state of south carolina ) county of pickens ) · state of south carolina ) county of pickens )...

State of South Carolina )

County of Pickens )

PICKENS COUNTY COUNCIL MEETING

MARCH 19, 2012

IN ATTENDANCE:

JENNIFER WILLIS, CHAIRPERSONNEIL SMITH, VICE CHAIRMANSAM WYCHETREY WHITEHURSTTOM PONDER

ALSO PRESENT:

WES HULSEYCRAIG ZELLERCHAPPELL HURSTCHRIS BRINKJIM WILKIE

2Pickens County Council Meeting - March 19, 2012

1 JENNIFER WILLIS: Good evening. Welcome to

2 the Pickens County Council meeting, Monday, March the

3 19th, 7:00 p.m. As is our custom, this evening we will

4 begin with the invocation and Pledge of Allegiance. If

5 you will, bow your heads.

6 (INVOCATION AND PLEDGE OF ALLEGIANCE BY

7 JENNIFER WILLIS)

8 JENNIFER WILLIS: You may be seated. I’d like

9 to thank everyone for being in attendance this evening.

10 We have some guests in the audience, as well as making

11 sure that everyone is familiar with who we have here

12 tonight. I would like to ask everyone to introduce

13 themselves. I’m going to begin with Councilman Tom

14 Ponder to my left. We’ll go across and then back

15 around.

16 TOM PONDER: Tom Ponder, Council District 6.

17 TREY WHITEHURST: Trey Whitehurst, County

18 Council District 2.

19 JENNIFER WILLIS: Jennifer Willis, Council

20 District 5, Chairman of the Council.

21 NEIL SMITH: Neil Smith, District 4.

22 SAM WYCHE: Sam Wyche, District 3.

23 JENNIFER WILLIS: Mr. Zeller, our guest.

24 CRAIG ZELLER: Craig Zeller, USEPA Region 4 in

25 Atlanta.


1 JENNIFER WILLIS: Okay. And you have with

2 you.

3 NESTOR YOUNG: I’m Nestor Young with the EPA,

4 Section Chief.

5 JENNIFER WILLIS: Great. I know I see Dr.

6 Dyck in the background. If you would, please, stand up

7 and tell us who you represent this evening.

8 LARRY DYCK: I’m Larry Dyck. I represent the

9 people who live on my road.

10 JENNIFER WILLIS: Is there anyone else who

11 would like to be identified this evening for the

12 record? Seeing none, Mr. Zeller, again, I’d like to

13 thank you for coming and being a willing participant in

14 our meeting tonight. We’re very grateful for your

15 dialogue.

16 We have several items that we would sort of like to

17 cover, and point, and we’re going to begin with Council

18 Chair -- Vice Chair Smith.

19 NEIL SMITH: Before you start us, are you

20 going to introduce Wes and ---

21 JENNIFER WILLIS: Oh, I’m sorry. I forgot the

22 people at the table. Mr. Hurst, if you’ll do your ---

23 CHAPPELL HURST: Chappell Hurst, County

24 Administrator.

25 WES HULSEY: Wes Hulsey, principal consulting


1 scientist with Hulsey, McCormick & Wallace, consultants

2 for the County.

3 JENNIFER WILLIS: And we also have Chris

4 Brink, the Planning Director, in the audience. And Jim

5 Wilkie, the Chair of the Planning Commission, who is

6 also helping us with some of the issues on the Twelve

7 Mile River.

8 Now have I got everybody in the audience? Thank

9 you. I’m sorry. I don’t usually follow a meeting

10 agenda quite this tightly, so I’m trying to stay on

11 track.

12 Mr. Smith, if you would talk a little bit about the

13 responsibilities of our government.

14 NEIL SMITH: Okay. Mr. Zeller, I guess being

15 the long-term councilman, I get the task of basically

16 stating that we kind of view that one of our

17 responsibility of County Council is to be concerned

18 about the health, safety and welfare of our citizens,

19 and we’re looking at this process as being one that we

20 can gather information and we can also clarify points

21 of -- clear up misconceptions, all the other issues.

22 I’ve been to some of the meetings. I’ve heard things

23 that corrected some of the things that had been told

24 previously. And that’s what we’re trying to do

25 tonight, is trying to figure out exactly where we are


1 and that will help us all. So I really appreciate you

2 spending the time.

3 When we look at the EPA, we’re under the assumption

4 that the EPA is to guard the whole remediation process

5 of the PCB contamination, and that’s how we’re viewing

6 EPA. So we do appreciate your time and effort here

7 this evening. Now, when we’re looking at this, we

8 feel that you’re the person who’s in charge of this

9 whole Superfund site; is that correct, that ---

10 CRAIG ZELLER: Yeah. I’m the EPA Project

11 Manager for the Sangamo Superfund Project. Yes, sir.

12 NEIL SMITH: Okay. And when you’re looking at

13 the site, what is the site? Kind of define it. We’re

14 trying to figure out, is that the river or is it -- I

15 mean, where does it start, where does it end?

16 CRAIG ZELLER: Okay. That’s a good question.

17 It’s a rather large Superfund site. And our strategy

18 for addressing it, first assessing the risk and then

19 actually going about clean-up of it. We actually split

20 it into to operable units. So you have the plant site,

21 it’s about a two hundred and twenty acre facility.

22 Good map there behind Wes. Then there was six

23 satellite disposal sites. They were named generally

24 after the people that owned the property that received

25 some Sangamo waste.


1 NEIL SMITH: Now, for us, those are the

2 landfills?

3 CRAIG ZELLER: Those are the little landfills

4 known as Breazeale, John Trotter, Nix, Crossroads,

5 Dodgens. I’m missing one. They’re all up there. So

6 those are the land based disposal sites that primarily

7 dealt with spent capacitors and debris that was hauled

8 there from the facility itself. Okay?

9 NEIL SMITH: Okay.

10 CRAIG ZELLER: Now, everything downstream of

11 there, the surface water pathways, the sediment impacts

12 and any potential impacts to, say, food web, the

13 biological side, were divided into operable unit two.

14 That essentially involves all of Twelve Mile River

15 downstream of the plant site, as well as the six

16 satellite dumps; and it’s about a one thousand acre

17 area of Lake Hartwell, what we call the Twelve Mile arm

18 of Lake Hartwell. Primarily from Clemson on above.

19 NEIL SMITH: If you were in the middle of the

20 river, how far from the middle of the river to the

21 side? Are you talking about a hundred feet or ---

22 CRAIG ZELLER: Shoreline. This would be the

23 Operable Unit Two stuff that would be from -- it’s the

24 river primarily.

25 NEIL SMITH: Okay.


1 CRAIG ZELLER: And then when you get into the

2 lake, it would be -- I’ve answered this question, but I

3 get a lot of questions by people that want to purchase

4 property. And when you see the way this property is

5 defined in a database that’s called Environmental Data

6 Resources, if you’re doing just a typical Phase I and

7 Phase II, if you look at the formal boundaries of this

8 thing, it’s rather large. But as far as our interests

9 are really the river and then what is the lake. All

10 right. Part of it is based on what we would know to be

11 the transport, you know, history, is that when Sangamo

12 was discharging, they were straight-piping material

13 from the upper unit to the site of the burial that

14 occurred from OU1 or at the land base stuff. After

15 that it was a pipe that had waste water affluent coming

16 out of their facility, discharged into Town Creek, Town

17 Creek goes to Twelve Mile Creek, the Twelve Mile River

18 as it’s known also, and then Twelve Mile River

19 eventually, once you get to about Maw Bridge, you

20 actually get into what is Lake Hartwell then. So we

21 were interested in the transport down that channel.

22 And that’s what we’ve been investigating.

23 NEIL SMITH: One of the things it’s created, a

24 lot of uncertainty and misinformation, has been the

25 civil lawsuit. Now, in that situation, we were told --


1 I think we were told by maybe you or somebody at EPA,

2 that EPA was not over that lawsuit, that was a separate

3 transaction. Is that correct?

4 CRAIG ZELLER: Are you talking about the dam

5 removal project?

6 NEIL SMITH: Dam removal project.

7 CRAIG ZELLER: Okay. That’s a great question.

8 And let me take a minute -- I’ll try to keep it brief.

9 All right. So, Superfund, the law that I primarily

10 work under, okay, has two main responsibilities, if you

11 want to just come down, you know, from the big

12 perspective, and then come down just to a slightly

13 lower level. All right. The first half of Superfund

14 is the investigation and clean-up of that hazardous

15 waste site. All right. That’s what I do. That’s the

16 whole -- the national priority, as well as the RI/FS,

17 the Record of Decision, all those things, okay, that

18 I’ve been doing here since 1990. Okay? Now, Superfund

19 also has another provision, which is kind of the other

20 side. If you flip the coin over, there’s a whole other

21 side. And that is the -- what’s called the National

22 Resource Damage Assessment.

23 NEIL SMITH: National Resource ...

24 CRAIG ZELLER: Resource Damage Assessment.

25 Superfund -- and I’m not a lawyer, so I don’t want to


1 screw up the citations, but I want to say it’s Surplus

2 Section 107 of the law, gives these other federal and

3 state agencies -- you’ve heard about them a lot in the

4 paper and here in this courtroom or -- the trustees.

5 It actually defines what a Natural Resource Trustee is.

6

7 Now, where the Superfund remedy or where the impact

8 of the Superfund site may have long-term injuries or

9 injuries to trust resources, like fish in this

10 instance, where the Superfund actual engineering remedy

11 may not be able to do much, there is an option in the

12 law that trustees, on behalf of the citizens, okay, may

13 pursue a settlement to compensate for that long-term

14 residual injury. So in this case, the other half of

15 this project did involve the project that you all are

16 very familiar with, the removal of Woodside I and

17 Woodside II, and then the disposal of about a half a

18 million cubic yards.

19 NEIL SMITH: Was EPA a trustee?

20 CRAIG ZELLER: No. EPA is not a trustee. Per

21 that section of the surplus statute, EPA is not a

22 trustee. And so, one of the reasons -- I think it’s a

23 good question, Neil, is that we got it a lot several

24 years ago, is why isn’t EPA up here? You know, why are

25 -- I understand this is an EPA Superfund site. It’s a


1 very valid question and a very valid concern. The

2 simple answer is, we had very limited, if any,

3 authority in that dam removal project. It was the

4 authority in that project was running out of the

5 Anderson County court, Judge ---

6 NEIL SMITH: Anderson.

7 CRAIG ZELLER: Judge Anderson was kind of the

8 overseeing official and appointed several receivers.

9 The one I’ve been in contact with the most is Leon

10 Harmon. And so he was in charge of making sure the

11 project met the intent or the requirements of the

12 court. Now, there were other people involved, of

13 course. But that’s one of the reasons, or probably the

14 reason, that I wasn’t here much during that time, is

15 because I was really instructed to kind of -- I had

16 limited authority as far as what I could ---

17 NEIL SMITH: So basically at that point the

18 legislation said you’re to deal with the PCBs and this

19 Natural Resource Damage Assessment is another process.

20 CRAIG ZELLER: It was part of Superfund.

21 NEIL SMITH: Superfund.

22 CRAIG ZELLER: It was part of -- yeah.

23 NEIL SMITH: So they can still claim the

24 Superfund umbrella?

25 CRAIG ZELLER: It was under Superfund,


1 correct. It was under that section of the law.

