percent of the 2.7 million cubic yards of contaminated sediment to be removed and treated during the 5-year dredging program.
Section 2.3.2 Air Monitoring Program Deficiencies
The existing air monitoring program relies on a network of eight fixed stations sparsely positioned along the Facility perimeter. Hourly total VOC (TVOC) concentrations are auto- matically monitored at each station, 24 hours per day, 7 days per week, using photoionization detector (PID) instruments.
Evacuated Summa canisters, equipped with 24-hour-averaged flow control devices, collect air samples at four of these stations, once every 6 days. Speciated VOCs are measured at an offsite laboratory using U.S. EPA Toxic Organic Compendium Method 15 (Method TO-15).
Community concerns include:...
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