Green Delaware Alert 540
An "Independent
study" of DuPont's Edge Moor, Delaware, Dioxin Pile has been released by
Delaware regulators
The report (
http://www.awm.delaware.gov/SIRBIronRichSite.htm) confirms that DuPont
manipulated, distorted, and misrepresented facts in a campaign to save money
by not removing a waste pile.
"The attempt to abandon this illegal dump
on the Delaware River is part of a long history of irresponsible mishandling
of dangerous wastes by DuPont, and also by Delaware regulators. The Dioxin
Pile has got to go!"
--Alan Muller, Green Delaware
"Public
comments may be submitted in writing until 4:30 p.m. Friday, March 2, 2007,
to: Qazi Salahuddin, Ph.D., Program Manager, DNREC-SIRB, 391 Lukens Drive, New
Castle, Delaware 19720 or via email to
qazi.salahuddin@state.de.us"
January
30, 2007
This Alert contains much background information that many readers will not
need. Feel free to skip down to our commentary on the actual report. Further
detail on most points mentioned are available at
www.greendel.org. Search on "Dioxin Pile," etc.
Background
DuPont accumulated a giant pile of dangerous wastes near the
banks of the Delaware River and Shellpot Creek in the City of Wilmington,
Delaware. The pile was accumulated between 1997 and 2001 and contains about
420 thousand cubic yards (550 thousand tons) of wastes. Originally it covered
23 acres but in 2001 it was bulldozed up into a higher pile covering 16 acres
and goop ("polymer coat") was sprayed on it to reduce dust blowing.
the wastes, which DuPont calls "Iron Rich," contains dioxins, PCB's, arsenic,
radioactive uranium and thorium, hexachlorobenzene, and many other toxic and
cancer-causing chemicals. Only a few of these were considered in the "risk
assessments" DuPont has offered up.
The pile sits on a layer of "dredged material" (called DM in the report) from
the Delaware River.
DuPont now produces about 100 thousand tons per year of these wastes at its
Edge Moor, Delaware plant, and similar or greater amounts at plants in DeLisle,
Mississippi, New Johnsonville, Tennessee, and Altamira, Mexico. These wastes
were also formerly produced at a DuPont plant in Antioch, California.
These wastes are a byproduct of making titanium dioxide ("TiO2"), a white
pigment used in paint and many other products. The TiO2 itself, if not
contaminated, is considered relatively harmless.
DuPont has been using the present "chloride" process for making TiO2 at Edge
Moor since about 1956. DuPont was the first in the world to commercialize
this process and Edge Moor was the first such plant in the world.
Until very recently DuPont did not admit that these wastes were harmful. The
company handled them in the most casual manner and sought to sell them or give
them away as construction materials and for other uses. In the Edge Moor area
alone, in addition to the famous "pile," these "Iron Rich" wastes have been
piled up in three other dumps, used as "cover"on the Cherry Island garbage
dump, and used as berm material by the US Army Corps of Engineers in
river-dredging projects.
(In Contra Costa county, California, similar wastes from DuPont's Antioch
plant were used as road base and in the construction of driveways and
playgrounds at public schools. The roads cracked and up came
dioxin-contaminated black ooze. At lease two public schools had these wastes
dug up and removed.)
DuPont is now sending current Edge Moor wastes by rail to a garbage dump in
Lee County, South Carolina. But DuPont claims it would be too dangerous to
move the Pile.
Back to the
Dioxin Pile:
DuPont piled up these wastes, supposedly with the intent of
selling them. They, after-the-fact, DuPont sought to abandon the pile,
essentially converting the site into a permanent hazardous waste dump.
All DuPont really wants to do is put a plastic cover over the pile.
Delaware environmental regulators (DNREC) went along with all this. One
Friday afternoon at 6:00 P.M. they held a public meeting, hosting it jointly
with their buddies from DuPont. They said all was well and they planned to
approve the DuPont plan on Monday.
Green Delaware representatives and others were at the meeting to say "NO!"
Officials quickly backtracked, public hearings were held, and publicity was
extensive.
State officials, however, seemed unable to grasp the reality of the
situation. DNREC official Jim Werner, for example, repeatedly claimed that
"there is no dioxin" in the Dioxin Pile, even after DuPont admitted to Green
Delaware that it likely contained hundreds of pounds of the substance.
A resolution of the Delaware General Assembly called for an "independent
study" of the Dioxin Pile. Green Delaware and others opposed the resolution,
noting that it did not include any meaningful role for the community. Many
felt that Rep. Diana McWilliams--who reportedly used to work for DNREC--was
actually representing DuPont and DNREC rather than her constituents. The
General Assembly ignored these concerns, the resolution was passed, and a Dec.