2 NEIL SMITH: The reason I’m asking that is

3 because when -- I think this is one of the areas that

4 generated a lot of the concern that we had, was where

5 we were being told by the trustees, and I think that’s

6 the correct group, that they didn’t have to get the

7 permits for landfills. They didn’t have to follow the

8 various procedures on the testing. They didn’t even

9 have to comply with our county ordinances that

10 pertained -- that we didn’t even allow a landfill,

11 because the Superfund legislation trumped local

12 ordinances. Is that a fair assessment to say?

13 CRAIG ZELLER: Okay. It’s not -- so let me

14 explain.

15 NEIL SMITH: Okay. That’s why we’re here.

16 CRAIG ZELLER: Right. So, yes, from the

17 umbrella standpoint, the project was under Superfund.

18 Okay. It was under the other half of Superfund that

19 I’m not necessarily in charge of or have no authority

20 over. Okay. So once you’re in Superfund and under

21 that umbrella, whether it be my side or this other side

22 that the trustee project was, there is a requirement, a

23 statutory requirement, that whatever action that is,

24 there’s two statutory fundamental requirements of work

25 conducted under surplus. That it must be overall


1 protective of human health and the environment. Okay?

2 That’s statutory requirement one. And the second

3 statutory requirement is called compliance with ARAR’s.

4 That’s A-R-A-R-’-s, and it’s applicable or relevant and

5 appropriate requirements. Okay?

6 Now, another government acronym, because we love

7 acronyms; right? But what it means in layman’s terms

8 is that if there are other state and -- other federal,

9 other state, other local laws or ordinance that are

10 applicable or relevant and appropriate, that the

11 Superfund action must meet what they call the

12 substantive requirements of that particular permit,

13 law, ordinance, whatever it may be. Okay?

14 When it was written and passed, you know, in

15 Washington, D.C., as a law, the intent was that

16 Superfund would be a one-stop-shop, that it would

17 address all the rules involved with this particular

18 whatever the decision was. But the “we don’t need a

19 permit” provision of CERCLA really was meant to

20 streamline the administrative process, meaning I don’t

21 need your piece of paper, kind sir, kind madam, but I

22 do need to meet your requirements. If you have -- for

23 instance, I’ll use the storm water example. If you

24 disturb a piece of property that’s, you know, generally

25 most counties, most states have it, if you disturb a


1 piece of property that’s one acre or more, you have to

2 go get your land stripper’s permit; right, and you have

3 to put up your silt fences and construct your storm

4 water ponds and all that stuff. So while -- if that

5 was an EPA action, while I may not need your permit, I

6 still have to meet your regs. So if it’s a ten year

7 twenty-four hour storm or if you say I have to put up

8 two rows of silt fence and I have to cover, you know,

9 with wheat straw fourteen days after the disturbance, I

10 must do those things.

11 NEIL SMITH: So who is responsible for making

12 sure that those requirements were met by the trustees?

13 CRAIG ZELLER: Well, it would have been ---

14 NEIL SMITH: What I’ve heard, that you

15 weren’t.

16 CRAIG ZELLER: That’s a good question. So it

17 would be the people overseeing the project. It would

18 be, in this case, I guess, ultimately the regulatory

19 officials on that project were trustee officials.

20 NEIL SMITH: The reason I’m pointing those

21 pieces out is that’s really where we get most of the

22 anxiety when we’re talking about this issue, was where

23 the local citizens were seeing things and you were --

24 in other words, you’ve got a reputation of being the

25 one that oversees this project.


1 CRAIG ZELLER: Correct.

2 NEIL SMITH: And then all of a sudden, here’s

3 a lawsuit, this is what we’re going to do, and it was

4 almost like, well, this is getting ram-rodded through.

5 And I’m just using that as a local term.

6 CRAIG ZELLER: Perception. I understand.

7 NEIL SMITH: Perception. So that’s part of

8 the whole process trying to -- for us to understand it,

9 as well as for us to be able to get that out of the

10 citizens, this is how it works. Now, part of this is

11 coming back to some of those other issues of, you know,

12 the roads being built and all those other things. And

13 I was at the meeting, and you know I made a statement,

14 like, yeah, guys, this got approved in six hours when

15 it would have taken us six years to get stuff approved.

16

17 So I understand the, you know, the concept of what

18 you’re trying to do to streamline it and everything

19 else.

20 CRAIG ZELLER: Sure.

21 NEIL SMITH: But the perception from the

22 citizens was that maybe their welfare was not being

23 properly represented, I guess, is the best way to

24 describe it.

25 But I mean, so far, you know, what we’re hearing is


1 pretty consistent with what we’ve learned since then

2 and trying to get everybody up to speed, so that kind

3 of sets us as far as what I was supposed to do.

4 JENNIFER WILLIS: I think that was a great

5 starting-out introduction. And then, as I said, we’ve

6 got several more points. And some of these, like the

7 first one, I’m going to defer to Mr. Hulsey because

8 this is his job all day every day, and this is not my

9 all day every day job. But I’m learning a lot about

10 it.

11 WES HULSEY: Mr. Zeller, I wanted to let you

12 know I’ve conducted a review of both the 1993 remedial

13 investigation and also the record of decision, as well

14 as the draft and supplemental remedial investigation

15 work planned. And I have a few comments that I’ll be

16 addressing regarding the actual technicalities, number

17 of samples and how the samples were collected. And I’m

18 going to start with kind of downstream and refer to the

19 map. Let me carry the microphone with me.

20 The sediment of the sampling that was conducted

21 during the 1993 remedial investigation is represented

22 by these dots within the Twelve Mile Creek arm of Lake

23 Hartwell. And one of the concerns that the county has

24 is it appears that most of these sampling points were

25 collected in the open water portion of the Twelve Mile


1 Creek arm, and that the shorelines were -- may not have

2 been adequately addressed with discrete sampling or

3 grab samples to assess what the PCB levels that may

4 exist along the portion of the lake most likely to be

5 utilized by recreational users or terrestrial wildlife

6 may come in contact with, particularly when you

7 consider that lake levels fluctuate. Today the lake is

8 down approximately five feet below full pool. During

9 the 2007 drought, the lake level was approximately

10 twenty-three feet below full pool. So there’s always

11 the potential for users of the lake to, you know,

12 travel those shorelines. Children can play along the

13 shorelines.

14 Could you just comment on what the potential levels

15 are along the shorelines and why, apparently, it was

16 not sampled during the 1993 RI?

17 CRAIG ZELLER: Well, that was done in a phase,

18 phase approach. The first phase was we -- the first

19 thing we did, like anything we do on these projects, is

20 we usually go to local academic institutions and the

21 first thesis papers we pulled were from Clemson masters

22 students in the mid eighties. Mid eighties to late

23 eighties. The conceptual site model at that point in

24 time, based on that data, in talking with the Clemson

25 University professor at the time, Alzerman, Dr. Alan


1 Alzerman, was that the majority of this sediment

2 appeared the hot spots, which is what we’re very

3 interested in finding, because we want to conduct our

4 risk assessment on the hottest material, or what called

5 to be the reasonable maximum exposure. At that point

6 in time that information was suggesting that the most

7 impacted material was deep. It was being covered up

8 with relatively cleaner material.

9 So that was kind of like our conceptual site model

10 going forward. And the sampling strategy was based a

11 lot off of that. Once we did a bunch of surface grabs,

12 which are zero to six inches. Just so people will

13 know, when you take a surface grab, it looks like a

14 small little clam shell. It’s called a Ponar grab

15 sampler, and it’s about that big. You drop it from the

16 boat and once it hits the substrate, you pull a little

17 cable and it releases the jaws and you pull that thing

18 up and it’s about -- it gives you about a sediment

19 sample about that much. We think that’s about -- we

20 generally estimate that’s about zero to six inches, all

21 right, in the surface. On top of the Ponar grab

22 samples, we also then submitted our advanced vertical

23 cores, two inches in diameter, think of straws that you

24 would, you know, vibrate or push down into the

25 subsurface, and you pull that straw out and then you


1 look at the different layers. The idea being you want

2 to collect stuff that’s down deep and not collect

3 intervals that up on the surface and see how that trend

4 -- you know, how does it look vertically.

5 Now, we’ve done a little bit of both. We’ve done

6 coring samples that show the majority of the stuff is

7 down deep and we’ve done a bunch of these Ponar grabs,

8 not just in the channel but also those -- a dot on that

9 map represents a lot of variability. Okay? There was

10 a lot of transect work that was done early on that had

11 -- we would draw basically an imaginary line every five

12 hundred feet and then we would take a left descending

13 bank, one in the center of the channel and then a right

14 descending bank. So you know, we were getting stuff

15 in the channel as well as on the, say, shoulders, if

16 you will.

17 Now, the risk assessment that was done to support

18 the ‘93 and ‘94 data, it was done with data, of course,

19 that we collected in that time frame. Sediment

20 concentrations in the surface, in these shallow areas

21 that may be prone to wading, at the time were on the

22 order of one to ten parts per million. Okay? Our

23 clean-up goal in the lake is one ppm. And that was how

24 we would -- if I could sum it up in one sentence, I

25 would say by and large the concentrations in the


1 surface sediment, in that one thousand acre study area,

2 was about one to ten.

3 Now, twenty years later, monitoring-wise, the same

4 sediment in that area is about one. Last year’s data,

5 2011, all the data in the Twelve Mile River on, again

6 it’s a transect approach, it’s left descending bank,

7 center, right descending bank. So it’s not just the

8 center of the channel. The concentrations for the last

9 round of data were all less than a part per million.

10 Now, let me back up. When we did the risk

11 assessment on the one to ten ppm data, we assumed

12 numerous risk assessment or, say, exposure scenarios.

13 One scenario that we evaluated was the consumption of

14 fish collected from a variety of places in Lake

15 Hartwell. Some other things that people were extremely

16 interested in, folks just like yourselves, folks that

17 recreate on the lake, folks that live on the lake,

18 would say, EPA, can I water ski on the lake? And EPA,

19 can my grandkids jump off the dock and wade around in

20 sediment and incidentally maybe stick their hands in

21 their mouth and maybe incidentally ingest some

22 contaminated sediment?

23 So we ran all those scenarios. And the scenario

24 for incidental ingestion of sediment or drinking and

25 swallowing some water as you might fall off your inner


1 tube, all those recreational scenarios fell within the

2 acceptable risk range. Okay? Meaning it was okay to

3 recreate. It was okay to kayak. It’s okay to wade.

4 It’s okay to swim. Now, that was based on data with

5 PCB concentration of sediment based on one to ten ppm.

6 Now, with sediment at less than one, I would

7 interpolate and stretch that reasoning out to say it’s

8 certainly okay now. If it was one to ten and now it’s

9 less than one, if it was okay at one to ten, it’s okay

10 now. And there’s no need to rerun that risk

11 assessment. I know the answer to that equation.

12 WES HULSEY: I believe some of the graduate

13 students that conducted sampling as part of the

14 university’s studies had PCB results in general in

15 order of magnitude higher than that detected in the

16 1993 investigation.

17 CRAIG ZELLER: Yeah. The highest we were able

18 to see ---

19 WES HULSEY: Would you ---

20 CRAIG ZELLER: Yeah. The highest

21 concentration, from memory, and believe me, there were

22 thousands of data points out there, but I believe our

23 highest concentration was about sixty to seventy ppm in

24 sediment in the Twelve Mile arm, kind of near the

25 Madden Bridge area, Maw Bridge area. But yeah, there


1 was -- I do recall some sediment samples -- Hulsey &

2 Associates collected one fifty-four this past June, one

3 fifty-seven. There were some Clemson students, I

4 believe, Jeff Germann and Donavant, and I forget all

5 the students’ names, but there were probably on the

6 order of a hundred to two hundred ppm. But again,

7 mostly deep up around the Woodside I and Woodside II

8 impoundments at the time. That was back, again, in the

9 mid eighties.

