EXPERT REPORT: PCB SOURCE, TRANSPORT AND FATE IN THE

26,7

MB

ANNISTON AREA

128

stron

2597

ID

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

2006

rok

I. INTRODUCTION, REPORT PURPOSE AND SUMMARY 5

A. Purpose of Report 6

B. Report Summary 8

1. False Premises Advanced by Solutia are Rejected 8

2. Despite S/P Comments, the Foundries are a de minimis PCB Source 9

3. Fatal Conceptual Model Flaws and Other Flaws in S/P's Expert Reports 12

II. HISTORY OF PCB PRODUCTION 20

III. CONCEPTUAL MODEL FOR PCB SOURCE, TRANSPORT AND FATE IN THE

ANNISTONAREA 22

A. PCB Chemistry and End Use 22

B. Conceptual Model for the Anniston Area 25

C. Contaminant Source Areas 32

1. PCB Losses to the Environment from the S/P Plant 32

2. Discharge to Process and Storm Water Sewers 38

3. West End and South End Landfills 42

4. Estimates of Historic Air PCB Releases from the Plant 47

5. Waste Disposal Activities by Other Parties 48

D. Surface Water Transport Pathway 48

1. Discharge to the 11th Street Ditch and Snow Creek 49

2. Discharge to the 9th Street Ditch 50

E. Air Transport Pathways 51

F. Conceptual Model Summary 52

IV. SOLUTIA SOURCES ARE THE MAJOR CONTRIBUTORS TO CONTAMINATION OF

ENVIRONMENTAL MEDIA IN ANNISTON WITH PCBS 56

A. Environmental Occurrence of Aroclors in Anniston and Surrounding Area 57

B. Solutia's Operations Released Significant PCBs via Surface Pathway to Environmental Media 57

1. Management of Monsanto Landfill 57

2. PCB releases to Ditches 59

C. Air Pathway Analysis Shows Dispersal Pattern Consistent with Air Deposition and that

Contaminated Soils Possess a Unique S/P Signature 60

1. Description of the Air Pathway 61

2. Ambient PCB Distributions 63

V. THE FOUNDRIES ARE NOT A SIGNIFICANT SOURCE OF PCBS IN THE ANNISTON AREA 72

A. PCBs in Foundry Wastes Originated, in part, From Solutia's Air Emissions 72

1. Significant Foundry PCB Disposal and Release has not been Established 72

2. PCBs in Conjunction with Foundry Waste in Soils does not Confirm Foundry PCB Source 76

3. Some Residential Properties have been Contaminated by Both Solutia and the Foundries 77

4. Widespread Aroclor 1268 Confirms Solutia PCB Source 77

B. Foundries have been a Source of Fill Material used in Residential Areas 77

VI. CONCLUSION 79

Appendix I History of PCB Cleanup at S/P's Anniston Plant

Appendix II Sample Selection Methodology

Appendix III Wind Direction Summary

Appendix IV Resumes