20, 2006, report prepared by Schnabel Engineering (West Chester, PA, office)
has been released.
In general, the 98 page report is more informative than we expected. Written,
as such reports usually are, in dense techno-regulatory language, it
nevertheless makes clear that
the DuPont/DNREC proposal to abandon the pile is, literally, full of holes.
Green Delaware will submit detailed comments later, and will
offer our readers an opportunity to "sign on" to them.
For the
moment, here is a summary of a few key point--far from all of them--from the
report. We will cover more in follow-up Alerts:
{Translations into plain language are market this way.]
The report was based solely on information reported by DuPont, plus one site
visit.
"For the 420,000 cubic yards ... a total of 7 samples were collected from the
IRM [Iron Rich Material. That is, the wastes] at the Edge Moor Plant. To
date, no in situ analytical data has been collected from the IRM pile."
{Not a single sample has ever been analyzed from the pile itself.}
"the groundwater underlying the IRM has not been fully characterized and
ground water monitoring locations are not located to effectively establish the
existing impacts of the stockpiled IRM on the ground water quality and (2) to
monitor the future impacts of the proposed remedy." Additionally, semi-
volatile organic compounds such as HCB [hexachlorobenzene] and
hexachlorobutadiene (HCBD), reported in DM [dredged material under the pile]
... have not been analyzed .... Because of this, ground water has not been
sufficiently characterized to effectively ... [design a cleanup plan].
{DuPont has not reported what contamination is actually in the groundwater and
apparently has avoided finding out.}
"... the IRM has not been sufficiently characterized to allow for the
effective risk assessment of the proposed remedy."
{Not enough is known about the contents of the pile to say that leaving it
there is safe.}
"The human health and ecological risk assessments for the site may have
significant shortcomings."
"The human health risk assessment (HHRA) has ignored a potentially critical
exposure scenario related to off site downwind receptors ...."
{Danger of toxic dust blowing off the site was ignored.}
"... the ecological risk assessment (ERA) appears to have ... excluded hazards
related to potential direct exposure of wildlife ... [birds and animals] ...
were observed foraging in the ... [wastes] ... during our site ... visit."
"... worker safety and health measures have been proposed as the basis for
addressing potential direct exposure to the IRM. [but] ... the site ... visit
revealed the absence of such measure and practices ... [including] ...
apparent lack of use of personal protective equipment and monitoring ....
{Site workers are not being protected from the toxins in the waste,
endangering their health.}
"[The DuPont proposal] ... has used language which appears to preclude
corrective actions that require groundwater ...[pumping] and or treatment."
{DuPont has written language into the proposal that could later be used as an
excuse for not cleaning up groundwater contamination.}
"The allowable concentrations provided for iron, manganese, and HCB do not
appear to be protective of human health and the environment."
{The DuPont plan would allow exposure to dangerous levels of toxins.}
"... DuPont has overstated the life of the proposed capping systems. [DuPont
claims hundreds of years, but] ... "We believe it is more likely on the order
of a few decades."
"Regarding [the option of removing the pile] ... we believe it was not
exhaustively evaluated, particularly for the use of rail transportation
options (In lieu of trucking)."
"Samples of the material ...[under the pile] were not collected and therefore
not evaluated for their permeability characteristics."
"...documents reviewed and the data presented at the hearings do not
adequately address the current conditions, nor the long term potential of
contaminants migrating from the IRM to the ground water, and then to the
surface water."
{Toxins in the pile might get into the groundwater, Shellpot Creek, and the
Delaware River.}
"One [public] concern was that leachate from the IRM would migrate downward
into the groundwater and subsequently into the Shellpot Creek and into the
Delaware River... this appears to be the case."
"Observations made during a recent site visit (July 2006) indicated that
several surface areas were in need of repair under the current operations and
maintenance procedures. This does not bode well for DuPont's long-term
stewardship of the site."
"...[cancer risk] ... calculated by DNREC staff ... [from eating
dioxin-contaminated fish from Shellpot Creek] ... is approximately 10 to 5000
times higher than that calculated by DuPont."
Is this
enough bad news for the moment? Probably.
But the good news is that the report make clear that we--the
objecting people--were 100 percent in our objections to the DuPont plan.
The report should also be helpful to communities near other DuPont TiO2 plants
including New Johnsonville, TN, where DuPont is now trying to expand a waste
dump.
If people stand firm, DuPont should eventually end up removing the Pile.
ACTION:
Contact:
o
o
o
o
o
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Ask that the stalling stop and removal of the Pile
begin. The time for excuses and delays is over. The time for action to
improve the health of our communities has arrived.
Green Delaware
is a community based organization working on environment and public health
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www.greendel.org , Box 69, Port Penn, DE, USA, 19731-0069