10 WES HULSEY: Would you attribute the

11 difference in sampling techniques like we use Ponar

12 dredge, the fine grain have a tendency to wash out as

13 you pull the -- retrieve the sampler, and considering

14 the PCBs tend to have enough affinity for the fine

15 grain sediments, do you think that that could have

16 artificially, I guess, skewed the population in -- or

17 lowered the overall PCB levels?

18 CRAIG ZELLER: There’s a lot of that. There’s

19 many factors that could contribute to that. Sampling

20 strategy, sampling methodology, what you actually get

21 in the sample jar. You know, we’ve all learned enough

22 now that, particularly here and other PCB jobs, that if

23 you sample sand, if you scoop up a bunch of sand and

24 run it in an eight ounce jar and send it to the

25 laboratory for analysis, I would be willing to bet you


1 dinner tonight that you’re not going to find PCBs in

2 it.

3 But if you sample a, you know, risk layer of dark

4 organic layer that’s high in organic carbon and you

5 submit it to the same laboratory, yes, you will

6 probably -- you know, much greater change that you’re

7 going to detect PCBs at an elevated level in that

8 sample.

9 WES HULSEY: In all the investigation during

10 the RI, where there were discrete samples, grab

11 samples, collected along the dry shorelines, I know

12 that the transects that are currently being sampled on

13 a routine basis are composite samples. And you can

14 correct me if ---

15 CRAIG ZELLER: There’s been virtually a little

16 bit of everything collected out there. There’s been

17 grab samples. There’s been discrete samples. There’s

18 been composite samples. And there has been a fair

19 amount of data collected. Not from the dry. I mean, I

20 didn’t walk -- I participated in most of that sampling

21 work. I was on the boat for most of that. And while

22 we did not walk shoreline at low water collecting stuff

23 that is what we call seasonally exposed sediments,

24 there was sediment that was collected out of that mud

25 flat area. It would probably have been -- it was stuff


1 that was primarily underwater most of the time.

2 WES HULSEY: One other thing that I noted in

3 the RI. It was frequently referred to as not defining

4 vertical extent of contamination was language that I

5 found in the report. My experience with the Superfund,

6 that it’s the responsibility of the responsible party

7 to determine the horizontal and vertical extent of

8 contamination. Is there a reason why the vertical

9 extent was not determined with depth, and what

10 implications does that have on the selected

11 alternative?

12 CRAIG ZELLER: Well, during the RI -- well, I

13 think, you know, the data, the 2011 and the data that’s

14 been collected annually, for that matter, is probably

15 the best data-set in the country.

16 Now, as far as -- I forgot the question.

17 WES HULSEY: I guess, what’s the vertical

18 extent of ---

19 CRAIG ZELLER: Oh, the vertical extent. So

20 the gravity -- thank you. So the equipment that we

21 used for the -- this was, just so you all know, this

22 investigation was an EPA lead investigation. All

23 right. We did this work. It cost about two million

24 dollars. It was the very first job that was given to

25 me out of college. And we hired our own contractors.


1 I hired a contractor to do the sediment work and I

2 hired the Corp of Engineers to do the fish work. When

3 the record of decision was all done, we did recover

4 that money back from Schlumberger. So industry did not

5 perform this investigation, we did.

6 Now, the equipment they were using for the core

7 sampling, which gets down to your vertical extent

8 question. Was it gravity corer. Okay. It had about a

9 three foot tube on it. The very top of it had a baffle

10 system like a fin, so if anybody plays darts here, it

11 would be the back part of a dart. Okay? And so we

12 dropped that thing with gravity. It had the little

13 electric wench and we hit the button and this tube,

14 think of a dart, went plunging down through the water

15 surface and had this baffle or the back part of the

16 dart to keep it straight. So it hit the bull’s eye;

17 right? So when it hit, it hit straight up and down.

18 So when you talk about vertical extent, that was the

19 best we could do with the gravity corer. We were given

20 whatever 32.2 feet per second would give us, okay,

21 through the friction of water.

22 Now, subsequent to that, and so in those cases

23 where you had, say, refusal or no vertical extent -- in

24 other words what you’d like to do in a perfect world is

25 if you see -- you know, the conceptual model we’re


1 working with here is on the surface, it’s, say, one

2 part per billion or part per million, and then as you

3 get deeper, say a foot down, you get five parts per

4 billion or million, and when you get maybe three foot

5 down, it’s fifty. There’s your peak; right? Sometime

6 after that you should start to get back when you get

7 down to, say, the sediment that was laid there pre

8 Sangamo, it should go back to non-detect; right? Our

9 gravity coring system sometimes got there, depending,

10 so our gravity coring system sometimes didn’t get

11 there, depending, again, on how much penetration we

12 had.

13 Now, we have gotten back since then, in the mid

14 2000s, we brought out vibracoring devices, all right,

15 that are mounted on thirty foot house boats that have a

16 hole in the middle and then now we can drive a ten foot

17 tube all the way into the subsurface. Not by gravity

18 but by a -- when you see pylons being driven in a

19 construction site and you can either hammer them down,

20 ping, ping, ping. In this case we had a vibrahammer,

21 like a concrete vibrator that if you turn it on and it

22 goes zzzzzzzzzzz. And it’s the actual mechanism, the

23 force, that inserts it into the substrate.

24 In the case of the mid 2000 data, we have defined

25 vertical extent. So, yes, the goal is horizontal and


1 vertical extent of contamination. Now, in this case,

2 you know, all the action in all these sediment sites,

3 all the action is in the zero to six and zero to twelve

4 inch layer, okay, because that’s the material that’s

5 going to be potentially bioavailable. That’s the

6 material that may be potentially, you know, diffused

7 out of that sediment layer into the water column.

8 So the zero to six, zero to twelve inches is

9 usually, from a trend monitoring, is what we’re most

10 interested in. That’s why our future monitoring

11 program every year focuses on the quality of sediment

12 at the zero to six inch layer. So I’m not so much

13 interested in deeper sediment. I have, I think, pretty

14 much established the fact that the bulk of the PCB mass

15 in Lake Hartwell is under about three foot of sand.

16 WES HULSEY: The reason I asked that question

17 is in 2007, the area between Maw Bridge Road and Madden

18 Bridge Road was essentially exposed, dry land. You

19 could walk across it. What occurred and you see

20 occurring every winter when the lake level is drawn

21 down is, you know, erosion of what was formerly the

22 lake bottom. And there’s always some potential for

23 erosion, resuspension of the sediment and transport

24 further downstream in the lake. And, you know, did EPA

25 consider that transport mechanism in the conceptual


1 site model at that time?

2 CRAIG ZELLER: Yeah, resuspension and bed load

3 transport. This system has been modeled on that stuff.

4 And as far as what’s happening with current transport,

5 you know, down either -- you talk about Twelve Mile

6 River flowing proper or what’s going on in the lake

7 itself would show up and will show up and should show

8 up in the monitoring program that we’ve been doing

9 annually now for twenty plus years, which is sediment

10 sampling in twenty-seven locations. It’s freshwater

11 clams at like fifteen stations. It’s small forage

12 fish, game fish, at -- game fish at six stations and

13 forage fish in three stations. It’s a pretty -- any

14 changes that would be going on, we should see spikes.

15 You know, we should see, you know, for instance

16 dredging that’s been done in the Hudson River.

17 Dredging that’s been done in the Fox River. They use

18 young of year, which means fish that are itty-bitty

19 fish. They use young of year fish that are less than a

20 year old to monitor resuspension of the water column.

21 It’s been well-established in the literature that if

22 you are going to -- if you’re dredging material,

23 potentially re-suspending material that those fish

24 tissue concentrations in those little itty-bitty

25 minnows are going to increase during that time frame.


1 As soon as you stop the dredging, guess what, the

2 concentrations in the fish respond accordingly and they

3 drop.

4 Now, we are doing forage fish sampling out there in

5 three locations. One of them is in the Twelve Mile

6 arm. So any resuspension that’s going on, we should

7 pick up in our monitoring system.

8 WES HULSEY: Would you not expect, rather than

9 burial, particularly when you consider fluctuating lake

10 levels that you’re actually disbursing the contaminants

11 even further throughout the lake rather than burial?

12 CRAIG ZELLER: There’s a lot of fancy terms.

13 There’s mixing. There’s advection. There’s diffusion.

14 There’s all kinds of real fancy words. But it’s burial

15 and it’s mixing and it’s dilution. Absolutely. If you

16 take ten ppm up at the plant and you transport it one

17 little particle of organic carbon and you transport it

18 down to Madden Bridge where it resides with ninety-five

19 other pounds of sand, what do you think the average

20 concentration is going to become? Much less than ten.

21 WES HULSEY: Do you think the PCB levels on

22 the lake bottom will go up after removal of the dams?

23 CRAIG ZELLER: No. You know, we haven’t seen

24 it yet. We, of course, -- what is it, March? We’re

25 going to be out there this spring. We always do our


1 work in the -- in April, usually, for all the sediment

2 work and corbicula work. We did not see, really, any

3 uptakes in the clams, which we were kind of looking

4 for. We didn’t see any PCB accumulations or uptakes in

5 the clams. During the last work, we did the last

6 sampling in April of 2011 when Woodside I was still in,

7 they were still working up in the reach. So we haven’t

8 seen the spikes.

9 And, of course, when that -- there was a bunch of

10 other monitoring that was done that was part of that

11 project that I really wasn’t an authority over those

12 water quality monitoring and a bunch of other stuff

13 that was done to support the dredging project.

14 WES HULSEY: It was conducted -- I believe the

15 last report I’ve seen is the 2010 -- or 2011 report

16 which showed the 2010 sampling, which predated removal

17 of Woodside I.

18 CRAIG ZELLER: Let’s see. We would have

19 sampled in April. There is one out there -- there

20 should be one that came out this fall. It would have

21 been April of 2011.

22 WES HULSEY: And that’s after Woodside I was

23 removed and Woodside II was still in place?

24 CRAIG ZELLER: Right. Yep.

25 JENNIFER WILLIS: Along that note, if there


1 was a report last fall, would it be possible for the

2 county to get a copy of that?

3 CRAIG ZELLER: You’re welcome to everything.

4 Yeah, absolutely. You know, we have administrative

5 records and repositories. And one of the things I

6 talked about back in December 1st, if this building is

7 interested in being an official, you know, repository,

8 if council wants to -- I mean, we usually put these

9 things in libraries because county administrators

10 usually don’t want to mess with the stuff.

11 JENNIFER WILLIS: Right.

12 CRAIG ZELLER: But we would be happy to

13 establish, you know, an independent or another

14 repository for information and ---

15 JENNIFER WILLIS: I am confident we just need

16 to determine the space you require and we will find the

17 place to accommodate that. I think that is very

18 important. And obviously you can tell, because we’re

19 all here, that we’re very interested in this. We want

20 to understand it. We want to have this conversation.

21 And I think having that here would certainly help.

22 CRAIG ZELLER: Yeah. I think that’s great.

23 It’s all publicly available information. That stuff is

24 submitted to me, but it’s, again, part of my

25 responsibility to make sure that people who want to see


1 it can see it.

2 JENNIFER WILLIS: Well, we’ll help you make it

3 available. That’ll be wonderful. And along that same

4 line, I know you have a site visit tomorrow. Wes was

5 invited.

6 CRAIG ZELLER: Yep.

7 JENNIFER WILLIS: But we would like to make

8 sure that council is included on those meetings going

9 forward and notified so that we can participate and

10 make sure -- again, I’ll be the conduit. If you get it

11 to me, I will get it to them. Or get it to me and Chap

12 and we will get it to everybody. But we really, you

13 know, want to stay apprised of this and make sure we

14 understand and are involved and you hear that.

15 CRAIG ZELLER: Very reasonable.

16 JENNIFER WILLIS: So I will be joining you

17 tomorrow.

18 CRAIG ZELLER: Oh, you’re going to come for a

19 river walk?

20 JENNIFER WILLIS: I’m ready for a river walk.

21 CRAIG ZELLER: That’s fine. That’s fine.

22 Part of the goal ---

23 JENNIFER WILLIS: Some day I want to be able

24 to tell my son why he can’t catch fish out of Hartwell

25 and eat them, which he wants to do.


1 CRAIG ZELLER: Well, you know, part of the

2 goal of tomorrow is -- Wes had made it clear to me

3 moving forward that that should be the case. That to

4 make sure I’m just not talking to Wes. I mean, I was

5 going with the assumption that Wes was representing

6 council and he ---

7 JENNIFER WILLIS: And he certainly is

8 providing technical advice. But council represents the

9 citizens.

10 CRAIG ZELLER: I understand. I understand.

11 And so Wes made it very clear that moving forward, you

12 know, you all should be included in that. That’s fine.

13 So part of the goal tomorrow, really, is to -- you

14 know, we had a draft sampling strategy before we -- you

15 know, right now they are just simple -- you know,

16 they’re dots on a map. And you know, all of these

17 sampling plans change and evolve from the time that you

18 write them up in the office to the time that you

19 actually, you know, physically collect the material.

20 So the objective of tomorrow is to get some input from

21 the community on this as far as, you know, here’s where

22 we’re planning to collect samples. Is there places you

23 think we should sample that we’re not.

24 JENNIFER WILLIS: Okay. Absolutely. We

25 certainly want to be a part of that.


1 CRAIG ZELLER: There are some limits, of

2 course. I’m not going to run all the way up to North

3 Carolina. We have limits in all this stuff. But, you

4 know, as long as we kind of stick within the reach that

5 we’re talking about. In other words, I’ll put it this

6 way, we have a sampling plan that’s under review.

7 We’re missing a few things that I’m trying to take care

8 of that are kind of part of my job. But we have about

9 a hundred to a hundred and fifty sampling points. All

10 right. Because of storms that have moved through, a

11 hundred to hundred and -- you know, all of those points

12 are no longer there. They’ve been washed away. So I

13 have a commitment from Schlumberger that, you know, if

14 we committed to doing X number of samples then we’ll

15 collect X number of samples. So to the extent that

16 those sample locations have been washed away, we will

17 make them up someplace else.

18 JENNIFER WILLIS: I think that sounds great.

19 Thank you.

20 Councilman Wyche.

21 SAM WYCHE: Can I follow up with that just ---

22 JENNIFER WILLIS: Sure.

23 SAM WYCHE: We’re all -- we’re missing one,

24 but normally there’s six of us and we’re responsible

25 for the health and safety and welfare of our citizens


1 and we’re also concerned about the health, safety and

2 welfare of those families and children that play and

3 enjoy the river and the lake in other counties,

4 adjoining counties. And we need to make sure that we

5 have regular updates from the EPA and we would like to

6 do that on a monthly basis the third Monday of each

7 month, the next one being the third Monday of April,

8 April 16th, would be the next one. But we need to be

9 updated monthly.

10 CRAIG ZELLER: Okay.

11 SAM WYCHE: And you had written us a letter

12 earlier ---


14 SAM WYCHE: -- and suggested that.

15 CRAIG ZELLER: Sure. Yeah. I mean, I -- this

16 is largely what we do. This is EPA’s mission. Fifty

17 percent of what we do is keeping communities, whether

18 they be people that just live next door or county

19 governments, mayors, council members, this is what we

20 do. So ...

21 SAM WYCHE: We do a committee of the whole

22 every third Monday. That is a convenient time. The

23 public is welcome and others could be there. And if

24 you could include the boundaries of the Superfund site

25 that you described earlier for Mr. Smith, that would be


1 the update that we would need for the full boundary of

2 that.

3 CRAIG ZELLER: So your regular, like, business

4 meeting is the first Monday?

5 JENNIFER WILLIS: Yes.

6 CRAIG ZELLER: And then you have a working

7 meeting the third?

8 JENNIFER WILLIS: We typically have a work

9 session the third. And that would be the best time for

10 you. And as we go forward on those, we will, you know,

11 coordinate with you specifically the items, because

12 we’re sort of getting a lot of information here tonight

13 and then we’ll specifically go into some of those

14 details.

15 CRAIG ZELLER: When we wrote back, when

16 Jennifer gave us a letter on December 1st, and we got

17 distracted by the holidays, I think we eventually got

18 back to you on the 23rd. I heard from you guys, I

19 guess, a week ago Friday inviting us to this meeting.

20 And we did commit. And I said, yeah, of course, we’ll

21 come to meetings as frequently or infrequently or

22 whatever you want. We’ve got to schedule them. I’ve

23 got other jobs, of course. But yeah, we have no

24 problem with this.

25 SAM WYCHE: We’ve got your email. You


1 graciously included that.


3 SAM WYCHE: And if we need to ---

4 CRAIG ZELLER: But, you know, like everything,

5 of course, community is the key. It goes both ways.

6 The earlier we know about these meetings and what your

7 expectations are like when I talked to you, I called

8 you, I think, on a Monday and said, sure, we’re in, you

9 know, what are your expectations? And I think you said

10 for this one we ---

11 JENNIFER WILLIS: Bring your rain gear.

12 CRAIG ZELLER: --- don’t need a slide show.

13 We just need you and whoever you’re bringing. But,

14 yeah, as we move forward if we want to go on a monthly

15 basis, I think that’s fine as long as ---

16 SAM WYCHE: That’s what we need to do. That’s

17 good, Jen.

18 JENNIFER WILLIS: Very good. All right. Wes

19 has a couple more technical points. I’ll let Craig

20 catch up with his pen first.

21 CRAIG ZELLER: That’s not possible. I’ve got

22 too much ... Go ahead, Wes.

23 WES HULSEY: Regarding ecological risks, I

24 know that there have been some ecological baseline risk

25 assessments done in the past, I believe, under those


1 supplemental activities that we plan on requiring

2 another baseline risk assessment based upon the new

3 sediment sample data that will be collected during the

4 supplemental -- or for human health.

5 CRAIG ZELLER: Correct.

6 WES HULSEY: Is there a reason why you’re not

7 requiring another ecological risk assessment and

8 considering, not just aquatic, but also terrestrial

9 wildlife?

10 CRAIG ZELLER: Good question. I’ve also heard

11 something similar from Dr. Larry Dyck who was out

12 there, all these comments to QAP, the Quality Assurance

13 Project behind the work plan for the supplemental

14 stuff. So there was an ecological risk assessment done

15 as part of the original record of decision that was

16 issued in ‘94. Okay. That ecorisk at that time was

17 still a little fuzzy. It was still a little, say, not

18 as well defined as it is today. The ecorisk procedures

19 that we now follow today were outlined in a guidance

20 document called Ecological Risk Assessment Guides for

21 Superfund. I think it was June of ‘97. Okay. And all

22 the other supplemental ecorisk assessments that

23 Superfund sites must follow that process.

24 Now, there was a bunch of other data that was

25 collected that year. When the Hudson River happened,


1 okay, there was a tremendous amount of politics

2 involved. And so Congress actually put a moratorium on

3 dredging projects in the United States while the

4 effective dredging and the EPA’s contaminated sediment

5 management program nationwide was studied. So there

6 was like a two year freeze on all dredging jobs

7 mandated by Congress. As a result of that, and usually

8 when Congress speaks there’s a reaction. Okay. There

9 was a bunch of money that was coming from D.C. Some of

10 it was funneled our way to our Office of Research and

11 Development out of Cincinnati. They came down here in

12 the mid 2000s and did a bunch of work to help us

13 understand sediment transport and PCB cycling.

14 This site has gotten a lot of attention from the

15 General Engineering -- or General Electric, excuse me,

16 and the other companies that are being made to spend

17 billions of dollars on dredging. They want to know how

18 did that PCB site -- how did they get by with

19 monitoring natural recovery down there? Okay. So

20 there’s been a lot of attention, I think it’s good, on

21 our project. So as a result there was a bunch of

22 really good science that was done in the mid 2000s by a

23 bunch of really smart government scientists that I work

24 with. We believe there’s some ecorisk assessment stuff

25 that we can get out of there with. I’ve talked with


1 them, I’ve been on the phone. I hope to have that by

2 the end of the month. They did a lot of that kind of

3 stuff that Larry’s been talking about, which was some

4 food chain modeling that looked at terrestrial

5 receptors, mainly a raccoon or a mink, and also fish-

6 eating birds, which would be like a Kingfisher. So

7 you’re worried about bioaccumulation up the human food

8 chain, you could be concerned about bioaccumulation up

9 the eco food chain, as well.

10 So I’m trying to tease that information out that

11 may already exist. I think it’s important at this

12 point to point out there’s really -- in this business

13 there’s ecorisks or there’s risk assessment. All

14 right. The actual -- you know, the quantification of

15 the degree of the risk posed to human health or the

16 environment.

17 Then there’s the risk management piece. Okay.

18 Once you think you have or you know you have a risk,

19 then you’ve got to manage it. How are you going to

20 manage it? You know, our management of contaminated

21 sediment sites really comes down to three choices.

22 There’s really not a lot of tools in the toolbox when

23 you get to these problems. You can let nature cap it

24 on its own. You can try and speed up the capping

25 processes by engineering means, by spreading sand, by


1 putting isolation barriers down. Or you can dredge.

2 That’s really it. Or you can do a combination of all

3 three. But in this case, you know, what are the

4 ecorisk, you might say there’s -- I can say an ecorisk

5 assessment right now done by today’s standards are

6 going to include one thing, PCBs do a real good job of

7 accumulating up through every level of the trophic food

8 chain. That’s what they do. They come out of the

9 sediments, they get into surface water, they get into

10 mayflies, things that eat mayflies, they get into that.

11 I mean, little fish eat fish food, big fish come eat

12 the little fish and the next thing you know that

13 largemouth bass has two ppm of PCBs in it. That’s what

14 it’s going to conclude, is that PCBs do a really good

15 job of biomagnifying in the future. It’s how you stop

16 that and how you manage that risk, is really, I think,

17 the question. And I don’t know of any other risk

18 management techniques that we can apply here that would

19 get us any further down the road.

20 If I could wave a magic wand and get that sediment

21 to non-detect, I would. But here’s the moral of the

22 story, this is kind of a PCB story, is that the Hudson

23 River -- everybody talks about the Hudson River because

24 it gets the front page news. The Hudson River remedy

25 is going to cost a half a billion dollars; five hundred


1 million dollars. And at the end of that expenditure,

2 the Hudson River will have a fish advisory forever.

3 Nothing you can do about it. I don’t like it. I’m not

4 saying it’s okay. I’m just saying that’s the facts.

5 That’s the reality. And so we are alike in one

6 instance, is that Lake Hartwell will probably have a

7 fish consumption advisory for PCBs for -- we’ve had one

8 since ‘76. We’re probably going to have one for

9 another thirty years. Maybe longer. And in the Hudson

10 River, we didn’t spend that much money. We have -- the

11 Hudson River is going to leave sediment more

12 contaminated than we have out there. I’ve talked to

13 the guys. They’re going to leave ten ppm. We’re down

14 to one. And they’re spending a half a billion dollars.

15 WES HULSEY: In table 8-1 from the ROD, it’s

16 estimated time to achieve protection ---

17 CRAIG ZELLER: I knew you were going to bring

18 that figure.

19 WES HULSEY: I presumed this was based on

20 modeling.

21 CRAIG ZELLER: That was. It was based on the

22 early food chain accumulation models known as FGETS.

23 It was the Food and Gill Exchange of Toxic Substances.

24 WES HULSEY: And the selected remedy, if I

25 remember correctly, is 2-A, which is basically


1 institutional ---


3 WES HULSEY: No action, with institutional

4 controls.

5 CRAIG ZELLER: That graph shows that we should

6 be less than two ppm by now; right? 2008?

7 WES HULSEY: Twelve Mile Creek, twelve years

8 to achieve the FDA tolerance limit.


10 WES HULSEY: I think at least the latest data

11 that I’ve seen, which is 12/10, I believe, indicated

12 that there were still fish exceeding two parts per

13 million.


15 WES HULSEY: I put the target date as 2006

16 from the time the ROD was drafted, and of course, it’s

17 six years later.

18 CRAIG ZELLER: Uh-huh (affirmative.)

19 WES HULSEY: If you look at it from a

20 performance monitoring standpoint, apparently the

21 remedy is not performing as anticipated or as modeled

22 in 1994. I think the county’s concerned with when will

23 the performance meet the objectives in 1994 and does

24 this question the effectiveness of this remedy, and you

25 go down the list of remedies, you mentioned dredging,


1 we really don’t have a measure compared to any other

2 performance standard. Clearly, the existing remedy is

3 not effective ---

4 CRAIG ZELLER: It’s ---

5 WES HULSEY: -- if you base it on that

6 standard. And too, I know you and I have had some

7 discussions in the past about water quality standards

8 not being violated. And of course, the water

9 classification standards which are the state water

10 quality standards that we have, regulations, which

11 mirror the federal water quality standards, I know that

12 many water samples were collected during the remedial

13 investigation, but the detection limits were half a

14 part per billion or somewhere in that range when the

15 water quality standards are .064 parts per trillion.

16 However, the fact that we have biological effects

17 within the aquatic life indicate that water quality

18 standards have been violated. If you take a look at R-

19 61-68, which are South Carolina’s Water Quality or

20 Water Classifications of Standards, if you have a

21 biological effect, even though the actual detection

22 limits cannot measure the numeric criteria and that’s

23 the consumption of water and water organism standards

24 in 61-68, that there is a water quality standard being

25 violated. So do the ARARs at that time that were


1 approved by EPA address those standards?

2 CRAIG ZELLER: Okay. Your question was rather

3 long and it consists of two parts. I’ll take question

4 part A ---

5 WES HULSEY: Okay. I apologize.

6 CRAIG ZELLER: Part A first. So the first

7 question has to do with reductions in fish tissue.

8 We’ve learned every other big PCB job, and I’m on a

9 national panel that goes around the country and looks

10 at other projects that have this type of problem, and

11 every project has that graph, and it’s based on a model

12 that says if I do something with the sediments that the

13 fish tissue concentrations are going to respond

14 accordingly. So as concentrations of sediment decline,

15 that fish tissue concentrations should also decline.

16 And you use these predictions and these models to then

17 help you weigh the various benefits of what you’re

18 buying, cost benefit analysis stuff.

19 What we have found that those fish tissue models

20 don’t work. They’re not very predictable. Okay?

21 We’ve -- it hasn’t come true here and it’s not showing

22 up anywhere else as far as these declined is that while

23 we see -- are able to measure statistically significant

24 declines with regard to sediment concentrations, for

25 reasons that are hard to explain in science that fish


1 tissue concentrations just don’t seem to keep pace. So

2 what we’ve learned and part of some new guidance that’s

3 coming out from over the last number of years is that

4 if you are using the reduction in fish tissue

5 concentrations as your sole metric to measure success

6 of your remedy, you are planning to fail. Okay?

7 Because we are not seeing decreased concentrations in

8 fish tissue in any of these projects overtime, not

9 much. There’s too much at stake. Fish have a large

10 feeding range. They’re -- you know, the fattier fish

11 have more propensity to accumulate PCBs than others.

12 There’s changes ---

13 NEIL SMITH: Are we still using those same

14 models?

15 CRAIG ZELLER: Excuse me?

16 NEIL SMITH: Are we still ---

17 CRAIG ZELLER: There are, say, successors to

18 FGETS, but they don’t predict much better. We have a

19 lot of heated dialogue across other parts of the

20 country over, you know, we’ve seen this stuff.

21 TREY WHITEHURST: As I recall, meaning we have

22 -- that you came and gave that presentation, one of the

23 things you stated was that we would see these levels of

24 PCB drop as the sediment covered.

25 CRAIG ZELLER: Now, in sediment -- see, in


1 sediment we have measured decreases ---

2 TREY WHITEHURST: No. I was referring to you

3 were doing the fish diagram that you were saying that

4 the ---

5 CRAIG ZELLER: They are -- they have decreased

6 substantially. The fish tissue has decreased since the

7 nineties. If it ever goes to zero, I don’t think we’ll

8 be around to see it.

9 TREY WHITEHURST: Here’s -- let me just kind

10 of interject here a little bit. This is my district

11 that this is in. I live right on that part of the

12 lake, and I’m getting lots of phone calls. People are

13 very concerned. You know, you’ve got the whole section

14 of lake, kids play on the river there. We’ve got a

15 high school down there. We’ve got a middle school.

16 We’ve got a couple thousand kids there. There is a ski

17 course back there. And I’m on that lake all the time.

18 So I’ve got a lot of concern from my constituents about

19 what’s going on here.


21 TREY WHITEHURST: And looking at this, you

22 know, record of decision in ‘94 where they’re saying

23 it’s going to be less and they’re finding out in 2010

24 that it’s not less, that we’re not seeing that

25 decrease, and I think what Mr. Hulsey was saying was


1 that the plan that you have to decrease this stuff is

2 not working. Do you have any other -- you said there’s

3 three options. Are y’all looking at another option or

4 is it pretty much, this is what you get, take it or

5 leave it?

6 CRAIG ZELLER: We don’t have a lot of other

7 technologies that once PCBs are introduced into aquatic

8 ecosystem, there are very few technology choices, if

9 any, that can then return PCBs in fish tissue to non-

10 detect. I haven’t seen it.

11 TREY WHITEHURST: You said there was three

12 choices of way to do it: dredging, ---

13 CRAIG ZELLER: Nature can cap it, you can

14 engineer a cap or we can dredge it. In the case of the

15 Hudson River, their clean-up goals are higher than what

16 we’ve already achieved. They are -- the project

17 managers that have some of the PCB sites around the

18 country would love to have less than ppm in sediment.

19 Because they’re spending a half a billion dollars and

20 they’re not going to get there.

21 TREY WHITEHURST: Well, I just know, you know,

22 from my concern with all this sediment that’s come down

23 and it’s all dumped right there at Madden Bridge.

24 CRAIG ZELLER: Right. And we are sampling the

25 stuff that is moving into the system on an annual


1 basis. We have continued to monitor it annually since

2 ‘94. And the concentrations of that surface sediment

3 in the Twelve Mile arm of Lake Hartwell are now all

4 less than a part per million, which was our clean-up

5 goal. When we issued that, our sediment concentrations

6 were above the clean-up goal. Now they’re below. So

7 it’s kind of, like life, there’s the good news and the

8 bad news. The good news is that sediment

9 concentrations have declined and we can show them

10 statistically.

11 TREY WHITEHURST: Is that using composite

12 sampling?

13 CRAIG ZELLER: It’s using a combination of --

14 yeah, we’ve been doing the same exact trend analysis

15 for sediment sampling for twenty plus years.

16 TREY WHITEHURST: And then you’re doing a

17 combination of things, but I ---

18 CRAIG ZELLER: A composite, because we are

19 interested in area-wide. Okay. I want to know from a

20 one thousand acre area out there how am I doing on the

21 -- you know, I want to look at the whole tabletop

22 instead of right here. That’s the only way you can do

23 it, because there is a lot of spacial variability in

24 sediments.

25 TREY WHITEHURST: And we appreciate what


1 you’re doing in your sampling. And one of the question

2 I’m getting from my constituents and a policy that

3 we’re adopting in the county is, you know, you’ve got a

4 -- how big is this site, a thousand acres or so?


6 TREY WHITEHURST: And there’s not been any

7 testing going up to where the original deposits were

8 put in. I’ve got people that live up along that river,

9 that play along there, that fish along there. And I

10 mean, that’s where they originally dumped in. It seems

11 like everything has taken place on the lower half. And

12 what we would like to see as a county is that you guys

13 test the entire area that you’re calling your Superfund

14 to see what the potential hazards are in other areas

15 that haven’t even been looked at yet. You know, we

16 have a -- further up there we have a jockey lot. We

17 call it a jockey lot. You know, a flea market. And

18 you know, it gets flooded.

19 CRAIG ZELLER: Right.

20 TREY WHITEHURST: And there are people all ---

21 CRAIG ZELLER: And we have sampled that. I’m

22 trying to find those results. We sampled that flea

23 market in the early to mid eighties.

24 TREY WHITEHURST: Okay.

25 CRAIG ZELLER: I haven’t been able to put my


1 fingers on the data, but there was a tremendous amount

2 of sampling. When we were involved in trying to get

3 this site on the national priorities list in the mid

4 eighties, I was still in high school, there was

5 sampling of the flea market done. Because we were, you

6 know, ---

7 TREY WHITEHURST: So you’re saying you sampled

8 all the way up to ---

9 CRAIG ZELLER: We haven’t sampled -- you know,

10 it’s impossible to sample -- you can’t sample all the

11 way up. You can’t sample everything.

12 TREY WHITEHURST: I don’t mean everywhere.

13 But I mean as far as, you know, you can do every -- I

14 don’t know how you would do it, five hundred foot or

15 whatever, but all the way up to the actual site of

16 dumping or how far up are you ---

17 CRAIG ZELLER: Let me take a step back. Okay?

18 I explained a little of this on December 1st about

19 where my authority comes. Okay? Now, we know enough

20 about PCBs, here and other places, is that the risk is

21 ingestion. Okay. It’s not really inhalation pathway,

22 it’s you’ve got to ingest it. Okay. So now we know

23 enough about PCBs and we’ve done the risk calculations

24 to know that wading and recreating, swimming and all

25 that type of stuff that we do when it’s hot is okay. I


1 have quantifiable numbers and my eco -- or my EPA risk

2 assessment that says that swimming, boating, wading,

3 recreating in Twelve Mile River waters is okay.

4 TREY WHITEHURST: Based on parts per million

5 that you’ve tested?

6 CRAIG ZELLER: Based on data, yes.

7 TREY WHITEHURST: Okay. But you haven’t

8 tested -- I’m asking if you’ve tested all the way up

9 the river?

10 CRAIG ZELLER: I don’t have to test it all the

11 way up. See, in this case that’s where we were -- the

12 reason we settled on the Twelve Mile arm of Lake

13 Hartwell is because our data suggested that’s where the

14 mass is at. That’s where it is. That’s why, if you

15 look at that map, that’s why all the samples are down

16 there, because that’s where we pretty much know it is.

17 You have to think of the conceptual site model.

18 Sangamo was straight piping.

19 TREY WHITEHURST: Right.

20 CRAIG ZELLER: They were discharging a pipe

21 straight down creek into Twelve Mile River. So it

22 would have flowed in the channel, except for when you

23 had major flood events. Okay. You could have gotten

24 some outer bank deposits, okay, I mean, that’s been

25 talked about.


1 Okay. So what’s up in Twelve Mile Creek? Well, if

2 materials have been transporting out of Twelve Mile

3 Creek for twenty plus years, if there was something up

4 there that was causing alarms in my head to go off, I

5 would pick it up in Twelve Mile arm. But my cores

6 don’t show that. I can go in and I can date sediment.

7 And I’ve done this since the ROD. Or I can go back

8 into, you know, the Twelve Mile River arm of Lake

9 Hartwell and send a core sample done and much like

10 anthropologists do when they discover some mummy tomb,

11 you can actually carbon date it and say, uh, these

12 Indians started a fire seven hundred years ago. I can

13 tell by the charting. You can do the same thing with

14 sediment, and I can show when the sediment down there

15 was deposited, what date. And it shows that in ‘55 and

16 ‘60 and ‘65, the stuff that was coming down Twelve Mile

17 River wasn’t very good because Sangamo was straight

18 piping it. But now I can get that very same sediment

19 core, I can say the stuff that’s coming down the

20 sediment -- or the river now is clean. It’s under a

21 part per million. And where is that material coming

22 from? It’s coming up from the Twelve Mile Creek

23 watershed. So it tells me that Twelve Mile Creek

24 watershed is not a current source of PCBs to Twelve

25 Mile River. It’s just not. I don’t see it. I don’t


1 have data that suggests that. Okay. So my authority -

2 - so we have -- we’re extremely confident, and I’ve

3 told this to everybody, I swim, kayak, recreate in

4 Twelve Mile River. I’ve had my kids and I’m not -- I

5 have data that suggests and strongly indicates no

6 problem. But what our data did suggest, why we are

7 here, why I’m sitting here and why I’ve spent twenty

8 years of my life up here is because I’ve had

9 unacceptable risks posed by eating contaminated fish.

10 That is the human health risk why EPA is here. Okay?

11 And I explained on December 1st, is that we have

12 also sampled people. We sent out twelve thousand

13 surveys in 2004. Of the twelve thousand surveys that

14 were sent out, and these were sent out to identify

15 people that reported eating large amounts of fish from

16 Lake Hartwell. All right. We’ve looking for the worst

17 case scenario. Of those twelve thousand surveys,

18 roughly three thousand were returned. Of the three

19 thousand returned, a little over three hundred said,

20 yeah, I eat a lot of fish from Lake Hartwell. Okay.

21 Of the three hundred we interviewed, we sampled thirty

22 people that said, I’ve eaten nothing but Lake Hartwell

23 fish for the past year. I’ve had one big giant fish

24 fry. All right. And so those people that we sampled,

25 those thirty people, twenty-nine of them were either


1 non-detect for PCBs in their blood or within the

2 expected range of the U.S. population, which is about

3 1.5 to about three parts per billion.

4 There was one gentleman that was in his eighties

5 that had 19.2 part per billion in his blood. High.

6 And we said, wow, where have you been? What’s up with

7 you? He goes, well, I forgot to tell you, I worked at

8 the plant in the sixties. But he had smoked for thirty

9 years. He was healthy as a horse, you know.

10 So part of this is education, that the real risk

11 here, the risk per EPA would be the consumption of fish

12 and you have to eat twenty-six meals a year, and a meal

13 is defined as three-quarters of a pound. So is that

14 twelve ounces? You have to eat two twelve ounce meals

15 a month for thirty years for your cancer risks to get

16 into EPA’s, say, red zone. So, in other words, you

17 have to eat a lot of fish for a long time for your

18 cancer risks to get into the red zone.

19 TREY WHITEHURST: But we still have to have

20 the sign out there.

21 CRAIG ZELLER: Yeah. Because of that. That’s

22 why there is a fish advisory in Lake Hartwell. And

23 it’s not just for PCBs. A majority of the lakes,

24 unfortunately, in upstream or upstate South Carolina

25 also have fish advisories for mercury. That’s because


1 of fossil plants burning coil of TBA.

2 NEIL SMITH: The gentleman that had the

3 nineteen parts per million, is he now a part of the

4 Superfund site?

5 CRAIG ZELLER: His name could not be released

6 ---

7 NEIL SMITH: We might have to have a permit to

8 bury him or ---

9 CRAIG ZELLER: Like I said, he was healthy as

10 a horse. He was ornery. But I’ve heard this a lot. I

11 mean, it really surprised me, I guess, December 1st,

12 that people were -- because I figured, and I figured

13 wrong, but I figured that people understood that it was

14 okay to recreate and it was okay to swim. It’s okay to

15 wade. It’s okay, you know, as far as from a PCB

16 standpoint.

17 And we’re going to do a more detailed analysis for

18 the supplemental RI and make sure that because things

19 have changed in this two mile reach between the dams

20 that was affected, we’re going to make sure that those

21 estimates are still accurate and that it is still. And

22 my gut feeling is that it is. It is safe. We’re going

23 to run the analysis to make sure. But if we felt that

24 there was some eminent substantial endangerment, we

25 certainly wouldn’t be letting people kayak. But I


1 understand that on some American river whitewater pages

2 that the creek has already become quite a popular river

3 raft. You know, there’s a bunch of people that’s

4 already got quite a following on the web page as far as

5 they have a nice little stream gauge when it’s peak

6 time to, you know, kayak it.

7 So, you know, that’s really -- the moral of this

8 story is if you -- we tell this to project managers all

9 over the country, state and federal alike, that if you

10 are measuring and basing the success of your PCB

11 sediment revenue on reduction in fish tissue, if that’s

12 all you’re looking for, you’re going to be

13 disappointed, because it doesn’t fall as rapidly as,

14 say, sediments do.

15 We have went and have since used stuff like

16 corbicula, which is the clam I was talking about. It’s

17 a freshwater clam. The nice part about it, it’s

18 indigenous to the area. The nice part about the clam

19 is the clam doesn’t move. You put it in the cage, you

20 set it out for twenty-eight days, and then you know

21 what it ate, you know. It hasn’t swam off fifteen

22 different miles in different directions and eaten prey

23 from God knows where. We have seen decreases in

24 corbicula concentrations over time. So, you know, we

25 -- you know, off the top of my head I’d say we’re


1 probably about ninety percent of reduction out here.

2 And it’s always the case, it’s kind of Environmental

3 Protection 101 is that, you know, if there’s ninety

4 percent reduction in contaminant concentrations, you

5 can get, you know, you can get for a fairly reasonable

6 amount of effort and a pretty reasonable amount of

7 money. You know, that’s everybody different -- meaning

8 of reasonable is different, you know. Someone says

9 half a billion dollars on the Hudson is not a

10 reasonable amount of money.

11 NEIL SMITH: Craig, you mentioned earlier that

12 the dredging kind of makes the numbers go up and

13 everything else. Trey owns property on Lake Hartwell.

14 I do too. And one of the things that’s going on now,

15 when the lake levels are down, you’ve got a lot of the

16 contractors that come out and they dredge.

17 CRAIG ZELLER: In the dock?

18 NEIL SMITH: Yeah. They get a permit from the

19 Corp to come out and dredge, because again, that’s one

20 of the major problems on any large lake like that, is

21 the sediment comes in. So as you look at that arm

22 going down, some of us are old enough to remember where

23 there was no sandbars. That was basically a beautiful

24 lake. A lot of people could swim, ski, in that whole

25 area, versus seeing the giant sandbars. But if these


1 individual landowners start dredging, is that going to

2 cause these numbers to go back up?

3 And then the second part of that is, where does the

4 dredging materials go when these companies dredge that

5 settlement?

6 CRAIG ZELLER: Those are great questions. We

7 have an agreement with the Army Corps that would issue

8 those permits. If there’s any permits that come in --

9 I’ll give you some examples of stuff I’ve seen that

10 comes across my desk. I do see that stuff. One

11 example was the -- what’s the park, Larry, that comes

12 off of Clemson, that little finger that comes off of

13 123?

14 JENNIFER WILLIS: Twelve Mile.

15 LARRY DYCK: City Park.

16 CRAIG ZELLER: City Park, yeah.

17 NEIL SMITH: City Park is on the left side.

18 It’s going to be Twelve Mile Landing.

19 JENNIFER WILLIS: It’s got to be Twelve Mile

20 Landing.

21 CRAIG ZELLER: It’s downstream of 123 and kind

22 of runs ---

23 NEIL SMITH: Go under the underpass?

24 LARRY DYCK: Twin Lakes?

25 CRAIG ZELLER: Yeah. It was City Park that


1 was dredged. They did it in the dry. It was during a

2 low period, low water, the City of Clemson, I think,

3 through some grant money or whatever, had an

4 opportunity to do -- City Park.

5 NEIL SMITH: It’s north of -- I mean, south of

6 123 behind where the Wendy’s is and all that.

7 CRAIG ZELLER: That’s it.

8 JENNIFER WILLIS: Behind ---

9 CRAIG ZELLER: Correct. I couldn’t think of

10 the name of it. So when that project was in its

11 planning stages, the Corp sent all that work -- that

12 design work to me saying, EPA, do you have a problem

13 with dredging this? You know, and we looked at data,

14 and because it was off the main stem, there wasn’t a

15 lot of ---

16 NEIL SMITH: Yeah. I was going to say, it’s

17 definitely off the main stem.

18 CRAIG ZELLER: It was off the main stem and we

19 looked at it and we said, no problem. A park for the

20 City of Clemson looks like a great idea for this place.

21 NEIL SMITH: But if you jumped up to Twelve

22 Mile Landing, which is coming right off the main stem,

23 would ---

24 CRAIG ZELLER: Might be a different story.

25 When the Ninety Three Bridge work was being done to get


1 Clemson fans in and out of the football game down there

2 by Tiger Stadium, and there was a bunch of coring and

3 caisson work, we looked at that material. Same thing.

4 When the 133 Bridge was just widened, I believe,

5 heading out of there, crosses the main stem, we were

6 working very closely with SCDOT at the time to make

7 sure that any spoil material, you know, it was sampled

8 and tested to make sure that we weren’t putting PCBs on

9 the side of the road someplace.

10 NEIL SMITH: Now, would those samples be a

11 part of the DOT files or would that be a part of your

12 files?

13 CRAIG ZELLER: We have -- both, both. Yeah.

14 NEIL SMITH: Okay.

15 CRAIG ZELLER: Yeah. But the Corp is really

16 good, I’ve got to say about -- this is their lake,

17 they’re stewards over it, of course. They’re very

18 familiar with it. If there’s anything that comes

19 across their desk about Twelve Mile arm and potential

20 dredging, main channel dredging, dock permit and stuff

21 like that, we do see it. They’ve been very good about

22 that.

23 So the other half, I think I tried to answer Wes’s

24 part A of his question about fish tissue metrics and

25 possibly the problem of using those to gauge success or


1 failure was the water quality issue.

2 Wes, what biological effects are you noting? You

3 said there was biological impacts or effect.

4 WES HULSEY: Bioaccumulation within the

5 aquatic life within the lake. I can show you later,

6 point that out, 61-68 ---

7 CRAIG ZELLER: Well, there’s bioaccumulation

8 because that’s what PCBs do. They do accumulate. They

9 accumulate at virtually all levels of the food chain.

10 But what we have noticed is that when you count bugs,

11 they don’t -- PCBs are not acutely toxic. They are not

12 wiping out whole levels of the food chain. They’re not

13 wiping out mayflies. Or they’re not wiping out high

14 level azteca. They’re simply accumulating. They’re

15 not -- it’s a chronic thing.

16 WES HULSEY: I seem to recall the assessment

17 conducted by the respective state department and

18 natural resources indicated that there were potential

19 reproductive effect in some of the organisms that were

20 receptors.

21 CRAIG ZELLER: That was that concentration of

22 largemouth bass higher than twelve ppm, and we don’t

23 see those concentrations anymore.

24 WES HULSEY: Going back to the exposure, the

25 health and safety plan, the HASP, they have a table,


1 4.4, contaminants of concern regarding potential or

2 exposure limits. And I presume this is for a site

3 worker actually at the treatment plant for remediation

4 of PCB contaminated sediments, or soils.

5 CRAIG ZELLER: Is it air or what is it ---

6 WES HULSEY: The exposure limit is limits or

7 PCB 1254, which I believe is one primary constituent,

8 at least we found, the exposure limit is .5 milligrams

9 per cubic meter.

10 CRAIG ZELLER: Uh-huh (affirmative.) That’s

11 an air.

12 WES HULSEY: Is that an air number?

13 CRAIG ZELLER: That’s air. Milligrams per

14 cubic meter is air.

15 WES HULSEY: And that’s not -- that will not

16 apply to soil?

17 CRAIG ZELLER: I mean, it would be

18 volatilization of the soil. I think this is -- this

19 is potential for treatment plant operation only. I

20 don’t know, is that the table you’re looking at, 4.4?

21 WES HULSEY: Yes.

22 CRAIG ZELLER: That would be, yeah, in a

23 treatment plant, that if you were probably trying to

24 remove some PCBs from a water stream, that you might

25 get some volitization. That .5 milligrams per cubic


1 meter is an air exposure limit. This is CH2 Inhaled

2 Health and Safety Plan. It’s important to note that

3 EPA does not approve or -- their health and safety plan

4 is the responsibility of their employees. We don’t --

5 we go by our own health and safety plan.

6 WES HULSEY: Okay. I agree with you. I’m not

7 certain what the media is specifically, but ---

8 CRAIG ZELLER: Well, I know milligrams per

9 cubic meter is air. That’s an air volume. That’s what

10 that is.

11 WES HULSEY: The footnotes don’t seem to

12 indicate. There is a sample designation in media ---

13 CRAIG ZELLER: Well, all this, I mean, PELs,

14 RELs, TOVs, that’s all air. It’s air. It’s ensued in

15 the methodology. It’s assumed that that’s what that’s

16 talking about.

17 WES HULSEY: If it were soil, and typically

18 you see soil reported in milligrams per kilograms.


20 WES HULSEY: And I just did a bulk density

21 calculation based on some of the sediment results that

22 we received last summer. We had equivalent PCB levels

23 in the soil converted based on bulk density and assumed

24 bulk density of upwards of two hundred and forty

25 milligrams per cubic meter.


1 CRAIG ZELLER: Why are you going from ppm to

2 air? I don’t know where you’re going with the air. I

3 don’t know why you would convert ---

4 WES HULSEY: I just didn’t see ---

5 CRAIG ZELLER: I don’t know why you would

6 convert a soil concentration to an air volume. I’m not

7 following that.

8 WES HULSEY: Yeah. I just didn’t see in this

9 table an indication that it applies to air. I presume

10 that it’s referring to soil and you’re looking at some

11 type of thermal treatment of soil. I can see how it

12 would possibly be applied to air as well.

13 CRAIG ZELLER: You’re mixing apples and

14 oranges.

15 WES HULSEY: Okay.

16 JENNIFER WILLIS: Councilman Ponder, did you

17 have something?

18 TOM PONDER: I just have two questions that

19 are short.

20 JENNIFER WILLIS: Okay.

21 TOM PONDER: I’m constantly hearing people in

22 the area talk about the source and that the

23 contamination continues to flow into the stream. I

24 know you’ve probably looked at that. I’m sure that

25 there’s still contamination going in the stream because


1 of the possibility of capping the contaminated areas.

2 Are there levels of concern there?

3 CRAIG ZELLER: Two questions. No, there are

4 not levels of concern as far as a human health risk

5 assessment. There are levels of concern because I

6 don’t -- I believe we’ve still got a little more work

7 to do up there, to be quite honest with you. Okay. So

8 this project has been very challenging. One, because

9 of the contaminant. It poses very unique challenges.

10 Two is the plant site itself, the actual -- the

11 subsurface of that facility is a nightmare, really,

12 from a transport standpoint. It’s -- you could not

13 have dreamt up a more challenging subsurface

14 environment. It sits kind of up on that ridge line and

15 there is some weathered soil that they call saprolite.

16 Sometimes a layer of saprolite can be eighty to ninety

17 feet thick, but then eventually you get to bedrock and

18 that’s the hard stuff with fractures.

19 Then we have -- so we’ve got bedrock interface and

20 we have groundwater really sliding off the backside of

21 the plant and kind of sliding down the front side of

22 the plant into Town Creek where the old lagoon used to

23 be, right there at Sangamo Road. And so it has posed

24 very touch -- once this material gets into the

25 fractures, it gets very creative. All right. So we


1 are recovering groundwater up there in seven different

2 locations. And we will likely recover groundwater up

3 there for a very, very long, long time. I can’t say

4 forever, because that’s a long time, but it’s going to

5 be a long time.

6 Now, we’ve accomplished a fair amount there. You

7 know, we started pumping and treating up there since

8 about the ‘96, ‘97 time frame. Now, right there above,

9 what is that, Reese Mill Road Bridge, right there at

10 Sangamo and Reese Mill Road where Town Creek flows

11 under, is one of our clam stations. And I mentioned

12 earlier, our clams, they behalf. We set them out in

13 the water, we know when we come back to get them in a

14 month what they’ve been doing. They haven’t been

15 outside of their cage. Now, before we started the pump

16 and treat systems on the hill there, clams, after

17 sitting out for twenty-eight days were ten parts per

18 million. All right.

19 Now, fast forward to where we’re at now, clams that

20 we pulled out of there last year in that same station

21 were less than a ppm. They were like .7. Okay. So

22 that’s a reduction from ten to .7. So what is that,

23 ninety -- a little -- you know, a little better than

24 ninety percent. Now, that’s good. But we’re not done.

25 You know, I’d like to see that clam tissue go to what


1 it looks like upstream.

2 Now, we’re trying a number of things. We’re not

3 done on that plant site. And I’d like -- the goal is

4 to get those clams to, you know, be in that .7, but to

5 get them to .5 to .2, .3, so we can say we have ninety-

6 eight percent reduction. We’re not done yet. But

7 we’ve made good progress. We are working on some

8 things with Schlumberger that hopefully continues to,

9 you know, crank that down. We’re still kind of

10 optimizing, tweaking, whatever term you want to use.

11 I’ll give you another example. We’ve been studying

12 groundwater out there for, what, twenty years, pumping

13 it. Well, we got -- about three or four years ago, we

14 got a call from Jerry Moore, who lives next door to the

15 Sangamo plant. He’s been very cooperative, been very

16 helpful for us. And he said, hey, you know, I’m

17 getting ready to clear my pasture. You know, clear

18 some of my property now to do some cattle ranching out

19 here. Can you come take a look at this spring for me?

20 It smells funny. So we went over and took a look at

21 Mr. Moore’s spring and I’ll be darned if it didn’t

22 smell funny. It smelled funny for a reason, because

23 there were VOCs coming out of the damn thing, you know,

24 volatile organic compounds everywhere coming from the

25 plant.


1 Now, again, how does this happen after twenty years

2 of EPA and Schlumberger and state involvement? Right?

3 Some people want to say, come on, you stupid you know

4 whats, can’t you get your stuff taken care of? Well,

5 you know, we learn, you know, nobody’s perfect. We

6 learn. So in this case instead of trying to pump it,

7 we put in a collection area. We put in like a big

8 french drain, big old rock-filled trench and we’re

9 collecting that water coming out of that spring. It’s

10 kind of like one of those, if you can’t beat it, join

11 it. Well, if it doesn’t want to come to our extraction

12 well, then heck with it, we’ll go to where it wants to

13 come out. So we’re collecting it where it wants to

14 come out and that water is being collected and going

15 back on the hill for treatment.

16 And so we’re continuing to adapt and manage, you

17 know, our strategy for dealing with that. We’re not

18 done. But we have made progress. I wouldn’t say we’re

19 -- it’s important to get the source control. I do

20 understand that. It’s important to turn that sink all

21 the way off so there’s not a little drip, drip, drip.

22 And we’re down to the drip, drip, drip. We’re trying

23 to get that thing -- you know, stop that.

24 TOM PONDER: Thank you. My second question.

25 Last week I -- and I live on the other side of the


1 county. I don’t get over there very often. But I was

2 on Maw Bridge Road and happened to cross the bridge and

3 I noticed that that whole area on the north side of the

4 bridge is filling in almost to the point of becoming a

5 delta.

6 CRAIG ZELLER: Yeah.

7 TOM PONDER: I would assume there’s -- because

8 of the movement of settlement downstream there’s

9 beginning to become a pretty good build-up of

10 contaminated material in that area. Would the remedy

11 be to leave it alone or at some point in time would the

12 agency consider some type of dredging -- controlled

13 dredging process to try to eliminate downstream

14 contamination? Or is there a concern about the build-

15 up? Because if you turn the other dam loose, it’s

16 going to create more of a downstream flow. So what’s

17 kind of in the -- I guess the framework as far as

18 looking at that area?

19 CRAIG ZELLER: What you’re seeing there is we

20 talked about a model that wasn’t so predictive, the

21 fish tissue and the subsequent declines or predicted

22 declines. We had another model in there that’s proven

23 to be quite accurate and that was the sediment

24 transport model. That if you pull out those figures

25 from the record of decision, after thirty years of


1 sediment moving down Twelve Mile River, it shows at the

2 headwaters of the lake, it actually advances past Maw

3 Bridge. So after thirty years of natural sediment

4 transport, what we’re seeing now is kind of maybe a

5 little unnatural -- or it was unnatural when the dams

6 when were there. Now what you’re getting is kind of

7 flushing on through and maybe a little more natural.

8 But yeah, that area will become -- it will change.

9 It’s going to move from being a shallow, say, at, what,

10 six sixty pool, the lake used to come all the way up to

11 Maw. And at the tail of the mid nineties it was hard

12 for us to get a boat back up there anymore. That was

13 about ‘95, ‘96, we had to walk from there. But yeah, I

14 mean, what you’re seeing is the shallow portions of any

15 lake are going to fill up first. We will always -- I

16 mean, nothing, I guess, is ever off the table. But I

17 don’t see us being real interested in wanting to dredge

18 Maw Bridge area for that open water environment.

19 Now, back in the day -- what’s been interesting

20 about this project is many things, is that it seems

21 almost like two different time frames, two different

22 groups of people. When we were talking to people about

23 our Record of Decision back in the mid nineties, then

24 it was, EPA, you’re exaggerating the bejesus out of

25 these risks, you know, ain’t nobody eating that much


1 fish. You know, we appreciate your study, but kindly

2 go back to Atlanta and take your fish fans with you.

3 That was one of the things we wanted to do at the time.

4 We were saying we would like to keep the hybrid bass

5 out of this arm of the lake so they wouldn’t

6 necessarily pollute or potentially exposure people on

7 the Georgia arm or down at the dam.

8 But as part of that analysis, we did look at other

9 sediment traps. This is -- Dennis Chastain was talking

10 about this. But we looked at constructing a low head,

11 like say a Woodside II or a Woodside I at Maw Bridge.

12 And we also looked at building a small little dam at

13 Madden Bridge. The thought being is to trap all the

14 sediment there, kind of, you know, cut off that pinky,

15 you know, of that arm of the lake, because, you know,

16 we did the analysis. I think Lake Hartwell is, what,

17 fifty-six thousand acres at full pool; right? At one

18 thousand acres, you know, you’re only losing two

19 percent of the lake total. Well, easy for me to say if

20 you don’t live on the two percent of the lake; right?

21 So people that were on the Madden Bridge and the Maw

22 Bridge said, EPA, you’re not building some bridge here

23 to trap sediment so I can’t take my boat to Clemson

24 games. No way, you know. So we ran into a bunch of

25 opposition to that. And at the time people weren’t


1 that concerned about PCBs, because I think they

2 understood that the risk was, you know, consumption of

3 fish filets.

4 Now, fast forward to where we’re at now and the

5 hearings we’re having and this is all very good

6 dialogue. But now it’s a different group, you know,

7 with different concerns. But I mean, I think part of

8 my job is risk education, and that’s what I want to try

9 and drive home here is that we have to keep in mind

10 what the risks are really from ingestion of fish.

11 Unless you think people are out there eating a lot of

12 mud, I just don’t see people, you know, ingesting fish

13 -- I mean, incidentally, yeah, I have kids. But I also

14 know my wife wouldn’t let my children, you know, eat

15 dirt for too long, you know, until she’s slapped their

16 hands and washed their hands. But I think that’s what

17 we want to keep in perspective. Again, I can’t be --

18 emphasize enough, recreation is fine. Swimming’s fine.

19 Wading is fine. Kayaking we think is fine. We’re

20 going to have numbers to back all that up. But if

21 you’re going to eat fish, you know, just keep in mind

22 you might not want to eat a lot of them. That’s why

23 the advisory is there.

24 SAM WYCHE: Let me just follow up with one

25 quick question here.


1 CRAIG ZELLER: Yes.

2 SAM WYCHE: I live up between the flea market

3 and Shady Grove Road, up that way. Why would you not

4 want to take samples of -- we all know where the source

5 of the PCBs comes from. Schlumberger; right?

6 CRAIG ZELLER: Right.

7 SAM WYCHE: We’re in agreement on that. And

8 that we know where it starts. Why would you not want

9 to see if there’s not residue up there just to be sure,

10 that it’s not some trapped up that way, that on the

11 next big rain we’re going to be back in the same mess

12 we’re in now?

13 CRAIG ZELLER: I understand. So when we

14 started this investigation back in the early nineties,

15 there was sampling that was done even prior to that of

16 -- from those plant sources. Very logical, obviously.

17 That’s what you want to do, is from the plant source

18 all the way down. And if you get into Twelve Mile

19 River between where it comes into Town Creek and as it

20 flows down past the former dam locations, I think you

21 will note there’s not a lot of sediment to sample.

22 It’s pretty rocky. There’s not -- I mean, you’ll get

23 local deposits of sand here and there. But when we

24 sampled material in the early nineties up through

25 there, we didn’t see a lot of residual PCBs.


1 SAM WYCHE: But your conclusion, therefore, is

2 that because of the rocky nature of it, that the PCBs

3 flushed on down and were trapped in sediment ---

4 CRAIG ZELLER: Went on through the system.

5 SAM WYCHE: -- down river?


7 SAM WYCHE: And that’s why you’re just

8 measuring that?

9 NEIL SMITH: But if you take that, does that

10 mean then you would move your sampling further down the

11 river, so instead of stopping at Woodside, you’d go on

12 down to Maw Bridge and Madden Bridge?

13 CRAIG ZELLER: Our sampling now goes down to

14 about the 123 Bridge, is where we kind of -- that’s our

15 southern kind of end.

16 JENNIFER WILLIS: By the railroad tracks?

17 CRAIG ZELLER: By the tracks, yeah. I’ll have

18 to double check that. Now, historically we do have --

19 I should say we do have four or five sediment sample

20 locations that are co-located with the fish stations.

21 So we actually do collect sediment samples all the way

22 down to the dam. But the bulk of sediment -- our focus

23 on sediment concentrations is really 123 and above.

24 And we’ve had a lot of talk over the years with other

25 folks, Larry and others, about sediment transport


1 dynamics. And yes, as -- you know, as the sand moves

2 in the system, you are going to -- it’s going to

3 continue to move on in. We’re trying to keep a look on

4 that.

5 WES HULSEY: Mr. Zeller, one comment. Are you

6 suggesting there’s about a thirteen mile section

7 between the confluence for Town Creek all the way down

8 to just above the Easley/Central dam, that there is

9 very little sediment and there are flood plains within

10 that section?

11 CRAIG ZELLER: I didn’t say flood plains. I

12 said if you step in the middle of the channel and tell

13 me what you see, what kind of substrates you see.

14 WES HULSEY: Because I know the river is a

15 fairly mature river, has a lot of meanders, extensive

16 flood plains all the way down, so there was potential

17 for over-the-bank flooding, you know, from this point

18 to this point, where there’s been few to no sampling

19 conducted.

20 CRAIG ZELLER: Back to my point, Wes, that

21 I’ve made before tonight and last December 1st, is that

22 if there was an ongoing source of significance in

23 Twelve Mile River between the plant site and the Old

24 Woodside I and II locations, I would see some sort of

25 indication of that in the main deposition area, which


1 is 123 to Maw. And over that course of time, I’ve seen

2 my average sediment concentrations drop from one to ten

3 ppm in twenty years to now less than one.

4 So my data -- that’s the net deposition. All my

5 modeling says anything coming out of Twelve Mile River

6 upstream is going to fall between 123 and Maw Bridge.

7 That’s where it dumps. That’s net deposition. So if I

8 had some kind of ongoing source, I should see at least

9 the same concentrations. But what I’m seeing in my

10 dataset downstream in that deposition, I’ve seen my --

11 the order of my concentrations drop in order of

12 magnitude. What that tells me is that if there is any

13 material up in that reach of Twelve Mile River is

14 negligible.

15 WES HULSEY: Okay. Going back to the

16 potential for human exposure, and I’ve got to find my

17 table 4.4, the media is for sludge and this is a

18 treatment plant when it was .001 parts per billion.

19 CRAIG ZELLER: That would be one ppb? Let’s

20 see, that’s ---

21 WES HULSEY: And then the SS, which I presume

22 is surface soil, .001, and again, symptoms and effects

23 of exposure, skin -- eye and skin irritation, acne

24 formed dermatitis, liver damage, reproductive effects.

25 And if you look at the IDLH, which is immediately


1 dangerous to life and health, and again, this is a

2 milligram per cubic meter limit, I presume, of five.

3 And we’ve seen levels, you know, in our sampling and in

4 sampling conducted by Castrol well in excess of these

5 levels. And granted, I understand ---

6 CRAIG ZELLER: Again, this is apples and

7 oranges. You’re citing data ---

8 WES HULSEY: Yeah, that is a site worker, but

9 still we found levels that are, you know, a hundred and

10 fifty-six part per million and less. And again, I

11 don’t know what the long term exposure limits are in

12 terms of hours of contact with sediment. But clearly,

13 a site worker is going to be wearing PPE when they’re

14 collecting samples and treating soils or sludge that

15 are infected with PCBs.

16 CRAIG ZELLER: So you’re citing information

17 for a worker that’s dealing with PCB sludges at a waste

18 water treatment system?

19 JENNIFER WILLIS: And I’m going to jump in

20 here, because I think we’re a little off track on this

21 one. And we’ve got opportunity. You’ve committed to

22 come back up here and have more conversations and

23 we’ll, you know, talk about more detail and get into

24 this and go back and do the analysis in depth. But I

25 want to thank you again for coming and for being


1 receptive to us participating. I want to remind you

2 that, you know, we’ve said we want to be fully

3 involved.


5 JENNIFER WILLIS: We want to make sure -- we

6 also are very concerned, based on, I think, the

7 documents that Wes had seen yesterday that we let the

8 comment period completely close on the remediation plan

9 before any plans are devised as to what other steps

10 might be taken ---

11 CRAIG ZELLER: Are you talking about the

12 consent decree stuff?

13 JENNIFER WILLIS: I am talking about -- hang

14 on, I’m sorry. I’m talking about the supplemental

15 remedial investigation, which is open for comment right

16 now.


18 JENNIFER WILLIS: But we want to make sure

19 that comment has been addressed from the public, but

20 also that our concerns have been addressed, not just as

21 the comment ---


23 JENNIFER WILLIS: -- of the public, but as the

24 representatives who are charged with protecting the

25 health and safety of the citizens. So I just want to


1 make sure that that was very clear. You know, we look

2 forward to working with you and we appreciate very much

3 you coming up here this evening and taking the time to

4 help us understand a lot of the questions we had and,

5 you know, we look forward to working with you in the

6 future.

7 CRAIG ZELLER: Yeah. Well, I’ll be back --

8 what is the third Monday of April?

9 JENNIFER WILLIS: April 16th.

10 CRAIG ZELLER: I’ll plan to be here at seven

11 p.m. again; right?

12 JENNIFER WILLIS: Yes. If you would like, if

13 it’s convenient, we can start a little bit earlier. We

14 had some preparation ahead tonight. We can start at

15 six or so, which means that we can have some time and

16 not be quite so late.

17 CRAIG ZELLER: Sure. Six would be good.

18 That’s fine with me. I could do that.

19 JENNIFER WILLIS: Okay.

20 CRAIG ZELLER: And let me add, there is no

21 formal -- I mean, we have, as part of CERCLA, we have

22 moments in the process where we actually have to have a

23 mandatory thirty-day comment period. That’s not the

24 case on this thing. It’s open for comment. It doesn’t

25 really begin and it doesn’t really end. So you’re not


1 going to miss, you know, ---

2 JENNIFER WILLIS: Good.

3 CRAIG ZELLER: -- you’re not going to miss

4 some deadline. Part of the plan, really, tomorrow, is

5 to get your real life or real time input on dots on

6 the map. The plan is, what I would like to do is, what

7 we’re trying to do is, I have comments from Larry that

8 we’re in the process of addressing and would like to

9 get your feedback tomorrow. And we’re going to do our

10 best to take really good notes and anything we pick up

11 tomorrow that we think we can accommodate and

12 integrate, we certainly will. But hopefully that week

13 of the 16th of April, I’m actually up here not just for

14 a meeting here, but I’m actually in the river

15 collecting samples.

16 JENNIFER WILLIS: Right.

17 CRAIG ZELLER: We want to get this data

18 collected in April. We haven’t picked a date or week

19 yet, but that’s the plan, is to get this plan, get your

20 input into it so we’re -- you know, put some

21 flashlights on it. We don’t want to do this stuff

22 under the cover of dark. You know that’s not, you

23 know, that’s not the way we go about things. Get the

24 plan finalized with your input and let’s get this data

25 collected. And so we can answer the question of a


1 hundred and fifty-seven, what that means, you know. So

2 I expect I’ll -- look forward to it. I’ll be back in a

3 month.

4 NEIL SMITH: Madam Chairman, I move to

5 adjourn.

6 JENNIFER WILLIS: I have a motion. Can I have

7 a second? Second by Councilman Whitehurst. All those

8 in favor? That is unanimous. We are adjourned. Thank

9 you for coming. Good night.

10

11

12 (Adjourned at approximately 8:45 p.m.)

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